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FORTY-NINTH SESSION OF THE IPCC
Kyoto, Japan, 8 - 12 May 2019
IPCC-XLIX/INF. 1, Rev.3(08.V.2019)
Agenda Item: 4
ENGLISH ONLYADOPTION AND ACCEPTANCE OF THE “2019 REFINEMENT TO THE 2006 IPCC GUIDELINESFOR NATIONAL GREENHOUSE GAS INVENTORIES”
Collated comments from Governments on the Final Draft Report and Authors’ responses(Submitted by the Co-Chairs of the Task Force Bureau)

Confidential – This document is being made available in preparation of
the Forty-Ninth Session of IPCC only and should not be cited, quoted, or distributed

IPCC Secretariat
c/o WMO • 7bis, Avenue de la Paix • C.P. 2300 • 1211 Geneva 2 • Switzerland
telephone : +41 (0) 22 730 8208 / 54 / 84 • fax : +41 (0) 22 730 8025 / 13 • email : IPCC-Sec@wmo.int • www.ipcc.ch2019 Refinement ‐ Collated Comments on Final Draft from Governments with Authors’ Responses

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For all types of forests

As far as Facility‐Reported Data (e.g. EU‐ETS) relates to "geographicallyresolved data" (cf. also new vol1 chap2 section 2.3), for cross‐consistency,that could be also reflected here. The title "Subnational GHG inventory
compilation (e.g. cities, states, provinces, territories)" could be extended
as : "Subnational GHG inventory compilation and facility‐reported data
(e.g. cities, states, provinces, territories, facility emission registers)". And
also the bracket "(including waste disposal and recycling/treatment sites)"might be completed with "(facility‐reported data including waste disposal
138 and recycling/treatment sites)".

Responses

Authors' notes

Iran

Accepted

Corrected.

FranceAccepted withmodification

Text reworded to clarify that geographic resolution is not only
about facility level for this paragraph, but it is one example.

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We welcome the new box 1.0A "LINKAGES OF GHG INVENTORYACTIVITIES WITH OTHER DATA COLLECTION AND REPORTING". We
appreciate the promotion of integrated and streamlined system for : agood cooperation with the national statistical system; a better
coordinational / harmonisation between emission works at national level
and compilations at local / territorial / facility levels; integrated national
FranceNoted
153 inventory system for both GHG and air pollutants.
Very good description of "National GHG inventory arrangements" : thatwill be useful for countries that will expect to shift or improve themanagement of their national GHG inventory, for the coming Paris360 agreement period.
France
Noted
Table 1.2, Column "Sectors & Categories": Propose to replace "FOLU" with
"LULUCF" and add "KP LULUCF", if the relevant reporting is provided by
Accepted with188 the Party.
Russian Federation modification

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187

Table 1.2, Column "Timeseries span": Propose to replace "…latest year ‐2"
Accepted with188 with "one but last calendar year" as outlined in the UNFCCC Guidelines.
Russian Federation modification

Revised text as: "Yearly values from 1990 until two years prior
to current calendar year"

363
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89

The term "CRF" is more coherent for the 2006 IPCC Guidelines.
NIR has been added as this is part of the reporting as well.
Deleted.

615
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207

Table 1.2, Column "Reporting formats": Propose to add "NIR" to the rows,
Accepted with188 where the "CRF" has been referred.
Russian Federation modification
New Zealand
Accepted
89 Delete "a" before "fossil" at the end of the line.
The IPCC is commended for including this essential guidance on national
greenhouse gas inventory arrangements as part of the refinement
360 exercise.
New ZealandNoted
193 Footnote (f) is not elaborated below the table
New Zealand
Accepted
Accepted with
198 Suggest replace "an isolated" with "a stand‐alone"
New Zealandmodification
In the box concerning Management/coordination, "expert" should be
202 "experts"
New Zealand
Accepted
207 Replace "well functional" with "well‐functioning"
New Zealand
Accepted

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210 Suggest delete "needed to function" from the heading in the table

Page 1New Zealand

Accepted

No action needed.

The commenter is thanked for his encouragement.

AFOLU is suggested as this would be coherent with table 1.1

The commenter is thanked for his encouragement.
Text for (f) added.
Revised text to also clarify what "this" referred to instead ofvague language of "functioning system".
Graph updated.
Replaced.
Deleted.

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Suggest the following additions and changes to the sentence "The processof engaging actors and stakeholders is likely to be different in different
countries" such that it will read: "The process of engaging actors andstakeholders is likely to vary between different countries and between
216 sectors within countries."
217 At the end of the line change "are" to "is"Suggest "This can be the Inventory Agency" is changed to read "This could
240 be an Inventory Agency"

Country

Responses

Authors' notes

New Zealand
New Zealand
New Zealand

Accepted
Rejected
Accepted withmodification

Clarified what "this" refers to.

Sentence changed as suggested.
are' is correct in the sentence.

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635
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454

Given that reporting under the Paris Agreement is to be every two years,
and that not all countries will be producing annual inventories, it may beadvisable for any contractual arrangements to be longer than 3 years as
this may cover only one reporting cycle. Suggest "(e.g. 3 to 5 years)" is269 changed to "(e.g. 4 to 6 years)"
Insert "to" before "provide" in "the receiving party provide feedback"345 thus: "the receiving party to provide feedback"457 Stongly support this point ‐ important to retain

56

Chapter 1 needs to update the concept of "anthropogenic emissions andremovals" as required in the outline adopted at the 44th plenary session.
However, there is no relevant text in the present report. It is suggested
95 that the author team explain this.

373

The report gives a regular inventory worksheet with a 52‐week (one‐year)
cycle. However, considering that emission inventories differ from country
to country in cycling (e.g., two‐ or four‐year cycles), it is suggested toclarify in the report that the timetable is extended accordingly when an
379 inventory cycle exceeds 52 weeks.

China

Accepted withmodification

The following sentence has been added "Table 1.6 is only
illustrative. It may require adjustment to the specific national
circumstances including the timeframes and time period of the
GHG inventory cycle which may be more than 1 year (e.g., 2 or
4 years)."

155

Concering "There is a wide diversity in approaches used by countries tomonitor, report, and respond to review of its GHG estimates on a regularbasis. ", we would like to include "verify" after "report" , so the statement
reads "...to monitor, report, verify and respond to review..." We believethat verification and QA/QC processes are very relevant to include in the
156 institutional arrangements.

SwedenAccepted

Included.

155"There is a wide diversity in approaches used by countries to monitor,
report, and respond to review of its GHG estimates on a regular basis.
"We would like to include "verify" after report so it will read to monitor,
report, verify and respond to review...... We believe that verification and
QA/QC processes are very relevant to include in the institutional
156 arrangements.

SwedenAccepted

Included.

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New Zealand

Accepted

Changed.

New Zealand
New Zealand

Accepted
Noted

Inserted.
No action to be taken.

China

Accepted

Updated.

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Authors' notes

The ToR for the Refinement called for a clarification of the concept of"anthropogenic emissions and removals" in Volume 1, Chapter 1. Anysuch clarification should be evidence‐based and need not be limited to"natural disturbances".
Major disturbances causing significant inter‐annual variability can be non‐anthropogenic, but can also be human‐induced. For example, the ignitionof most forest fires, regardless of the scale or location (managed or
unmanaged land) is due to human activities. Land management (including
fire suppression regimes) can have a major influence on the frequency
and magnitude of extreme events and peat fires are most often facilitatedby human activities such as drainage and land‐use change.

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61

We think that flexibility regarding the setting up and/or implementationof institutional arrangements is essential and we do not see the need for acommon definition of ‘good practice’ as there can be many different goodpractices in different countries. Having said this, the only reference to‘good practice’ in the chapter is in line 107 ‘It is considered good practicethat countries maintain and where possible improve the quality(transparency, accuracy, completeness, comparability and consistency) of
national GHG inventories’. We think that improving GHG inventories
should be ‘good practice’ even if this cannot happen in specific years due
to a number of possible and justified reasons. We know that inventories
cannot be perfect. However, we think that institutional arrangements
should support continuous inventory improvements. We would therefore
suggest to rephrase line 107 as follows: ‘it is considered good practice thatcountries aim at improving the quality (TACCC) of national GHG
inventories on a continuous basis’.

1

1

1

There Appears to be insufficient evidence base for linking the estimationof anthropogenic (versus non‐anthropogenic) emissions on managed land
64 solely to "inter‐annual variability".
61 The term "LULUCF" is not used in Chapter 2, Volume 4.

EU
EU

EU

Accepted
Accepted

Updated.
Changed accordingly.

Accepted withmodification

Agreed on change, with modification that improvement not
simply be an "aim", which implies only intention, butsomething that is actively worked for and it should happen on acontinuous basis.

187

UK + Over seas Territories' should be changed to 'UK + Overseas
187 Territories'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Changed.

187

The EU Monitoring Mechanism Regulation should have Geographical187 resolution for the geographical resolution, not 'Mainland UK'

United Kingdom (ofGreat Britain and Accepted with
Northern Ireland) modification

Text revised to clarify resolution is "Regulated installations
within mainland UK".

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Authors' notes

89

This section needs to be more complete, to be definitive. The lastsentence currently infers that if you burn biogenic waste without energy
recovery, that you don't report the CO2 at all. Why would that be correct,
to take a different reporting approach to the CO2 emitted from waste
burned (i) with energy recovery, or (ii) without energy recovery? It would
make no sense to do so, but the text here reads as such. Therefore please
specify again for combustion of biogenic waste without energy recovery
that the CO2 is reported as a memo item, and not within the national
inventory total. Further, it would be clearer ‐ more definitive ‐ to also
simply state here that all GHG emissions from the burning of the fossil‐
component of mixed wastes are to be reported in the national inventory
United Kingdom (oftotal ‐ in Energy for EfW and in Waste for incineration without energy
Great Britain andrecovery. I realise this chapter 1 section is dealing with "burning of
95 biomass", but to make this clear point is worthwhile.
Northern Ireland) Noted

270

Last sentence here is duplicated in the next paragraph, so can delete this272 sentence.

288

Given the effort put in for other stakeholders to establish core
responsibilities (e.g. for SNE, compilation experts), this section on data
providers is very light‐weight. It warrants some guidance adding here.
There is an opportunity here to set out some example expectations of e.g.
engaging with the inventory compilation (steering committee etc),
providing data for users (including inventory compilers) that support
inventory data quality objectives (notably time‐series consistent, i.e.
collect data on a consistent basis, and complete across all nationalsources, all regions etc). You could even talk about data quality systems(ISO...) that stats organisations should seek to achieve. You could go
United Kingdom (offurther and talk about data reporting formats, units, annual checks on
Great Britain and
290 data, data templates ‐ or that may be covered in later chapters.
Northern Ireland) Noted

The whole of Chapter 2 of Volume 1 is addressing datacollection. It was the intention of the writing team to avoid any
duplication but include references in the text ‐ which have been
included.

315

Useful to add that where data are accessed from a regular source (e.g.
website, annual statistical release), that it is good practice to also log thedate on which the data were accessed for the use in the national
inventory, as there are many data used in inventories where a more
recently published dataset becomes available during the inventory
compilation and reporting cycle, but is not used. Therefore good to state
328 explictly the origin data date.

This chapter 1 has a focus on the organisational aspects of thenational inventory system. The technical details of
implementation are addressed in other chapters of volume 1.
However, the note in table 1.5 was revised to indicate that thedataset description should include the version numer or date.

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United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

United Kingdom (ofGreat Britain and Accepted with
Northern Ireland) modification

It would not be helpful to go into any detail in this volume. The
details have to be discribed in AFOLU and/or energy sector
volume.

Deleted.

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345

The sentence as it stands is poorly drafted and confusing. Suggest "A
mechanism for the data users (e.g. SNE, inventory agency) to provide
feedback to the data provider on any priorities for future improvement of United Kingdom (ofGreat Britain and Accepted withthe dataset, e.g. perhaps data would be more directly useful in different
346 units."
Northern Ireland) modification

Reworded "procedures that enable the receiving party (thedata user, e.g., SNE or inventory agency) to provide feedback to
the data supplier on priorities for future improvement of thedata set".

331

This section misses the opportunity to elaborate on the benefits of a DSA.
Suggest that you add sentences along the lines of; "The purpose of
establishing a Data Supply Agreement is that it can be beneficial for bothparties ‐ the SNE/inventory compiler and the data provider; the DSA will
help to establish a secure data provision into the future, such thatinventories can be compiled in a timely, efficient and consistent manner,with a clear understanding on both sides of the expected data to bedelivered, the deadlines for delivery and the data quality requirements foruse in the inventory. Also a DSA can assist the data provider organisation,
United Kingdom (ofas it formally documents the data requirements and can help to secureresources within the data provider organisation to deliver the data on
Great Britain andNorthern Ireland) Accepted
360 time, to quality etc."

Sentence added "Ideally, a DSA is arranged between the GHG
inventory SNE and the data supplier stakeholder. A DSA can bebeneficial for both an SNE/inventory compiler and data
provider. A DSA can help secure data provision in the future.
Also, a DSA can assist a data supplying organisations by
establishing a formally recognized acknowledgement that canpromote the allocation resources within a data supplying
organisation to deliver high quality data on time. DSAs can be
useful for managing a regularly updated GHG inventory."

389

Change to either "Calculating GHG Estimates" or "Calculation of GHG
389 Estimates"

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Changed in 'Calculating GHG estimates'.

381

This paragraph is muddled english. Suggest you consider something like:"The process of preparing a national inventory will involve the use ofnumerous datasets, the application of a range of assumptions, expert
judgements, data conversions and manipulations (e.g.
aggregation/integration of data from multiple data sources). Inventory
compilation and the documentation of the data inputs, assumptions andother details may be performed in a range of models, and the model
outputs from across all source categories will need to be aggregated andreported in a consistent national dataset. (See Volume 1, Chapter 2 forfurther details on models and tools typically used for inventory
383 compilation.)"United Kingdom (ofGreat Britain and Accepted with
Northern Ireland) modification

Simplified text and focused on reference to other chapters for
guidance on documentation.

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Responses

Authors' notes

384This paragraph misses a key message in my view. I suggest that you add
that: "In all cases, the choice of data management system for inventory
compilation and reporting should consider factors such as: the available
resources (human, financial, IT) for inventory compilation; the existing
capacity and skill‐set of the inventory compilation team, and provision oftraining where necessary, to ensure that the development of new models
and data management systems will support and improve the inventory
United Kingdom (ofquality." Also useful to draw out that communication across all parties
Great Britain andinvolved in the inventory compilation of inventory‐wide protocols (e.g.
388 colour‐coding) is necessary.
Northern Ireland) Noted

The factors listed in comment are mostly relevant for all
aspects of inventory development (e.g., resources, capacity,etc.), so it seems odd to mention them specifically here. Plus,
the list given is not comprehenisve of all factors so it seems
improper to list some factors and not others. It is beyond thescope of this section to provide detailed guidance on the designof data mgmt systems.

56

Concepts from Volume 1 of the 2006 IPCC Guidelines have been
inexplicably removed from this section. These concepts relate to:anthropogenic emissions and removals, National territory, Inventory year
and time series, Inventory reporting, Greenhouse gases, Other gases,
Sectors and Categories. These are essential to the basis of the IPCC
Guidelines; deleting this text would not respect the terms of reference forthe 2019 MR. The 2006 IPCC GLs clearly define these concepts as applying
to all sectors; in the current version the only sentence referring toanthropogenic emissions and removals relates to the LULUCF sector,
95 which is misleading.

Accepted

Concepts' have been reinserted.

CanadaNoted

It would not be helpful to go into any detail in this volume. The
details have to be discribed in AFOLU and/or energy sector
volume.

CanadaAccepted

Changed.

Canada

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Please include biomass fuels not sourced from harvested wood or forest
products. For example, from agricultural products or landfill/waste
management sources of biomass fuel (landfill gas or 'renewable natural
95 gas') products.
The text should read ‘…emissions and removals…’ and NOT ‘…emissions
68 and sinks…’.

77

There is a significant transparency issue when CO2 emissions frombiomass ‐ a major source of energy globally ‐ is quantified implicitly; the
IPCC should ensure its guidance ensures a transparent ‐ as opposed to
77 “implicit” – quantification of emissions from biomass energy.

Canada

Noted

There are good reasons for estimation of emissions frombiomass combustion based on biomass carbon stock change in
AFOLU sector.

103

The text continues to mix scientific guidance on how to develop high‐quality estimates with policy prescriptive text on reporting requirements
or how countries could organize their inventory systems. This issue wasraised during the first government review and we find it has not been
sufficiently addressed. The introductory statement that “the details of thissection should not be considered prescriptive” (line 113) is insufficient toaddress our concerns; specific changes are provided below for this361 section.

CanadaAccepted withmodification

The comment has been taken into consideration and text
revised where possible.

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TolineComments

Please change text: “They provide suggested possible approaches and
113 examples…”Please change text: “The development of national GHG inventory systems
could benefit from being should be developed in cooperation or
116 integration with…”
Please change the title of Table 1.1: “AN ILLUSTRATIVE EXAMPLE OF A
179 SUGGESTED STRUCTURE FOR CAPTURING AND…”Please change headings in Table 1.3: “Common Actor and Stakeholder
210 Type” “Typical Necessary Capabilities”
Please change text: “Table 1.4 provides examples of suggested metadata
218 for…”
Please change the title of Table 1.4: “EXAMPLES OF SUGGESTED
221 METADATA FOR TRACKING GHG INVENTORY STAKEHOLDERS”
Please change text: “Inventory management and coordination can be is
258 delegated to…”

Country

Responses

Authors' notes

CanadaAccepted withmodification

Sentence reworded to include the word possible, although it
implies that it is necessary to clarfy that the reader needs to be
told that approaches are not "impossible".

CanadaCanadaCanadaAccepted withmodification
Accepted withmodification

Text revised with appropriate grammatical correction.
Wording changed for readibility.

CanadaRejected
Accepted withmodification
Accepted withmodification

CanadaAccepted

Changed in "Table 1.4 provides examples of metadata for …".
Changed in "Examples of metadata for tracking GHG inventory
stakeholders".
Changed in "Inventory management and coordination can bedelegated to…"

CanadaAccepted withmodification

Changed to "A private company, university or other non‐government organisation. The inventory management andcoordination can be contractually delegated to an organisation
outside of government, such as a university, research institute,or a consultancy/private company. This organisation may be
selected for its technical competency and capacity tocoordinate the activities and expertise for the compilation andreporting of the inventory. Contracts can be typically set‐up
with well‐defined deliverables and quality objectives andcommitments to engage the organisation preferably over a
suitable period (e.g. 4 to 6 years) to promote the sustained
development and maintenance of the GHG inventory.
Provisions could be in place for the full transfer of data,
documents, calculation and reporting tools and knowledge ofthe national GHG inventory from the contracted organisation to
the SNE or new contracting organisation at the end of thecontract period."

CanadaAccepted

Changed.

CanadaAccepted

Changed in "These provisions can help ensure national ..".

CanadaThe current heading reflects the text.

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Please change text: “A private company, university or other non‐government organisation. The inventory management and coordination
can be are contractually delegated to an organisation outside ofgovernment, such as a university, research institute, or aconsultancy/private company. This organisation may be is selected for its
technical competency and capacity to coordinate the activities andexpertise for the compilation and reporting of the inventory. Contracts
can be are typically set‐up with well‐defined deliverables and quality
objectives and commitments to engage the organisation preferably over a
suitable period (e.g. 3 to 5 years) to promote the sustained development
and maintenance of the GHG inventory. Provisions could should be inplace for the full transfer of data, documents, calculation and reporting
tools and knowledge of the national GHG inventory from the contractedorganisation to the SNE or new contracting organisation at the end of the
272 contract period.”
Please change text: “…provisions could should be in place for the transfer
274 of data…”
Please change text: “These provisions can help will ensure national
276 retention of…”

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Please change text: “A national GHG inventory system can benefit from279 needs a committed team of inventory compilation experts.”

CanadaAccepted

Changed in "A national GHG inventory system can benefit froma ..".

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Please change text: “As an example, roles and responsibilities for core
284 compilation functions of the GHG inventory team are also outlined in…”

CanadaAccepted

Text changed.

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Please change text: “Further examples suggestions for the289 formalization…”

Country
CanadaAccepted

CanadaAccepted

Changed in : “Possible contents, taken from examples of…”

Accepted

Text revised taking into consideration the comment.

Noted

It would not be helpful to go into any detail in this volume. The
details have to be discribed in AFOLU and/or energy sector
volume.

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448

The new proposed text related to GHG inventory training activities
appears to impose requirements which are beyond the scope of IPCC
guidance and additional clarity indicating the content is not prescriptive
should be added. The introductory statement that “the tools in thissection should not be considered prescriptive” (see line 369) is insufficientto address our concerns, however the following specific changes provided
for this section will: “Suitably trained and/or experienced GHG inventory
experts help should support the national GHG inventory system toefficiently produce high quality outputs.” “Ready access to training and
449 regular review participation can will help build national capacity…”

Canada65

This is a good addition to the 2019 refinements. It is a concise summary of
how biomass is currently accounted for within national GHG inventories.
However, recommend to put more emphasis on how this accounting
practice only works when assessing/reporting emissions across all source
categories, or at least both Energy and LULUCF sectors. Furthermore,when reviewing individual sectors (e.g., assessing Energy sector without
also assessing AFOLU), the current IPCC accounting/reporting approachfor the CO2 emissions from the combustion of biomass does not hold true
95 because the carbon/CO2 reported to LULUCF is not accounted for.

United States ofAmerica

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Authors' notes

Changed in "An important component of institutionalarrangements is a systematic approach to data management
and the collection of data. A first step could be to create andmaintain an archive and list of the datasets that are needed for
the GHG inventory compilation. This archive and list, which canbe established for each sector or as a centralised entity, canhelp to build and maintain institutional memory and support
efficient and transparent compilation of regular updates. An
illustrative outline for a list of datasets is presented in Table
1.5.

Please change text: “An important component of institutionalarrangements is a systematic approach to data management and thecollection of data. A first step could be is to create and maintain anarchive and list of the datasets that are needed for the GHG inventory
compilation. This archive and list, which can be established for each sector
or as a centralised entity, can will help to build and maintain institutional
memory and support efficient and transparent compilation of regular
updates. An illustrative outline for a list of datasets is presented in Table
320 1.5.”
Please change text: “Possible Suggested contents, taken from examples
337 of…”

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Though this text is an improvement toward clarifying the 'why' behind
IPCC accounting for biogenic CO2 in the AFOLU sector, it still is a bit
muddied and requires further clarification. Specifically, this paragraphshould also include additional text that puts more emphasis on how thisaccounting practice (of assigning the biogenic emissions associated withbiomass use for energy to AFOLU) ONLY works whenassessing/inventorying emissions across all or at least both the AFOLU andenergy sectors. It should also assert that when looking at individual
sectors (e.g., assessing energy sector without also assessing AFOLU), thisaccounting method for assigning biogenic CO2 emissions to AFOLU does
not hold because the biogenic CO2 contribution from AFOLU‐based
biomass combustion/conversion is not accounted for. It is imperative thatthese important disctinctions be made to eliminate further confusion on
88 how the IPCC views biogenic CO2 emissions.

United States ofAmerica

Responses

Authors' notes

Noted

It would not be helpful to go into any detail in this volume. The
details have to be discribed in AFOLU and/or energy sector
volume.

Accepted

Corrected.

Accepted

Repeated.

Rejected

Requested explanatory text has already been provided in lines
170‐178.

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Footnote pertaining to clarification on accounting for biogenic CO2 related
to annual crops should be at the end of the sentence on that topic, which United States ofAmerica82 ends on line 79. Currently the footnote is at the end of line 82.
It would be helpful to repeat here "The details of this section should not
United States of
157 be considered prescriptive."
America

179

Provide additional information on how to fill out and use the table, andclarify or provide some examples on why the table is helpful. As is, thetable is confusing and inventory compilers would have no idea how to fill
179 this out, or what to use it for.

United States ofAmerica

Accepted withmodification

United States ofAmerica

Accepted withmodification

It is suggested to keep the "Steering group" in the figure.
However, a footnote has been added to highlight that this is a
generic term used to represent any coordinated review anddevelopment of the GHG inventory.
The role of the policy advisor should be to help make theinventory policy relevant, e.g. by being able to reflect
mitigation actions being implemented. Revised to "policy
analyst".

Accepted withmodification

Sentence added to state that a single individual may serve inmore than one actor role. Experience shows that usuallysmaller countries use linear structures whereas large countries
need more complex and larger organisation.

2973

1

1

2975

1

1

201

Consider removing "Steering group" from this figure. Consider also that
there are many ways to bring outside input into the inventory process,e.g., through a public review period for the inventory. These other201 approaches should be noted in this chapter as well.

2977

1

1

209

Given that inventories are meant to be policy neutral, recommend
209 deleting the role of policy advisor.

209

It would be good to note here that a good inventory can be developedwith far fewer actors/stakeholders than this table is implying. This table
would be intimidating to a group trying to develop an inventory program
209 for the first time.

2979

1

1

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United States ofAmerica

Noted

The details of such information are included in Chapter 2 ofVolume 1.

378

Table 1.6: Consider moving the point on stakeholder consultation up in
the process. There will not be much that can be done with that feedback
379 with only a few weeks before submission of final inventory.

United States ofAmerica

Noted

Table 1.6 is only illustrative. It may require adjustment to thespecific national circumstances.

1

1

209

2985

1

1

1

2991

1

1

408

2993
73

1
1

1
2

455
102

365

1

2

219

367

1

2

296

369

1

2

1252

371

1

2

1288

373

1

2

Sentence added to state that a Steering committee is just one
approach for the purpose of getting external input. It is up tocountries how to structure input or governance over inventory.
It is not an issue for this section to prescribe whether or not a
Steering committee is establish or what advisory role it shouldhave. The figure is already labeled as an example.

288

2983

1

Authors' notes

Note here that a wide variety of data sets from a wide variety of data
providers may be appropriate/necessary to compile the GHG inventory.
Note also that a lot of (maybe most at this point?) data may be publicly
available over the internet. In that case, the inventory compiler should
review the QA/QC plan of the data set and ask any questions to clarify
appropriate use of the data set, but no formal arrangement is likely to be
290 necessary.

209

2989

When discussing the idea of a steering group, specify that the groupshould be balanced and unbiased. Industry stakeholder groups will point
to the "Steering Committee" as discussed in the IPCC guidance to try tohave more influence on the national inventory process, perhaps
209 introducing a bias to the process.

Responses

209

1

1

Country

209 Change "Typical Roles" to "Example Roles"
For sector experts, add "Identification of potential improvements to
209 estimates"

11Comments

United States ofAmerica
United States ofAmerica
United States ofAmerica

2981

2987

Toline1288

Accepted withmodification
Accepted withmodification

Revised to say "examples of typical roles".

Accepted

Added.

Some subsources require thousands of data inputs (usually pasted into
spreadsheets in rows). The suggested table is not practical for many ofUnited States of
412 these categories, this issue should be discussed in this paragraph
America
Rejected
Consider adding sector‐specific training activities (e.g. conferences, site
visits) to improve the source lead's understanding of emission sources and United States of
455 trends
America
Noted
All types of forests
Iran
Accepted
Figure 2.0b: It is proposed to increase the size of the figure, because it isRussian Federation Accepted
220 impossible to read the text in the boxes.
Box 2.0A: It is proposed to edit the text of Confidentiality Agreement,
because "we", "you" and "your" seem irrelevant in the context of the344 formal agreement.
Russian Federation Rejected
It is proposed to include "emission and removal categories" in the text ofthe bullet to read: "Methods and emission and removal categories used
Accepted with
1252 are in line with IPCC methodologies"
Russian Federation modification
Figure 2.3: It is proposed to increase the size of the figure, because it is1289 impossible to read the text in the boxes.
Russian Federation Accepted

Figure 2.3: It is proposed to include in decision tree a requirement thatmethods and categories used by the FRD must be consistent with those in
Accepted with
Russian Federation modification
1289 the IPCC Guidelines.

Page 10

The focus of Chapter 1 is on the organisational structure andalso the necessary skills have been addressed. The guidelines
cannot describe any detail of the "how".
Training on IPCC Guidelines and methodologies is addressedalready in section 1.6.4.
Adds clarity.
Figure has been formatted.
This is a quotation from a national agreement as an example.
The words are correct.
Incorporated suggested text with modification by placing'categories of' before 'emissions and removals'. Also delected
text after methodologies.
Figure has been formatted.
Modified text corresponding to 'Conduct quality assessment of
FRD' to 'At minimum, quality assessment should be based on
country’s FRP and IPCC quality requirements. See Section
2.3.2.1, Table 2.4 and Table 2.5, for quality criteria examples.'This section including tables note that methods must align withinventory or be of higher tier.

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639

641
643

VolumeChapter111Fromline222

TolineComments

Country

70

70 Suggest "required" be changed to "necessary" [it sounds less prescriptive]

82
93

The sentence "A network of data providers will need to provide
information on an annual basis" needs to be modified to take into accountnational circumstances such as the country doesn't produce an annual ghg
inventory, and even if it does, collection of annual data is not always
83 necessary to enable a country to prepare a ghg inventory report annually.
93 delete "emission" from the end of the line

Suggest that the phrase "need to be estimated using higher Tier methods"
be modified. The application of higher tier methods to key categories will
always depend on national circumstances, and while it is highly desirable,using the phrase "need to be estimated using higher tier methods" is toostrong, particlularly if read in conjunction with the first part of thesentence "When starting the inventory compilation for the first time...." .
A possible redraft would be to delete "need to be estimated using higher
Tier methods" from the first sentence, with the second sentence reading:"It is good practice to use Tier one methods for non‐key categories andhigher tier methods for key categories if national circumstances allow (seechapter 4)" . This language is consistent with that in footnote 1 which
97 occurs in line 176 and is at the bottom of page 2.7

645

1

2

95

647

1

2

194

649

1

2

211

Change "undertake new surveys targeting inventories relevant sectors" to
195 "undertake new surveys targeting data from relevant inventory sectors"
Change "formalized in any agreement to data supply" to read "formalized
211 in any data supply agreement"

355

The sentence "Each inventory compiler will need to find suitable
categories to aggregate confidential emissions suited to their national
circumstances" should be removed from Example 2 and placed near the
356 top Box 2.0B as a chapeau for Examples 1 and 2.

729

1

2

Page 11

New Zealand

Responses

Authors' notes

Rejected

Authors consider the word "required" as not prescriptive.

Rejected
Rejected

Data collection should be on an annual basis. And it is best to
have an annual inventory process to mantain expertise, allow
for improvements and track emissions. Nevertheless, in casedata are missing for certain temporal periods there aremethods that allow for the estimation of data gaps.
They are called emission inventories.

New Zealand

Accepted withmodification

Sentence changed. "Need" changed to "Should" and added thesame footnote here for consistency and so it is clear that thisshould be done but there is an allowance for a lack ofresources.

New Zealand

Accepted withmodification

New Zealand

Rejected

Changed in "undertake new surveys targeting inventory
relevant sectors".
The proposed change may imply a specific type of agreement.
This is more generic (e.g. MoU, LoA etc).

New Zealand

Accepted

Changes implemented.

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Country

Responses

Authors' notes

Text changed in "If there is insufficient information onemissions data, then it may be necessary that these countries
undertake measurement programs in a cost‐effective androbust manner".
Added missing article ‐ changed to ", if available to thecompiler, "

731

1

2

684

The sentence "If there is insufficient information on emissions data, thenit is necessary that these countries undertake measurement programs inan effective and robust manner" could be interpreted as ratherprescriptive given that there may be extenuating circumstances thatwould prevent this, as well as, in some cases, undertaking suchmeasurement programmes on a more regional basis (involving more than
one country) could be a more efficient approach. In addition, as theparagraph goes on to say, there may be other ways of
improving/developing country‐specific factors. Consider modifying to say:
"If there is insufficient information on emissions data, then it may benecessary for these countries to undertake measurement programs in a
686 cost‐effective and robust manner"

733

1

2

960

960 Make "compiler" plural

New Zealand

Accepted withmodification
Accepted withmodification

965
973
980
988

Suggest the phrase "integrating facility‐reported data (FRD) into inventory
is optional" be modified to read "integrating facility‐reported data (FRD)
965 into the national GHG inventory is optional"
973 Change "primarily" to "primary"
980 Change "proposes" to "purposes"
988 Make "definition" plural

New Zealand
New Zealand
New Zealand
New Zealand

Accepted
Accepted
Accepted
Accepted

Modified.
Changed.
Changed.
Changed.

New Zealand
New Zealand
New Zealand
New Zealand

Accepted
Accepted withmodification
Accepted
Accepted

Sentence rephrased.
each' has been removed from the sentence in consideration ofanother comment (ID 1847).
Changed.
Changed.

New Zealand

Accepted

Sentence rephrased using 'practical and efficient'.

New Zealand

Accepted

Rephrased 'it would be productive …'

735
737
739
741

1
1
1
1

2
2
2
2

743

1

2

1073

745
747
749

1
1
1

2
2
2

1088
1098
1109

The phrase "by providing at via single point common data requirements"
needs some attention. A possible redraft would be: "by providing
1073 common data requirements"
Change "each participating organisations" to "each participating
1088 organisation"
1098 Change "threshold" to "thresholds"
1109 Change "estimate and method" to "estimates and methods"

751

1

2

1181

753

1

2

1195

755

1

2

1206

757

1

2

1240

Possibly not appropriate to say "it is stongly recommended" as this will beseen as being presecriptive. Look at rephrasing using something like "it1181 would be practical and efficient that emissions reporting facilities …"
As above, it may not be appropriate to say "it is strongly recommended".
1195 Look at rephrasing
Suggest "will account for completeness issues due to coverage" bechanged to "will address completeness issues due to coverage i.e. avoid
1206 use of "account for"
Change "When such break occurs and it may be justifiable" to "When such
1241 a break occurs it may be justifiable"

759
761
763

1
1
1

2
2
2

1242
1248
1265

Change "In these cases, explanatory documentation should be required"
1242 to "In these cases, explanatory documentation should be provided"1248 Change "process" to "processes"
1265 Change "consumptions" to "consumption"

Page 12New Zealand

New Zealand

Accepted

Changed as suggested.

New Zealand

Accepted

Changed.

New Zealand
New Zealand
New Zealand

Accepted
Accepted
Accepted

Changed.
Changed.
Changed.

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767

769
771
773
775
777

941

943

991

VolumeChapter
1

1

1
1
1
1
1

1

1

1

Fromline
2

2

2
2
2
2
2

2

2

2

1275

Comments
Change "compare with inventory’s" to "compare with inventory" or
1275 "compare with the inventory’s"

New Zealand

Responses
Accepted withmodification

Text changed in 'compare with inventory’s emission estimates'.

1288

In the second to bottom row of the decision tree, change "Is coveragecomplete and activity data is in‐line with national dataset?" to "Is
1289 coverage complete and is activity data in‐line with national dataset?

New Zealand

Accepted

Changed.

1296
1304
1309
1310
1319

Not obvious why the period "5 to 8 years" is specified (except in thatthese periods are the same as CP1 and CP2 under the Kyoto Protocol.
These time periods are close to irrelevant for the purposes of the 2019refinement. Suggest that the first use "only once every 5‐8 years" ischanged to "only once for a multi‐year period"; and that the second use"e.g. for landfills, the collection of data on waste composition may occur
every 5‐8 years in this case, the composition of waste should be used torepresent the composition within those years" is changed to "e.g. forlandfills, where the collection of data on waste composition may notoccur annually, the composition of waste should be used to represent the1299 composition within those years" .
1304 Delete "the" before "it"1309 Insert "of" before "Models"1310 Change "IPCC, 2011" to "IPCC, 2011b"
1319 Change "IPCC, 2011" to "IPCC, 2011b"

New Zealand
New Zealand
New Zealand
New Zealand
New Zealand

Accepted
Accepted
Accepted
Accepted
Accepted

Changes implemented.
Deleted.
Inserted.
Changed.
Changed.

Accepted withmodification

Changed to:
3. Modify existing data sets to meet the inventory
requirements (e.g. where data is not collected on a calendar
year basis annually, convert from (e.g. financial year) convert tocalendar year, adjust for different classifications of sources orfill gaps in territorial coverage).

NotedThis section does encourage the development of emission
factors of one's own national condiitons. It is not possible toprovide methods specifically for developing countries ‐ they are
the same as for all countries. Providing actual emission factors
for developing counties as a whole is an enormous task beyond
the scope of this document.

Accepted withmodification

Sentence changed. "Need" changed to "Should" and added thesame footnote here for consistency and so it is clear that thisshould be done but there is an allowance for a lack ofresources.

188

TolineConsidering the fact that countries differ in the cycle of preparing
emission inventories on an annual, biennial or quadrennial basis, it issuggested that "where data is not collected annually" be replaced by
188 "where data is not collected regularly".

680

As required in the outline adopted at the 44th plenary session, thischapter should develop emission factors for developing countries. So it issuggested to add recommendations, encouraging the development of
814 emission factors suitable for one’s own national conditions.

96

Sentence "It is good practice to use Tier one methods for non‐key
categories" indicate that Tier 1 method should always be used for non‐key
categories. However, if Tier 2 or Tier 3 method is already in use or moresuitable for a certain country it is also good practice to use these methods
even for non‐key categories and even though not mandatory according todecision trees. The sentence should be removed or modified as "Tier 1
97 methods can be used for non‐key categories according to decision trees".

Page 13

Country

China

China

Finland

Authors' notes

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TolineComments

Country

173

On line 173 it is stated that "Following the 2019 Refinement, it is possible
to provide a Tier 1 estimate for every category. The sectoral volumes
contain default Tier 1 emission factors and parameters that can be used".
174 Have the writers checked that this is certainly the case in every category?

Responses

Authors' notes

FinlandAccepted

Changed in "Following the 2006 IPCC Guidelines and its 2019
Refinement..."FinlandAccepted withmodification"Provided a Tier 2 or 3 method exists in the guidelines." added
as a footnote as the authors think it unlikely that a key category
will not have a tier 2 method.

995

1

2

682

Please change the sentence "for key categories it is good practice todevelop country specific emission factors" to "for key categories it is goodpractice to develop country specific emission factors if Tier 2 or Tier 3
method for that specific category requires it". Not all Tier 2 approaches,
which can be used for key‐categories, require country‐specific EFs (e.g.
684 2F1, transport)

1241

1

2

365

after 'provided;' add ' the most appropriate way to impose corrections to
365 activity data based on other sources as well as expert knowledge;'

India

Rejected

1243

1

2

435

Add the sentence at the end ' Screening process may involve theoretical
435 excercises utilizing backup knowledge which identifies improper data.'

India

1245

1

2

450

India

Rejected
Accepted withmodification

Changed "national" to "extent of".

1423
1441

1
1

2
2

1417
127

SwedenEU

Accepted
Accepted

Removed.
Inserted.

1443

1

2

252

EU

Accepted

Consistency in NSO usage has been ensured during final
editing.

1445
1447

1
1

2
2

1054
1432

EU
EU

Accepted withmodification
Accepted

Added 'this'.
Changed.

1449

1

2

1435

EU

Accepted

Link updated.

450 After 'national coverage,' add 'extent of coverage and limitation,'.
"Another document published by UN is on definitions, units of measure
and conversion factors relative relative to energy statistics (UN,1987),
which contains detailed information on terminologies for energy
commodities, units of measurement and conversion from one unit to1419 another." Remove one relative.
127 insert 'data from' after 'use existing', add 's' to collection
The sentence ends with '...national statistical offices (NSO)', but
afterwards the abbreviation NSA is mostly used. NSA is defined earlier.
Use either the term NSO or NSA consistently through the chapter, or
252 explain the different usage.
Split the sentence into two or insert the missing word: '… and is why many
1054 inventories'. Replace inventories by inventory compilers.
1432 Please use Eurostat instead of EUROSTAT
Footnote 32; a much more relevant link is:1435 https://ec.europa.eu/eurostat/web/energy/overview

Page 14

Corrections to activity data are NOT part of chosing a proper
methodology.
This comment is related to original text from the 2006 IPCC
Guidelines. Theoretical exercises and backup data are unclear.
This was not intended to involve reseach type exercises but areview of existing data.

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1817

1819

1821

1823

VolumeChapter

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Fromline

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TolineComments
In our view, the decision tree shownin figure 2.0b cannot be considered‘good practice’, contrary to what line 821 suggests’: ‘It is good practicewhen producing suitable activity data to follow the stepwise approachshown in Figure 2.0b.’ Some reasons are: a) the decision tree is toocomplex and difficult to implement in practice; b) we do not agree thatcountries should use ‘expert judgement’ or ‘surrogate data’ in all cases.
We think that there should be a distinction between key categories, forwhich you would expect data collection activities when activity data is
missing, and non‐key categories, for which it may be justified using
surrogate data; c) This decision tree should also be consistent with sector‐
specific decision trees, where lack of activity data for key categories
generally leads to an expectation of data collection activities; d) The
phrasing in boxes such as 'data is satisfactory' or 'assumptions arereasonable', is in our view too vague to be ‘good practice’. Thus, even if
the rationale for developing a decision tree for data collection isimportant, we would see this decision tree as an example of how
countries could approach data collection. We do not think it qualifies as‘good practice’ as it stands now. We do not think it should be removed asa whole either, as some countries may find it useful with the needed
modifications. For instance, distinguishing between key sources and non‐key sources is very relevant. Thus, we could suggest adding ‘is it a KC?
Yes/No’ after the box ‘can the data be collected…?’ If Yes, then ‘set up
programme to collect data’; if No, then ‘use surrogate data’. While expert
judgement is relevant for the choice of methods and input data, we thinkthat expert judgement by itself should be avoided as input to estimating
GHG emissions. Expert judgement may be used in some cases as a lastresort involving non‐key categories or when the actual or surrogate data
are missing.

Country

Responses

Authors' notes

There is a circularity here ‐ how can you identify key categories
if you do not have any data?
Do not agree this is too complex ‐ it has to cover the available
options. Data collection is a very important part of compiling an
inventory and should not be over simplified. For countries withestablished inventories this should not impose additional
activities.
The comment would be true for developed countries but for
those with few resources some allowances should be made,especially when an inventory is being compiled for the firsttime.
Text on "data satisfactory" and "assumption adequate" hasbeen replaced with "Ensure data is complete, has uncertainty
information, is transparent, consistent over time and with thesectorial definitions, and is as accurate as practical".
EU

Accepted withmodification

Boxes added on key categories.

79 Change 'statistical' to 'statistical or administrative'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Changed.

194

194 Change 'inventories' to 'inventory' (or 'sectors relevant to inventories')

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Suggestion implemented as proposed.

728

It's useful having the web links for the new data sources ‐ if possible,
728 could these be added for the other entries in this table?

United Kingdom (ofGreat Britain andNorthern Ireland) Rejected

Web addresses are avoided as they change.

973

This sentence should be reworded to 'Although the primary focus of thissection is to provide guidance on integrating industrial facility data of
industries under the Energy and the Industrial Process and Product Use
sectors of the IPCC’s Guidelines, these integration concepts and guidance United Kingdom (ofcan be adapted to most other IPCC sectors and categories such as Waste
Great Britain and
976 (i.e. wastewater treatments or landfills)'
Northern Ireland) Accepted79

Page 15

Sentence rephrased.

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1827

1829

1831

1833

1837

1839

1841

1843

1845

1847

1849

VolumeChapter

1

1

1

1

1

1

1

1

1

1

1

1

Fromline

2

2

2

2

2

2

2

2

2

2

2

2

TolineComments

Country

Responses

Authors' notes

986 Change 'approached' to 'approach'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Changed.

987 Change 'multiply' to 'multiple'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Changed.

988 Change 'definition' to 'definitions'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Changed.

1042 Remove 'of'United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Removed.

1043 Replace 'facility's' with 'a facility'

United Kingdom (ofGreat Britain and Accepted with
Northern Ireland) modification

Deleted in paragraph revision in response to comment ID 1959.

1044

1044 Remove 's'United Kingdom (ofGreat Britain and Accepted with
Northern Ireland) modification

Deleted in paragraph revision in response to comment ID 1959.

1051

In last bullet, replace 'request for supporting documentation' with
1051 'request supporting documentation'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Revised.

1051

1051 In footnote 27, replace 'contributes' with 'contribute'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Replaced.

1073

Replace 'at via single point common data requirements' with 'common
1073 data requirements at a single point'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Replaced.

1087 Replace 'This' with 'These'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Replaced.

1088 Remove 'each'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Removed.

1103 Replace 'overtime' with 'over time'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Replaced.

986

987

988

1042

1043

1087

1088

1103

Page 16

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1853

1855

1857

1859

1861

1863

1865

1867

1869

1871

VolumeChapter

1

1

1

1

1

1

1

1

1

1

1

Fromline

2

2

2

2

2

2

2

2

2

2

2

TolineComments

Country

Responses

Authors' notes

1140 Replace 'established' with 'establish'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Replaced.

1196

1196 Replace 'multiply' with 'multiple'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Replaced.

1198

The text on the diagram isn't very legible, particularly s=2 and s=3 due tothe text being on top of a patterned background ‐ these could maybe
1198 moved elsewhere on the diagram for clarity

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Figure has been formatted.

1203

1203 Replace 'allow' with 'allows'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Change implemented as proposed.

1240

Replace 'When such break occurs and it' with 'When such a break occurs
1241 it'United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Replaced.

1258 Remove ','United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Removed.

1260 Remove 'for'United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Removed.

1296 Replace 'period' with 'periods'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Replaced.

1304 Replace 'how the it has' with 'how it has'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Replaced.

1309 Replace 'Use Models' with 'Use of Models'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Replaced.

1397 Replace 'published' with 'publishing'United Kingdom (ofGreat Britain and Accepted with
Northern Ireland) modification

Changed with 'with published statistics…'

1140

1258

1260

1296

1304

1309

1397

Page 17

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1933

1935

1937

1939

1941

1943

VolumeChapter

1

1

1

1

1

1

Fromline

2

2

2

2

2

2

TolineComments

Country

Responses

Authors' notes

80

Confusing sentence. Suggest you simplify and turn the second bit around:"During the data collection for the greenhouse gas inventory, interactions
between the inventory compilers and stakeholders will take place. This
consultation with data providers and other stakeholders may be the mosttime‐consuming part of the emission inventory compilation process, evenwhen many statistics useful for the inventory may be freely available via
the internet." Even better if you explain here WHY this can be time‐
consuming, e.g. to ensure that the inventory compilers understand theUnited Kingdom (ofscope and origin of the data; to enable discussions to identify potential
improvements (in completeness, quality) of data gathering systems, such Great Britain and Accepted with82 as new survey questions or parameters to be reported.
Northern Ireland) modification

Sentences have been revised to improve clarity.

97

Several instances of cross‐references to "chapter 4". Suggest that you are United Kingdom (ofconsistent with the approach generally in the GLs of also citing theGreat Britain and
99 Volume, in this case "Volume 1, Chapter 4".
Northern Ireland) Accepted

Consistency in usage of cross‐references has been ensured
during the final editing.

103

Not convinced that the sentence "Inventory compilers should aim forcompleteness and focus on further improvements of inventories in later
years.." sits here in the Data Collection section ‐ this appears to be astatement asserting the order of priority for TCCCA. If valid, thenpresumably that should sit in Vol 1 Chapter 1.5? Also ‐ do we think this IS
valid? Should a developing country for example focus on ensuring
completeness for all sources before worrying about the accuracy ofUnited Kingdom (ofemissions from key categories? The similar text in lines 199‐200 is pitched Great Britain and
104 much better, so perhaps just delete the text in lines 103‐104.
Northern Ireland) Accepted

Deleted ". Inventory compilers should aim for completenessand focus on further improvements of inventories in later
years" as this was not clear.

119

VERY small text in the diagram here. Borderline illegible. Please can you
amend the diagram so that the text in each box is readable, if printed on
121 A4 paper?

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Figure has been formatted.

171

This sentence seems out of place here. If retained, then suggest that you United Kingdom (ofwrite out in full "the European Union Emissions Trading System (EU ETS)" Great Britain and
172 as this appears to be its first use.
Northern Ireland) Accepted

EU ETS written out in full.

222

Good section but would be useful to also stress the benefits to the data
provider organisation. Suggest adding (to last sentence for example)"…and to clarify/document the inventory data requirements with data
suppliers may help to secure the regular provision of resources within that United Kingdom (ofGreat Britain andorganisation to provide the data to the required quality and on time inNorthern Ireland) Accepted
229 future inventory cycles."Suggestion followed.

Page 18

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1945

1947

1949

1951

1953

1955

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1

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1

1

1

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2

2

2

2

2

2

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Authors' notes

245This section presents information on how to manage the process ofgathering confidential data. It would be useful (and help promote
efficiency for the compiler) if the link can be made, regardingtransparency, of the prevailing national inventory review process and that
review teams are mandated to maintain data confidentiality, and hence
that in the compilation and management of confidential data, thatcountries should consider how they will be able to report the data to areview team, for example for the UNFCCC process. If this is not
appropriate in the "Data Collection" section, then can you add a link towhere this information is covered in an "Inventory Data Reporting"section of Volume 1? You could even add examples within that Box 2.0B,
such as adding text to the "Example 1" along the lines of: "Further, in thereporting of the national inventory it may not be possible to present
details of the facility‐level data, but for the purposes of the inventory
review process the inventory agency may prepare a spreadsheet to beshared with the UN review team, presenting facility‐level data, to ensure United Kingdom (ofGreat Britain andthat the transparency of the inventory can be maintained without
357 disclosing the information in public domain publications.
Northern Ireland) Rejected

No action can be taken because comment is out of scope of2019 Refinement. It is not up to the IPCC to decide on how theUNFCCC reviews should treat confidentiality.

399

Can you provide examples, similar to in lines 397‐8? E.g. perhaps you
United Kingdom (ofmean "leading academic researchers", "emission inventory sector experts Great Britain and Accepted with
400 from other countries with similar national circumstances"..?
Northern Ireland) modification

Academic researchers are covered already. Added tointernational experts.

700

Sentence doesn't scan. Suggest: "For more detailed guidance onparameters influencing emission factors, see sector‐specific guidance in
701 Volumes 2‐5."

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Suggestion followed.

702

In RH column suggest adding: (Energy‐fuel comb‐mobile) CH4 and N2O..
"Emission control technologies, including additives and equipment fitted
703 to vehicles in the fleet."

United Kingdom (ofGreat Britain andNorthern Ireland) Rejected

This does not seem to be a significant source.

958

Suggest adding some examples of improved data supply that can help to United Kingdom (ofderive higher‐tier methods, to help clarify to compilers what they may be Great Britain and
959 able to use, e.g. add "..such as fuel NCVs, industrial production data.."
Northern Ireland) Accepted994This paragraph really belongs in the introduction to section 2.3, not here
997 under the "design" section

Page 19

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Implemented.

Paragraph moved to section 2.3.1.

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1957

1959

2581

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Country

Responses

Authors' notes

Within this table, one key aspect of facility reporting that needs to be
included as a quality criterion (I suggest under "transparency", but you
may consider a different TACCC criterion as more appropriate, as there
are related points made under both comparability and completeness) is
thus: "Where a facility reports emissions from more than one emission
source category, for example a cement kiln reporting emissions fromcombustion of fuels (Energy) and decarbonisation of minerals (IPPU), thenthe reporting of AD, EFs and emissions should enable resolution of thetotal GHG emissions between these different source categories." You may
regard this as implicit due to the wording one of your other statements, United Kingdom (ofbut I think to specify this clearly will be important for some inventory
Great Britain and Accepted with
1026 compilers.
Northern Ireland) modification

Accepted but text shorten and made stronger: "• FRD should
be reported at a sufficient level of disaggregation forassessment and use. For example, where a facility reports
emissions from more than one emission source category,(e.g. a cement kiln reporting combustion emissions (Energy)
and process emissions (IPPU)), then AD, EFs and emissions
should be reported separately for these source categories."1037

Two concerns with this paragraph. Firstly the provision of permits /reports for each facility and inference that the inventory agency should
check each one (at least for method outliers or changes) does infer a verysignificant resource requirement ‐ it certainly would do for many EU
Member States for example, and I'm sure for the USA and many othercountries too. Second, that last sentence basically says that it is up to theinventory agency to work directly with the facility to improve themethods. In most cases, there will be a specific regulatory or trading
scheme requirement for the facility reporting, and this will be governedby a regulator for the reporting mechanism. This paragraph needs tobetter‐reflect that the inventory agency needs to work with thoseregulators, and discount the facility data for use in the inventory if theUnited Kingdom (ofdata aren't good enough until the matter is resolved. At least add inreference to engagement with the regulators of the reporting mechanism Great Britain andNorthern Ireland) Accepted1044 in this paragraph.

Agreed the original paragraph does potentially put a burden on
inventory compilers. Although in some scenario, via industry
consultation it is possible for all parties such as the regulationand inventory compilers to work closely with facilities.
Paragraph revised:"Where methods are used that do not meet recognised
standards, a report describing facility specific methods (such asengineering approaches, site specific emission factor
development etc.), measurement techniques (that deviate
from standards) and assumptions should be provided to allow
transparent understanding of the basis of the data. Where
methods do not meet national regulatory requirements, orrecognised standards, national inventory compilers should only
use the data if they can be assured that that facility specificmethods will result in quality data that would be equivalent toor better than those resulting from national regulatory
requirements, or recognised standards. When facility specificmethod(s) is found to be deficient, national inventory
compiler(s) is encourage to work with regulator and where
possible reporting facility to better understand and resolve
issues as to increase data quality".

183

Figure 2.2: Second box on the left that says "Can the data be collected
through measurements, surveys or census, considering existing
resources?" should mention remote sensing and geospatial as possible
method for data collection. Suggest to modify text as: "Can the data becollected through measurements, surveys, census, remote sensing or
183 geospatial products, considering existing resources?"

Sentence rephrased (geospatial products not included).

1025

Page 20

CanadaAccepted withmodification

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2851

2853

2995

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Authors' notes2

Problems relating to the preparation of national greenhouse gas inventory

Sri Lanka

Noted

2

347

Aggregating data for preserving confidentiality is the contrary oftransparency. If this is absolutely necessary, a high level quality should be
356 implemented.

Belgium

Accepted withmodification

This does not seem to be a comment for the authors. However,preparation of national greenhouse gas inventory, problems
and solution are already described (e.g section 2.2)
This is true: aggregation reduces transparency (as indicated inline 273‐4) but the box is solely about aggregation. Added text
in line 277: ", noting the need to ensure the quality of theinventory".

483

Surrogate data should have a validation process independenly of theirsource and production algorithm. This process should be indicated in the
502 document.

Belgium

Rejected

This text is unchanged from the 2006 IPCC Guidelines except
for the additon of reference to other parts of the guidelines.
The comment seems to indicate a too extensive study.

209

Another bullet point in addition to those found from lines 202 to 209:
"Has the collected data already undergone specific QA/QC procedures?
210 (important to document those procedures)"

United States ofAmerica

Accepted withmodification

The following has been added:• Has the collected data already undergone specific QA/QC
procedures? Are these procedures documented?

Rejected

This is a comment to unchanged 2006 IPCC Guidelines text. The
text does indicate what representative means without listingsome of the parameters in the comment. Not all theparameters in the comment are relevant to all source, e.g.
geographical may not be suitable for process emissions.
Therefore the original text is kept.

Accepted

Included.

Accepted

Inserted.

Accepted

Replaced.

Accepted
Accepted withmodification

Deleted.
Changed to "emission factors" as comment ID 3005 haschanged earlier text.

Accepted

Implemented.

Accepted

Replaced.
Bias is meant here. The issue of overall quality is included in thehead of the paragraph. To clarify "accuracy" is included in line
965.

2

2

2997

1

2

551

2999

1

2

566

3001

1

2

940

3003

1

2

941

3005

1

2

949

3007

1

2

949

3009

1

2

953

3011

1

2

956

3013

1

2

968

3015

1

2

968

3017

1

2

970

3019

1

2

1025

It would be helpful here to expand on what "representative" means. E.g.
in terms of any emissions controls, geographically, practices, operators,
etc. and to emphasize that any measurement study should provide thecritical background data used to assess representativeness and to562 determine how to appropriately apply the data for a natiaonl inventory.
For documentation, include documentation of the representativeness of
567 the measurements.
For clarity, recommend inserting "which is" between "facility data" and940 "increasingly collected"
Facility‐specific data is not "implemented." Recommend replacing
941 "implemented" with "generated and collected"
The meaning "other indirect activity data" is not clear. Other than what?
949 Can you provide an example? May be easiest to delete.
949 Recommend replacing "these parameters" with "the latter parameters"
Recommend ending sentence after "needs" and beginning the next new
953 sentence with "Thus"

United States ofAmerica
United States ofAmerica
United States ofAmerica
United States ofAmerica
United States ofAmerica
United States ofAmerica
United States ofAmerica
United States ofAmerica

956 Replace "Else" with "If this is not possible,"
Recommend replacing "biases" with "errors," since the errors introduced
by using poor‐quality facility data could be random (imprecision) as well
968 as systematic (inaccuracy or bias).
Recommend replacing "fuel quantities" with the more general "activity
969 data."

United States ofAmerica
United States ofAmerica

Rephrase this sentence; its meaning is unclear "Bias is also present if
971 measurement methods are similar across industry…"
In Table 2.4, in "Comparability" row, recommend inserting a new bullet
1025 "Facilities in same industry use similar methods."

United States ofAmerica
United States ofAmerica

Page 21

Rejected
Accepted
Accepted withmodification

Replaced.
Changed to "Bias may also be present if measurement methods
are similar across industry or and do not account for facility‐
specific operation and processes. "Accepted

Bullet inserted.

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3023

3025

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1025

United States ofAmerica

Rejected

We assume this is consistency not comparability.
This table contains goals ‐ provision for achieving consistency is
not a goal ‐ is it the way of achieving the goal.

1025

In Table 2.4, in "Completeness" row, recommend replacing "facilities"
with "emissions" in third line. It is the fraction of emissions, not facilities,
covered that determines the completeness of the reported emissions. In
many cases, a high percentage of emissions can be covered even if a1025 relatively low percentage of facilities is covered (the "80/20 rule").

United States ofAmerica

Rejected

This completeness point is considered in the first bullet. The
intent of the second bullet is for complete industry coverage.

1034

After "fuels and feedstock;" recommend adding "standardized methods ofmeasuring emissions of GHGs from vents and correlating these withactivity data measurements to establish emission factors." These types ofmeasurements and correlations are essential for many industrial source
1034 categories, such as fluorochemical production and aluminum production.

United States ofAmerica

Accepted withmodification

Replaced the word 'establish' in the suggested text with'develop'.

Rejected

The purpose of a deminimis is to reduce reporting burden at a
facility level and if allowed must be clearly stated. This is similar
to the UNFCCC's NE allowance and is included in several
reporting regimes. The deminimis is only applicable to faciity
reporting and does NOT replace inventory reporting or IPCC's
completeness criteria. An inventory compiler will need toestimate the outstanding deminimis portion, respecting IPCCand UNFCCC requirements. As presented in Figure 2.2, national
inventory compiler (via activity data) should know the total fora specific source to address completeness and coverage issues
araising from FRD when generating a national inventory
estimates.

3027

1

2

1050

3029

1

2

1050

1051 Under activity data, also include "information on any emissions controls"

United States ofAmerica
United States ofAmerica

3585

1

2

960

Recommend replacing "bias is" with "errors are" for the reasons cited in
970 the comment on line 968.

United States ofAmerica

61

1

1

2

3

Authors' notes

In Table 2.4, in "Consistency" row, after Time series demonstrates
consistency," recommend adding "or if not, provision is made for1025 achieving such consistency."

Rephrase the part on de minimis to say "If the reporting program requires
a de minimis provision (for burden reduction, etc.), the deminimis shouldin no case be set larger than the absolute value of the uncertainty." From
the GHG inventory perspective it's preferable to have no de minimus so
1051 unclear why this guidance would seem to promote it.

3587

Responses

967

Recommend simplifying and clarifying this paragraph to read, "Theprimary focus of this section is to provide guidance on integrating
industrial facility data for the Energy and Industrial Processes and ProductUse sectors into national GHG inventories. However, these integration
concepts and guidance can be adapted to most other IPCC sectors and973 categories such as Waste (i.e., wastewater treatments or landfills)."

United States ofAmericaestimation of uncertainty includes some equations and formula which
could be difficult to users with limited experience, it would be better if afriendly use tool maybe designed to help in estimating the uncertainty,
otherwise to be taken into consideration in the update of the 2006 GL
software (the 2019 Refinements Software)

Egypt

Page 22

Accepted

Rejected

Included.
Bias is meant here. The issue of overall quality is included in thehead of the paragraph. To clarify "accuracy" is included in line
965.

Accepted withmodification

Maybe this relates to line 973? Keeping one sentence as this is
one concept, see also comment ID 1823. Change text to:"Although the primary focus of this section is to provide
guidance on integrating industrial facility data for the Energy
and IPPU sectors into national GHG inventories, these
integration concepts and guidance can be adapted to mostother IPCC sectors (e.g. Waste) and categories (e.g..,
wastewater treatments or landfills)".

Noted

Tool is already provided as an Addendum to Chapter 3. No
further action needed.

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Iran

75

1

3

427

77

1

3

428

79

1

3

548

C stock of a certain type of forest to
the average C stock of a portion of a certain type of forest to infer the C
stock of the entire forest)of the forestland in a country. The biomass C for each type of forest ismultiplied by a weight

375

1

3

170

It is proposed to remove from the paragraph the last sentence starting
171 with the words"The approach 2…", because it is not needed here.

377

1

3

302

379

1

3

359

381

1

3

958

665

1

3

661

779

1

3

149

Iran
Iran

Responses
Accepted withmodification
Accepted withmodification
Accepted withmodification

Russian Federation Accepted

Box 3.0: It is proposed to edit the text in the box to include the descriptionof how the Monte Carlo Analysis was applied and how the results of the
Accepted with
358 analysis allowed for reducing uncertainty of inventory estimates.
Russian Federation modification
Box 3.0: It is proposed to edit the text in the box to include the reference
to the figure in lines 359 to 360. It is further proposed to explain what the
Accepted with
360 figure illustrates.
Russian Federation modification
To enhance usability of the Monte Carlo method, it is proposed to develop
a worksheet for Monte Carlo Analysis similar with the worksheet for
Approach 1 uncertainty calculations and include it in the 2019958 TheRefinement.
Russian Federation Rejected
Guidelines suggest using eq. 3.2 for calculating uncertainty of total
emissions expressed in percentage terms.
as a module (absolute value) of sum of all emissions in denominator.
Footnote 4 in line 662 suggests that the formula should be used "caution
should be exercised in the interpretation of the results in cases where thepoint estimate is very small when compared with the size of theconfidence interval (e.g. a sector or inventory where removals andemissions are of similar sizes). Moreover, in the unique case the sum ofnegative quantities is equal to the sum of positive ones, the denominatorin the Equation 3.2 is equal to "0" and the formula has no sense."
The problem with the denominator has been inherited from GPG2003,
where in attempt to take into account that LULUCF sector emissions could
have negative values (as they could represent removals of CO2 from theatmosphere), a module was introduced for the summation in the
denominator. It was meant for individual components of the sum, not for
the total ‐ this most likely was a typo overlooked during the compilationand editing process. Previously, in GPG2000, the denominator did nothave an absolute sign around the sum.
Indeed, when most Annex I Parties are approaching the zero carbon net
economies, the use of absolute sum in denominator will lead to extremely
large uncertainties values (like millions) that will definitely not portray theuncertainty of a country's net emissions and ultimately will not make any
sense. As the denominator should portray the range over which theabsolute uncertainty of the sum expressed in the numerator is spreadover, it would be more accurate to use the sum of absolute values in the
denumenator instead of absulute value of the sum,i.e. |x1| + |x2| + |x3| + ...+|xi| instead of |x1 + x2 + x3 + ... + xi|.
671 This change will not make any difference for combining emissions
Change "biannually" to "biennially" [the former means twice a year, the
149 latter means once every two years]

Page 23

Authors' notes
Text has been revised to reflect that the estimator is for a standin forest land or a stand in a specific forest type.
Text has been revised to reflect that the estimator is for a standin forest land or a stand in a specific forest type.
Text changed to "The biomass C for each of the sampled forest
stands is multiplied by a weight of 20..."Sentence has been deleted.
This information is provided in Volume 4. A reference has been
added to the section with more information about the Monte
Carlo analysis.
The content of the figure is already explained in lines 344 to
346. A caption was added to provide more context for the
figure.
It is not feasible to develop a worksheet for a Monte Carlo
Analysis that could be used across categories and include all
flexibility including correlations that a Monte Carlo package
provides.

New Zealand

Accepted withmodification

Footnote has been amended by the following sentence: "In thatcase, the uncertainty should be expressed just as half the 95%
confidence interval (±1.96σ)".
This case has been carefully considered and the conclusion isthat equation 3.2 is mathematically correct. The proposal
would change the meaning of the formula and would not be
consistent with the technical background.

New Zealand

Accepted"biannually" replaced by "biennially".

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781
783

VolumeChapter11

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3
3

303
506

TolineComments

Country

Could be useful to state somewhere that moving to a higher tier does not
303 necessarily reduce uncertainty, and that in some cases, might increase it
506 Suggest "double counting" is replaced with "over counting"

785

1

3

747

1341

1

3

172

The subscript "s" is an error: should be VS. Also need to be consistent
with the formula in line 745, where we see VS dairy [subscript dairy], buthere in line 747 where the terminology in the formula is explained, VS rate
747 [subscript rate] is included i.e. VS rate, dairy [subscript rate, dairy].
This figure needs some text to clarify what it shows, otherwise it does not
172 provide good information.
Box 3.0 is very heavy text and does not provide a practical approach to
doing uncertainty analysis with process based models. The main challenge
in carrying out Monte Carlo analyses with Tier 3 models is that model runs
are not fully independent, since many parameters are not randomized andremain the same for multiple runs. Guidance would be valuable on thehandling of these constant parameters across multiple runs as dependent
358 variables.

2583

1

3

302

2585

1

3

342

2587

1

3

758

2589

1

3

793

2909

1

3

664

The validation of the model results against independent research data
346 would be an assessment of accuracy, not precision, please revise.
As mentioned in lines 163‐166, improvement plan takes into accountuncertainty assessment along with KC analysis, QA and resources
available. This is not consistent with a tool directing priorities as stated in
760 759. Please revise

It might be easier to understand if 2% is changed for 2 points of
793 percentage
Equation 3.2 is misleading while in case of subtraction the denominatorshould be the absolute value of the difference and not the sum ofquantites. If the title of this equation is "Addition and subtraction" thedenominator should follow this distinction and should be for example: |x1
671 ± ...±xi±.... ± xn|.

Page 24

New Zealand
New Zealand

Responses

Rejected
Accepted

Authors' notesLine 287 states that "Moving to a higher tier method in thesecases will likely increase accuracy. Applying a higher tiermethod may also improve the precision of estimates, as shown
in Box 3.0". Moving to a higher Tier can sometimes give theimpression that the uncertainty is increasing as there is a small
probability that the true value for emission factors and possibly
activity data falls outside of the confidence intervals used in a
Tier 1 analysis because we are typically using normal
distributions. However, it seems unnecessary to add any
elaboration in Box 3.0 because this does not appear to be thecase for the example in the box.
"double counting" is replaced with "overcounting".

New Zealand

Accepted

SwedenRejected

Term corrected in line 747. In the equations in lines 745, 771
and 772 all subscripts "d" are replaced by subscripts "dairy" forconsistency.
Figure is introduced and explained in lines 159 to 171. Further
text will not be much helpful.

CanadaAccepted withmodification

Box is intended to show the benefit of moving to higher tiersand not as a detailed guide for the application of Tier 3 models.
However, there is more information provided in Volume 4about the uncertainty methods. A reference has been includedin the Box.

CanadaRejected

The benefit covers both bias (accuracy) and precision.

CanadaAccepted

CanadaRejected

The comment seems to refer to line 792 (?). Text "directing
priorities of improving the inventory" replaced by "helping inprioritizing improvements to the inventory".
The comment seems to refer to line 825 (?). If that is the case it
is already mentioned in line 822 that the trend uncertainty ismeasured in percent points. The sentence in line 825 is an
example that "2%" means different things for the level andtrend uncertainty.

Hungary

Accepted withmodification

In order to increase clarity the definition of xi has been changed
to say that xi may be a positive or a negative number; and'combined' has replaced the term 'added'.

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3031

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1

Fromline

3556

TolineComments

Country

Suggest rewriting this example, as it is not fully clear and the approach tostratification beyond the determination of intitial production systems is
not obvious. The text states that there are funds to sample 100 farms ineach of 15 production systems. The next line states that 10 farms were
sampled in each production system. Please explain the relationshipbetween the 100 farms that might be sampled, and the 10 farms thatwere sampled. In this example, was each production system further
562 divided into 10 strata?

Comment for all "grassland" repeated in text, which should be definedand used as "grassland and / or rangeland"81

1

4 3B3a

95

1

4

55

97

1

4

88

suggested that the development of simplified procedures approved by
56 countries( Islamic Republic of Iran).
It is necessary to specify the methodology used to identify the key
categories in order to find out that the methodology used corresponds to
91 the decision tree of the sector.
Given that it is the operation of the national inventory arrangements thatwill identify the priorities etc, suggest a re‐ordering of "Key category
analysis helps the National Inventory Arrangements (see Section 1.5 ofChapter 1) identify the priority categories for which methods, activity
data, emission factors and.." to read: "Within the National Inventory
Arrangements (see Section 1.5 of Chapter 1) application of a key category
analysis will help identify the priority categories for which methods,
65 activity data, emission factors and..."

787

1

4

64

789

1

4

119

791
793
795

1
1
1

4
4
4

124
126
131

797

1

4

386

799

1

4

396

801

1

4

400

803

1

4

402

119 Change "...countries…." to "….countries'…" i.e. insert an apostrophe
Suggest "This will be facilitated by an approach, which
aggregated/disaggregated based on methodology and in particular
uncertainties" is changed to"This will be facilitated by an approach whichis aggregated/disaggregated based on methodology and in particular
125 uncertainties"
126 Change "principals" to "principles"
131 Change "adequate" to "adequately"
See comment above on lines 64 and 65. Suggest "designed to inform the
National Inventory Arrangements" is changed to "designed to inform the386 operation of the National Inventory Arrangements"
More correct to say "Finland's greenhouse gas inventory" rather than "the396 Finnish greenhouse gas inventory"
400 Make the change suggested for line 396 above to the title of Table 4.5
Make the change suggested for lines 396 and 400 above to the title of
402 Table 4.6

Page 25

United States ofAmerica

Responses

Authors' notes

Accepted

Description has been corrected.

Iran

Rejected

Iran

Noted

The IPCC land use category name is “Grassland" and changes tothe name is outside the scope of the Refinement. Is worth torecall that according to the definition: "This category includes
rangelands and pasture land that are not considered Cropland”.
The procedure developed to identify key categories is welldeveloped and builds on country‐specific emissions inventory
data and information.

Iran

Noted

The methodology provided already addresses this comment.

New Zealand

Accepted withmodification

Changed to "Within the National Inventory Arrangements (seeSection 1.4a of Chapter 1) application of a key category analysis
will help identifying ....."New Zealand

Accepted

Changed.

New Zealand
New Zealand
New Zealand

Accepted
Accepted
Accepted

Changed.
Changed.
Changed.

New Zealand

Accepted withmodification

Changed to "designed to inform the functions of the National
Inventory Arrangements".

New Zealand

AcceptedDone.

New Zealand

AcceptedDone.

New Zealand

AcceptedDone.

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805

1

4

403

807

1

4

404

857

1

4

180

TolineComments
Make the change suggested for lines 396, 400 and 402 above to the title
403 of Table 4.9
Make the change suggested for lines 396, 400, 402 and 403 above to the
404 title of Table 4.10
In category 2C1 'Metal industry ‐ Iron and Steel Production' N2O gas
180 emitted by flaring of BFG and LDG should be considered.
The calculation with Equation 4.2 is inconsistent with the data in Table
4.6, according to which, it is assumed that Equation 4.2 should be .
Please check.

Country

Responses

New Zealand

AcceptedDone.

New Zealand

AcceptedDone.
It makes sense since Table 8.2 in Volume 1, Chapter 8 includes
emissions of N2O.

Republic of Korea AcceptedWith regard to Table 4.3: Since the definition of Ti,t was not given earlier,
it is suggested that Ti,t here be changed to Tx,t and y in line 292 to x
accordingly. If Ti,t is retained, it is suggested that the definition of Ti,t begiven in the earlier text, and y in line 292 to i and Tx,t in Table 4.6 to Ti,taccordingly.
China

Accepted withmodification

Equation 4.2 is correct. Agree that Table 4.6 is inconsistent with
Equation 4.2. Example in Table 4.6 has been corrected. On thedefinition of Ti,t, and Ei,t, there is no need to define Ti,t in
addition to Tx,t. It is the same definition referred to different
categories.
In line 207 there should be absolute value. In line 267 there is
no absolute value.

Finland

Rejected

Equation 4.2 compares the absolute value of the trend for the
category with the absolute value of the trend of the inventory.

Finland

Rejected

Equation 4.2 is correct.

945

1

4

259

997

1

4

259

999

1

4

279

402 note: Formulas are in the supporting file 1
Please correct mathematic formula of the equation 4.2, absolute value
signs should be placed as follows
261 T(x,t) = |E(x,t)‐E(x,0)| / sum(|E(x,t)‐E(x,0)|)Please correct the column headings in the Table 4.3. Current column
headings refer to the equation 4.2 (lines 259‐261), which is not correctly
written. In the example table later in the chapter (line 402) column
280 headings are correct.

NorwayNorway

3697

1

4

150

The footnote 3 reads: "The methodology is also applicable for otherweighting scheme, but for the derivation of threshold for Approach 1 and
2 and for the examples in Section 4.5 CO2‐equivalent values were
calculated using the global warming potentials (GWP) over a 100‐year
horizon of the different greenhouse gases, provided by the IPCC in its
Second Assessment Report (SAR)". Please update the footnote withcorrect reference to which GWP values that should be used. We
recommend that the reference to IPCC reports are done less spesific, as
we envision that the IPCC/UNFCCC will update the GWP values more
often than the GL will be updated. Moreover the calculations in the
Refinement should be provided with reference to the most recent AR4
150 GWPs, hence the examples in Section 4.5 should be updated.

3699

1

4

399

400 Table 4.5. Please specify what GWP values that are used in this table.

186

Country‐specific categories/and or forest ecosystem‐specific categories: Incases where the 2006 IPCC Guidelines and its 2019 Refinement do notprovide guidance on allocation and methodological guidance for a specificcategory and country or region deems the category to be significant(according to its national or regional definition) to its national or regionalemissions total (e.g. CH4 emissions and removals from agricultural soils or
189 forest ecosystem in low forest cover countries).

83

1

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Authors' notes

Iran

The comment was considered and the note updated to clarify
the version of the IPCC AR used for the examples: "Themethodology is also applicable for other weighting scheme, but
for the derivation of threshold for Approach 1 and 2 CO2‐
equivalent values were calculated using the global warming
potentials (GWP) over a 100‐year horizon of the different
greenhouse gases, provided by the IPCC in its Second
Assessment Report (SAR). For the examples in Section 4.5, CO2‐
equivalent values were calculated using the GWPs provided by
the IPCC in its Fourth Assessment Report".

Accepted withmodification
Accepted withmodification

Note 3 has been updated to explain this.

Accepted

Suggestion implemented as proposed.

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809
811

1
1

5
5

279
285

813

1

5

364

815

1

5

427

Comments
Suggest "(E.G. DATA FROM EMISSIONS TRADING SCHEMES OR OTHER
280 NATIONAL DATA REPORTING PROGRAMMES)"
285 Delete "etc". As this is a list of examples, "etc" is not needed
Delete "so that" i.e. "able to understand the differences so that to be surethat the new…" becomes "able to understand the differences to be sure
364 that the new…"
Suggest "the time series shows a linear time series" is changed to "the427 time series is linear"

1309

1

5

237

Add 'These EFs should be applied from the year the changes took place.
238 These EFs can not be applied prior to the year of change'.

2855

VolumeChapter

1

Fromline

5493

TolineIn Table 5.1, regarding the Non‐linear Trend Analysis, under the comment
section "Should not be applied for long periods. Applicable in the case oflarge annual fluctuations." It should be more specific about what a "long493 period" or "large fluctuation" means to avoid ambiguity.
This paragraph is inconsistent with the guidance on fugitives, where thelower emissions of CH4 due to flaring or other activities is alreadyreflected in the EFs. One fix is to remove the sentence "These
activities…for different years." Another option is to add at the end of theparagraph, "For example, methane emissions in the oil and gas sector are
impacted by flaring and other activities/technologies. The fraction of oil orgas production with and without these activities/technologies can be
determined and distinct emission factors can be applied to each
251 population."where agriculture, forestry and other land‐use is dominant, which weneed to enhance research to find inventory method with least
uncertainties.

Country

Responses

Authors' notes

New Zealand
New Zealand

Accepted
Accepted

Suggestion implemented as proposed.
Suggestion implemented as proposed.

New Zealand

Accepted

Suggestion implemented as proposed.

New Zealand

Accepted

Suggestion implemented as proposed.

India

Accepted

Suggestion implemented as proposed.

Accepted withmodification

The sentence making reference to long period has been
removed as the application of the splicing techniques will apply
based on the nature of the data presented. In some cases thenon‐linear trend analysis can well apply in datasets with longer
time series. Example in Box 5.2B illustrates this very well.
Sentence dealing with large fluctuations has been improved toaddress the use of standard deviation to interpret fluctuations
in line with Chapter 3, Volume 1.

United States ofAmerica

Accepted

Second option implemented by authors as both scenarios artrue. The paragraph now covers both scenarios.

Iran

Noted

Comment is valid, but discussion of improving AFOLU inventory
may belong to another chapter?

New Zealand
New Zealand
New Zealand
New Zealand

Accepted
Accepted
Accepted
Accepted

Suggestion implemented as proposed.
Suggestion implemented as proposed.
Suggestion implemented as proposed.
Text has been revised.

New Zealand

Accepted

Text has been revised accordingly.

Belgium

3033

1

5

242

85

1

6

411

817
819
821
823

1
1
1
1

6
6
6
6

130
315
483
550

825

1

6

553

More accurate to say "the Kyoto Protocol Clean development Mechanism
131 (CDM), not "the UNFCCC Clean development Mechanism"
315 "NGHGI" is an unnecessary acronym
483 "were detected" not "where detected"?
550 "GHGI" is an unnecessary acronym
Easier to understand if "a to the power of minus 1" were changed to "per554 year" such that it reads "25 Gg CO2 equivalent per year"

827

1

6

590

590 Change "Greenhouse Gas Inventory" to "greenhouse gas inventories"

New Zealand

Accepted

Suggestion implemented as proposed.

603

The more common term is "fluorinated gases", not "halogenated gases".
Suggest this change is made to the heading and in the rest of the621 paragraph and wherever else it might be relevant in the full document.

New Zealand

Accepted

Changed from halogenated to fluorinated, as it was in 2006
IPCC Guidelines.

829

1

6

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833

VolumeChapter11

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6

703
716

TolineComments

Country

Suggest "Recommended" is deleted. Could be replaced with "Key",703 making the language in the heading consistent with that in line 708
716 Insert "a" before "UK"

835
837
839

1
1
1

6
6
6

728
848
865

841

1

6

894

Suggest "On inventory side, following several steps are recommended totake" is changed to "On the inventory compiler side, the following step‐
729 wise approach is isuggested" . i.e. avoid the use of "recommended"
848 Change "necessary" to "necessarily"
865 Change "those" to "they"
Change "Use of Models in Good Practice National Greenhouse Gas
Inventories" to "Good Practice Use of Models in National Greenhouse Gas
894 Inventories"
Change "In order to set up, calibrate and parameterise the model real
data (“calibration data”) is needed" to "In order to set up, calibration and927 parameterisation of the model real data (“calibration data”) is needed"

Responses

Authors' notes

New Zealand
New Zealand

Accepted
Accepted

Text revised accordingly.
Suggestion implemented as proposed.

New Zealand
New Zealand
New Zealand

Accepted
Accepted
Accepted

Text revised accordingly.
Suggestion implemented as proposed.
Suggestion implemented as proposed.

New Zealand

Accepted

Suggestion implemented as proposed.

New Zealand

Accepted

Suggestion implemented as proposed.

New Zealand
New Zealand

Accepted
Accepted

Suggestion implemented as proposed.
Change implemented as proposed.

New Zealand

Accepted

Suggestion implemented as proposed.

FinlandAccepted

Text has been revised accordingly.

843

1

6

927

845
847

1
1

6
6

938
978

849

1

6

1002

1001

1

6

555

Models are used for removals too. Suggest "emissions in a source
938 category" is changed to "emissions or removals in an inventory category"
978 Change "buy" to "by"
Change "In planning implementation of any model allowance should bemade for….." to "In planning the implementation of any model, allowance
1002 should be made for…."
Something, possibly a verb, is missing from the sentence "Where possible,
556 facility‐level emissions ..". Please correct/complement.

Finland

Noted

The text implies we work with national inventories. Throughout
the section we don’t discuss verification of other types ofinventories.

FinlandAccepted

Indentation corrected.

FinlandAccepted withmodification

New text added at the end of para 6.12.4 to give guidane toinventory compilers for handling of verification and validationfor established and well‐known models.

1003

1

6

393

Please check the term "national inventory estimates" here and throughout
the text under "Comparison with atmospheric measurement". Should it
not refer to estimates used in the national ghg inventories or used toverify estimates presented in the national inventory? It should not refer tocountry‐level estimates made outside inventories, which may in some395 cases disagree with the ghg inventory requirements.

1005

1

6

890

Please correct the indentation for (i)‐(iii), they should be at the level of
893 other bullet points? Otherwise, this part of the list is incomprehensible.

920

The text is unclear and not pragmatic. Please rephrase that when choosing
a model, differences in management, conditions etc should be carefully
considered and please remove the good practice guidance on the need toreport speculatively on suitability of the model. With no actual data, theseremain highly speculative. List under 6.12.6 should suffice. Verification of
inventory estimates or evaluation comparisons are more important to be
documented carefully so adding the reporting burden with speculative
924 interpretations of the impacts of differences is unnecessary.

1007

1

6

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1011

VolumeChapter11

Fromline

66

TolineComments

923

923 Please clarify what does "outside parameter space" mean.

929

The text says that it is good practice to evaluate model behaviour i.e.
compare model ouputs with data used in calibration. This seems to becontradictory to what is written in Volume, Ch.2, lines 2109‐2111 and2169‐2171 where it says that It is good practice to use measurements
independent of those used for model calibration when evaluating model
behaviour. Evaluation of model behaviour and verification of model
outputs can be seen as different things (the latter needing data
independent of calibration data for sure) but please correct forconsistency between volumes the guidance on use of models between
932 volumes.

Country

Responses

FinlandAccepted withmodification

Authors' notes
Outside parameter space means "outside the range ofparameter " for which the model was developed. The sentence
has been updated to reflect the use of the phrase "outside therange of parameter".

FinlandAccepted withmodification

Text has been changed as follows: "it is good practice tocompare model outputs with data independent of thecalibration data (e.g. evaluation of model behaviour)".
I cannot see why the documentation required (section 6.12.6)
cannot apply to a transport model. Indeed, most transportmodels will already be documented with reports giving most,or all, of the items listed. Even transport models need to becalibrated and validated. Data will be used during theconstruction of the model to ensure it is working correctly(calibration) and after it is complete outputs should becompared against the real world (validation). QA/QC is always
needed.
However, to clarify this some text has been added:
after line 906
Established and well‐known models (e.g. some transportmodels) are usually well documented, calibrated and validated
already. For these inventory compilers can rely on publishedreports and peer‐reviewed publications and simply reference
this material. There is no need to duplicate the reports,
calibration or validation work, or uncertainty analysis.

1013

1

6

832

Chapter 6.12 is written with a point of view of models typical to naturalsciences, such as process models used in the AFOLU sector. Thus, not all
guidance, including documentation and reporting requirements, areappropriate for other kinds of models, such as some transportation
models. Please modify the text and lists of requirements to reflect the1118 variety of complex models used in the inventories.

1311

1

6

127

Needs more clarification for the term 'verification' used in carbon market
129 and IPCC

India

Accepted withmodification

351

Not all approaches using atmospheric data are largely independent ofactivity data and emission factors. Suggestion to edit: "This approach is352 particularly valuable as it can be largely independent of…"

CanadaAccepted366

A reference should be given why these techniques are considered "cost‐and labour intensive". Is this in comparison to creating an annual NIR
366 update or relative to author QA/QC procedures>

Canada

Noted

2591

2593

1

1

6

6

Page 29

FinlandAccepted withmodification

after line 927• Transport models should conserve vehicle number.
A sentence has been added at the end of the box to indicatethat verification has a wide range of meanings depending
where it is used.

Suggestion implemented as proposed.
Wording is kept from the 2006 IPCC Guidelines. The meaning isthat the atmospheric observation and modeling costs are not at
the scale of minor fraction of NIR preparation, but comparable
to it.

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2595

1

6

368

2597

1

6

427

2599

1

6

430

Should be specified that current studies extend beyond the inventory
cycle, but the community is working towards faster turn arounds.
368 Suggested edit: "Currently, the required analysis time …"
Fossil fuels are void (virtually free) of radiocarbon not "very low". Somefuels e.g. diesel/gasoline have a non‐fossil contribution nowadays, but this428 should not be confused here.
Suggest adding a reference here: e.g. Levin et al. 2003, GRL, Vol. 30, NO.
430 23, 2194, doi:10.1029/2003GL01847

2601

1

6

474

Suggest adding more up to date references e.g.: CH4: Saunois et al. 2016,
476 ESSD, 8, 697‐751; SF6: Levin et al. 2010, ACP, 10, 2655‐2662

2603

1

6

499

2605

1

6

538

2607

1

6

642

2609
2611

1
1

6
6

808
820

2613

1

6

977

2615

1

6

1024

2831

1

6

This sections neglects to mention ground‐based total column
observations. They are similar in technique to satellite measurements, but
measure at fixed locations (e.g. the TCCON and COCCON networks). Thisdata can be used to validate satellite retrievals or atmospheric models and509 help integrate in‐situ and satellite observations.
In Volume 1, the comment was made to expand the discussion ofchallenges of reconciling top‐down and bottom‐up emissions posed bynatural emission sources. This was not addressed and is an important
issue questioning the validity and applicability of top‐down approaches invalidating emissions. The proposed article clearly documents these538 challenges.
Significant progress has been made since 2005 (as stated in the previous
644 sections) ‐ these references should be updated

Responses

Authors' notes

CanadaAccepted

Suggestion implemented as proposed.

CanadaAccepted

Suggestion implemented as proposed.

CanadaAccepted

Suggestion implemented as proposed.

CanadaAccepted

Suggestion implemented as proposed.

Accepted withmodification

Revised, added mention of TCCON use for satellite validation.
Unfortunately a number of related papers on direct use of
TCCON data for emission estimates came out after literature
cut‐off date.

CanadaCanadaThe proposed paper was cited in same context earlier in thesection.

Noted
Accepted withmodification

Text revised accordingly.

CanadaCanadaAccepted withmodification
Accepted

Revised, elaborated on ways to determine required number
and locations of the observing networks. Note that clear
guidance is difficult to formulate. Good practice examples of
the current networks are constructed by taking into account all
consideration: available funding, available infrastructure andminimising uncertanty of emission estimates. UK had only site
at first, which was not enough for annual emission estimates,
they could only do 3 years mean estimate.
Text revised accordingly.

CanadaThe examples provided of inventory validation with inverse model
estimates suggest that anywhere from one to four sites have been used
for this purpose. Stating that the number of observation sites will varywith the geography and situation does not provide concrete and usefulguidance. Comments to this effect on the SOD were not addressed. Pleaseelaborate on how an inventory compiler would assess whether thenumber of observation sites justifies a comparison with inventory
809 estimates.
820 Figure 6.1 Correct third box to " Improve and validate the model"
Guidance on what should be reported goes beyond the mandate of the
IPCC Therefore, change “It is good practice to report:” to “It is good
978 practice to document”
Guidance on what should be reported goes beyond the mandate of the
IPCC Therefore, change “It is good practice to report:” to “It is good1024 practice to document”

CanadaAccepted

Change implemented as proposed.

CanadaAccepted

Problems relating to the preparation of national greenhouse gas inventory

Sri Lanka

Noted

Suggestion implemented as proposed.
Not possible to address the comment as we can not locate theline number the comment is referring to.

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VolumeChapter

Fromline

TolineComments

Country

Responses

Authors' notes

Text revised to read:

2887

3035

3037

3039

1

1

1

1

6

6

6

6

Accepted

Simple approaches to estimating greenhouse gas emissions andremovals may be unsatisfactory for some specific categories insome countries because they fail to capture the complexity anddiversity of systems and practices, in that sector. Therefore,
some inventories rely on more sophisticated approaches, using
models or direct measurements.
In general, models may be used to estimate those emissions or
removals that cannot be easily otherwise obtained, to extend
limited information to cover national emissions and removals,
both spatially and temporally, or to improve the accuracy ofthe estimates. Model development relies on data from direct
measurements and uses measured data for calibration andevaluation.
However, models should be used with care. Complex models
are not necessarily improvements over simple ones (e.g.
carbon dioxide emissions from road transport is best estimatedfrom fuel sold and its carbon content: no transport model will
provide a better estimate although they may allocate theemissions to specific vehicle types and estimate improved
emission of methane and nitrous oxide). Models are limited by
the underlying quality of the data.
Use of models will require resources for additional QA/QC anddocumentation.

United States ofAmerica

Accepted withmodification

A sentence has been added at the end of the box to indicatethat verification has a wide range of meanings depending
where it is used.

345

As there have been particular sensitivities around external stakeholders"verifying" country‐reported data using atmospheric measurements, it
may be useful here to specify that the verification contemplated is done
by/with inventory compilers and understood in the inventory sense (asexplained in Box 6.1), as opposed to done by external stakeholders andunderstood in the carbon markets‐related sense. (A different term, such
379 as "validation," might also be considered.

United States ofAmerica

Accepted withmodification

In this occasion changed from verifying to comparison. Use ofverification term in this context is clarified in Box 6.1.

407

In the text, F gases are considered good candidates because they are long‐
lived, but also in the text it is noted that there are additional challenges
416 with N2O because it is long‐lived. Is one a typo or is there a difference?

United States ofAmerica

Accepted

Revised, noting very long N2O lifetime (as opposed to several
years for F‐gases and methane).

839

It is not clear what this section tries to say. It needs to be made clearer tothe reader. For example, it needs to say when there are no gains in using
849 more complex methods and illustrate this by examples from the literature.

Estonia

114

Verification, as referred to in these lines, is not only done in carbon
markets, but for a number of other other reasons (including results‐based
payments). Inserting carbon markets into a discussion of QA in this way
may be confusing to some. It would be better to delete the reference inlines 114 and 115 and simply include the text at the end of the thirdparagraph include a line at the end of the box noting that "verification"
has different meanings in different contexts, and in the case of carbon
markets, results‐based payments, etc has a meaning more similar to the
115 QA definition above.

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3041

1

6

408

3043

1

6

471

3045

1

6

537

409 It's worth mentioning the influence of natural sources of CH4 here as well.
Global dynamic monitoring does not have as much apparent relevance fornational GHG inventories. Suggest either clarifying the relevance to
489 estimates at a national level, or deleting.
Sentence does not make sense as currently written, possibly just a typo,539 but it needs editing.

551

This is an inaccurate description of the gridded US GHGI. Livestock
emissions estimates are available by state, but the emissions are mapped
to livestock population locations in the gridded US GHGI. Petroleum
estimates at the national level were used to develop emission factors (e.g.
552 CH4 per well) to apply to wells at specific locations throughout the U.S.

3047

1

6

3049

1

6

552

3051

1

6

568

3053

1

6

607

3055

1

6

819

This is an inaccurate description of the use of the GHGRP data in thegriddedUS GHGI. GHGRP data is used as an input to the gridded inventory
to help allocation national emission totals across facilities for the gridding.
It is suggested to confirm final language with the team that developed the556 gridded US CH4 inventory.
It would be good to mention here the influence of natural sources andtemporal aspects (e.g. a measurement in the summer, or when high‐emitting events are occuring is not necessarily useful in evaluating
average national emissions unless temporal aspects are taken into
568 account)
Earlier in the chapter "top‐down" is used to describe use of national level
activity data to estimate emissions. Use a different term here, or define
607 its use here.
It is unclear that this decision tree is necessary, or even helpful, but if it
stays, we recommend changing the last box to "document the results ofthe comparison, take steps to assess difference (see box 6.5)." It's
inconsistent with the rest of the chapter to say "use estimates in
819 reporting."

3057

1

6

827

Under Remapping to make national total, the text should note that thisstep is unnecessary with a gridded inventory. It's also unclear why it isnecessary to report differences to the inverse modellers. I'd recommend
827 changing "report preparation" to "documentation"

87

1

7

120

We may need to refer to the REDD and REDD+ here (in addition to vol4).

Page 32

Country
United States ofAmerica

Responses

Authors' notes

Accepted

Suggestion implemented as proposed.

United States ofAmerica
United States ofAmerica

Accepted withmodification

New text included to clarify relevance.

Accepted

Sentence revised for better reading.

United States ofAmerica

Accepted withmodification

Revised, removed detail. Readers can find needed informationin the paper.

United States ofAmerica

Accepted withmodification

Revised, simplified. Readers can find detailed information in
the paper.

United States ofAmerica

Accepted

Revised, sentence added.

United States ofAmerica

Accepted

Text revised accordingly.

United States ofAmerica

Accepted

Text revised accordingly.

United States ofAmerica

Accepted withmodification

Iran

Noted

Text revised to "Documenting the results of the comparison".
No action can be taken because comment is out of scope of2019 Refinement.

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133

VolumeChapter

1

Fromline

7

98

TolineComments

Country

Concerning fuel combustion, in fact, except for coal and maybe HFO(heavy fuel oil), for most other fuels, the thermal‐NOx / prompt‐NOx is
generally more important than the "fuel‐NO" bound to the nitrogen in
fuel. So the refinement sentence should reflect the general situation.
Furthermore, for some countries, the consumptions of coal and HFO
represent now minor contributions to the national energy balance.
‐ Original sentence: "Most NOx emissions resulting from fuel combustion
are typically ‘fuel‐NO’ that is formed from the conversion of chemicallybound nitrogen in the fuel. The content of nitrogen in different fuel varies.
Depending on the combustion temperature, thermal‐NOx and prompt‐
NOx can also be formed from nitrogen contained in the combustion intake
air."‐ Possible new sentence : "Generally, NOx emissions may result from'thermal‐NOx', 'prompt‐NOx' and/or ‘fuel‐NO’ that is formed from theconversion of chemically bound nitrogen in the fuel. The content of
nitrogen in different fuel varies. Depending on the combustion
temperature, thermal‐NOx and prompt‐NOx are more or less formed from
101 nitrogen contained in the combustion intake air."FranceResponses

Authors' notes

Accepted withmodification

This guidance on precursors and indirect emissions is notintended to consider the relevance of any of such emissions. It
is up to the inventory compiler to make such assessment. The
respective guidance on activity data for any source category isprovided in Section 2.1 of Volume 1.

383

1

7

180

1015

1

7

51

The methodology for estimation of CO2 added to the atmosphere fromindirect emissions and precursor oxidation has not been provided. It is
proposed to develop the relevant equation(s) and supporting parameters
for estimation CO2 input to the atmosphere from indirect emissions andprecursor oxidation. Otherwise this sections should be moved to theRussian Federation Rejected
182 annex as an issue for further methodological development.
Please delete the first sentence, it is unnecessary and incorrect. Volumes
2 to 5 of the 2006 IPCC Guidelines do not provide GWP‐weighted GHG
52 totals. They provide guidance by gas in mass units.
FinlandAccepted

55

This text should provide also an introduction to precursors of CO2 (CO,CH4, NOVOCs), which are addressed in the guidance and reasoing for
estimating these emissions which is to take to total warming impact ofthese emissions into account, when compared with emissions of other63 gases. Please complement ‐ othewise the introduction makes no sense.

1017

1

7

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FinlandAccepted withmodification

A method has been provided ‐ see lines 171 to 221.

Suggestion implemented as proposed.
Subsection 7.2.1.5 includes the rationale and explanation forindirect CO2 emissions. A sentence was added to introduction
stating that the majority of the carbon emitted in the form of
non‐CO2 species (i.e., CH4, CO, and NMVOCs) eventually
oxidizes to CO2 in the atmosphere and this amount can be
estimated from the emissions estimates of the non‐CO2 gases.

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1019

VolumeChapter

1

Fromline

7

TolineComments

Country64

The text says "The guidance of this chapter is consistent with the use of
any radiative forcing metric (e.g. Global Warming Potential or Global
Temperature Potential) included in the asessment reports of the IPCC so
far and follows the principle to avoid double counting". (see section
7.2.1.5). However, it does not provide guidance to estimate the overall
radiative forcing resulting from emissions of greenhosue gases, precursors
and indirect emissions". This guidance is missleading and should be
improved. Therefore, please change it to read: "The guidance provided in
Sections 7.2 to calculate emissions for presursors of CO2 (CH4, CO andNMVOCs) is only applicable when the metric (GWPs or GTPs or other)used to assess the warming impact of these gases do not take into
account the impact of the atmospheric conversion of these gases into CO2
67 in the atmosphere (see section 7.2.1.5)."

1021

1

7

167

Please clarify the text and change it to read: Two options are possible toaddress input of CO2 from CH4 to global warming. If countries use ametric for CH4 that includes the impact of atmospheric oxidation of CH4
to CO2 ( such as the GWP and GTP values for "fossil methane" provided in
the Appendix 8.A in IPCC 2013), they should not estimate separately theamount of CO2 resulting from atmosperic oxidation of CH4 to avoid
double counting the warming impact. If countries use a metric which does
not take into account the conversion of methane into CO2 atmospere,countries should apply the methods described below to calculate theamount CO2 from CH4. Countries should transparently document the
170 option used.

1237

1

7

101

after the phrase 'combustion intake air', add ',as this takes place in typical
101 cases of pulverised coal combustion.'

Page 34

Responses

Authors' notes

Finland

Noted

This is just an introduction. The detailed guidance is provided in
the subsections. It would not be a good logic to repeat suchdetailed guidance already in the introduction. In order toprovide the clarity, reference to subsection 7.2.1.5 has been
already included in the FD.

FinlandAccepted withmodification

The text has been modified building on the suggested text ‐with slight modifications without change of the story line of thetext as suggested.

India

Accepted withmodification

At the end of the sentence reference has been included inbrackets to the example of pulverized coal combustion.

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295

2617

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2619

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2621
2623

1
1

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7

129
131

Comments

Country

There is a description that "the carbon in NMVOC emissions from fuelingstations would typically be captured in fossil fuel consumption activity
data and therefore in emissions from 1.A." in the column of explanationfor 1.B. Fugitive Emissions from Fuels in Table A7.1 (new), but the carbon
in NMVOC emissions from fueling stations may not necessarily be
captured by the emissions from 1.A. depending on the statistical survey
method. If the amount of fuel actually refueled to cars is surveyed for thefuel consumption data, the carbon included in NMVOC emitted fromfueling stations is not included in the fossil fuel consumption data used for1.A. Therefore, we suggest that the description of the explanation in thistable be revised by "the carbon in NMVOC emissions from fueling stations
might be included in fossil fuel consumption activity data depending on
the scope of the statistical survey, and such carbon should be included in
295 emissions from 1.A for those cases".
The text in section 7.1 is unclear and will create confusion for inventory
compilers and reviewers as to the core purpose of inventories, i.e. thedirect release of GHGs as a result of human activities. Determining CO2
from the atmospheric oxidation of precursors is an option. This sectionneeds to be clearer in that respect, by unambiguously stating that it issufficient to estimate GHG emissions from Volume 2‐5. Going beyond
would exceed the terms of reference for this report.
The main natural source of nitrogen is from air. Air contains 78 to 79%
nitrogen. What is fuel NO (what fuel does this apply to)? If technically99 correct as written, then it should be referenced.

Indirect CO2 is not an ‘input” to the atmosphere; instead it is formed in
the atmosphere from precursors. The use of ‘input’ to the atmosphere is
129 technically incorrect. Replace “CO2 input to” with "CO2 formation in”.
131 Replace 'inputs of CO2' with 'formation of CO2'.

Page 35

Responses

Authors' notes

Rejected

The common IPCC methodology for estimating CO2 emissions
from the combustion of liquid transport fuels is based activity
data on fuel sales. The fuel sales will capture all carbon
contained. The fugitives are then based on the emission factors
provided in the guidelines.

CanadaNoted

The revision is clear on situations where it would beappropriate to calculate indirect emissions and when it would
be inappropriate. The proposed general statement would
create additional confusion, rather than reduce it.

CanadaAccepted withmodification

This comment addresses an editorial issue, text has beenrevised to NOx from NO.

Rejected
Rejected

It is noted that the Glossary does not include a definition ofindirect emissions. Given the unequal treatment of this term it
would be difficult to provide such definition. As there has been
no mandate to introduce a coherent concept of indirectemissions/precursors in the whole 2006 IPCC Guidelines, it
seems premature to address that comment now. Everysuggestion would very likely raise a lot of comments.
Furthermore, the focus in 2006 IPCC Guidelines is clearly on theterm "input" which has already been extensively used in the2006 IPCC Guidelines, including in formulas as well as capture
to tables. 'Formation' was only kept mainly in those part of thetext where this term has already also been used in the 2006
IPCC Guidelines. It would create very likely a range ofcomments if we start to change terminology alreadyintroduced by 2006 IPCC Guidelines without having a specificmandate to do that.
See comment ID 2621 response.

Japan

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156

2627

1

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53

2629
2631

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7

165
167

2633

1

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180

2635

1

7

188

2637

1

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207

2639

1

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208

2641

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211

2889

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64

2891

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93

2893

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105

3059

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TolineComments
Replace for both instances, “CO2 inputs to the atmosphere" with"formation of atmospheric CO2 from" to avoid confusion between direct
156 and indirect CO2.
The meaning of “indirect” is inconsistent across the report (notably
between this section and the chapter on agricultural soils); to avoid
53 confusion use the term precursors rather than ‘indirect CO2’.
Replace: ‘CO2 resulting from emissions of…’ with ‘atmospheric CO2
formation resulting from the oxidation of ….’ to be more specific and
165 clear.
167 Replace 'inputs of CO2' with 'formation of CO2'.
Replace ‘Inputs CO2’ with ‘input precursors’. The term ‘Inputs CO2’ ismisleading since this discussion is focused on formation of CO2 in the
190 atmosphere from releases of precursors.
Need references and justification to support the default values of 0.6 and0.85 for NMVOC and which would be applicable for a specific condition
since this will vary based on speciation profiles and local atmospheric
188 conditions.
Justification (or details from a supporting reference) should be provided
for the applicability of the default percentages of mass carbon content
presented (i.e., 60%, 85%), considering it can range from 51% to 100% for
211 CH4 (as an example).
This text: “Boucher et al. (2009) assumes 95% of emitted CO2 is oxidized
with a range of 51 to 100 percent”, is not very informative, given therange provided and the lack of a time period. : What use is this for
211 compiling inventories? Consider deleting.
Bottom line is that oxidation of NMVOC may take from ‘minutes tomonths’ and up to years while some species don’t get oxidized. How
214 necessary is this to inventory compilers?
A discussion on radiative forcing. It is very technical and needs to be madeclearer and more easier to understand to people who are not involved inclimate science. Also please add the term 'radiative forcing' to the
67 glossary.

Country

Authors' notes

CanadaRejectedSee response to comment ID 2621.

CanadaNoted

No action can be taken because comment is out of scope of2019 Refinement.

CanadaCanadaRejected
RejectedSee response to comment ID 2621.
See response to comment ID 2621.

CanadaRejectedSee response to comment ID 2621.

CanadaAccepted withmodification

Peer reviewed literature reference added to text as source ofdefault values.

CanadaNoted

A method has been provided ‐ see lines 171 to 221. And withrespect of justification see response to comment ID 2635.

Canada

Noted

This reference should be seen as a starting point. If thiscategory is relevant or even key (e.g. after practical phase out
fossil fuels) it might be appropriate to base the calculation on
more specific and elaborated studies.

CanadaNoted

See response to comment ID 2639.

Estonia

Noted
Accepted withmodification
Accepted withmodification
Noted

Noted. No action can be taken because comment is out of
scope of 2019 Refinement.
Navigation has now been mentioned separately in the context
of SO2 emissions.
In addition to stationary also mobile sources have been
included with specific reference to 'marine'.
This might depend ‐ as with GWP. There is no standardized
calculation.

United States ofAmerica

Rejected

The current wording is clear. Footnote 6 informs on specific
cicumstances that would require additional calculation.

United States ofAmerica
NorwayAccepted
Accepted

Suggestion implemented as proposed.
Change implemented as proposed.

55

106 Shipping and aviation emissions need a specific mentioning here.
In shipping scrubbers are also one way of reducing SO2 in addition to low‐
106 sulfur fuels.
Are precursors included in GTP‐weighted totals? If not, this sentence
56 might be revised to not only refer to GWP.

Estonia
United States ofAmerica133

Add an i.e. to this sentence (i.e., source categories not requiring separate
134 estimations)

295
214

Table 7.1 needs to be updated to be consistent with new structure of oil
and gas fugitives. One option is to just delete the venting and flaring rows
in the first column and add the information related to flaring in the last
296 column to the row above it.
214 Brackets around reference should be removed.

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Responses

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89

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18Fromline
72

TolineComments
from road transportation by its sources depending on

137

1

8

121

139

1

8

129

HFC‐1234yf has been included in the examples of hydrofluorocarbons. We
suggest to add a precision to explain that HFOs have to be considered in
the HFC family. "hydrofluorocarbons (HFCs: e.g., HFC‐23, HFC‐134a, HFC‐
152a), including hydrofluoro‐olefins (HFOs: e/g/, HFC‐1234yf, HFC‐
122 1234ze)
HFCO‐1233zd could also be added in the list of examples. It is an HCFO
130 (HCFC with a near‐to‐zero ODP) recently developed.

108

What about possibly including hydrocarbons (e.g. HC‐290, HC‐600a), as
they are progressively used as alternatives of HFCs in refrigeration and air‐
158 conditionning applications (and as far as they do have a non zero GWP)?.

141

1

8

1239

1

8 2A4a

1811

1

8

2907

1

8

115

Add the sentence 'This should include emission from calcination of clay,
bauxite,dolomite, of
calcite,magnetite
etc.toinprovide
integrated
unit'.
FN2:
Refinements
Ch 8 Vol
1 attempt
consistency,
but in atleast one point pick wrongly from new information. In fact, the newfootnote 2 in Vol. 1 Chapter 8, Page 8.5 is misleading as Table 8A.1 should
not be used (does not include the effects of climate‐carbon feedbacks). As
a minimum change, it needs to be deleted or replaced by ‐‐ Begin Text ‐‐See, e.g., the IPCC Fifth Assessment Report “Climate Change 2013: The
Physical Science Basis” by Working Group I, Chapter 8, Table 8.7 and Table
8.SM.16. ‐‐ End Text
It
would be more helpful to inventory compilers if a proper explanation on
the proper use of GWP values could be included, either here or by also
cross referencing from this footnote‐‐ Begin Text ‐‐ Details of the proper use of GWP are provided in xxxx ‐‐End Text ‐‐This text should then include‐‐ Begin Text ‐‐ GWP values to compare the effects of other relevant
GHG’s with those of CO2 have been established by the IPCC. These values
can be seen as factors to convert a mass of a given gas into “CO2‐eq”
mass. Although subject to uncertainty, GWP values are based on clear,
traceable scientific methods as described in the WGI AR5; and they are
currently the best available methodology to calculate the respective
importance of different well mixed greenhouse gases. The use of thelatest update of these values in the version “with climate‐carbon
feedback” (IPCC AR5 Working Group I, Table 8.7 and Table 8.SM.16: IPCC,
2013) is recommended. Note that other main tables in AR5 WGI Chapter 8
list GWP values, but these are not recommended for emissions reporting(e.g., Table 8A.1). Future IPCC Assessment Reports may supersede thevalues provided therein. Until then, recommended values are 36 for CH4
from fossil sources, 34 for CH4 from biogenic sources (for which
115 subsequently formed CO2 needs not to be accounted for), 298 for N2O,

45

Use of CO2: the two examples (CO2 use in greenhouses and soft drinks)
given are too specific and can be confusing. These are not discussed
specifically elsewhere and can raise questions, for example, about
calculating CO2 stored in fizzy drinks. It would be better to say 'for46 agricultural and industrial use' instead of giving too specific examples.

2A4aPage 37

Country
IranResponses
Accepted

Authors' notes
Changes implemented as proposed.

FranceAccepted

Suggestion implemented as proposed.

FranceAccepted

Suggestion implemented as proposed.

FranceNoted

No action can be taken because comment is out of scope of2019 Refinement.

India

Accepted

Suggestion implemented as proposed.

Austria

Accepted withmodification

The footnote 2 has been deleted from Chapter 8. GWPs aredefined in the Glossary.

Accepted withmodification

The word "greenhouse" has been retained as it is not clear toauthors what categories would be applicable in agriculture
other than this application. Industry has been proposed in placeof soft drinks and other processes.

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3067

VolumeChapter11

Fromline

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TolineComments

Country

We assume lines 71‐73 refers to road transport which crosses national
borders? If it is accurate, the text should be clarified to read as such. Lines
71‐73 currently could be understood to imply that a production, vs
73 consumption, approach should be applied to road transport emissions.

91

It would be helpful if the guidance were clearer on where removals are
removed. For example, if biogenic carbon is captured from an ethanol
plant, it is clear per the guidance that if the CO2 storage meets the
96 requirements, it can be deducted from the inventory, but where?

3069

1

8

97

Note that CO2 is reported as an information item in Energy, and that Non‐
CO2 from biomass combustion for energy and biomass energy fugitives
99 are both reported under energy.

3071

1

8

238

239 Table needs a row for post‐meter emissions in 1.b.2.b

3703

1

573

1 Annex 1

8

110
51

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

Page 38

United States ofAmerica

United States ofAmerica

Responses

Accepted

Accepted

United States ofAmerica
United States ofAmerica

Accepted

NorwayAccepted

New Zealand

Accepted

Accepted

Authors' notes

Changes implemented as proposed.
Issue addressed by adding the folowing sentence "In the Energy
Sector however, these emissions are reported as memo items.
If CO2 emissions from biomass combustion or energy
production are captured, Energy Sector inventory compilers
should ensure that these captured emissions are subtracted
from the amount of CO2 estimated in AFOLU as part of net
carbon stock changes".
Text revised to highlight that CO2 combustion emissions arealso reported in the energy sector as memo items. And also
included the treatment of non‐CO2 fugitive emissions from
biofuel production.
Row added as proposed.
The authors thank the reviewer for highlighting these new F‐
gas observations. The electronics authors recognize PFTBA as apopular heat transfer fluid used in electronics manufacturing.
Although the compound's GWP and atmospheric lifetime havenot been published in the peer‐reviewed scientific literature,research by the manufacturer, as well as the compound's
perfluorinated structure, indicate that it has a very longatmospheric lifetime and a 100‐year GWP near 10,000.
Guidance on estimating emissions of this and other fluorinatedliquids is provided in Chapter 6 of the Refinement. Research
into the other compounds indicates that they are used in avariety of applications, some of which are addressed in the2006 IPCC Guidelines. For example, PFPHP is used in cosmetics
and medical applications, whose emissions of perfluorinatedcompounds are addressed in Volume 3, Section 8.3 of the 2006
IPCC Guidelines (Use of SF6 and PFCs in Other Products). The
authors will note the other substances as potentially of interest
for future IPCC research.

Corrected.

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1 Annex 1

72577

1 Annex 1

95579

1 Annex 1

127

581
583
585
587

1 Annex 1
1 Annex 1
1 Annex 1
1 Annex 1

156
159
161
162

589

1 Annex 1

187

591

1 Annex 1

221

851

853

TolineComments
Suggest "of" is replaced by "to" in the phrase "approaches of data
72 collection" becoming "approaches to data collection""Refinements undertaken for chapter 3 involves a series of updates"
should be "Refinements undertaken for chapter 3 involve a series of
95 updates" ("involve" is singular)First row in the box, question the inclusion of "source" before "category"as there are sink categories as well. Suggest delete "source":"Example ofreducing uncertainty in a
128 category by adopting higher tier methods"

Country

Responses

Authors' notes

New Zealand

Accepted

Corrected.

New Zealand

Accepted

Corrected.

New Zealand

Accepted

Source' deleted.

New Zealand
New Zealand
New Zealand
New Zealand

Accepted
Accepted
Accepted
Accepted

Finland's used instead of Finnish.
Corrected.
Corrected.
Corrected.

New Zealand

Accepted

Corrected.

New Zealand

Accepted

Corrected.

1 Annex 8A.2

A consistent approach should be taken for the header on Table A
Summary Table (1 of 6) through to Table A Summary Table(6 of 6) (pages
T4 to T9) in that NF3 should be in the header regardless of whether thesectors/categories listed are sources of NF3. If the sector/category isn't asource of NF3, then it is shaded out. We see Table A Summary Table as
being one table that is split into 6 parts, not as 6 separate tables.

New Zealand

Accepted

Changes implemented as proposed.

1 Annex 8A.2

Similar to the above comment, a consistent approach should be taken forthe header on Table B Short Summary Table (1 of 2) and Table B Short
Summary Table (2 of 2) (pages T11 and T12) in that NF3 should be
included in the header regardless of whether the sectors/categories listed
are sources of NF3. If the sector/category isn't a source of NF3, then it isshaded out. We see Table B Short Summary Table as being one table thatis split into 2 parts, not as 2 separate tables.

New Zealand

Accepted

Changes implemented as proposed.

In the last four rows of the table it would be more correct to say "Finland's
157 GHG inventory" rather than "the Finnish GHG inventory"
159 Same as comment for line 95: "involve" not "involves"
161 Suggest "provision of "guidance" rather than "provision of text"
162 "become" not "becomes"
Insert "for" before "methane" in the third line of the table: "overlap
method for methane", and before "direct" in the last line of the table: "188 for direct soil N2O emissions"Word missing in the phrase: "background science precursors and indirectemissions". Suggest "background science on precursors and indirectemissions" and then the language will match that in the overview Chapter,
221 line 249

Page 39

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2

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149

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1829

193

TolineComments

Country

General comment on Vol. 1: The guidance in Vol.1 is related general andcrosscutting issues, sectoral guidance is given in Volumes 2 to 5. Generaland crosscutting guidance should include "good practice" sparsely as
detailed guidance is given in the sectoral volumes which can better reflect
the specificities involved with the estimation and documentation ofemissions/removals, and also for ensuring consistency of the guidance.
We note that this is the case for most chapters and sections in Vol. 1.
However, the sections 6.12.4 to 6.12.7 on how to choose, apply anddocument the use models in inventory preparation include many goodpractice sentences, many relevant only in special circumstances. Pleaseevaluate the general applicability the good practice guidance given, andrevise accordingly .

Finland

Noted

Saint Lucia

Noted

Estonia

Noted
Rejected

Would inverse models correct uncertainty issues? Inverse models seems
253 to suffer from cross contamination.
It is good to see an increased number alternative approches tocollecting/measuring/estimating GHG data that is likely to lead to more
precise outcome.
counting. Emission reduction or changes following of forest management(REDD and REDD+) needs to be mentioned here.

Responses

Authors' notes

Section 6.12 has been included to provide specific guidance onreporting use of models in certain cases.
All elements of comparison with atmospheric concentrations
have inherent uncertainty associated with them. Therefore,
these uncertainties should be quantified and reported fortransparency.
Chapter 2 documents approaches to collection, estimation ofactivity data.
REDD projects are outside of the scope of the IPCC national
GHG Inventory guidelines, and their mention in the energy
volume would likely confuse Energy compilers. The current text
has the right level of detail. Additional detail on AFOLU
methods can of course be found in the AFOLU volume.

Iranto charcoal (FAO, 2016) natural forest and forest plantation as wood forenergy may differ in its productions, and most of the remainder was

Accepted
Iran1829 The tier 1 EF for 1B2aiv from table 4.2.4c for non‐combustion CO2 fromoil refining is : 5.85 t CO2 / 1000m3 refined oil (within the confidence
interval [2.9 ; 13.5]. According to reported IEF from Parties in 2018 CRF
table submissions for 1B2aiv, we can see that among e.g. 5 Parties (4member states and one other developped country) the IEF are bewteen 2
and 67 t/1000m3 refined oil (2; 13; 35 (FR); 41; 67). This present
dispersion is widely over the maximum value of the confidence interval of
the IPCC tier 1 proposed EF. The explanation of such situation is certainly
due to the issue of the reporting of catalyst regeneration. For France, wecurrently report it in 1B2aiv (that may not be the case currently for all
Parties). We can see that for the new 2019 IPCC refinements, it isrecommended to report catalyst regeneration emissions in 1A1b. So the
IPCC 2019 refinements should bring more reporting harmonisation. Can
you confirm the analysis of this issue? Furthermore with the 2019refinements, flaring and venting will be gathered within 1B2aiv which will
make reporting more simple and harmonised.

Noted

FrancePage 40

Yes, box 4.2.2 explains, that catalyst regeneration is a thermal
process and heat is used within the refinery. Therefore such
emissions should be reported under 1.A.1.b. It can also be
confirmed that flaring and venting are now included in
1.B.2.a.iv. Comparing CRF tables ‐ especially in this segment ‐may lead to misinterpretations. To stick with your example:
France reports fugitive CO2 emissions in the same range as
Spain and the USA (all 2000‐4500 kilotons) while Canada andDenmark reports a thousandth or even hundred thousandthpart (5 to 1000 tons). This cannot only be explained withrefinery capacity or used technology. As all countries passed
the UNFCCC reviews several times, it seems to me that somecountries included certain emissions here whereas others
reported them under 1.A.1.b, 1.B.2.c or 1.B.2.d or evenanywhere else. A comparison is not quite appropriate.

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385

2

1

62

387

2

4

401

389

2

4

471

TolineComments
2579 The 2019 IPCC refinements recommend : "The fugitive CH4 and N2Oemissions from production of biochar to be used for energy purposes
would be reported in the Energy volume, while those emitted during thebiochar produced that is applied in agriculture sector would be estimatedand reported following the methodologies set out in the AFOLU volume".
This choice is quite unusual compared to the general principle of emission
inventory to estimate and report emissions relating to the source(emitting activity) and not relating to the end user of the product (except
for actual emissions from the activities of the user). It is also unusualcompared to the other principle of reporting the related emissions during
the year when it is emetted. These two main principles would be nolonger followed in the case of biochar applied in agriculture soils. So it
would be more simple and more consistent with the usual "source
oriented" approach to consider instead : "The fugitive CH4 and N2Oemissions during the production of biochar are to be considered andreported in the Energy volume whatever the final uses of biochar (energy
purposes or agriculture soil uses). Consistently, the AFOLU volume would
need to be reviewed concerning the calculation of carbon capture relating
to biochar uses for agriculture soils. Maybe flexibility could be introduced,
and the 2 possible options could be considered?

Country

Responses
Accepted withmodification

FranceAccepted
63 Figure 1.1: It is proposed to increase the size of the figure, because it isRussian Federation
almost impossible to read it.
401 Equation 4.1.2: It is recommended to provide the default fraction of CO2
Accepted within the recovery gas, otherwise it is impossible to estimate emissions frommodification
underground coal mines as recommended by the Equation 4.1.2.

Authors' notes
Clarifying text on reporting added.

Figure size increased.
the amount of CO2 contained in the recovered gas shoud be
determined in a similar way as how the volume of methane
recovery and utilization in Equation 4.1.2 is obtained, and there
may be 3 approach options for the potential users to choose
based on whatever sources they could get.

Russian Federation
472 It is proposed to clarify description of Tier 1 approach to indicate that itprovides global average method for calculation of methane emissions
from underground mines before correction for methane utulization andflaring. The present text of Tier 1 description is misleading.

Rejected

Russian Federation

Page 41

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Volume2

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4

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TolineComments
996 The use of augmentation of coal reserves as activity data for estimation of
methane emission from exploration boreholes has a fundamental
problem, because it may result in underestimation otherwise
overestimation of the emissions. The underestimation may occur, if there
is no proved increase (augmentation) in coal reserves despite of thenumber of boreholes constructed. The overestimation may be a casewhen significant increase in coal reserves will be associated with a few
boreholes constructed, because it is unlikely that these boreholes will besources of significant methane emissions, given the fact that the methane
is mainly adsorbed in coal deposit, and only minor part of it will releasethrough the borehole. It is recommended that the authors reconcile
methodological approach for exploratory emission estimation in a view tocollect the information on specific methane emissions per exploratory
borehole and provide these as default emission factor for Tier 1.

393

2

4

1843

1870 Sub‐section 1 B 2 a vii Abandoned Oil Wells provides methodology anddefault emission factors for greenhouse gas emission estimation fromboth abandoned oil and gas wells. With this, the section title (Abandoned
Oil Wells) and caption of Table 4.2.4E are inconsistent with textual
content. It is proposed to change the title of sub‐section 1 B 2 a vii and thecaption of table 4.2.4E to include the refrence to gas wells otherwise
remove reference to gas from the sub‐section and develope a separate
sub‐section with the guidance on estimation of greenhouse gas emissions
from abandoned gas wells.

395

2

4

1975

397

2

4

1999

399

2

4

2013

Country

Responses
Accepted withmodification

Authors' notes
This section has been moved to the appendix for future
methodological development.

Accepted withmodification

From one hand, changing of name of the sub‐section would
lead to categories structure inconsistency. From another hand,developing of a separate sub‐section on abandoned gas wells
would duplicate the current sub‐section. For that reasons,accent has given to oil wells in the text.

Russian Federation

Russian Federation1975 The reference to oil production is irrelevant to natural gas production andAcceptedgathering as described in section 1 B 2 b ii. It is proposed to remove it
Russian Federationfrom line 1975.
2005 The text in paragraph in lines from 1999 to 2005 refers to oil wells and it is
Accepted withirrelevant to natural gas production and gathering as described in section
modification
1 B 2 b ii. It is proposed to remove this paragraph from this sub‐section.
Russian Federation
Accepted2013 Equation 4.2.14: The equation includes methodology for estimation
emissions from onshore coalbed production that has not been describedin sub‐section 1 B 2 b ii. It is recommended that the authors provide thedescription of methodology for estimation GHG emissions from onshorecoal bed production in sub‐section 1 B 2 b ii. Otherwise the estimation
approach should be removed from the Equation 4.2.14.
Russian Federation

Page 42

The text refers to both oil and gas wells and is relevant here as
it discusses how to determine which wells are included inwhich category (oil versus gas). Some edits were made to try to
make the text clearer.
While noting that rows 2004 to 2007 already describe approachfor estimation of emissions for onshore coal bed methane
production, have also added text in row 1985 noting thatfactors for onshore coal bed methane are also available in
Table 4.2.4G. Also clarified in Row 2036 that the term is“Volume of onshore coal bed methane produced, and likewise
in Row 2037 “Emission factor for onshore coal bed methane
production”

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CommentID
401

Volume2

Chapter
4

Fromline
2027

TolineComments
2028 Table 4.2.4G: The table includes default emission factors that differ
notably from the parameters provided in the 2006 IPCC Guidelines,
making it impossible to compare the estimates made with the use ofthem. Besides, new emission factors combine several activities that havebeen previously considered separately, which provides for anothercomparability problem. It is recommended that the authors addressinconsistency between the emission parameters in the 2006 IPCC
Guidelines and in the 2019 Refinement and justify the rationale for theuse of the new factors provided.

2

4

2119

2131 Equation 4.2.16: Obviously, the authors make an assumption that annual
gas storage is equal to annual gas consumption, which may not be thecase for many countries. It is proposed that the authors reconcile theassumption on the basis natural gas consumption data otherwise provide
more clear rationale for the assumption made.

Country

Responses
Rejected

Russian Federation
403

405

2

4

2172

407

2

4

2205

409

2

4

2290

411

2

4

2642

Accepted

Russian Federation
2177 Equation 4.2.17: The legend for the equation is not included. It is
Accepted
recommended that the authors include the legend for the Equation
Russian Federation
4.2.17.
Accepted
2205 The identification of the parameter is misleading. It is recommended thatthe authors identify the parameter as the volume of gas consumption atindustrial plants and power stations.
Russian Federation
2291 Table 4.2.7: Table caption is inconsistent with its content. It is proposed
Accepted
that the authors replace the caption with the list of activity data that
seems more appropriate than the guidance on activity data obtaining.
Russian Federation
2643 Table 4.3.3: Table 4.3.3 is inconsistent with Table 4.3.2, because different
Accepted
uncertainties are provided for the same emission factors. It is
recommended that the authors merge uncertainties in tables 4.3.2 and4.3.3 and remove table 4.3.3 from the text of the refinement.
Russian Federation

Page 43

Authors' notes
In terms of the categories included in the 2019 Refinements,
the text is very clear on which activities are included, and thecategories are consistent to the extent possible with the 2006
categories. To do a detailed comparison with the 2006
guidelines, one could review the appendix, which gives theapproximate split between venting, leaks, and flaring emissions
for each subsegment. It is also possible to sum the leak,venting, and flaring information from the 2006 IPCC guidelines
to compare with the updated values in the 2019 guidelines. In
the text where the Tier 1 factors are first discussed, thefollowing text provides information on use of the new factors:“The factors in Tables 4.2.4 to 4.2.4k are derived using detailed
emission inventory results from the United States, Canada,
Australia, Germany, and other countries, and, where possible,
have been updated from the values previously presented in the
IPCC Guidelines for National Greenhouse Gas Inventories(2006) document to reflect the results of more current andrefined emissions inventories. In many cases, technology‐ andpractice‐specific emission factors are presented, so that aninventory compiler may select factors that best represent
industry practices in the country. While the emission factor
options are meant to cover technologies and practices that arecommon in the oil and gas industries, technologies andpractices can vary significantly. In addition, the accuracy offactors is dependent on the uncertainty of underlying data. A
country should periodically assess changes in technologies andpractices, and changes in available emissions data, andddl is used for the activityhText added
clarifying why consumption
basis, and what to do if better data are available.

Rechecked parameters in the legend and equation and madecorrections.

Table 4.3.3 is removed.

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63b9088a

CommentID
413

Volume2

Chapter
4

Fromline
3217

415

2

4

3181

859

2

4

1776

861

2

4

2208

863

2

4

2703

865

2

4

2720

867

2

4

2720

869

2

4

2720

871

2

4

2722

873

2

4

2721

875

2

4

2812

TolineComments
Country
Responses
3217 It is recommended that the authors edit text in line 3217 to avoid
Accepted
Russian Federation
repetition.
Rejected
3189 The harmonization of the units is very important, and it is commendable
that the authors address it in the Refinement. However, Annex 4A.1 does
not include the values of correction factors referred to in Equations 4A.1.1(K15), 4A.1.2 (K60/60) and 4A.1.3 (KAPI). The absense of the correction
factors makes it impossible to harmonise the units and the entire Annex
4A.1 looses the importance. It is recommended that the authors provide
values of correction factors referred to in Equations 4A.1.1 (K15), 4A.1.2(K60/60) and 4A.1.3 (KAPI).
Russian Federation
Accepted
1780 When hydrogen is produced as a by‐product in refineries, Box 4.2.1
explains that it is good practice to report the GHGs in the Energy sector
and its methodololy can be adopted from Ch.3.11 Vol.3(IPPU).
‐ However, no appropriate methodology is provided in Ch.3.11 Vol.3. It isnecessary to explain a detailed estimation methodology including theselection of activity data, default EFs, etc. in a proper volume.
‐ Also in the chapter3.33 Vol3(line 1254, Table 3.29, Notes2 and Box 3.16)
it is described that the emissions are typically already accounted for therespective sectors. Therefore it should make clear whether the emissions
from producing hydrogen in refineries are needed to estimate additionallyusing IPPU methodology and report to energy sector or already accounted
for the energy(fugitive)

Republic of Korea
2208 The table 4.2.5 is omitted(table 4.2.5 is quoted in Ch.4, Vol2, Line2888,
Republic of Korea
2909)
2703 It is impossible to recognize letters in Figure 4.3.2. Please revise the figure.
Republic of Korea
2721 In the table 4.3.4 because flaring of COG in coking stage is separated incomparison with the second draft, " from any flaring of the COG
produced" should be deleted in source and significance of fugitive
Republic of Korea
emissions2721 In the table 4.3.4 carbonisation process emissions in coking stage should
Republic of Korea
be reported in1.A.1.c(energy) instead of 2.C.1(IPPU).
2721 In the table 4.3.4. in 'flaring of COG' and 'coking' stage, reporting non‐flaring fugitive needs to be changed from 1.b.1.c to NO, and flaring from
Republic of Korea
NO to 1.b.1.c.
2722 It is very difficult to recognize letters in Figure 4.3.3. Please revise theRepublic of Korea
figure.
2817 The usage of different expressions such as BOFG, LDG, and converter gas
for the same gas is very confusing.
A consistent expression will make readers more easily understand theguideline. Furthermore, it is necessary to write together their full names(i.e. Basic Oxygen Furnace Gas, Linz‐Donawitz Gas).
Republic of Korea
2812 Please revise a typo "upto" to "up to".
Republic of Korea

Page 44

Rejected

Authors' notes

There are around 30 pages of values of parameters used in
Equations 4A.1‐4A.4. Including these pages in the GLs is notreasonable. The references on documents, from which theparameters may be taken, are provided.

Clarifying language provided.

Flaring‐specific uncertainty values are from the 2006 GL. They
are not available in the 2019 Refinement.

Accepted
Accepted withmodification

Accepted
Accepted

Accepted
Accepted

Accepted

The text "(COG flaring is covered in a separate line below)" wasadded for clarification.

2019 Refinement ‐ Collated Comments on Final Draft from Governments with Authors’ Responses

63b9088a

CommentID
877

Volume2

Chapter
4

Fromline
2832

2

4

2919

TolineComments
2832 Please revise an error "Table 4.3.6" to "Table 4.3.7".

Country

Responses
Accepted

Authors' notes

Republic of Korea
879

2919 Please revise a typo "double counting are" to "double counting is".

Accepted
Republic of Korea

881

2

4

2949

883

2

4

2999

885

2

4

3127

887

2

4

3849

889

2

4

3886

891

2

4

3921

947

2 Annexes

14949

2 Annexes

432949 It is written that "Current production levels … 120 million tons of CO2
equivalent.", however, it is unclear on what year and reference thecurrent data is based. Please state clearly in the guideline on its reference
doument and year.
2999 Please revise a typo "Do country‐specific EFs exists?" to "Do country‐
specific EFs exist?".
3127 Please delete a repeated phrase "it is good practice charcoal and biochar
production:".
3876 The references for Appendix 4a.2 are provided at lines 3849‐3876,
however, all but World Bioenergy Association (2018) are already includedin the References for wood pellet production at lines 4150‐4176.
Please delete repeated references and merge World Bioenergy
Association (2018) into the References for wood pellet production.

Accepted withmodification
Republic of Korea
Accepted
Republic of Korea
Accepted
Republic of Korea
Accepted

Republic of Korea
3886 Please revise an error "please see Section 4.2.2.3 of Volume 2, Chapter 1"
Republic of Korea
because there is no such phrase in Vol.2, Ch.1.
3921 Please revise errors "Figure 4.3.5" and "Subsection 4.3.2.1.1" to "Figure
Republic of Korea
4.3.7" and "Subsection 4.3.2.2", respectively.
14 Annex1: It is suggested that “Surface Mines” be replaced by “Exploration”.
China
49 Annex1:It is noted that the "worksheets" for oil and natural gas systems
have substantially changed in terms of the classification of emission
sources as compared with the 2006 edition, which (including the CRF
tables in the current national inventories of Annex I Parties to theConvention) requires that the three sources of flaring, venting and leakage
emissions be calculated separately for oil and natural gas systems, among
which leakage emissions is further subdivided into different segments,
while the "2019 Refinement" makes a consolidated calculation with theaggregated emission factors directly under the segments of oil and natural
gas systems, that is, flaring, venting, leakage emissions are no longer
reported separately. This is not only a change in accounting methodology,
but also a change in the requirements for or contents of future inventory
information reporting. So it is suggested that the author briefly explain thereasons for this change where appropriate in "4.2 FUGITIVE EMISSIONSFROM OIL and NATURAL GAS SYSTEMS" for the sake of users'
understanding and acceptance.
China

Page 45

The reference has been moved from the footnote into the text)

Accepted
Accepted
Accepted
Accepted

Explanation included in 4.2.4. The mandate of the refinement
was the develop technology‐specific tier 1 emission factors. To
do so, the best data available does not have a clear distinction
between leaks, venting, and flaring (though the authors domake a best estimate of this split in the annex). To maintainconsistent reporting between the tiers, the table has beenrevised. It is the view of the author’s that this new formulation
allows for clearer and more accurate reporting.

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CommentID
951

VolumeChapter
2 Annexes

Fromline
32

TolineComments
33 Annex2:This passage does not fully reflect "Fugitive emissions frommining, processing, storage and transportation of coal". So it is suggested
that "and on carbon dioxide (CO2) emissions from underground mines."
be replaced by "and on carbon dioxide (CO2) emissions from undergroundand surface coal mines." In addition, please modify Lines 255‐257 in the
Overview by referring to the above.

Country

Responses
Accepted

Authors' notes

China
953

955

2

2

4

4

938

1032

957

2

4

1351

959

2

4

2053

Accepted

1131 "4.1.6 Coal Exploration" does not offer enough literature support or data
availability to come up with a scientific, reliable and operable
methodology. There are three main problems as follows:First, there is a lack of literature support:
1) The relationship between the annual augmentation of coal resources
and the fugitive emissions from coal exploration. It is true that the annual
augmentation of coal resources is easier to obtain than the exploration
borehole data (see 964‐965 for details). However, section 4.1.6 does notprovide any valid literature to prove that there is a positive or linear
relationship between the annual augmentation of coal resources and the
fugitive emissions from coal exploration. So it is not scientific enough to
use the annual augmentation as activity data to calculate the emissions.
The Tier 2 and Tier 3 approaches have the similar defects.
2) The default emission factors of Tier 1 Approach are not supported byany literature. It is merely said that they are based on expert judgment(see 1036‐1037 for details), without producing any valid documentation.
The relevant information about the experts involved and theirprofessional background, logical basis for judgment, whether the resultsof expert judgment are peer‐reviewed or externally recognized is not clear
or transparent.
Second, the Tier 1 Approach has weakness in methodology:
Tier 1 Approach counts up the annual augmentation of ‘proved resources,
indicated resources and inferred resources’ as activity data, and applies
them with the same emission factor without any distinction. However,according to line 1095‐1099, there are significant differences in spacing of
exploration boreholes between the three categories of resources and theirh 4.3.2 and 4.3.3,b which
d are
b not
d ffclear due
h to lowf resolution,h2724 Figures 4.1.4,
are suggested to be modified and improved.
1352 This version updates the "decision tree" in Figure 4.2.1. In the old version,
the decision tree was given to natural gas and oil systems respectively,
while in the new one, the decision trees are merged. However, thedecision trees in 4.1 and 4.3 of the report are given separately by theemission source type. So it is suggested to keep 4.2 structurally consistent
with 4.1 and 4.3.

China
Accepted
China
Rejected

China2054 It is mentioned here that the fugitive emissions from gas production
process will be considered in Section 4.3, which (P100, lines 2553‐2555),
however, states that no gas methodology is specifically provided. Please
give it a check and explanation.

Page 46

Text has been moved to an appendix. Additionally the decision
tree has been corrected.

Accepted

China

The current version of the “decision tree” is compiled for better
representation of oil and gas industry taking into account
updated Annex 4A.3 (Definition of terminologies used in
Section 4.2). Unification of two separated for oil and gas"decision trees" aimed to avoid duplication similar proceduresof decision making, and hence to avoid extra volume of the
Guidelines.

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CommentID
961

Volume2

Chapter
4

Fromline
2602

963

2

4

2885

965

2

4

2891

1025

2

4

1027

2

4

2178

1029

2

4

2614

1031

2

4

2891

1033

2

4

3044

TolineComments
2603 The unit of emission factors, which is not clearly expressed, is suggested
to be modified as: Emission factor GHG = emission factor GHG (g GHG/kg
charcoal(or biochar) produced)
2889 It is noted here that the N2O emission factor is cited from Table 4.2.5 ofVolume 2 of the 2006 Emission Inventory, which, however, has been
updated as Table 4.2.4G (P74, Chapter 4, Volume 2 in the 2019
Refinement. So it is suggested to make a revision as such.

Country

Responses
Accepted

Authors' notes

China
Accepted

China2892 Table 4.3.7: 1) The multiplier (x sign) in the equation containing the N2O
emission factor should be a divisor (÷ sign). So a check is requested. 2)
The equation for calculating the CH4 emission factor lacks the calorificvalue and density parameter of COG and the method for K calculation.
Such an addition is requested.
General and crosscutting with IPPU, also Waste: Some fuel transformation
processes use the same processes (gasification) and feedstock which are
addressed in the IPPU sector (hydrogen production). Some guidance how
to avoid double counting of emissions would be useful. Also reference
between the sector in places where double counting could be an issue
would be useful. The guidance should clarify the basic principles ofreporting emissions, energy use in Energy sector, non‐energy use in the
IPPU sector. This is especially important as sometimes it is not that clear
how and where the related emissions should be reported.

Accepted

Numbers and formulas has been corrected

Accepted

Clearer guidance has been provided on hydrogen, refineries,
and coke production to clarify reporting and double counting
issues.

Rejected

No sound data is available to generate a good emission factor.

China

Finland2178 Table 4.2.4J: Please add emission factors per gas distributed for town gas
distribution (as alternative choice for EFs per km of pipeline) as this would
make calculations easier.
2614 Please check if is this correct, seems a little bit surprising: "Kilns withlower efficiency tend to have lower emission factor and vice versa."

FinlandAccepted
Finland

1035

2

1037

2

1231

2 Annexes

1233
1235
1247

4
4

3818

40

2 Annexes45

2 Annexes
2

3232

48
4

54

2891 In Table 4.3.7. calculated N2OEF (9.76 E‐06) does not correspond to theformula shown; probably numerator and denumerator have changed
places. Please check and correct if necessary.
3044 In Table 4.3.10. the emission factors for different CtL gas types show very
different magnitudes: please check.
3232 In Table 4A.2.5 percentages of the second subcategory do not add up to100%; please correct.
3818 In Figure 4a.2.2 Burner startup emissions are shown as potential emission
sources for a typical pellet plant. These emission should not be allocatedunder sector 1B, but under 1A (emission from fuels used by the dryer
burners). Please correct.
40 For Annex 1, under table 1.B.1.c in the row of 'Code', the title of 4th
Column should be 'Activity Data', instead of 'Activity'.
45 For Annex 1, under table 1.B.2 in the row of 'Code', the title of 4th Column
should be 'Activity Data', instead of 'Activity'.
48 For Annex 1, the title of the 4th Column should be 'Activity Data', insteadof 'Activity'.
54 Add 'and' between 'Overview' and 'description'.

Page 47

Accepted

Numbers and formulas has been corrected

Accepted

The EFs were reviewed and fixed for Syngas/H2 and SNG, aswell as for GTL in Table 4.3.11
Added a footnote

FinlandFinlandAccepted
FinlandAccepted

FinlandAccepted
India
Accepted
India
Accepted
India
India

Accepted2019 Refinement ‐ Collated Comments on Final Draft from Governments with Authors’ Responses

63b9088a

CommentID
1249
1251
1253
1255

Volume2

Chapter
4

Fromline
101

2
2
2

4
4
4

103
257
326

Toline101 Add ':' after 'Tier 2'.

Comments

Country

103 Replace '‐' with ':'.
257 Add 'left over coals in' before 'abandoned coal mines..'.
326 Coalbed' is one word. Remove any space between 'coal' and 'bed'.

India
India
India

Responses
Rejected
Noted
Accepted
Rejected

Authors' notes
This comment is rejected as the wording in equation 4.1.11
refers to the “approach”, i.e.., “tier 2 approach”
This is out of scope of the 2019 Refinement
Based on an internet search, both spellings are acceptable.

India
1257

2

4

328

328 Replace 'understanding strata geophysics' with 'obtaining core samples
for resource estimation and, investigation of various chemical and geo‐mechanical parameters essential for designing the resource recovery (maybe coal by mining or CBM through production wells)'

1259

2

4

329

329 Coalbed' is one word. Remove any space between 'coal' and 'bed'.

Accepted withmodification

Have inserted text with minor modification in order to maintainoriginal purpose of the sentence.

Rejected

Based on an internet search, both spellings are acceptable.

India
India
1261
1263
1265
1267
1269
1271
1273
1275
1277
1279

2
2
2
2
2
2
2
2
2
2

4
4
4
4
4
4
4
4
4
4

356
358
387
414
794
804
896
1077
1079
1178

356 macropores' is a single word. No space needed between 'macro' and'pores'.
358 Add a '‐' between 'hydro' and 'fracturing'.

Accepted
India
India
India

387 in situ' should be in italics.
414 Correct 'subtraction' to 'substraction'.

India
India

794 Correct 'exept' to 'except'.
804 Correct 'referrs' to 'refers'.
896 Delete the phrase 'and inventory year'.
1077 Remove '‐' between in and situ
1079 Remove extra dot after etc.
1178 Coalbed' is one word. Remove any space between 'coal' and 'bed'.

India
India
India
India

Accepted withmodification
Accepted
Rejected
Accepted
Noted
Noted
Accepted
Accepted
Rejected

Changed to hydraulic fracturing“Subtraction” is correct. “Substraction” is not a word in the
English dictionary.
This is out of scope of 2019 Refinement, however this will be
modified as typo after IPCC‐49.
This is out of scope of the 2019 Refinement

Based on an internet search, both spellings are acceptable.

India
1281

2

4

1229

1229 Replace 'capstone' with 'caprock'.
India

1381

2

4

2632

2642 The title of Table 4.3.3 reads "DEFAULT UNCERTAINTY ASSESSMENT FOR
EMISSION FACTORS FROM CHARCOAL PRODUCTION". However, theuncertainty values differ significantly from the uncertainty ranges
provided in table 4.3.2. Also, while the text above table 4.3.3. talks about
activity data uncertainty, Line 2641 reads: Table 4.3.3 provides theuncertainties associated with charcoal production. Thus, there seems to
be a mismatch between the informatio and especially concerning whattable 4.3.3 displays.
SwedenPage 48

Accepted withmodification
Accepted

Both definitions are correct.
Table 4.3.3 has been removed. Suggestion taken and sentence
on double counting added.

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63b9088a

CommentID
1453

Volume2

Chapter2

Fromline
46

2

4

449

TolineComments
79 It would be most useful to include in this section "new guidance" in a box,
for information purposes only, similar to that in Box 2.0A of Chapter 2,
Volume 4 (AFOLU). This is because IPCC guidelines on biomass are often
applied or referred to outside of the NGHGI context, for example life cycle
analyses or biomass projects. Many of those applications would be
usefully informed by guidance similar to that in Box 2.0A mentioned
above. It could point out the potential implications arising fromdifferences in system boundaries, sectoral boundaries, timeframes andthe like. Such guidance would recognise the important role the IPCC
guidance already plays beyond its immediate purpose, and could help
practitioners adapt it to other contexts, avoiding the inadvertant
misapplication of methodologies.

Country

Responses
Rejected

Authors' notes
The revised text elaborates on (but does not change themeaning of) the information previously presented in the bullet
points, in this section of the 2006 IPCC guidelines. There is noneed to highlight this information in a box, which was alreadyaccepted to be presented in bullet format.
The additional information requested by the commenter is
outside of the scope of this section which deals specifically withthe treatment of biomass. Any more general information on
the use of IPCC guidelines can be found in Volume 1.

EU
1835

1873

2

4

3127

450 "Low temperature oxidation of coal..." would read better than "Coal lowtemperature oxidation..."3127 Delete one instance of "Charcoal and biochar production: it is goodpractice". It is said twice

2643

2

4

2063

2065 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 theaverage of the Germany (40%) and Austria (25%) sour gas shares. Given
that the two countries combined produce about 0.3% of total world gas
production, the suggested value of 32% is not representative of world
conditions. This is also overly prescriptive for the guidelines. Suggest
removing this sentence and the accompanying footnote.

2645

2

4

2290

2291 Table 4.2.7 is titled “Guidance on obtaining the activity data values
required …” but it doesn’t offer any guidance. It simply lists the activity
data values previously discussed for each industry segment. Suggest
deleting “Guidance on Obtaining the” from the table title.

3073

2

4

843

845 Column one, row four of updated Table 4.1.7 refers to an Equation 4.1.10.
However, there is no such numbered equation in the draft. The equation
numbering skips from Equation 4.1.8 directly to Equation 4.1.11, omitting
numbers 4.1.9 and 4.1.10.

Accepted
United Kingdom (ofGreat Britain andNorthern Ireland)
Accepted
United Kingdom (ofGreat Britain andNorthern Ireland)
Rejected

I totally agree that using this split factor should not be the very
first option and the value is not representative to the wholeworld. However, the two sentences above explain, thatcompiler should attempt to determine the fraction of the gas
using nationally available statistics or industry information. If
no data is available, the fraction should be assumed bycomparing with adjacent countries or taken from the study
provided. The split factor in the footnote should be used if allother attempts fail.

CanadaAccepted

CanadaPage 49

Rejected
United States ofAmerica

Numbering of equations and tables corresponds to the IPCC
2006 Guidelines

2019 Refinement ‐ Collated Comments on Final Draft from Governments with Authors’ Responses

63b9088a

CommentID
3075

VolumeChapter2

4Fromline
937

TolineComments
1131 The draft method for coal exploration (4.1.6) is unsupported and should
be moved to an appendix for further development. The draft Tier 1
method does not provide any technical support for the activity data to be
used. In particular, no technical support is provided for the assertion that
there is a positive correlation between the augmentation of national coalresource in a reporting year (i.e., the discovered coal reserves during thereporting year) and the number of exploration boreholes drilled during
the reporting year. The draft narrative itself acknowledges that "thespacing of boreholes depends on the geological structure, deposit
character, nature of data required for mine planners etc." (lines 978‐979).
The draft Tier 1 method also presents no technical support for the default
emission factors used in the method, ascribing their basis to "expert
judgement". No explanation is provided for the technical basis
underpinning the "expert judgement" used in establishing these emission
factors. In contrast, the narrative of the draft acknowledges that therelease of gas from a coal seam is highly dependent on gas desorption
parameters (lines 1022‐1031). Overall, no technical support is provided
for either the validity of the activity data (coal resource augmentation as aproxy for number of exploration boreholes) or the validity of the emission
factors (m3 of CH4 per tonne of augmented coal resource) used in thedraft Tier 1 method.

Country

Responses
Accepted

Authors' notes
This section has been moved to the appendix for future
methodological development.

Accepted withmodification

This section has been moved to an appendix

Accepted withmodification

This section has been moved to the appendix for future
methodological development.

United States ofAmerica
3077

3079

2

2

4

4

984

996

996 The Tier 1 approach relies on coal resource data by depth of coal seam.
The U.S. does not collect coal resource information by depth of coal seam
(Form EIA‐7A, Annual Survey of Coal Production and Preparation). Provide
another method or move this to an appendix.

United States ofAmerica

1002 The Tier 1 approach does not specify the definition of "augmented
resource". Values for coal resources can vary widely depending on
definition, such as "resource base", "recoverable resource", "measured
reserves", "proved reserves", "indicated reserves", and "inferredreserves". As an example of these widely varying values, see the U.S. EIA
report, U.S. Coal Reserves: 1997 Update (DOE/EIA‐0529(97)) (p. 2; Figure2, p. 5) . These values, depending on the coal resource definition, can varyby an order of magnitude. The draft method states that "[a]ll different
categories of coal resources such as measured (or proved), indicated andinferred etc. (UNFC 2009), should be taken into account for determining
activity data of augmented resource." It is not clear what is meant by thisstatement and how it should be applied when using the method. Applying
the method using data based on different definitions of coal resource
would result in widely different estimated emissions results.
United States ofAmerica

Page 50

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CommentID
3081

VolumeChapter2

4Fromline
2544

TolineComments
2545 It might be useful to add something in here before the discussion oftransformation processes on the different types of feedstocks that could
be used, in particular biomass vs. fossil feedstock and the implications forreporting CO2 emissions in particular.

Country

Responses
Accepted

Authors' notes
Text added: Table 4.3.1 provides cross references to thelocations in the guidelines for the methods for estimating
fugitive emissions from the transformation, and, shows thecategories where emissions should be reported. Compilers
should note carefully the differences in reporting of CO2 frombiomass and fossil feedstock

Accepted

Table was corrected and table 4.3.1 was added for further
clarification.

United States ofAmerica
3083

2

4

2556

3085

2

4

2564

3087

2

4

2565

3089

2

4

2566

3091

2

4

2575

3093

2

4

2590

3095

2

4

2602

2557 Table 4.3.1, should coke production row include CO2 (flaring COG), BtL
and BtG rows should it read Appendix 4a3 and why are emissions
reported in 1.B.3 instead of 1.B.1.c?
2564 add "and" after (industrial),
2566 It is unclear what Emissions is referring to in start of sentence,
recommend adding Emissions "from harvested wood energy use" are …
2567 add "only" after process, so reads: the solid to solid transformation
process only
2575 Not sure what Section 4.2.2.3.1 is referencing, 4.2.2.3 is choice of activity
data on dead organic matter.
2590 Figure 4.3.1, Second decision box that reads are kiln level efficiencies or
emission factors available, this is after indication that kiln level activity
data is not available so should change box to read: Are country specificefficiency or emission factors available
2603 add "of a given" between factor and GHG delete the (kg GHG/unit ofcharcoal (or biochar) produced) first set of parenthesis as units arecovered by second set, add "produced" to end of second set

3097

2

4

2608

2608 Change "this source" to "lignite briquette production"

3099

2

4

2614

3101

2

4

2623

3103

2

4

2629

2614 confirm lower efficiency leads to lower emission factors, seems like itwould be opposite
2623 Not sure export of charcoal matters since country would still account for
production emissions here
2629 Include something in this paragraph about double counting, for example,
confirm CO2 from charcoal is not accounted for under fuel combustion or
harvested wood production emissions/accounting. In the US we include
wood combustion emissions based on activity data that includes : Woodand products derived from wood that are used as fuel, including roundwood (cord wood), limb wood, wood chips, bark, sawdust, forest residues,charcoal, paper pellets, railroad ties, utility poles, black liquor, red liquor,
sludge wood, spent sulfite liquor, densified biomass (including woodpellets), and other wood‐based solids and liquids.

3105

2

4

2647

2648 If possible can this also reference Fig 4.3.2 for where emissions areaccounted forPage 51

United States ofAmerica
United States ofAmerica

Accepted
Accepted

United States ofAmerica
United States ofAmerica
United States ofAmerica

Accepted
Accepted withmodification
Accepted withmodification

United States ofAmerica
Accepted
United States ofAmerica
United States ofAmerica
United States ofAmerica
United States ofAmerica

Accepted
Accepted
Accepted
Accepted

United States ofAmerica
United States ofAmerica

Accepted

Deleted reference to 4.2.2.3.1
In examining the comment carefully, we had reached theconclusion that to address the comment, this decision treeneeds to be revised totally, thus the figure was replaced.

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63b9088a

CommentID
3107

3109

VolumeChapter2244Fromline
2703

2720

TolineComments
2704 Figure 4.3.2, If possible can this figure show where the different emission
sources would be accounted for, e.g., this category vs 4.2, vs energy
combustion
2721 Table 4.3.4, coke pushing line should flaring column be NO? Flaring COG
line should no‐flaring fugitives column be NO and reporting moved toflaring column? Also should flaring of COG be in a separate discussion
since there is a separate section on it?

3111

2

4

2763

3113

2

4

2790

2764 add "or process" after combustion, should read the combustion "orprocess" emissions are not included …
2790 Should reference to box be Box 4.3.1

3115

2

4

2797

2797 delete "which" after 5%

3117

2

4

2802

3119

2

4

2848

2802 Specify the location for COG flaring emissions reporting. Is it in section
1.B.1.c.ii??
2848 Review Box 4.3.1 and edit for clarity

3121

2

4

2849

2849 Add "as shown in Table 4.3.7" to end of sentence

3123

2

4

2847

2849 Recommend making formula based on COG produced and add into thecalculations % of COG flared that way it is something the country canadjust as needed and to make more consistent with non‐CO2 calculations

3125

2

4

2858

2858 should this reference equation 4.3.3?

3127

2

4

2871

2871 Add language from CO2 calcs here "The Tier 1 approach assumes that 2%(by volume) of the coke oven gas produced is removed from theproduction stream and then flared"
2870 Recommend adding in % of COG flared to the equation directly instead ofbuilding into Efs, that way country can adjust if needed.

3129

2

4

2866

3131

2

4

2881

2881 Add "The" to beginning of sentence, so reads "The" Ch4 emission factor …

3133

2

4

2891

3137

2

4

2924

2892 Table 4.3.7, recommend pulling % flared out of EF calc and make part ofequation, in N2O calculation EFN2O should be divided by EF CO2 for oil
and gas production, not the other way around2921 Also include something about how care should be taken with any
adjustments or emissions from COG used in the energy fuel combustion
calculations
2924 change "composed by" to "composed of"

3139

2

4

2927

2927 change "obtained at" to "obtained through"

3135

2

4

2921

Page 52

Country

Responses
Accepted

Authors' notes

United States ofAmerica
Accepted

United States ofAmerica
United States ofAmerica
United States ofAmerica
United States ofAmerica
United States ofAmerica
United States ofAmerica
United States ofAmerica

United States ofAmerica
United States ofAmerica

Accepted
Accepted
Accepted
Accepted withmodification
AcceptedBox 4.1 has been changed by Box 4.3.1 in the text

Accepted withmodification

Equation 4.3.3 has been changed, and the text modified
accordingly

Accepted withmodification
Rejected

The number of the Equation has been changed

Accepted withmodification

The approach has now changed to let compilers enter theirown value for flaring, but 2% can be used as a default.
The equation and the EFs has been change accordingly

Accepted
Accepted

United States ofAmerica
Accepted
United States ofAmerica
United States ofAmerica
United States ofAmericaCorrect category is 1.B.1c.

Accepted

United States ofAmerica
United States ofAmerica
United States ofAmerica"Coke pushing line should flaring column be NO?” Yes, it
should. I have changed it. “Flaring COG line should no[n]‐flaring
fugitives column be NO and reporting moved to flaring
column?” I have added a reporting category to the ‘flaring’column. There might be non‐flaring fugitives released during
flaring, so I propose leaving the reporting for non‐flaring
fugitives as it is. Also should flaring of COG be in a separate
discussion since there is a separate section on it?” Forcompleteness, it is included here as well.

Accepted
Accepted

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63b9088a

CommentID
3141

Volume2

Chapter
4

Fromline
2946

Toline2946 Should CO2 be CO?

Comments

Country
United States ofAmerica
United States ofAmerica

3143

2

4

2959

2962 Indicate which of these sources are included here

3145

2

4

2981

2982 Here and throughout this section CtL emissions are based on syngas
produced but actually think coal used would be a better factor and there
might be better activity data on that at the country level, syngas produced
would have to be obtained from each facility and might be confidential
business information (CBI)

3147

2

4

2989

2989 change "feedstock combusted" to "feedstock used"

3149

2

4

3096

3097 Add something about potnetial double counting in the energy fuelcombustion activity, in US we adjust energy use to account for syngas
production used as fuel so we would already account for CO2 emissions

3593

2

4

1

3215 Fugitive CO2 emissions from coal mining have been included for the firsttime in 2019 IPCC refinement report. These emissions constitute a
reasonable amount of GHG emission from coal mining activities. The
methodology, activity data and emission factors, should be included in therefinement guidelines to provide guidance to national inventory
compilation.
1168 Unsure that the definition of what Oil and Natural Gas System comprise all
we want to include. What about abandoned wells/fields?

3705

2

4

1166

3707

2

4

1256

1256 The term waste gas is used much throughout the document ‐ is it the sumof gas being flared, vented or leaked? Please clarify and consider toinclude waste gas in the glossary.

3709

2

4

1257

1257 Already stated above

3711

2

4

1276

1287 We are not sure how this summary of practices( which may vary greatly
by countries and facilities) can be useful. There is little of direct reference
to reporting under specific categories

3713

2

4

1308

1309 Here there term used is Oil System and Natural Gas System in capitalletters , often not elsewhere in the document. Should be consistent andperhaps as: Oil and Natural Gas Systems. They are in the real world oftenvery integrated and is also get a bit lost throughout the Guidelines,
inclduding in the otherwise useful figure 4.2.0

3715

2

4

1436

1436 How useful is this table given the coverage of empirical data and therelative importance of the emission sources in question? Please consider
if it is possible to improve the coverage e.g by including data from morecountries/regions.

United States ofAmerica
United States ofAmerica

Responses
Accepted

Authors' notes

Accepted

Sentence added to clarify the sources of CO2 considered.

RejectedYes we agree but the literature presents emission factors as afunction of syngas produced which makes sense because it is
not the coal but the amount of syngas that determines
production of liquid fuels downstream. No change to the text isdone

Accepted
Accepted

A sentence has been added to deal with this issue and also thequality control aspect of coal use as feedstock in syngas
production is already addressed in lines 3144‐3147 below

Noted

The methodology and default emission factors have alreadybeen included in the refinement guidelines. Activity data, which
are country‐specific and dependent on inventory year, should
not be pre‐assigned by the refinement.

United States ofAmerica

India
Accepted
NorwayAccepted

Glossary definition added, “Waste gas: gas stream containinghydrocarbons and/or other gases that are vented or flared andnot used for other purposes (e.g. production of useful energy)”

Rejected

It is critical here to highlight the that fugitives here include
venting, flaring, and leaks since there is sometimes confusion
around the definition of “fugitive”

Rejected1) the major part of the commented paragraph is unchanged
text from 2006 GLs, which is not open for revision; 2) in 2019refinements, flaring emission factor for difference segments
are provided aggregately in each relevant segment anddisaggregation could be found in Annex 4A.2.

Accepted withmodification

Text was added to clarify the intent of this sentence

Noted

Out of scope of the refinement

NorwayNorwayNorwayNorwayPage 53

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CommentID
3717

VolumeChapter2

4Fromline
1763

TolineComments
1764 Table 4.2.4B (New):
The CH4 emission factors for offshore oil loading in Table 4.2.4B are given
with reference to data submitted by Norway. However, they do notcorrespond to the current knowledge of emissions in Norway.
‐ The suggested factor without recovery is based on implied emission
factors for data reported for 1990‐2000. These data do reflect conditions
without recovery in those years. However, current emission factors forloading without recovery is lower, as shown below.
‐ The suggested factor with recovery is based on implied emission factors
for data reported for 2001‐2016. However, emissions in these years werepartly from loading with recovery, and partly for loading without recovery.
Thus, the suggested factor will overestimate emissions from loading withrecovery in this period.

Country

Responses
Accepted

Authors' notes
Used factors provided in comments and revised text to reflect
information about the new factors.

As an alternative, we have prepared new and updated emission factors,
developed from emission data reported to the Norwegian Environment
Agency by operators of the oil field on the Norwegian Continental Shelffor the years 2015‐2017. Emission data are generated by a comprehensive
monitoring programme including measurements of gas flow,
temperature, pressure and gas composition and also modelling.
The VRUs used are mainly condensation plants.
Her is our proposal for new and updated emission factors in Table 4.2.4B ‐offshore loading of crude oil. We include suggestions for NMVOC factors:
Sub‐segment: Loading of offshore production on tanker ships without
3719

2

4

3290

3291 Annex 4A.3 Definition of terminologies used in Section 4.2: Please observethat the definition of CCS is very different from the definision normallyused by IPPC (see the glossary in AR5, WGIII). Normally also transport isincluded in the definision. Is there a particular reason for this change indefinition? If not consider to use the definision in AR5, WGIII: Carbon
dioxide capture and storage (CCS)
A process in which a relatively pure stream of CO2 from industrial andenergy‐related sources isseparated (captured) from industrial or energy‐related processes,
conditioned, compressed andtransported to a storage location for long‐term isolation from theatmosphere.

3721

2

4

3252

3723 Annex 4A.3 Definition of terminologies used in Section 4.2. Pleaseconsider if some of these definitions should also be in the Glossary, e.g.
ETS, CCS. Please also check if the teminology used here is consistent withthe termiology in other IPCC reports.

NorwayAccepted

NorwayPage 54

Accepted

NorwayETS and CCS are added and agree with AR5 WG III Glossary inthe case of CCS

2019 Refinement ‐ Collated Comments on Final Draft from Governments with Authors’ Responses

63b9088a

CommentID Volume
503 General

Chapter

Fromline

TolineComments
According to the Minsk_Scoping_Meeting_Report Table 2 New guidance
for Category 1.A.1.c (issue #1 Table1) was proposed to be treated in new
section 4.3 on fuel transformation of V.2 Ch. 4. However, in the Final Draftof the 2019 Refinements section 4.3 provides methodology only for"Fugitive Emissions from Fuel Transformation". While methodology for
estimation of stack emissions from fuel combustion and the carbonisation(fuel transformation) of coal is provided in the IPPU V.3 ch.4 section 4.2.2.
It is noted in the V.3 ch.4 section 4.2.2 that stack emissions estimated by
the suggested methodology should be reported in category 1.A.1.c
Manufacture of solid fuels of Energy sector. The Energy volume (v.2) does
not provide any references for new guidance developed for the category
1.A.1.c as well as any explanations in which case and for which fuels thisnew guidance should be used. This situation is unacceptable, because it
will lead to misunderstanding of the Refinements quidelines and possible
double‐counting or underestimation of emissions. Please, consider
providing in V.2 ‐ Energy a reference for new guidance developed for the
category 1.A.1.c and explanations in which case this new guidance should
be used.

Country

Responses
Rejected

Authors' notes
This comment belongs to Volume 2.
This comment is out of scope of TOR (IPCC‐XLIV/L.3) and theDraft TOC elaborated at the scoping meeting in Minsk. In fact,
what the reviewer points was included in item #1 of table 1(not table 2) of the Minsk report, which is the list of issues
considered but this issue was not finally included forrefinement as indicated in p.17 of the Scoping report and in thedraft TOC of that report.

NotedThis comment belongs to volume 2.
The methodology and default emission factors have alreadybeen included in the refinement guidelines. Activity data, which
are country‐specific and dependent on inventory year, should
not be pre‐assigned by the refinement.

Accepted withmodification

A definition of bioenergy has been added to the glossary.

Russian Federation
2943

5

6

1

3215 Fugitive CO2 emissions from coal mining have been reported for the firsttime in 2019 IPCC refinement report. These emissions constitute a
reasonable amount of GHG emission from coal mining activities. The
methodology, activity data and emission factors, although not very
definitive, should be retained in the refinement guidelines to provide
guidance to national inventory compilation.

65

67 Please clarify if the terms "biofuel" and "bioenergy" are interchangebale
and consider including the defintion of bioenergy in the glossary.

India3853 General

Glossary

Norway
895

3

3

1245

1245

In the Table 3.29, note2, the Box number might be wrong "See Box 4.26
for the definition of main product," : Box 4.26 ‐> Box 3.15, "by‐productand intermediate product and Box4.26" : Box 4.26 ‐> Box 3.16

897

3

3

1245

1245

Please explain which sector compilers should report when it is difficult toseparate Activity Data into 'main product' and 'by‐product'.

899

3

3

1431

1562

Typically, Tier b methodology uses more specific data with lessuncertainty than Tier a (eg, Ch 6. electronics industry). Thus, changing theorder (a ‐> b‐> c higher tier) would reduce confusion.

Accepted

Republic of Korea
Accepted

The response is made by adding a new bullet point to Box 3.16,
which is referred to in line 1245.

Accepted

The response includes amending a sentence to line 1435,
saying that: "There is no Tier method labelled 2a or 3a on thissection."Republic of Korea

Republic of Korea

Page 55

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CommentID Volume967
3

Chapter3

Fromline
Toline562
572

Comments
The sentence “for new operations located in developing countries that
operate without significant abatement, the emission factor is 0.04 kg HFC‐
23/kg HCFC‐22 produced” states that the emission factor is 0.04, but thatfor "Plants of recent design, not specifically optimised" in Table 3.28 is
0.03. So a check and revision is requested.

Country

Responses
Accepted

Authors' notes
We agree with the commenter that the draft emission factor
revisions need additional review and clarification. The draft
2019 Refinements document included review of an additional
2007 reference by A. McCulloch. In retrospect, following thecommenter's note, we recognise that the change in description
and characterisation of the 0.04 emission factor on lines 562 to
564 was not correct. We have deleted the draft text that
discussed "new operations located in developing countries."
The 0.04 emission factor is correctly characterised in Table 3.28
as "Old, unoptimised plants." In addition, the discussion of the0.019 emission factor, also from the McCulloch 2007 reference,
should appropriately refer to use of abatement. This sentence
has also been deleted, as it refers to use of abatement andshould not be included for a Tier 1 default emission factor.
We have confirmed that the characterisations of the emission
factors appropriately reflect their intended use.

China
1039

3

3

General and crosscutting with IPPU, also Waste: Some fuel transformation
processes use the same processes (gasification) and feedstock which are
addressed in the IPPU sector (hydrogen production). Some guidance how
to avoid double counting of emissions would be useful. Also reference
between the sector in places where double counting could be an issue
would be useful. The guidance should clarify the basic principles ofreporting emissions, energy use in Energy sector, non‐energy use in the
IPPU sector. This is especially important as sometimes it is not that clear
how and where the related emissions should be reported.

Noted

FinlandPage 56

The authors note that the basic principles of reporting ofemissions (e.g. Energy use in the Energy sector, NEU in IPPU) is
already well‐established within the 2006 GLs. Specific to theRefinement, the authors have made very significant efforts toensure that there is sufficient text to alert compilers to the riskof gaps and double‐counts, including within the new Energy‐
Fugitives chapter, several IPPU chapters (including:Introduction, Hydrogen, Iron and Steel). Within that text theauthors have noted specific issues, such as the ability to accessactivity data that are disaggregated to a sufficient level toenable reporting in accordance with good practice, and also toclarify where the use of specific methodologies may be limited,in light of the methods used in other parts of the inventory (e.g.
where the use of carbon balance methods in Iron and Steelproduction impacts upon the method options for fugitive
emissions from coke production, in the Energy sector). The
authors therefore consider that the guidance text will help tominimise the risk of reporting gaps and double‐counts.

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63b9088a

CommentID Volume
1041
3

3

Chapter

Fromline
Toline1158
1680

Comments
In earlier guidelines, there were no mention, that CO2 emissions from
biological feedstocks in IPPU sector have to be reported as a memo item.
This need to report the CO2 emissions from use of biomass as feedstocks
in the IPPU sector as a memo item does not appear to be included in theoriginal draft Table of Contents /Chapter Outline as attached to the Termsof Reference for the 2019 Refinement either. Please delete the guidance
to report the CO2 emissions from use of biomass as feedstocks in the
IPPU sector as a memo item.

1287

3

3

770

770

Process vents are typically configured for batch/intermittent orcontinuous measurement(s) of the concentration.

2647

3

3

1456

1474

CO2 emission estimation for H2 production and for ammonia production
should be similar because both production processes use steam methane
reforming. The carbon oxidation default factor for a Tier 1 Ammonia
production estimation is set to 1.0, and could be specified for Tier 2 or 3.
Suggest adding this factor and methodology to the H2 Production Tier 1
evaluation with the option to specify a different factor for Tier 2 or higher.

3151

3

3

1

9999

Chapter 1 (Introduction) of Volume 3 needs to be updated to reflect the
new source categories in the Refinement (e.g., Hydrogen Production, Rare
Earth Metals, Waterproofing of Electronic Circuits, etc.) This will affectboth the text and the tables.

Country

Responses
Rejected

Authors' notes
The ToR was established to generate emission estimation andreporting guidance for Hydrogen production,and one
component of this industry is the generation of biogenic CO2from certain technologies. The proposed approach to reportingof biogenic CO2 emissions from Hydrogen production isentirely consistent with the principles established elsewhere in
the IPCC GLs.

Accepted

We agree that processes and therefore process vents may bebatch or continuous, and the approach for concentration
measurements would need to reflect this. We have revised thesentence to reflect that, as the commenter suggested, process
vents may be batch or continuous in nature and therefore
intermittent or continuous measurements could be made.

Rejected

The estimation method provided in the Hydrogen chapter apply
only when the feedstock is completely oxidized. This isconsidered to be the case for all production processes yieldinghydrogen as the main product. The guidance in Ch. 3.2
Ammonia production specifically covers partial oxidation
reactions, and should not be used as a reference for theHydrogen chapter in this context.

Accepted

Chapter has been updated to include the new source
categories.

Rejected

This comment refers to a tier 3 method in which measurements
have to been undertaken and inventory compilers should havethem documented so they need information on thetechnologies employed (at least for internal documentation).

Finland

India

Canada

3153

3

3

221

221

United States ofAmerica"In addition," should read as "If available,".

United States ofAmerica

Page 57

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CommentID Volume3155
3

Chapter3

Fromline
Toline973
974

Comments
NF3 should probably be removed from the table of typically emitted
compounds (3.28b) because there is already a specific Tier 1 default EF for
production of NF3, and NF3 is not commonly generated as a by‐productduring production of other fluorochemicals.

3157

3

3

1169

1169

Insert item d. Ethylene production (Volume 3, section 3.9)

3159

3

3

1227

1227

change spelling of "oxidise" to "oxidize" for consistency w/rest of chapter

3161

3

3

1244

1245

Table 3.29, Footnote 2, last sentence, revise first instance of "Box 4.26" to"Box 3.15" and second instance of "Box 4.26" to "Box 3.16"

153

3

4

807

808

Country

United States ofAmerica
United States ofAmerica
United States ofAmerica

Authors' notes
We agree with the commenter that the majority of NF3emissions occur from the intended production of NF3, andoutside of intended production of NF3, NF3 emissions are
significantly less. We conducted additional analysis to review
the actual contribution of NF3 emissions from other non‐NF3
fluorochemical processes based on the available data in the
U.S. EPA GHGRP. For example, in RY2016, NF3 emissions
reported under the GHGRP were 219,000 mtCO2e,
approximately 218,000 mtCO2e (99 percent) of the emissions
were from the intended production of NF3, and approximately
1,150 mtCO2e (1 percent) were from other types offluorochemical processes (i.e., non‐NF3 processes). Over the six
years of reporting data, the NF3 emissions from intended
production is 92 percent, and the NF3 from otherfluorochemical processes is 8 percent. With the additional
review, we revised Table 3.28b to replace the NF3 component
with the next most commonly emitted fluorinated GHG.

Accepted withmodification
Accepted

Included in item c, as methods are the same as for methanol.
Line 1178 is amended accordingly.

Accepted
United States ofAmerica‐ The values for Scrap Iron and Steel in Table 4.3 make reference to Table
4 of the ISO 14404‐1 and ‐2 standards. However, Table 4 of thesestandards does not mention neither Scrap Iron, nor Steel. Table 4 only
suggests a value for Cold Iron i.e. 0.172 tCO2/t (0.047 tC/t) whichcorresponds to the value suggested for Purchased Pig Iron in Table 4.3.
‐ Material‐specific carbon contents have to be given for Scrap Iron andSteel, and also for Steel Scrap which are consistent with practice. We
suggest to use the value given in Annex C of standard EN 19694‐2 for post‐
consumer scrap i.e. 0,0066 tCO2/t (0.0018 tC/t) which is based on the
average of the carbon content of all the steel put on the market by EU
producers in the years 2007/2008. Hence, this 0.0018 tCO2/t value should
be used for both Steel Scrap and Steel (which should be renamed Carbon
Steel Scrap and Carbon Steel). It is much more consistent with the actual
values observed in practice than the 0.01 tC/t used for steel in the current
Table 4.3.

Accepted

FrancePage 58

Responses
Accepted

The text of FD has been changed accordingly as commenter
proposed: in the table 4.3 Steel will be replaced with Steel
Scrap and Steel.

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63b9088a

CommentID Volume
417
3

4

Chapter

Fromline
Toline274275

Comments
This statement is not correct: "The emission estimation methodology fromthe carbonisation of coal is presented here as there is a significant overlap
with the activity data used for iron and steel production" because at least
Tiers 1a and 1b calculates not only "carbonisation emissions" but also"combustion emission". This should be clearly explained to avoid double‐
counting

419

3

4

297

298

421

3

4

358

359

Table 4.1A. Note (1) ‐ is not correct, because methodology described inthis chapter (at least Tiers 1a and 1b) calculates not only "carbonisation
emissions" but also "combustion emission"
Table 4.1B. It is necessarily should be indicated that "if Tier 1a or Tier1b
method is applied, do not also calculate emissions from coke oven gas
combustion using methodology described in v.2 ch 2 to avoid double
counting".

423

3

4

358

358

425

3

4

515

516

427

3

4

520

521

429

3

4

590

594

431

3

4

590

626

433

3

4

614

614

435

3

4

622

622

Country

Responses
Accepted

Authors' notes
Text has been changed accordingly

Rejected

Table 4.1A. Indicates the place where the emissions estimateshas to be allocated, not where the methodology is described

Accepted withmodification

The comment 421 is correct, but not only for Tier 1a andTier1b, but for all the tiers. To address this issue, at the
begining of the item 4.2.2.1, we added: "In all cases, themethods encompass emissions from carbonisation and fuelcombustion"
Text has been changed accordingly in this Table, but also in the
Title of the Item 4.2.2.1

Russian Federation

Russian Federation

Russian Federation
Table 4.1B ‐ Title of the table "TIERS TO ESTIMATE CO2 EMISSIONS FROM
Accepted
METALLURGICAL COKE PRODUCTION – CARBONISATION PROCESS" is not
appropriate ‐ because at least Tier1a and Tier 1b include emissions not
only from "carbonization process" but also from coke oven gas
Russian Federation
combustion
Figure 4.8a: on the right arrow from diamond‐shaped cell at the bottom ofAccepted
decision tree (with inscription "Is this a key category?") to Tier1 box
Russian Federation
should be written "no" instead of "yes"Figure 4.8b: on the right arrow from diamond‐shaped cell at the bottom
Acceptedof decision tree (with inscription "Is this a key category?") to Tier1 box
Russian Federation
should be written "no" instead of "yes"Authors should check on the possible underestimation of CO2 emissions
Acceptedfrom iron and steel production in the equation 4.9. The amounts of steel
and pig iron scrap containing carbon are not included in equation 4.9.
Russian Federation
Carbon mass balance is not full.
Authors should check on the possible double counting of CO2 emissions
Acceptedfrom use of blast furnace gas in iron and steel production (eq. 4.9) and insinter production (eq. 4.10) or include comment to clarify this issue. If
sinter plant is included into an integrated iron and steel production facility
then blast furnace gas combustion has already been accounted for by theequation 4.9. Only blust furnace gas transferred off site (line 614) is
subtracted in the equation 4.9, so all emissions from blast furnace gas
combustion within an integrated iron and steel production facility has
accounted for by the equation 4.9.
Russian Federation
Blast furnace gas is BG in the equation 4.9 and it is BFG in the list of
Accepted
Russian Federation
parameters for this equation. Please, harmonize.
Blast furnace gas is BG in the equation 4.10 and it is BFG in the list of
Accepted
Russian Federation
parameters for this equation. Please, harmonize.

Page 59

Text has been changed accordingly

Text has been changed accordingly

Text has been changed accordingly

Text has been changed accordingly

Text has been changed accordingly
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63b9088a

CommentID Volume
437
3

4

Chapter

Fromline
Toline
628
632

439

3

4

721

721

441

3

4

2083

2084

443

3

4

2085

2086

445

3

4

2154

2158

447

3

4

2161

2166

Comments
Country
Responses
The CO2 emissions from the combustion of blast furnace gas andAccepted
converter gas for different needs within an integrated iron and steel
production facility have been accounted for automatically by the equation
4.9 because only blast furnace gas transferred off site is subtracted.
Applying of additional methodology described in Chapter 2 Volume 2 will
Russian Federation
result in double counting.
CH4 should be changed to N2O
Accepted
Russian Federation
To make more clear it may be reformulated as follows: "SBS = mass
Accepted withfraction of alumina produced by sintering process. The parameter can be
modification
varied from 0 to 1, where 1 is related to 100% of alumina produced bysintering process." Also, the default SBS value should be provided for Tier
Russian Federation
1 methodology.
Accepted with
There is a contradiction between statement "The parameter can be varied
modificationfrom 0 to 1, where 1 is related to 100% of alumina produced by sintering
process" and line 2098‐2099 indicating that "In case of alumina
production from the nepheline ore, 100% of alumina is produced with thesintering process". It may be reformulated as follows: "SNP = massfraction of alumina produced by sintering process. The parameter equals
1, because 100% of alumina in this process produced by sintering
Russian Federation
process."
Accepted
Equation 4.27h CO2 emissions from carbon‐bearing non‐fuel materials are
subtracted from the total CO2 emissions. It is contradictory to thestatement that this materials may contribute to the emissions (lines 2137‐
Russian Federation
2144).
It seems that it is better to use "bauxite/limestone raw mix" andRejected"nepheline/limestone raw mix" instead of "bauxite and nepheline ore".
Otherwise, it is not clear why bauxites and nephelines contain remarkableamounts of carbonates .

Authors' notes
This paragraph corresponds to Tier 1, and has been moved up.

Text has been changed accordingly
The text has been changed as follow "mass fraction of alumina
produced by sintering process (BSP and BSS). The parametercan be varied from 0 to 1, where 1 is related to 100% ofalumina produced by sintering process." Default Sbs added.
Text has been changed as per GOV reviewer comments, withminor clarifications added

Changes made to text ‐ agree "+" used instead of "‐", Corrected
another incorrect symbol in the equation.

Bauxite and Nepheline ores have carbonates and it is not
because of mix ore and limestone. Limestone separatelly
considered in as ELC. So to avoid confusion suggested do notconsider this comment.
Some clarifications have been made to the text on 'ores'

Russian Federation
449

3

4

2192

2194

It seems that it is better to use term "potential emissions" instead of"emissions" because emissons do not actually occur in the process.

451

3

4

2198

2208

Authors should check on the possible double counting of CO2 emissions
from soda ash use in alumina production (Equation 4.27h). In equation
4.27i only mass of soda ash produced for using out of plant is accountedfor (Line 2208), while in equation 4.27h the total amount of soda ash usedin the sintering process is accounted for (not only soda ash purchasedfrom other producers).

Accepted withmodification

Changes made to text as recommended + added notification: ",that is not emitted because some carbon absorbed by residue
and stored at bauxite or nepheline residue areas",

Rejected

Soda ash produced for using out of plant is used out of plant. If
it used at other alumina refinary it will be considered atparticular alumina refinary as an input material in equation
4.27h. So There is no possible double‐counting possibe.

Russian Federation

Russian Federation

Page 60

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CommentID Volume
453
3

4

Chapter

Fromline
Toline
2223
2232

455

3

4

2249

2250

457

3

4

2307

2314

893

3

4

375

375

901

3

4

430

431

903

3

4

614

622

969

3

4

369

380

1043

3

4

2669

2670

Comments
1. It seems that it is better to use "bauxite/limestone raw mix" and"nepheline/limestone raw mix" instead of "bauxite" and "nepheline". 2.
There is a contradiction between lines 2227‐2228 and line 2232. The
authors propose to calculate the weighted average content of CO2,
assuming 100% calcination of the carbonate, while in the equation 4.27k
there is a factor (Fj) taking into account that calcination is not 100%. 3.
The authors propose to calculate the weighted average content of CO2 forcarbonates consumed in the kiln. Soda ash is a carbonate too, but it isaccounted for separately in the equation 4.27h. It seems that it is betterto indicate clearly which carbonates are meant.

Country

Responses
Accepted withmodification

Russian Federation
It should be reformulated as "EFk = emission factor for kerogen or otherAcceptedcarbon‐bearing nonfuel raw material k, tonnes CO2/tonne carbon‐bearing
Russian Federation
nonfuel raw material".
Accepted
Needs language editing.
Russian Federation"CF4" should be changed into CH4
Accepted
Republic of Korea
In tier 2 methodology using mass balance, CH4 emissions are not
Rejectednecessary to be estimated since all carbon emissions are already counted
Republic of Korea
as CO2.
"BFG" need to be changed into "BG" followed by equations 4.9, 4.10
Accepted
Republic of Korea
Accepted
The units in Equation 4.1 and Equation 4.1A are not identical. According to
the formula, the unit on the left side is in kg, and the right side is in tones.
It is suggested that the unit of emissions be changed to tones in line 378.
China
Default Tier 1 emission factor for emissions from rare earth metals
Rejected
production in Table 4.26 is based on information only from 4 industrial
production lines. There is a risk that this emission factor is not
representative and applicable as a default emission factor for all processlines. Tier 3 method presented in the guidelines requires facility specificemission factors and the use of this method is not feasible if this emission
source is minor in certain countries. Proposition: move description ofthese two methods and emission factors to an appendix.

FinlandPage 61

Authors' notes

Changes made as recommended.

Changes made to text for clarity
Text has been changed accordingly
IPCC methodology has to cover the emissions of all GHGs,
including CH4.
Text has been changed accordingly
Text has been changed accordingly

While it is acknowledged that the default emission factor (EF)was based on anode carbon consumption data from 4
industrial potlines in China, these potlines are considered
representative of current technology in China (ref. Cai et al2018), and China currently represents >90% of global
production. This default EF is also consistent with what is
expected from first principles / mass balance calculation
approach with stoichiometric ratios of carbon consumed (andhence CO2 formed) vs. RE metal formed; this was described infootnote 1, page 4.83, and has now been moved to note ‘b’under Table 4.26 for clarity. The method of estimating CO2
emission factors from net anode carbon consumption isconsistent with CO2 accounting approach for aluminium
production. Further clarification has been made to note ‘a’ in
Table 4.26. While a level of uncertainty is expected inestimating CO2 emissions outside China (or for othertechnologies), it is not expected to be greater than theuncertainty levels indicated in Table 4.26. Therefore, we
believe the risk that the default EF is not representative to allprocess lines is manageable.

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63b9088a

CommentID Volume
1289
3

4

Chapter

Fromline
Toline
375
375

1291
1385

3
3

4
4

1930
765

1930
766

1735

3

4

872

872

Comments"CF4" should be "CH4"
EQUATION 4.1A (NEW):
CH4 EMISSIONS FROM COKE PRODUCTION (TIER 1A)
Replace "NO2" with "N2O"
The presented default CH4 EF for coke production is equal to thereference "Japan NIR 2018", but outside of the range of the otherreference "EU IPPC BREF 2013". The Japan NIR is not a sufficientreference, as the basis for the EF the original source is not referenced. The
authors have neither provided any reasoning for choosing a value outsideof the BREF ranges.

Country

India
India

Responses
Accepted

Authors' notes
Text has been changed accordingly

Accepted
Rejected

Changes made to text as recommended
The availability of this data is scarce, but surely the variability ishigh. The data from EU corresponds to measurements made ina single plant, while the data from Japan is the average value of
measurements made in some plants of the country, but wehave not the corresponding range. For the default EF we
consider that: (1) the data reported by both are highly
consistent (same order of magnitude) and (2) The values fromJapan surely includes higher values, as 0.089 is the average. In
this context we chosen the higher value found in literature.

Accepted withmodification

A new paragraph has been added: " To avoid double counting
and to ensure completeness it is a Good Practice to cross‐checked the proper allocation of the emissions between the
Energy and IPPU sectors, and to document where and how they
are reported in the inventory"

SwedenAs stated in paragraph 849 – 850, we also recognize that it is difficult to
calculate CO2 emissions for the Energy Sector and the Industrial Processes
Sector separately without any ambiguities because of complex iron andsteel production processes. The most prioritized point for the estimationof emissions from this category is to calculate all GHG emissions from ironand steel production completely and accurately and to report themwithout any double counting and omission of emissions, even if national
circumstances of a reporting country such as data availability make it
difficult to allocate emissions from iron and steel production into theEnergy and IPPU sector in strict accordance with the concept provided in
the IPCC guidelines. There is also a description that “it is good practice tocheck the completeness of all fuels and sources discussed here and to
document where and how they are reported in the inventory” in Vol.3.1.4
QC OF COMPLETENESS AND ALLOCATION OF CO2 FROM NON‐ENERGYUSES of the 2006 IPCC guidelines. Therefore, we suggest that thefollowing sentence be added at the end of the "RELATIONSHIP TO THE
ENERGY SECTOR" section of "4.2.2.5 COMPLETENESS" in order to request
a country which does not report emissions from iron and steel productionin accordance with the allocation rule provided in the IPCC guidelines toprovide clear explanation on which emissions are reported under which
category of the Energy or IPPU sector to make sure that there is neither
double counting nor omission of emissions in the inventory.
"Due to national circumstances of a reporting country such as data
availability related to the difficulty of allocation of emissions resulting
from complexities of iron and steel production, the emissions from ironand steel production are not allocated between the Energy and IPPU
sector in accordance with the IPCC guidelines In such a case, a clear
l
h
h
ll
db
h

Page 62Japan

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CommentID Volume
1961
3

4

Chapter

Fromline
Toline
207
252

1963

3

4

256

454

3163

3

4

1

1000

3165

3

4

260

260

3167

3

4

335

336

3169

3

4

358

359

3171

3

4

460

460

Comments
Country
Responses
Whilst this section may be greyed out and considered "out of mandate"
Accepted
for any revisions, nevertheless it requires a small change to reflect thatthe new Energy‐Fugitives chapter now presents the emission sources andmethods for fugitive releases from transformation process, including cokeproduction. It doesn't make sense that this greyed out section includes
reference (lines 241 to 247) to the reporting of emissions from fuel use incoke production in the Energy Volume, but doesn't also mention themethods and reporting of fugitive emissions in the Energy Volume too.
United Kingdom (ofPlease make it clear to compilers and amend those cross‐references.
Great Britain andNorthern Ireland)
Accepted withThis entire section needs to be reviewed (and much of it removed) in light
modificationof the decision to now include fugitive emissions from coke production
under the new Energy Volume chapter. The IPCC approach is that cokeproduction is an energy transformation process. Combustion is reported
in Energy; fugitives are now to be reported in energy. Therefore, all of therelevant information ‐ the description of the coke production
technologies, the combustion and fugitive emission sources ‐ should only
be included in the energy volume of the inventory guidance ‐ duplicationof inventory guidance across Energy and IPPU will cause confusion forcompilers. Guidance should be in one place only for a given emission
source. There is still a need to retain some residual information in IPPU
and to cross‐reference properly, especially where methodological choices/ decisions are inter‐twined (e.g. some methods in Energy‐fugitives will
have to be discounted if a carbon balance approach is used in I&S
including the coke works in IPPU).. but the vast majority of this section
should be deleted, and the Energy‐Fugitives chapter clearly cross‐
United Kingdom (ofreferenced.
Great Britain andNorthern Ireland)
Accepted
If necessary, update the guidance on IPPU/Energy relationships in Chapter
United States of
1 (Introduction) of Volume 3 to reflect the updated or new guidance inAmericathe Iron and Steel and Hydrogen sections.
Recommend inserting "emissions" after "GHGs" and deleting the "s" from United States of Accepted
America"GHGs."The variability of processes and their GHG emissions should be considered
Accepted
while determining the appropriate frequency and duration of testing toestablish site‐specific emission factors. With this in mind, recommend
adding "the variability of the process and its GHG emissions," after
United States of"information on the frequency and duration of the measurements."
America
United States of Noted
Table 4.1B is very helpful.
America
Accepted
The meaning of "to generate the reported production outputs" is notclear. Does this refer to the iron and steel produced or the emissions
estimates reported? If it refers to the iron and steel produced,
United States ofrecommend either deleting or revising to "to produce the sinter, iron,
America
and/or steel."

Page 63

Authors' notes
The authors agree with the reviewer about the need to modify
this paragraph in grey.

The comment is right, in the sense that the methodologies toestimate and report GHG emissions from combustion andfugitives are included in the Energy chapter, but is incomplete
because combustion and fugitives do not comprise non‐fugitive
carbonization emissions that occurs in coke oven batteries.
To clarify this issue the consistency between combustion andfugitives (described in Energy reported under Energy) and non‐fugitives from carbonization (described in IPPU, reported under
Energy), has been improved with modifications in the text

Chapter 1 has been updated to reflect the updated and new
guidance in the iron and steel and hydrogen sections.
Text has been changed accordingly
Text has been changed accordingly

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63b9088a

CommentID Volume
3173
3

4

Fromline
Toline
463
464

3175

4

465

3177

3179

3181

3183

3185

3187

3

3

3

3

3

3

3

Chapter

4

4

4

4

4

4

560

575

597

768

772

780

468

563

576

614

786

777

781

3189

3

4

799

799

3191

3

4

846

846

Comments
For completeness and consistency, a brief description of the Tier 2
method for Iron and Steel Production would be helpful here.
The variability of processes and their GHG emissions should be consideredwhile determining the appropriate frequency and duration of testing toestablish site‐specific emission factors. With this in mind, recommend
adding "the variability of the process and its GHG emissions," after"information on the frequency and duration of the measurements."
Equation 4.8a: Recommend including "BFG and LDG" between "From" and"Flaring" in the equation title, to clarify that emissions from flaring of COG
are not included in IPPU.
Equation 4.8a includes formulas to calculate EFCO2BFG flaring andEFCO2LDG flaring, but does not include the results of those calculations(i.e., numerical values for the EFs) based on default carbon‐content
values. Instead, those numerical values are presented under Equation
4.14b, at ll. 780‐781. Unless inventory compilers are expected to apply theformulas in Equation 4.8a based on country‐specific carbon‐content
values, recommend replacing the EFCO2 formulas in Equation 4.8a withthe calculated numerical values from ll 780‐681, documenting theirderivation in a footnote.
The variable name for blast furnace gas changes between "BG" and "BFG"
in this equation and its definitions and throughout the document. One
name should be used consistently; recommend "BFG" as more intuitiveand consistent with use of "COG" for coke oven gas.
Recommend presenting Table 4.2b at the top of this section, unlessinventory compilers are expected to apply Equation 4.14b based on
country‐specific values for EFCO2BFG flaring, EFCO2LDG flaring, and/or
the ratios of the EFs for CO2 and N2O for oil and gas, which does notappear to be the case. Moving up Table 4.2b will clarify to the compiler
that they are not expected to perform the calculation in Equation 4.14b.
Instead of showing equation 4.14b in the main text, it can be moved into afootnote or supporting documentation.
In both of the equations titled "Equation 4.14B (NEW)," the forumla does
not appear to result in the correct estimate/units. It appears that theterms (EFCO2/EFN2O) in both equations should be inverted to(EFN2O/EFCO2) to yield emission factors for N2O.
These CO2 EF definitions incorrectly reference equation 4.14a, which isfor N2O emissions. They should reference equation 4.8a, which includes
terms for these CO2 EFs.
Recommend replacing "indicative" with "representative" for clarity.
Recommend replacing "among each other" with "to each other" forclarity.

Page 64

Country
United States ofAmerica

Responses
Accepted

Authors' notes
Text has been changed accordingly

Accepted

Text has been changed accordingly

Accepted

Text has been changed accordingly

Rejected

Eq 4.8.a is for CO2 emissions from flaring, while eq 4.14 b is forN2O emissions from flaring.

Accepted

Text has been changed accordingly

Accepted

Text has been changed accordingly, and also including theconsistency with Table 4.3.7 of the Volume 4 of Energy Chapter(Fugitive emissions). An error in the CO2 EF for LDG has been
identified and corrected.

Accepted

The formula has been changed

Accepted

Text has been changed accordingly

Accepted

Text has been changed accordingly

Accepted

Text has been changed accordingly

United States ofAmerica
United States ofAmerica

United States ofAmerica

United States ofAmerica

United States ofAmerica

United States ofAmerica
United States ofAmerica
United States ofAmerica
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63b9088a

CommentID Volume
3193
3

3195

3197

3

3

Chapter444Fromline
Toline
857
857

866

874

867

876

Comments
Recommend deleting "with the following peculiarities," which is an odd
phrasing, from the end of the sentence. Instead, include a new sentence,"Note in particular:"Sentence is jumbled. Recommend deleting "then if the gas is delivered to"and moving closing parenthesis from after the word "example" to after
the word "producer," and following the parenthesis with a comma.

Country

Responses
Accepted

Authors' notes
Text has been changed accordingly

Accepted

Text has been changed accordingly

Accepted

Fig. 4.8 has been improved‐ To include in a separate sheet, theItem RELATION TO OTHER METHODOLOGICAL APPROACHES
has been moved up.

Accepted withmodification

The paragraph has been deleted

Accepted

Changes made to text as recommended ‐ merged twoparagraphs and removed redundant information

United States ofAmerica

United States ofAmericaFigure 4.8d is potentially quite useful but needs to be clarified further. It isdifficult to follow the flow of emissions through the process and whether
they are under IPPU or Energy. For example, it is difficult to see the flowof metallurgical coke into the steelwork boundary and how it connects toEnergy.The three arrows extending straight down from the COG, BFG, and
BOG pipes in the middle of the figure do not connect to anything, so their
meaning is unclear. Are they supposed to touch the IPPU "Electricity
and/or heat production" box to their left? What is the significance of thedotted green line around the blue boxes titled "blast furnace" and "steel
making?" Should this line be extended around the "Sinter plant" and IPPU"Electricity and/or heat production" boxes as well, since their emissions
are also supposed to be reported under IPPU? In addition to clarifying
these points, recommend expanding Figure 4.8d to take up an entire
page, similar to Figure 4.1 between lines 249 and 252 (page 4.10), which
would allow more space to see the flow of emissions to be allocated.
United States ofAmerica

3199

3201

3

3

4

4

899

1092

902

1104

Currently, this sentence could be interpreted as an IPCC opinion regardingwhether the ISO 14404 method can be used for emissions trading
schemes, which the IPCC should not be judging. Suggest revising to read
"Although the World Steel Association [or other relevant organization]
does not recommend using these calculations to determine thebenchmark for free allocation under emissions trading schemes (because
different regions have different energy sources and raw materials
available), the calculations can be used to compare the performance ofsteel plants globally and to help plant staff determine their own positionin energy and CO2 efficiency."
This paragraph focuses on methodological choice and therefore would bebetter placed under "Choice of Method" and merged with the paragraphthat appears at lines 1154‐1162. (It is currently somewhat redundant withthat paragraph.) Because this section is long and relatively complex, it isparticularly important to focus and streamline it by systematicallyproviding information first on industry background and then on
methodological choice.

Page 65

United States ofAmerica

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CommentID Volume3203
3

Chapter
4

Fromline
Toline1117
1150

Comments
These paragraphs focus on sources and mechanisms for emissions rather
than methdological choice. They would therefore be better placed under"Introduction to Primary Aluminum." (A partial exception is the transition
paragraph at lines 1146‐50, some part of which could be repeated in boththe "Introduction" and "Choice of Method" sections.) Because this section
is long and relatively complex, it is particularly important to focus andstreamline it by systematically providing information first on industry
background and then on methodological choice.

Country

Responses
Rejected

Authors' notes
While acknowledged this would improve clarity, the changes
recommended have not been made since doing so would also
require moving background on CO2 emisisons (currently insections 4.4.2.1, which are outside the scope of 2019
Refinments) to the Introduction also. Therefore, we have kept
the background information on PFCs in this section as previous

Accepted withmodification

Changes made to text as recommended, with adjustments,
since industry background material was not moved to theIntroduction

Accepted

Changes made to text as recommended

Accepted

Changes made to text as recommended

Accepted

Changes made to text as recommended

Accepted

Changes made to text as recommended

Accepted

Changes made to text as recommended

Accepted

Added a new decision tree for LVAE emissions. Existing HVAE
decision tree has been updated with labels for "HVAE" and withsome diamonds updated for consistency with LVAE decision
tree.

United States ofAmerica
3205

3207

3209

3211

3213

3215

3217

3

3

3

3

3

3

3

4

4

4

4

4

4

4

1151

1154

1157

1173

1175

1221

1224

1153

1155

1157

1173

1175

1222

1233

Recommend starting the "Choice of Method" section with this paragraphand adding the following sentence to the beginning of the paragraph toprovide an overview: "This section includes guidance for estimating
emissions from HVAE and LVAE using a range of methods."
This sentence provides a helpful summary of the Tier 2 and 3 methods,
but it should include a similar summary of the Tier 1 method. Recommend
inserting "the Tier 1 method is based on aluminum production, while"
between "For HVAE emissions, and "the Tier 2" on line 1154.
"generally" or a similar qualifier should be inserted before "good practice"in recognition of the exception to this statement described in thefollowing sentence.
This sentence provides a helpful summary of one Tier 3 method for LVAE,
but for completeness and consistency, it should be preceded by a similarsummary of the Tier 1 method for LVAE. Recommend adding thefollowing to the beginning of the paragraph: "For LVAE emissions, a Tier 1
method and two Tier 3 methods are provided. The Tier 1 method
calculates PFC emissions by multiplying technology‐specific default
emission factors by aluminum production. The first Tier 3 method
calculates PFCs by multiplying a facility‐specific factor. . . [continue withcurrent text on ll. 1173‐74]."
Recommend changing "The alternative is to use" to "The second Tier 3
method for LVAE uses." "The alternative" implies that there is only one
alternative to the first Tier 3 method, when the Tier 1 method is anotheralternative.
Insert "neither to omit nor" between "Care should be taken" and "todouble count." Delete the "not." Avoiding omissions is at least as
important as avoiding double‐counting.
Figure 4.12 (Decision Tree) works reasonably well for HVAE emissions but
does not appear to address LVAE emissions at all. Recommend either
integrating LVAE emissions into Figure 4.12 or creating a separate decision
tree for LVAE emissions.

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Comments
Figure 4.12 (Decision Tree) clearly indicates that the Tier 1 method should
be used to estimate HVAE emissions from smelters without automatic
HVAE termination strategies. This is very useful to the user. The figure
would be even more helpful if it included detail on which technologies canuse the Tier 2b method.
The decision tree refers to calculating PFC emissions using the various
tiers but it is really focused on calculating PFC emissions from HVAEs.
Authors should consider revising tree to refer to HVAE emissions
calculations (not total as stated in title). There is no guidance in the tree
about the method for LVAEs. Or the authors could provide a modified
decision tree. If keeping decision tree as‐is, it would be useful to provide
guidance about whether it is acceptable e.g. to combine a Tier 3 HVAE
method with Tier 1 LVAE estiamtes if facility specific LVAE measurements
are not available earlier than the time‐series consistancy section (where it
does talk about it)

Country

Responses
Rejected

Authors' notes
To avoid overcrowding the decision tree with information. It
was decided to limit the decision box to main Tiers. The
numerous details regarding the requirements and limitations
for sub‐tiers are well described in the text of the chapters, andin the updated Table 4.14a.

Accepted

Added a new decision tree for LVAE emissions. Renamed
caption in Decision Tree Fig 4.12 to refer to "HVAE related"emissions only, raher than 'total' emissions previously. In the
HVAE decision tree (Fig 4.12), question in diamond "Is there an
automatic HVAE termination strategy?" replaced with "Is thetechnology class PFPB_MW", to be consistent with theequivalent quesion diamond in the new LVAE decision tree (Fig
4.12a).

Accepted

Table 4.14a has been updated, taking suggestion (1), i.e.
replacing the final 2 columns in the original table (which did notcontain much extra useful information) with 1 column
summarising which methods are applicable to which
technologies. Footnotes have been updated accordingly

Accepted

Table 4.14a has been updated, taking suggestion (1), i.e.
replacing the final 2 columns in the original table (which did notcontain much extra useful information) with 1 column
summarising which methods are applicable to which
technologies. Footnotes have been updated accordingly

United States ofAmerica

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Table 4.14a is very helpful. It would be even more helpful if it included asummary of the smelting technologies to which each method isapplicable. Such a column would fit before or after the final two columns,
which relate to each method's applicability to normal operations and start‐
up. If this would make the table too wide, other options include: (1)replacing one or both of the final two columns with the column including
the smelting technologies to which the method is applicable, or (2)creating a second table that focuses on the applicability of each method
and that includes the first three columns (repeating them from the firsttable), the final two columns (moving them from the first table) and a newcolumn with the smelting technologies to which the method is applicable.
Option (1) may be simplest and least disruptive. The fact that all but oneof the cells in the current final two columns say "Yes" indicates that thesecolumns are not conveying much information. Although information on
the applicability of each method to each technology appears in thefootnotes to the table, it is considerably more difficult to extract the
information from the footnotes than it would be to extract the
information from a table.
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Consider removing the "Applicable for" columns. With almost all values
listed as "Yes", the columns do not really enhance the table but instead
make it more confusing, especially as all of the methods can be used toestimate start‐up emissions, but sometimes it's already included,
sometime it's not, sometimes you use different slope coefficient, etc.
Althernatively, if the authors keep the columns, consider being more
descriptive than "yes", "Included in HVAE default", "Start‐up speciificcoefficients required"

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Comments
Footnote "i" of Table 4.14a mentions emission factors in connection with
the Tier 3dm approach, but the Tier 3dm approach does not include thedevelopment of emission factors. Instead, it appears to requiremeasurement of all emissions at all times during the year, either throughthe time‐integrated or continuous measurements. Therefore recommend
replacing "emission factors" with "emissions measurements" in footnote"i" of Table 4.14a .
First sentence is unclear. Is "have" meant to be "HVAE"? This section also
lacks an introduction to what the section is about. Suggest replacing
beginning with "The Tier 2a and Tier 3a methods estimate HVAE CF4emissions based on the relationship between anode effect emissions andperformance. In both methods, the slope coefficient in Equation 4.26 isbased on direct measurements of PFCs."

Country

Responses
Accepted

Authors' notes
Wording "emission factors" has been replaced by "emissions
measurements" in Table 4.14a, footnote 'h' (updated footnote
numbering).

Accepted withmodification

Changes made to text as recommended except second
sentence on direct measurements as Tier 2a is not based on
direct measurements.

Rejected

In order to correctly recommend a method for different
scenarios, additionnal data would have been required. The
purpose was to present the available newer and more accurate
methodologies along with their limitations and an overview of
their uncertainty range. The final choice of a method is up to
inventory compilers based on the availability of the data, thedistribution of the data and the limitations of the different
methods.

Accepted

Re‐edited the table for clarity

Accepted withmodification

Added a sentence at the end of the box to specify that it isapplicable to all methods.

Accepted

Edited accordingly

Accepted

Edited accordingly

Accepted

Edited accordingly

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Authors may want to consider summarizing the method options in a tableby technology class. E.g. If using SWPB and have AEDs greater than 150s,
which method(s) are recommended?

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1355

1487

Shouldn't the division be PFPB(L) and SWPB are recommended to use
Marks and Nunez and PFPB(M) use the Dion approach? Table 4.16B (line1603), which has the uncertainties for the Tier 2b methods, groups SWPB
and PFPB(L) together. If you are basing the suggestion on the relative
uncertainties, the recommendation for PFPB(L) and SWPB should be thesame.
The final sentence of Box 4.3 states that "This detection threshold isspecific to each facility (based on historical data) and should be used for
calculating HAVE performance at the facility when estimating cell start‐up
emissions." This sentence needs to be clarified. Is it applicable to each of
the three methods described in ll. 1493‐1507? If not, to which of thesemethods is it applicable?

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"as it is based" should be replaced by "as they are based"

3239

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To clarify that this is the first of the three options discussed in thepreceding three sentences, replace "First" with "The first option is to"

3241

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1504

To clarify that LVAE emissions must always be included in CSU emissions
estimates, add the following sentences to the end of the paragraph:"Again, LVAE emissions during start up can be estimated using Tier 1 orTier 3."

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Comments
Recommend adding a sentence to emphasize that both measurement
approaches provide continuous coverage of total emissions, e.g., "Bothapproaches provide continuous coverage of total emissions."

Lines 1601‐1603 mention only PFPB(m) and PFPB(L) but the table also lists
SWPB.
It's consfusing to have lines 1350‐1355 say that Marks & Nunez is notappplicable to SWPB (by omission) but have an uncertainty in Table 4.16
(due to the grouping of SWPB and PFPBm). If the uncertainty in Table
4.16 is accurate for SWPB for Marks & Nunez, it would be helpful if theauthors note why the Marks & Nunez method is not applicable for SWPB.
Recommend adding a summary sentence to the beginning of the"Completeness" section that is similar to the summary sentences in otherchapters: "Completeness for the aluminium production source category
requires reporting of emissions of all GHGs (CO2, CF4, and C2F6) from all
sources (see Table 4.14) for all aluminium production in all smelters in acountry."
Recommend inserting "(imprecision)" after "higher level of uncertainty" toreflect the fact that including the LVAE emissions will make estimates
more accurate (i.e., no longer biased low due to omission of someemissions) even if they are also less precise.

Page 69

Country

United States ofAmerica
United States ofAmerica

Responses
Accepted withmodification

Authors' notes
Adjusted previous sentence (removed "common" since both
direct measurement methods are not being used routinely atpresent by the industry) and added sentence similar to what
was recommended: "While neither are routinely carried out by
the industry at present, both have the potential to provide
continuous coverage of total emissions." There should beflexibility in the IPCC GLs to allow for the possibility of non‐continuous coverage. For example, one approach used forother atmopsheric pollutants from the industry (e.g. fluoride
emissions) is by direct measurement, on a representative but
non‐continuous sampling frequency, depending on regulatory
requirements. The question of whether continuous coverage or
not is should be a conversation between governments/
regulators and the industry, and should not be specified here.
Line 1558‐1560 already recommend continuous coverage fortime‐integrated measurements as 'good practice'.

Accepted

Re‐edited the table for clarity

Accepted withmodification

Re‐edited the table for clarity

Accepted

Changes made to the text as recommended

Accepted

Changes made to the text as recommended

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Comments
The recommendation to wait until 2020 to begin applying the 2019
Refinement for HVAE emissions is not appropriate, given that thetechnological changes described in Introduction were occurring in the late
2000s (i.e., starting before 2010), and that the measurements supportingthe 2019 Refinement default EFs and other factors must have occurred
before July 2018 to have been included in the Refinement. Under therecommended approach, countries that have produced aluminum using
the PFPBM and PFPBMW technologies since the early 2010s would nothave appropriate technology‐specific EFs to apply for the years before
2020. One potential solution to this problem would be to requireapplication of technology‐specific EFs to each technology regardless ofwhen that technology was used, as is done in Chapter 6 (Electronics) for
the 200‐mm and 300‐mm wafer sizes. If this approach would not work
for all smelting technologies (e.g., because changes were occurring within
the technologies as well as across them), another approach would be torecommend use of the Refinement beginning with an earlier year, e.g.,2010 or 2015 (at the latest), for some or all of the technologies.

Country

Responses
Accepted withmodification

Authors' notes
Lead Authors have adjusted guidance. The transition moment is
no longer uniform for all technologies. Instead, the refinements
refers to the time‐span over which measurement data (onwhich default Tier 1 EFs and Tier 2a default slope coefficientsare based) was collected for each technologyand recommends
the Median Year of measurements as the moment to change ortransition the EFs from the 2006 GL values to the 2019
Refinement values. This can be through interpolation /backcasting of Tier 1 default EFs or Tier 2a default slope
coefficients from 2006 to the Median Year. The exception is
PFPB_MW technologies, where the 2019 Refinement default
Tier 1 EFs would apply across the entire time span, as it isconsidered more accurate than reverting to CWPB emission
factor values from 2006 GLs. For PFPB_M and PFPB_L
tecnhnologies, compilers can backcast back to CWPB values.

Rejected

Authors have decided to reject the comments about“backcasting” LVAE prior to 2006 because we are convincedthat these emissions are the results of new and recent
dynamics in the electrolysis cells. Firstly, there is no literature
to support the “existence” of this type of emissions prior to2006 and all the measurement data indicate that the level of
PFC remained within the noise of the HVAE PFC emissions.
Secondly, any small contribution of LVAE emissions would havebeen insignificant in comparison to HVAE emissions, due to thevery high HVAE frequencies pre‐2006. Finally, top‐down andbottom‐up measurement were in good agreement prior to
2006, in agreement with the statement that LVAE were
negligible or non‐existent during this period of time.
Nonetheless, there was some important changes to the text inorder to include these justifications and explain why the periodprior to 2006 should be neglected from considering LVAE
emissions.

Accepted

Changes made to the text as recommended

Accepted

Changes made to the text as recommended

Accepted

Changes made to the text as recommended

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The guidance not to report LVAE emissions before 2006 is not well
supported. The footnote includes the observation that the factors thatmake LVAE emissions more prevalent "in today's current smelting
technologies" were absent in earlier technologies, but that technologicaldifference is already accounted for in the differentiation between theModern PFPB technology and the other technologies. Indeed, Table 4.15
includes much lower default EFs for Legacy PFPB, SWPB, VSS, and HSS
than for Modern PFPB. Thus, unless it is definitely the case that currently
used Legacy PFPB, SWPB, VSS, and HSS all have higher anode current
densities, lower anode‐cathode distances, and/or larger anode
dimensions than the versions of these technologies that were used before
2006, the guidance should recommend accounting for LVAE emissions
using technology‐specific EFs back to 1990. If there have been changes
WITHIN each of the technologies, that fact should be clarified in theguidance (e.g., the footnote).

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For clarity and consistency with the following bullet points, recommend
substituting "involves" for "consists of" at the end of this sentence.
Recommend splitting this bullet into one that simply says "Hightemperatures (1050‐1100 C)" and one that begins, "Depending on thetechnology, the process may be periodically interrupted or disturbed. . ."Recommend adding "to increase production efficiency" before "to reduce
perfluorocarbon GHG emissions"Page 70

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Comments"it is assumed that industrial rare earth facilities currently do not
manufacture or pre‐bake their own graphite anodes." Is this assumption
based on the fact that such pre‐baking has not been observed at rareearth facilities whose emissions have been measured? If so, please clarify
this.

In the last box on the left in Figure 4.17, recommend replacing "processdata" with more precise "anode data"
Recommend replacing "uses a lower order estimate based only on" with"multiplies a default emission factor by." The method generates anestimate rather than using it, and "lower order" estimate could beinterpreted to mean underestimate.
Recommend including guidance for situations where anode composition isdifferent for different REs, such as "where the anode composition differs,
replace Impa with Impi, the impurity content of the anodes used to
produce each type of RE."
It is unclear why RE‐iron is assigned a unique emission factor. Authors
should consider adding a note on how it was determined that RE‐ironalloys should have a unique EF from other REs, e.g. is there a scientificreason for a different EF or is the separation just based on measurement
differences? If the latter, consider whether there is enough data to
support a unique EF.

Country

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United States ofAmerica

Authors' notes
The following sentence is added: "For example, it is assumed
that industrial rare earth facilities currently do not manufactureor ‘pre‐bake’ their own carbon anodes, but rather theypurchase graphite anodes. This is the case in the Chinese rareearth metal industry in 2018 (expert opinion), given the much
lower process volumes and smaller anode sizes compared tothe primary aluminium industry". This is based on observationthat no rare earth facilities in China manufacture or bake theirown carbon anodes, rather they purchase graphite anodes
from third party providers. This is based on expert opinion from
IPCC Contributing Authors: Prof. Youming Yang who is anindustry expert in Chinese Rare Earth Metal production and Dr
Xiping Chen, who was one of the senior Chinese researchers
who has worked with the local rare earth industry andmeasured PFCs in the two reported industrial campaigns.

Accepted

Changes made to ext in Figure 4.17 box as identified

Accepted withmodification

Changes made to text, with some slight adjustments. "The Tier
1 method for calculating CO2 emissions is through multiplying adefault emission factor by rare earth metal production. "Accepted

Changes made to the text as recommended

Accepted withmodification

An explanation as to why RE‐Fe (e.g. Dy‐Fe) alloys are expected
to have greater PFC generation ‐ and therefore justify having
separate emission factors (EFs) ‐ was provided in footnote 1 ofpage 4.85; this footnote 1 has been further updated to provide
extra clarity of the following. Due to the high melting point ofthese elements, they require alloying with Fe to produce aliquid metal product, which requires high temperature and highcell voltage ‐ since PFC generation occurs at higher
electrochemical potentials, these two conditions theoreticallyincrease the risk of PFC emissions for production of RE‐Fe alloys
vs. other RE metals. This theory is supported by industrial
measurements in Cai et al. 2018 and Zhang et al. 2018.
Furthermore, the following sentence has been added after Line
2782, "RE‐Fe alloys were reported to have greater PFC
emissions than other RE metals (Cai et al. 2018; Zhang et al.
2018), consistent with the greater risk of PFC generation
expected with the higher temperature and cell voltage
operation required. "United States ofAmerica

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The EF(CF4) for Re‐iron alloys is shown as 146.1 g/t. However, for thetwo papers cited, the value reported were 106 and 109.4. Is there acitation missing or an error? Also, the EF (CF4) is shown as 35.8 but the
average of the 4 values cited (26.9, 26.66, 36.16 and 33.96) is 30.9. If amethod other than a straight average of the measured EFs was used, theauthors should specify it.

Country

Responses
Accepted

Authors' notes
Footnotes a in Table 4.28 have been updated, noting that the(Zhang et al 2018) value of 106 g‐CF4/t‐metal for Dy‐Fe
production was divided by 57.97% gas collection efficiency (%process gases sampled vs. lost, from Cai et al. 2018 study). Thisis a straight average. Similarly Footnotes b in Table 4.28 havebeen elaborated, noting that the 26.9 g‐CF4/t‐metal for Nd
metal (Zhang et al. 2018) was correctetd by dividing by thesame 57.97% gas collection effiency from Cai et al. 2018
study.This was a straight average.

Accepted

Footnote a in Table 4.28 has been updated, clarifying that thisis 2 industrial measurements from the same facility for thedefault EF for Dy‐Fe production.

Rejected

IPCC Guidance on GHG Inventories is intended to focus onnational GHG emissions, not other types of emissions or
impacts (in‐door or toxic concentrations).
Adding Tier 2a values for gamma. We will note that it is goodpractice to account for abatement but it is acceptable to report
unabated emissions.

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Footnote a: Are the two industrial measurements from a single plant? Or
two different plants? Both cited papers characterize the data as from asingle cell from Qiangdong. Consider revising footnote to specify numberof locations and not just number of measurements.
The GL needs to give more concentration on the ghg emissions fromelectronic industries because of its high dangerous toxicity
compared to other anthropogenic emissions.
Emission estimation methods for semiconductor, LCD and photovoltaics
manufacturing given in the guidelines are complex and not always
straightforward for Tiers 2 and 3. It is for example indicated that inmethod 2a it is not necessary to know substrate sizes (e.g. lines 141‐142,
680‐684). However in order to calculate eq. 6.10 with the default values inTable 6.4, the wafer sizes have to be known. The guidelines for Tier 2ashould clearly point out that it is also good practice to calculate emissions
without taken into account the emission control systems if those are notin place or would require too heavy reporting burden for facilities (e.g. eq.
6.12 requires too detailed (min/year) information on operating times).

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Please replace phrase "good practice" with word “advisable” in thissentence. This requirement is too strict for example for small research
institutes in which production capacity is low and new gases or process
types are just tested. It is not feasible to collect data on Tier 3 level fromthese facilities supposing that the data is even available if the emissions
from this source are insignificant compared to country's total GHG
emissions. Also please check other parts of this chapter referring to this"accounts for (less than) 1%".

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1173

The statement that county‐specific default emission factors are lessdesired is confusing. Country‐specific emission factors can be used if theiruse is justified. On the other hand, default emission factors given in
guidelines should not only be country‐specific. Please edit sentences.

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757

757

The units for "EABi,CF4" and "Ci" are not given (may be prescribed in"kg"). They should be provided.
The units for "EABi,CF4" and "Ci" are not given (may be prescribed in"kg"). They should be provided.

United States ofAmerica

Egypt
Accepted

FinlandAccepted withmodification

The term "good practice" was maintained; however, authors
agree that an additional threshold is needed and have modified
text

Accepted

Language revised.

Accepted

Added units (kg)

Accepted

Added units (kg)FinlandFinland

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994

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Comments
Usage of parameter "k" not reflected in Equation 6.15 in line no. 994.

3277

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1

The electronics and RAC chapters include several fluorinated compounds
that are not currently addressed in Chapter 1 (Introduction) of Volume 3.
Chapter 1 should be updated to remain consistent with Chapters 6 and 8
and especially with Volume 1, Chapter 8, section 8.2.2 ("Gases Included"),ll. 108‐145, and with the updated Reporting Tables.

Country

Responses
Accepted

Deleted k

Authors' notes

Accepted

Chapter 1 has been updated to include additional GHGs.

Accepted

Chapter was clarified and streamlined.

Accepted

This list was edited and moved to the mapping tables.

Accepted

Clarified in list; entire list was moved to the mapping tables

Accepted

Additional detail was added to the list under "Tier 1 method".

Accepted

Subheadings were added as suggested

Accepted

Added substrate surface cleaning for MEMs to list offluorinated liquid uses.
Added "before 2010" and clarification that they are no longer
used

India

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133

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2404

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The electronics chapter is relatively long and complex. Therefore, theguidance needs to be focused and streamlined to make it more usable byremoving repetition (particularly within and between the Introduction and
Choice of Methods sections), by reorganizing some discussions, and byadding tables to summarize information that is currently sprinkled
throughout the text.
This list should be edited to remove redundancey and clarify which sub‐sectors have had EFs updated (SC, LCD), which have not (PV), and which
are entirely new (MEMS). Because a similar list of changes appears later in
the Introduction, it probably makes sense to move this bulleted list (withthe edits suggested) to the Mapping Tables.

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138

Clarify that apportioning may also be required between wafer sizes.

3285

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154

Provide additional detail regarding updates to guidance regarding
fluorinated liquids (e.g., mention new EFS for packaging, testing, andsoldering).
To increase readability, strongly recommend breaking the Introduction
into two smaller sections called something like "Overview of Emissions
and Their Sources" and "Summary of Refinements," and reorganizing asnecessary to remain consistent with these titles.

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Should note that fluorinated liquids are sometimes used to clean
substrate surfaces, e.g., for MEMS.
Correct to indicate that fluorinated liquids are no longer believed to be
used to clean TFT display panels during manufacturing. (They were used
before 2010)
Delete "Inventory compilers should also account for" since this section isintended as background rather than guidance. Similar language should
also be deleted at 182.
Note that "dry removal of photoresist" is an additional "other" N2O using
process.
"light emitting devices" should be "light emitting diodes"
This is a rather long paragraph and currently, the sentences regarding thesources of emissions run together. It should be revised to more clearly callout the different emissions sources.
Delete sentence beginning "However, if the emissions control system's
OEM." This level of detail is too high for an introduction.

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Accepted
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United States ofAmerica

Accepted

Removed "inventory compiles should aslo account for" fromsetences

Accepted
Accepted"Other" N2O using processes examples were expanded toincluded dry removal of photoresist
ChangedAccepted

Paragraph edited for clarity

Accepted

Deleted sentence

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To increase usability, strongly recommend adding a new table thatprovides an overview of the sources of and types of GHGs emitted during
electronics manufacturing, and where in the guidance each is discussed.

Country

Responses
Accepted

United States ofAmericaThis text addresses methodological choice and therefore should bemerged with the discussion in the "Choice of Method" section.

Accepted

The refinements portion of this paragraph were moved thesubheading "Summary of Refinements". The remainder was
merged with the "Choice of Methods" section

Accepted

Added language to clarify that where semiconductor "Tool andprocesses" are used, Tier 2 Efs can be used for MEMs (Choiceof Methods Section). Added discussion of via process andrelated high SF6 EF (Section 6.2.2.1).

Accepted
Accepted

Tier discussions separated. Moved to summary of refinements
subsection per another comment
Most of this section was deleted, as suggested by commenter

Accepted

Changed to "using the Tier 2 and Tier 3a methods"

Accepted

Most of this discussion is now in the Choice of method section

Accepted

Note on applicability to all sub‐sectors added.

Accepted

Moved from "summary of refinements" section to "QA/QC"

Accepted

New Table 6.2

Accepted

Tier 2b Efs for PV from 2006 guidelines were added to the
document as the current Tier 2c. Tier 2a and Tier 2b methods
cannot be used if emissions control technology is used because
Gamma data is not available.

Accepted

Section renamed as suggested

Accepted

Section is now organized to move systematically from Tier 1 toTier 3b and emphasizing the increased precision and accuracy,
as well as the increased detail of the required data

Accepted

Sentence edited to note that emissions can vary with thequantities of the gases used (which vary roughly with substrate
processed), the identities of the gases used, and the wafer size(for semiconductors.

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226

Here and elsewhere, please clarify the guidance regarding MEMS. Can theguidance recommend that inventory compilers use semiconductor Tier 2
EFs for MEMS that are manufactured using semiconductor tools and/or
processes? Are MEMS manufactured on the same wafer sizes assemiconductors?
Move the sentence regarding the Tier 2b and 2c methods further down.
This paragraph focuses on Tier 2a method.
Recommend deleting much of this discussion as it is redundant with ll 342‐
46.
Apportioning is also relevant to the Tier 3a method.

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3313

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3315

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3317

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258

This discussion on apportioning should be merged with the Choice ofMethod section.
Note that the Tier 3b approach is applicable to all subsectors.

3319

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263

This discussion would fit better in the QA/QC section.

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268

3323

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268

Strongly recommend adding a new table to provide an overview of which
Tiers have been updated for which sub‐sectors.
It appears that the emission factors and guidance for the photovoltaic
subsector, which appeared in the 2006 Guidelines, have been dropped.
Strongly recommend including EFs and guidance for PV for the following
reasons: (1) even if current PV manufacturing only rarely uses FCs,
countries still need to estimate emissions from historical PV
manufacturing that did use FCs, and (2) at least one PV manufacturer in
the US has recently reported emissions under the Greenhouse Gas
Reporting Program.

3325

3327

3329

3

3

3

6

6

6

277

277

279

277

386

279

For simplicity, and to parallel the title for the Fluorinated Liquids
discussion, recommend renaming this section something like "Gaseous
Fluorinated Compounds and Nitrous Oxide."
Strongly recommend reorganizing this text to move systematically fromTier 1 to Tier 3b, emphasizing the increasing precision and accuracy of themethods, as well as the increasing detail of the required data, as one
moves from the lower to the higher Tiers.
Note that emissions also vary with the quantities of the gases used (whichvary roughly with substrate processed), the identities of the gases used,
and the wafer size (for semiconductors.

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Authors' notes
Table added.

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Comments
Note that the choice of method also depends on whether the category is
key.
Would be helpful to reorganize this paragraph to move systematicallyfrom lower to higher Tiers.
This discussion belongs further down, in the discussion of why it isworthwhile to move from Tier 2 to Tier 3.
This paragraph includes valuable insights but should be broken up into
multiple paragraphs (e.g., at line 316) providing an overview and thenbrief discussions of Tier 1 and Tier 2a. The first of the resulting paragraphs
should be reorganized to increase readability, noting at the beginning thethe precision of the emissions estimates improves as one moves fromlower to higher Tiers and building on that generalization.

3339

3

6

304

306

Delete; redundant with ll. 280‐83.

3341

3

6

311

311

The current discussion of errors in gas apportioning could lead to theconclusion that apportioning always leads to increased error, but this is
not the case at the Tier 2 level (i.e., in moving from Tier 2a to Tier 2c).
Recommend revising discussion to clarify this.
This discussion would fit better in the Uncertainty section.

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316

3347

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3349

3

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349

3351

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369

3353

3

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388

3355

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404

417

3357

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404

418

Note that the choice of method also depends on whether the category is
key.
In the discussion of the Tier 1 approach, note also that the Tier 1 method
does not account for the quantities of the gases consumed (which are
only loosely correlated with production), the identities of the gases
consumed, the process type, and the wafer size (for semiconductors).
Recommend adding a paragraph discussing why apportioning increases
the precision and accuracy of the Tier 2c method compared to the Tier 2aand 2b methods, considering both the distinctions among process types
and the per‐tool emissions of each gas from each process type for theabatement calculations.
Consider moving Box 6.1 to the Tier 2a discussion or possibly to theIntroduction.
Move lines 300‐304 to follow this sentence. They fit here more logically.
Figure 6.1 should be revised to eliminate the reference to 6 generation for
Display in the fourth diamond down on the right, and to replace"substrate size" with "wafer size (for semiconductors)" in the third
diamond down on the right. Only semiconductor manufacturing includes
different EFs for different substrate sizes or technology vintages.
Figure 6.1 references tracking gas usage by generation (less than 6th vs.
6th or greater) for display to decide whether to use Tier 2a or Tier 2b;
however, there is no Tier 2a or Tier 2b for display or a differentiation by
generation.

Page 75

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Responses
Accepted
Accepted
Accepted
Accepted

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Authors' notes
Reference to using Tier 1 only when electronics category is not
key aded to section
Whole section was re‐organized to move systematically fromTier 1 to Tier 3b
Whole section was re‐organized to move systematically fromTier 1 to Tier 3b
Whole section was re‐organized to move systematically fromTier 1 to Tier 3b

Accepted

Reference to Figure 6.1 deleted

Accepted

Discussion on potential error due to errors in apportioning
revisedAccepted

Uncertainty discussion removed from this section

Accepted

Added to discussion of Tier 1

Accepted

Added suggested note

Accepted

Added paragraph on the why Tier 2c is more accurate than Tier
2a and 2b

Accepted

Now box 6.2 and is in section on Tier 2a

Accepted

Moved to later in the disucssion, as suggested

Accepted withmodification

Reference to 6 gen for Display was removed from Figure 6a.
Authors prefer "substrate size" but added "(forsemiconductors)"

Accepted

Reference to 6 gen for Display was removed from Figure 6a.

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Comments
Consider whether Table 6.1 is still necessary or useful. If so, break up
and/or simplify this table. Recommend breaking up by emissions source,e.g., gaseous FCs vs. liquid FCs. Could also (1) merge similar data elements(e.g., Ui and Ui,p), noting that for higher Tiers, more disaggregated data isrequired, and (2) re‐order to “follow” gas flows (consumption, EFs, DREs,
etc. as in 2006 GL). Authors may want to present this in landscape format
to allow small amounts of detail in each cell (e.g., for Ci by process typefor Tier 2c, “Ci,p (by process type)”
Recommend adding "EFs based on Production" to the title to clarify
difference between Tier 1 and other Tiers, which are based on gas
consumption
Recommend noting that Tier 1 does not account for actual gas
consumption or for differences in EFs among process types.
Recommend adding "for Tiers 2 and 3" to the title to clarify applicability ofthe section
Recommend adding language to clarify that apportioning can also be
performed to manufacturing of specific wafer sizes if more than one
wafer size is produced in the same facility. Apportioning would be
performed first by wafer size and then by process type.

3369

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520

520

“l” is a confusing variable name because it looks like the numeral “1”.

3371

3

6

541

544

3373

3

6

547

548

3375

3

6

557

581

This language is very similar to the language at 582‐589. Should choose
one or the other.
Recommend replacing "inventory compilers should" with "it is goodpractice to" in this sentence.
This section should be rewritten to be clear, but less prescriptive. It iscurrently written more like a regulation than guidance.

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567

3379

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676

3381

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620

This requirement appears to apply to stack testing rather thanapportioning and should be deleted from the text here.
Recomend combining, streamlining, and moving this discussion above
Equation 6.10, which is the first to use the weighting factor gamma.
Recommend discussing the benefits of the gamma factor as well as its
drawbacks. Applying the weighting factor gamma to tool counts tocalculate the fraction of emissions abated is a vast improvement overusing unweighted tool counts even if gamma is also uncertain. The
example in the second paragraph of the Box should probably be replaced;
it appears to be confusing total emissions for each process type with per‐tool emissions for each process type.
Should be "ratio of of emissions of input gases or by‐products k per tool
between process types"

Page 76

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Responses
Accepted

Table was revised.

Authors' notes

Accepted

Title modified as suggested

Accepted

Added to Tier 1 discussion

Accepted

Title modified as suggested

Accepted

Added reference to clarify that apportioning must also be doneby wafer size

Accepted

Changed "l" to "c"Accepted

Removed from 582‐589

Accepted

Changed to "it is good practice"

Accepted

Edited for clarity and revised to be less prescriptive

Accepted

Sentence removed

AcceptedBox and discussion moved as suggested. Example in box was
replaced.

Accepted

Gamma was clarified as based on per‐tool emissions ratios

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3391

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Comments
Gamma should be an emissions per tool based ratio. Since gamma shouldbe emissions per tool, it shouldn't matter if a facility has mostly IPC or
mostly RPC. Instead a higher gamma could be reflective of differences in
the number of chambers for each process type or a change in the gas
ratios used in etching (e.g. an old facility might use more C2F6 per tool for
etch than a new facility, resulting in a lower gamma)
Should be "when the percentage of tool equipped with emission control
technologies is not the same for different process types using the same
input gas…"
Should be "uncontrolled emissions…per in‐situ plasma cleaning tool…"
Recommend adding "Default EFs based on gas consumption" to the title
to clarify difference with Tier 1 method.
This discussion is redundant with the introduction to the Choice ofMethod section and can be deleted.
Here and elsewhere in the document, clarify that the inventory compiler’s
responsibility is to verify that the emission reductions are real, not torequire use of abatement devices.
Recommend including a sub‐heading just above this line similar to"Emissions and emission reductions from emission control devices"
Unclear what "when direct reaction with hydrocarbon fuel and fluorinatedspecies is not certified" means. I assume the equipment in questionneeds to certified (in line with lines 750‐752), not that the reaction iscertifiedLines 773‐777 are similar to lines 1017‐1021. It may be worth combining
and discussing earlier in the Tier 2 section. Also, the wording in 1017 isclearer than in 773. 1017 uses "Inventory compilers should calculate" and773 uses "Inventory compilers should note that"
Recommend including a sub‐heading just above this line similar to"Calculation of ai and ak using the default weighting factors gamma I andgamma k"Need to add guidance to this section on how to calculate destruction
terms for gas and process‐type combinations whose consumption isapportioned under Tier 2a and 2b (e.g., NF3 and C3F8 used in remote
plasma clean processes and N2O used in either CVD or "other" processes.)In these cases, recommend referring users of the guidance to Equations
6.18 and 6.19.
This discussion is somewhat confused because it implies that Equation
6.10 should be used for gas and process‐type combinations whose
consumption is apportioned. This includes, e.g., NF3 and C3F8 used inremote plasma clean processes and N2O used in either CVD or "other"processes. The discussion can be simplified by removing these gas andprocess type combinations. This will also enable direct reference to"etching" and "chamber cleaning" rather than "process type 1" and"process type 2."

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Responses
Accepted

Authors' notes
Gamma was clarified as based on per‐tool emissions ratios.
Example was changed.

Accepted

Changed to "fraction of process tools" from "number of process
tools"

Accepted

Fixed throughout document

Accepted

Modified heading as suggested

Accepted

Discussion removed

Accepted

Modified sentence to clarify compiler's responsibility

Acceptedsub‐heading added

Accepted"when direct reaction with hydrocarbon fuel and fluorinatedspecies is not certified not to occur by the emissions control
equipment OEM or electronics manufacturer"

Accepted withmodification

Authors decided to keep each calculation method section as
stand‐alone sections. Thus, the repetition is needed. Wording
change accepted.

Accepted

Heading added as suggested

Accepted

Guidance added to use 6.18 and 6.19 for apportioned gases

Accepted

Guidance was added to use 6.18 and 6.19 for apportioned
gases. Also now directly references "etching" and "chambercleaning" rather than "process type 1" and "process type 2."

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3413

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824

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826

864

3417

3

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828

863

3419

3

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3421

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Comments
If Tier 2a is used (due to a mix of wafer sizes), which set of Gammas
should be used from table 6.4? Table 6.4 requires choosing a wafer size
Instead of "number of tools…is not the same" it should be "percentage oftools…is not the same"
Gamma should be a ratio of emissions/tool for each process type
It is unclear why in the case of 300mm facilities that gamma is the sum of
IPC and ITC but that this wouldn't occur for 200.
Here and in the introductions to the other Tiers, recommend starting withthe applicability and general principles of the Tier, then moving to thedefault emission factors and equations. There is no need to reiterate thefull discussion that appears in the introduction to the Choice of Method
section.
For na(i) and ma(i), perhaps "a" should be a subscript? Currently it looks
like n is mulitplied by a (subscript i) instead of nai being one variable thatis dependent on both a and i. On line 903, these are listed as n subscript(a,i)
Gamma should be emisions/tool
In Equation 6.11, would it reasonable to estimate m(k) as the the total
number of process type 2 tools (assuming process type 2 is EWC) as all
EWC gases, except CF4, produce CF4 as a by‐product? This would be
simple and avoid double counting of tools that use multiple input gases.
Was gamma(k) calculated this way? This may also be a reasonableapproximation for C2F6 m(k)Should say "process type 1" instead of "process type 2"This statement states that it is "good practice" to use interlock process
tools or backup emissions control systems, but specifying use ofabatement is beyond the purview of the Refinement. Recommend
replacing with "Thus, using interlock process tools or backup emissions
control systems reduces uncertainty by eliminating the need to estimate
UT for the reporting facility."
Default gammas should be different for Tier 2b than Tier 2a. The gamma
factors in table 6.4 are substrate size specific
Consider whether you can merge at least some of the Tier 2a and Tier 2cequations, e.g., by simply noting that in most Tier 2a calculations (except
for those for N2O and for NF3 and C3F8 used in RPC), the “p” subscript
can be ignored.
Suggest rewording setence to the following: "The Tier 2c method isapplicable to the semiconductor and display sub‐sectors and is based on aset of equations and default emission factors that account for thedifference in emissions between distinct process types.

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Responses
Accepted

Authors' notes
Gammas were developed for Tier 2a. Table 6.4 now has Tier 2agammas and Tier 2b gammas

Accepted

Changed to "fraction of tools" from "number of tools"

Accepted

Fixed throughout document

Accepted
Accepted

Changed to general guidance about counting all tools running
ITC or IPC processes
Changes made.

Rejected

Authors think current variables are already clearly defined.

Accepted

Revised.

Accepted

Footnote added regarding tendancy to double count.

AcceptedError corrected

Accepted

Changed here and in other similar sentences

Accepted

Sentence revised to indicate that gamma is substrate size
dependent for Tier 2b
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Comments
In the clause " that reactions between …to form CF4 is not occuring…" thesubject and verb are not in agreeement. Suggest changing to " thatreactions between …to form CF4 are not occuring…""but such emissions are calculated using…" should be a new sentence(and not include "but"). Suggest "...are not occurring within theiremissions control systems). Tier 2c emissions are calculated using..."Country

Responses
Accepted

Changed as suggested

Authors' notes

Accepted

Changed as suggested

Accepted

Discussion was shortened and refers to previous discussion

Rejected

Keeping for ease of compilers.

Accepted

Footnote added to explain how authors decided on thesedefaults
Revised to explain that developing robust country‐specificdefaults may be challenging

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United States ofAmericaThis language appears to be identical to ll 736‐752 (under Tier 2a). This is
one of many such repeats throughout the document. Recommend
referencing the earlier discussion here and deleting at least some of therepeated text. One approach would be to include sections that are
applicable to all Tiers (or e.g. all Tier 2 methods) at the front end and thento focus on the differences under each Tier description. Another would beto repeat the basic guidance regarding how to handle the calculation of
byproducts, but to include the background information only once. Either
aproach will simplify and reduce the length of the document.
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3441

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6

1195

1246

1195

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This language appears to be identical to ll 864‐880 (under Tier 2a).
Consider referencing the earlier discussion here and deleting some of therepeated text.
Was there a quantitative basis for the default EFs of 0.8, 0.15, and 0.05 ?
This should be explained.
Recommend eliminating "country‐specific default emission factors areless desired" because it is a vague statement and country‐specific factors
may in fact have some value. Explain instead that countries are likely tofind it challenging to develop representative coumtry‐specific factors, andthat it is often preferable to refine factors at the global level.
In the title, recommend inserting "process‐specific" between "measured"and "parameters" to more clearly distinguish between the Tier 3a method
and the Tier 3b method (which also relies on measured parameters).
Recommend adding "Stack testing" after the title to more clearly
distinguish between the Tier 3a and 3b methods.

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acceptedsub‐heading modified as suggested

Accepted

Title modified as suggested

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The preliminary estimate and subsequent methods used to estimate
emissions from untested stacks raise a number of challenging issues.
First, the preliminary estimate permits the use of unweighted tool counts
to apportion gas usage to various stack systems (ll. 1282‐84). No
distinction is made between etching and TFD equipment. Since thepreliminary estimate is the source of the factor (theta) used to scale up
the EFs to account for untested stacks, errors here are a significant issue.
Second, the equations for the gas‐specific emission factors (6.26 and6.27) assume that (1) the uptime of abatement equipment for the facility
is the same as the uptime of abatement equipment for the tested stacks,and (2) the fraction of gas abated (ai,f) for the facility is the same as thefraction of gas abated for the tested stacks. Both assumptions appear
questionable. Consider whether it may actually be simpler to require
testing of all stacks initially, and then to permit less frequent testing ofstacks that are identified as low‐emitting through the initial test. This
would eliminate the theta factor from Equations 6.26 and 6.27.

Country

Responses
Accepted

Changes made.

Authors' notes

Accepted

Revised for clarity

accepted

N2O removed

accepted

Modified as suggested

accepted"should be conducted" removed

Accepted

Guidance revised for consistency

accepted

Modified as suggested

Accepted

Added parenthesis

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3459

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3461

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This language is somewhat confusing and should be clarified. Presumably,
the goal is to recommend retesting when the fraction of annual
consumption of FC gases (expressed in CO2e) accounted for by any one FCgas changes by more than 10 percentage points compared to the year of
the most recent emissions test. A distinction should be made between
percentage and percentage points.
Recommend removing N2O from this criterion and, if necessary,
establishing a separate criterion for it. N2O is used for different purposes
than the F‐GHGs; thus, one wouldn’t expect changes in N2O consumption
to cause changes to FC EFs.
This does not specify what "change in consumption" means for an FC not
used during the emissions test. Recommend that retesting be required
when the FC accounts for 5% or more of facility consumption in mtCO2e.
Recommend shortening many bullets by eliminating "should be
conducted."
The guidance does not distinguish between possible and expectedbyproducts here, but it does distinguish between them at ll. 1453‐8. It
probably makes sense to distinguish between them everywhere, but inany event, the guidance needs to be internally consistent.
Recommend emphasizing the importance of accurate gas consumption
measurements during the stack test. Can add a sentence something like:"Because stack testing is conducted over a relatively brief period,
measurements and calculations of gas consumption during that period
must be precise to ensure that the resulting emission factors areaccurate."
Equation 6.26 is missing a parenthesis

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Recommend clarifying the subsectors for which default Tier 1 fluorinatedliquid emission factors are (and are not) available. It is worth noting that
although Tier 1 EFs are not available for cleaning of MEMS, emissions
from this process can be quite high.
Need to expand this equation (or the definitions of its terms) to include
guidance on how to calculate emissions from testing, packaging andsoldering, the emission factor for which is expressed in thousands ofpackaged devices.
Recommend including a list of the common fluorinated liquid compounds
and their trade names, as well as some discussion of their GWPs (ifapplicable).
Authors should add information on how the Tier 1 Efs were calculated,
including regions associated with the data, wafer sizes, whether wafer
sizes were equally weighted, etc.
Tables 6.2, 6.3, 6.4, 6.5, 6.6, 6.7, and 6.8 do not cite sources of data

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Need to restore default EFs for photovoltaics

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1728

What weighting factors were used to develop Tier 2a and Tier 2b? Nosources are cited. Can the authors provide guidance on what facilities
may be accurately described by using a Tier 2a or Tier 2b?

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This table includes default gamma weighting factors for gas and process‐type combinations whose gas consumption is apportioned and that
therefore should not require gamma weighting factors. The table should
be streamlined and clarified.
It seems highly unlikely that Gamma(i) and Gamma(k) are the same for
CF4 from IPC/EWC. Likewise it seems unlikley that Gamma(i) andGamma(k) are the same for C2F6 from IPC/EWC. Were theretranscription errors in this table?
Since a gamma(i) exists for NF3 (IPC+ITC)/EWC for 300mm, then agamma(k) for CF4 (IPC+ITC) should also exist since there is a CF4 by‐product listed for both clean process types and CF4 is produced as a by‐
product in EWC. Also, since a gamma(i) exists for NF3 (IPC+ITC)/EWC for
300mm, than it should also exist for NF3 (IPC) and NF3 (ITC), unless bothprocesses always exist simultaneously. The corresponding gamma(k) forCF4 should also exist.
What should faciliites do for instances were no default gamma exists? E.g.
if they use NF3 in in situ thermal clean in a 200 mm facility. Can they usean analagous gamma?
C3F8 is not listed as a by‐product for RPC. Thus there should be no
Gamma(k). Was this value intended to be a gamma(i)?
How were the default gamma(i) and gamma(k)s calculated? No sources
are listed. For gamma(k) for CF4, was the total number of EWC tools used(since all gases produce CF4 as a by‐product, to avoid double counting oftools)?

Page 81

Country

Responses
Accepted withmodification

Authors' notes
Availability of Tier 1 HTF Efs added. Emissions from cleaning of
MEMs is not discussed here as there are no Tier 1 Efs available.

AcceptedDefinition expanded and guidance added to text

Accepted

Added table of commonly used HTFs with GWPs

Accepted

Information on Tier 1 calculations was added [does not discusswafer sizes]

Accepted[Still need reference to either sources]

Accepted
Accepted

Tier 2b Efs for PV from 2006 guidelines were added to the
document as the current Tier 2c.
Authors will provide explanatory paper. The explanatory paper
will contain information on the "average" fab that would be
accurately described by the default Efs

AcceptedErrors in Table were identified and fixed

AcceptedErrors in Table were identified and fixed

Accepted

Gammas are provided for different process combos for all
substrate sizes. Other errors were identified and fixed

Accepted

Defaults provided by analogy gammas were we do not havedata. Footnote added to gamma table to direct facilities to use
a gamma of 10 where no gamma exists
Errors in Table were identified and fixed

United States ofAmerica

United States ofAmerica
United States ofAmerica
United States ofAmerica
United States ofAmerica
United States ofAmerica

United States ofAmerica

United States ofAmerica

United States ofAmerica

United States ofAmerica
United States ofAmerica
United States ofAmerica

Accepted
Accepted

United States ofAmerica

Authors will provide explanatory paper. Potential issue of
double counting is noted in text

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63b9088a

CommentID Volume
3491
3

3493

3

Chapter
6

6Fromline
Toline
1729
1730

1768

1772

Comments
There are no in situ thermal clean emission factors in Table 6.6 or any
indication that situ thermal clean is used for 200 mm. However, there arereported emissions from in situ thermal clean from 200mm facilities in the
US. It would be good to clearly indicate that the process is used (either byhaving a data row and "NM" for gases used or otherwise in the text) but
that no data exists
Run‐on sentence. Suggest changing to: "These processes can lead to theformation of significant amounts of molecular fluorine (F2) originatingfrom the conversion of NF3 into F2 or the limited ultiization efficiency ofF2 (when the latter uis used as a cleaning precursor). When the exhaustgas contains large amounts of F2 AND when hydrocarbon ‐fuel‐based
combustions emissions control technology is used, direct reaction of thehydrocarbon fuel with F2 to form CF4 can occur.

Country

Authors' notes
Footnote added to Tier 2c for <=200 that ITC is known to occur

Accepted

Changed as suggested

Accepted

quotation mark removed

Accepted withmodification
Accepted

Adding an X for C3F8 greater than 850. No X is assigned to
COF2 as COF2 is not in the table
ChangedAccepted

Added as footnotes to discussion above figure

Acceptedchanged to fractions

AcceptedError corrected

Accepted

Titles clarified

Accepted

Sentence removed

United States ofAmerica

United States ofAmerica
United States ofAmerica
United States ofAmerica

3495

3

6

1809

1809

Source contains one quotation mark. Typo?

3497

3

6

1813

1814

3499

3

6

1816

1818

3501

3

6

1816

1818

3503

3

6

1821

1822

3505

3

6

1821

1822

3507

3

6

1824

1825

3509

3

6

1855

1857

Please check whether Xs should appear for C3F8 and COF2 for the Hot‐
wet technology in TABLE 6.11 (NEW)In figure 6.4, clarify that if an OEM‐measured DRE is to be used, then it
needs to be backed‐up by supporting data. In addition, to avoid confusing
abatement devices with semiconductor devices, recommend replacing"abatement device" with "abatement equipment" (or possibly "abatement
system") here and throughout the document. For [4], recommend adding
United States of“to the levels shown in Table 6.12."
America
You may want to consider adding the following two references here or in
the text related to abatement. The references concern the formation of
CF4 from organic process chamber residues during CVD chamber cleans
using NF3, and similarly by direct reaction with hydrocarbon fuel if there
is sufficient mixing in the emission control equipment. Gray, Fraser, andAfroza Banu, "Influence of CH4‐F2 mixing on CF4 by‐product formation in
the combustive abatement of F2," Research Disclosure.
Czerniak, Mike, "Mechanisms for PFC Formation in CVD Applications,"
United States ofpresented at SESHA 2018.
America
United States of
The values in Table 6.12 should be expressed as decimal fractions rather
Americathan percentages.
the 2 in N2O should be a subscript, not a superscript; The 8 in C3F8 should United States ofAmericabe a subscript.
The titles in Table 6.13 should be clarified to distinguish between heat
United States oftransfer fluid applicatons and testing, packaging, and soldering (currently
Americareferred to as "burn in") applications.
This statement seems doubtful given that at least one PV manufacturer
United States ofreported emissions through the US Greenhouse Gas Reporting Program.
America
Consider revising or deleting.

Page 82

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CommentID Volume3511
3

Chapter
6

Fromline
Toline
1859
1859

3513

3

6

1859

1907

3515

3

6

1860

1861

3517

3

6

1862

1867

3519

3

6

1920

1922

Comments
Recommend adding the following overview sentence at the beginning of
this section: "Completeness for electronics manufacturing requires
accounting for all fluorinated GHGs and N2O (see section 6.1.1) andfluorinated liquids (see Table X ) emitted from all emissions sources (seeTable 6.1) at all facilities in all electronics manufacturing subsectors (seeTable 6.2) in a country."
There is some redundancy among the bullets that can probably beeliminated.
Recommend making the bullet points more parallel to the issues in theoverview sentence suggested for line 1859.
Recommend deleting this bullet on the imprecision of the Tier 1 estimate.
This is not what is meant by completeness. Tier 1 is less than ideal, but it
is provided in case countries don’t have data to support anything better.
This is more of a precision issue.
Considering that in 2006 very little 300mm technology existed, is thechange in the Tier 1 emission factors largely due to the introduction of
300mm technology or the improvement of processes? If the former,
would it be more accurate for 200 mm facilities to use the 2006 Tier 1
emission factors, regardless of year? Countries using Tier 1 may be more
likely to be manufacturing on 200‐mm and smaller wafers.

3521

3

6

1923

1923

The meaning of "comparison or benchmark" should be clarified.

3523

3

6

1939

2015

This discussion should not focus on the inability of the authors to estimate
the uncertainty of the Tier 1 factors, but should note that Tier 1 EFs arehighly uncertain and discuss why. The quantitative uncertainties
calculated for Tier 2a, 2b, and 2c should be verified.

3525

3

6

1941

1942

3527

3

6

1972

1977

3529

3

6

2058

2058

3531

3

6

2109

2335

1425
1653

3
3

7
7

322
413

323
413

"Accuracy" is generally interpreted to be included in the term
"uncertainty."
This discussion relates more to activity data uncertainties.
The discussion of gamma at 2045 through 2051 should be moved here,
since gamma is used to calculate ai and ak.
Many of the sources listed in the "References newly cited in the 2019
Refinement" are not actually cited anywhere in the document, e.g.
Trudinger (2016) is not cited anywhere

Spelling error; "partiesa" should be "parties"
7.5.1: We suggest to add blends such as R‐448A, R‐449A, R‐452A, R‐454A,
R‐455A, R‐513A, which became common replacements for R‐404A, R‐
410A, etc. during the last 5 years. Please check the supporting document.
In turn, we suggest to delete blends that contain CFCs such as R‐400.

Country

United States ofAmerica
United States ofAmerica
United States ofAmerica

Added as suggested

Authors' notes

Accepted

Section streamlined

Accepted

Bullets now more in‐line with introduction to section

Accepted

Removed as suggested

Accepted

Authors revised guidance to say that if wafer size is known and200mm or smaller, it use good practice to continue to use the2006 Tier 1 factors even after 2010. Text added to both Tier 1
method discussion and time series consistency

Accepted

Removed "or benchmark".

Accepted

Disucssion of Tier 1 modified as suggested. Uncertainties werereviewed and accepted as calculated.

Accepted

Sentence removed per another comment; no longer relevant

Accepted

Moved to uncertainty of activity data section

Accepted

moved as suggested

Noted

Many of the references in the document are listed in thereference section as they are good resources for inventory
compilers, but are not directly cited in the document are they
are not specifically discussed. Where resources were useddirectly to e.g. develop emission factors, those references arecited.

United States ofAmerica

United States ofAmerica
United States ofAmerica

United States ofAmerica
United States ofAmerica
United States ofAmerica
United States ofAmerica

United States ofAmerica
SwedenGermany

Page 83

Responses
Accepted

Accepted
Accepted withmodification

A reference to the list of blends provided in the reporting
guidelines of the UNEP secretariat is provided in the text

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63b9088a

CommentID Volume
1655
3

7

Chapter

Fromline
Toline682
682

Comments
Please revise the following incomplete sentence: "The spreadsheet"Calculation example for 2F1 (Tier 2) of the 2019 Refinement" and add
SHOULD BE USED.
Box 7.2: The case removal through export of equipment is not consideredin the figure. Please add the word “Exported” in the “Retired Equipment”
portion of the pie chart.

1657

3

7

713

713

1659

3

7

832

834

1661

3

7

907

907

1663

3

7

907

907

Due to the supporting material (NIR Germany, table 198), the emission
factor of operation emissions for MAC in maritime can be smaller than
20%. Please adjust the value accordingly. Also, we suggest to use thefollowing values for column "annual loss, operating lifetime": 0.2 ≤ k ≤ 1.0

1665

3

7

907

907

Due to the supporting material (NIR Germany, table 198), the emission
factor of operation emissions for other MAC, namely agriculturemachines, can be bigger than 20%. Please adjust the value accordingly.
Also, we suggest to use the following values for column "annual loss,
operating lifetime": 10 ≤ x ≤ 25 (other MAC)

1895

3

7

657

658

The web link included here does not work and needs updating

Country

Responses
Accepted withmodification

Authors' notes"Can be used" is added in stead of the suggested "should beused" because the use of the spreadsheet is optional

Accepted withmodification

The fact that retired equipment can be exported, and not only
scrapped, is now pointed out in the explanatory text in box
7.2B. It is also included in the worksheet (as an extra column
for data entry) and the illustration in the worksheet. It is
however not added in the pie chart as suggested, because webelieve it is important to keep the chart as simple as possible to
make it easier to understand.

Germany

Germany
Please revise the sentence: "Information on the year each relevant kind of
ODS‐substitute was first used in each relevant type of equipment (sub‐application) in your country (for instance, the year HFC‐134a was firstused in mobile air conditioning in your country)" and NEED TO BE
COLLECTED.
Due to the supporting material (NIR Germany, table 198), the lifetimes for
MAC in maritime and railway can be longer than 16 years. Please adjust
the value accordingly. Also, we suggest to use the following values forcolumn "at time of charge": 0.2 ≤ k ≤ 1.0

Accepted

Germany
Rejected

Suggested statements and values were not found in the
supporting materials or references therein

Rejected

Suggested statements and values were not found in the
supporting materials or references therein

Rejected

Suggested statements and values were not found in the
supporting materials or references therein

Rejected

The web link is correct

Germany

Germany

Germany
United Kingdom (ofGreat Britain andNorthern Ireland)
1897

3

7

1019

1032

It might be worth including a note that European Member States must
report to the European Commission annually on production and importsof (bulk gas) HFCs in line with the EU F Gas Regulation.

Page 84

Accepted
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63b9088a

CommentID Volume
1051
3

8

Chapter

Fromline
Toline361
362

Comments
Default Tier 1 emission factors for waterproofing of electronic circuits are
based on measurement in one facility (Table 8.11). There is a risk that thisemission factor is not representative and applicable as a default emission
factor for all facilities. Proposition: move description of the calculation
method and emission factors to an appendix.

1053

3

8

399

410

1055

3

8

393

395

Please remove from this paragraph the phrase “authors propose” and edit
text accordingly. Please add a clear statement to the chapter thatcountries are not obligated to report emissions from this potential new
source since the proposed emission estimation methodologies arepresented in an appendix.
Please remove the word “significant” from the sentence since no actual
indication of the level of emissions is presented in the chapter.

Country

Responses
Rejected

Authors' notes
The current default emission factors are believed to be
representative for the following reasons:‐ The measurement data represents significantly more than one
data point, though admittedly from a single productapplication. The results were from several days of FTIR testing
to eliminate run‐to‐run variability.
‐ The process equipment that the testing was conducted on
represents at least 30% of the global installed population ofsuch equipment, and is therefore expected to be representativeof the entire market.
‐ The process is not altered for different circuit boards; theequipment contains “pockets” which hold the circuit boards sothat the same equipment and process can be used for a wide
variety of product applications.
‐ LAs compared the data used to estimate the EFs with datafrom Stockholm University on Sony‐Erikson phone circuit‐board
waterproofing, and the results were consistent.

Accepted

The Phrase "author propose" was remove and the text edited
accordingly. The explanation about a role of Appendices will be
added to the Overview Chapter of 2019 Refinement. A note
about he Overview Chapter was added to the text.

Rejected

See Comment ID#1057

FinlandFinlandFinlandPage 85

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CommentID Volume
1057
3

8

Chapter

Fromline
Toline391
393

Comments
Please remove the text “, but, by analogy with plasma‐based processes
used in the electronics industry, FC emissions resulting from the use of
input gases such as CF4, C2F6, CHF3, SF6, and other fluorine‐containing
molecules in plasma processes may be significant.” There is no actual
indication of the potential significance of the emissions level from thissource and therefore no speculation on the possible significance should
be presented in the guidelines.

1299

3

Annex 128

28

In Column D (CO2 emissions); Equation should be divided by 1000 toarrive at Gigagrams from tonnes.
Or otherwise, the unit of column D should be changed to "tonnes"

1301
1303
1305

3
3
3

Annex 1
Annex 1
Annex 1

30
32
86

30
32
86

Similar comment as above for column E
Similar comment as above for column D
Under Column E: it is unclear how kg value is being divided by 10^9
(instead of 10^6) to arrive at Gg value.

1307

3

Annex 1

89

89

Similar comment as above for column E

1383

3

Annex 517

17

Annex 5. The line reads: "CHAPTER 3". It would enhance theunderstanding if the line read: "CHAPTER 3 CHEMICAL INDUSTRY". This isrelevant for all chapter headings in Annex 5.

Country

Responses
Rejected

Authors' notes
It is true that there are no available data about the textile
fluorocarbons coating emissions in the atmosphere, however,treatment of both textiles and electronics with different kindsof plasma gas is a well‐studied subject. There is no doubt fromthe scientific point of view that these process can havean incomplete use of the input gases or low emission ofresidual fluorocarbon monomers. The problem is the lack of
information about the extent of this emissions and theirrelevance as GHG gases. However, considering that the world
market of textile finishing repellent agents has been estimatedto be 24.5 million tons in 2015, there is no doubt that even verysmall FC emissions released from these process could represent
a significant new source, due to the large volume of substrates
treated. The authors recognise the need for clarification inorder to avoid misunderstandings by reediting the sentence asfollows: "The extent to which plasma‐based textile treatment
processes have penetrated volume production is unclear, but,by analogy with plasma‐based processes used in the electronics
industry, and considering that many FC molecules
are particularly stable and difficult to disassociate, theutilization efficiency of the input gas is likely to be limited, andFC emissions resulting from the incomplete use of input gases
such as CF4, C2F6, CHF3, SF6, and other fluorine‐containing
molecules in plasma processes may be significant"FinlandAccepted

India
India
India

Accepted
Accepted
Accepted

Units for the emission coefficients C1 has been adjusted to "g
CF4/s‐tonne Al". This was an error in units. When divided by
10^9, this now correctly gives emissions in Gg CF4 units. The
units have been corrected in both Annex 1, as well as in the
Final Draft (variables for Equations 4.27b and 4.27f).

India
Accepted

Units for the emission coefficients C3 has been adjusted to "gC2F6/s‐tonne Al". This was an error in units. When divided by
10^9, this now correctly gives emissions in Gg C2F6 units. The
units have been corrected in both Annex 1, as well as in the
Final Draft (variables for Equations 4.27b and 4.27f).

Noted

The format of the Mapping tables is standardised across all
Volumes; the text in Annex 5 is consistent with the approach inother Volumes.

India

Page 86

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63b9088a

CommentID Volume
1427
3

1429

3

1431

3

65

3

Chapter
Fromline
Spreadsheetfor
2F1(Tier2)_Ch7
Spreadsheetfor
2F1(Tier2)_Ch7
Spreadsheetfor
2F1(Tier2)_Ch7

TolineComments
The spreadsheet example calculation should include years up to 2050 tobe able to estimate emission scenarios.

Country

Responses
Accepted

Authors' notes

SwedenThe calculation does not work if emission years up to 2050 is included.
Some years show negative emissions and amounts.

Accepted

SwedenFor some emission estimates, years before 1988 may need to be included.
A note about this should be added.

Accepted

SwedenThe GL needs to provide more clarification and simplifying for reporting
ghg emissions from refineries with integrated chemical industries andsome processes, because the language used in the GL may leads tomisinterpretation of the location where the mentioned emissions bereported

Noted

The authors have reviewed the text within Energy and IPPU andacknowledge that there are complexities in the reporting ofemissions from integrated (refinery‐petchem) complexes.
However, the GLs provide appropriate methodologies for all
emission sources, indicate good practice for reporting
allocations, but also provide flexibility for compilers in orderthat national circumstances (e.g. of resolution of activity or
emissions data) can be accommodated, with the over‐archingguidance to avoid gaps and double‐counts in national GHG
emissions estimates. Separate guidance is presented specific torefineries, and also specific to chemical and petrochemical
production, within the Energy and IPPU volumes. The authors
therefore consider that the risk of misinterpretation of the GLs
is minimised.

Accepted with
Modification

Data on cropland management practices are compiled in Step
3. Text has been added to Step 3 for improved clarity.

New Zealand

Noted

The context for the refinements associated with biochar andflooded land are discussed briefly later in the chapter. It does
not seem necessary to explain all refinements in this Chapter
because the overview chapter has already provided thiscontext. In addition, the mapping tables provide considerable
detail about the refinements. Chapter 12 was admended asnecessary to address the consequential changes on the updatesof the variables following the mandate.

New Zealand

Noted

It is beyond scope to refine this diagram.

New Zealand
New Zealand

Noted
Accepted

It is beyond scope to refine this diagram.

Egypt

161

4

1

365

655

4

1

39

667

4

1

180

669
671

4
4

1
1

180
342

"Compile national‐level statistics for livestock, manure management
systems, soil N management, biochar C, liming and urea application" thislist is not exhaustive. Why compile only statistics on these kind ofactivities ? Other activities must be informed for cropland reporting. Thisis implicit from step 3 (« categorize by specific management ») but maybe
France369 a specific step should be added.

Introduction section introduces new section on disaggregating naturalcauses of IAV but does not mention the introduction of new guidance forsoil c estimation (including for biochar) in Chapter 2, flooded land in
Chapter 7 or the complete re‐write of the HWP guidance in Chapter 12.
Suggest revise to remove the inconsistency of treatment of the scale of
143 changes introduced in the chapters of this volume.
Could this diagram also include N2O emissions from the deposition of
181 urine and dung directly onto pasture?
Could this diagram have an expanded soil carbon component? At the
181 moment it seems very basic
342 Start "Tier 3" on a new paragraph

Page 87

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63b9088a

CommentID

673

1463

1875

VolumeChapter444Fromline1

11

Responses

New Zealand

Accepted with
Modification

Authors' notes
Data on cropland management practices are compiled in Step
3. Text has been added to Step 3 for improved clarity. Have
also added crop yields in step 4.

Rejected

To have a common approach among all Volumes, no specificreferences to the refinements listed in ToR were made.

109

This introductory section should clarify the purpose of Ch2.6 by making
explicit reference to the ToR and the outcome of the May 2009 expert
meeting on the Managed Land Proxy. In particular, this meeting agreed
that annual emission inventories should estimate the actual emissions in
the inventory year and that the aim of emission inventories is not to try to
remove or reduce the impact of inter‐annual variations (see conclusion 5EU
117 in the expert meeting report).

227

Consider changing 'long‐term' to 'long' for clarity. In addition, pleaseprovide an example on what the long turnover time may refer to:
227 centuries, millenia or more.

1

265

3533

4

1

95

3535

4

1

112

1

Country

specifically mention statistics for cropping activities (e.g. area and369 yield/tonnage)

4

4

Comments

366

1877

3537

Toline

118

3539

4

1

130

3723

4

1

87

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted
United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

265 Remove 'occur', and add 'of' after 'by‐product'
It would be good practice not only to quantify and track area of
unmanaged land over time, but also REPORT on it as well? Recommend
United States ofAmerica
96 making that explicit in this sentence.
The distinction made between the two types of events may not be soclear. "Extreme events" such as hurricanes kill trees and result in
immediate emissions; severe and prolonged drought and pests can also
kill trees. These may also be considered natural disturbances. Suggest
United States ofAmerica
116 making this gradiation more clear.
Dissaggregating MLP estimates and removals into those of human andnatural effects provides "refined estimates" still does not take into
account that those emissions/removals are happening on managed lands.
So regardless of if they are human or natural, if they are happening on
managed lands they should be quantified and reported as such in the GHG United States ofAmerica
122 inventory.
The "Optional guidance" for disaggregating the MLP should be an
appendix to Volume 4. Phrasing as a new guidance and method for
estimating emissions/removals for AFOLU is confusing since countries do
not have to use this approach. Additional comments on chapter 2.6 "Inter‐ United States ofAmerica
132 Annual Variability" are provided as well.
Please consider to include explanations of direct and in particular indirect
Norway87 emissions and removals.

Page 88

Rejected

Text is from the current 2006 GL and was not subject torefinement

Accepted

Text revised.

Accepted

The text in Section 2.6 states that countries that chose to
disaggregate the components of the MLP are to report both thetotals and the compnents as requested here. We have revised
Chapter 1 text accordingly

Rejected
Noted

The section provides good practice guidance for inventory
compilers who choose to use the guidance. The 2019
Refinement includes many other examples of choices that canbe made by inventory compilers, including the choice of Tier 3
methods, and the GL contain guidance for those cases as well.
This text is out of scope for revision because the use of direct
and indirect did not change from the 2006 GL.

2019 Refinement ‐ Collated Comments on Final Draft from Governments with Authors’ Responses

63b9088a

CommentID

VolumeChapter

Fromline

TolineComments

Country

3725

4

1

90

3727
3729

4
4

1
1

97
107

Managed land is defined as land where human interventions and practices
have been applied to perform production, ecological or social functions
and "Emissions/removals of greenhouse gases do not need to be reported
for unmanaged land". Is previously degraded land by human intervention
where now human intervention is no longer allowed due to natural
restoration without human interventions /management classified as
managed or unmanaged land? Moreover, due to urbanization, croplands
might be abandoned in some places. Please consider specifying how thisabandoned cropland are to be classified. It would be beneficial if thesepotential sources and sinks could be evlauated to estimate the net GHG
Norway96 balance.
Please consider to elaborate on howpolicy decisions also can directly
influence emissions/removals from unmanaged land. E.g. if an area is
protected from human activities. Examples could be concervation of in
Norway108 forest areas, national parks etc.
Norway108 The sentence is very unclear

112

Please clarify the statement "The two largest causes of inter‐annual
variability (IAV) in GHG emissions and removals in the AFOLU sector are(1) natural disturbances and (2) climate variability". The anthropogenic is
mentioned as third factor but not part of the largest causes of IAV. Does itmean the anthropogenic factor has less effect on IAV than the
aforementioned causes? How is this related to the conceptual illustrationin Figure 2.6A (line 2432‐2436), which shows that managed land has adominant effect on the GHG emissions and removals? Maybe the reason
Norway117 is that the anthropogenic emissions have lower IAV?

3731

3733

3735

3737

4

4

4

4

1

1

1

1

406

Please consider explaining what Managed Land Proxy (MLP) is referring
to. How is this related to the statement of "the managed land proxy isimperfect (Ogle et al. 2018) because reported emissions from any area
407 can include non‐anthropogenic sources, such as natural disturbances"?

465

Table 1.2: Cropland (chapter 5). This section shows different classificationof C pools and non‐CO2 gases. However, croplands used to cultivate both
crops and fruits might also have below ground biomass (BGB). Pleaseconsider if possible to include estimation of BGB as a potential carbon
pool in the subcategories of Cropland Remaining Cropland (CC) and Land
Norway466 converted to Cropland (LC) .

467

Table 1.2: Grassland (chapter 6). Please consider is possible BGB as apotential carbon pool in the subcategories of both Grassland Remaining
468 Cropland (GG) and Land converted to Grassland (LG) .

Page 89

NorwayNorwayResponses

Rejected

Rejected
Accepted

Accepted

Authors' notes

Text is from the current 2006 GL and was not subject torefinement; in particular the land use categories
To avoid introducing extensive description about "management
and policy decisions" the last sentence of the paragraph wasremoved; and therefore there is no need to elaborate on policy
decisions.
Sentence was deleted

We have revised the text to clarify that we are refering to the
IAV in the emissions and removals due to human activities, notthe absolute amounts.
Additional text was introduced to better explain the context of
MLP within the proposed refinement.

Accepted with
Modification

However, since the purpose of the section is only to briefly
describe the organization of the Volume, is not appropriate tocomment and/or respond to assessments about the "quality"of the MLP made in other publications. More details about the
MLP and it’s characteristics can be founded in Chapters 2 and
3.

Noted

Belowground biomass may be estimated and reported at Tier 2
or 3 as discussed in Chapters 2 and 5.

Noted

Belowground biomass may be estimated and reported at Tier 2
or 3 as discussed in Chapters 2 and 6. However, note that
there was no refinements to the biomass C section of Chapter 6in this report due to lack of sufficient data.

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467

Table 1.2: Wetland (chapter 7). In this section only emissions of CO2 andnon‐CO2 gases are expected to be estimated. However, flooded landremaining flooded land, such as hydroelectric reservoirs, can have apotential to fix signifcant amount of CO2. Does this mean net emissions
468 including removals?

NorwayNoted

Removals of CO2 due to activty of biota (e.g. bacteria,
macroinvertebrates, plants, fish, and other aquatic species), butthese removals reflect short‐term carbon cycling by the aquaticbiota, and are not addressed in this guidance. There may also
be storage of C in reservoirs that is transported from uplandsystems. This C is addressed as a loss in the upland systems,
but estimating the amount of C that it is transferred to thereservoir is challenging as discussed in Box 7.1. Compiler may
estimate these transfers, but this requires a higher tier method.

467

Table 1.2: Settlements (chapter 9). Please consider if possible BGB as apotential carbon pool in the subcategories of both Settlements Remaining
Settlements (SS) and Land converted to Settlements (LS) since urban
Norway468 green space can act as a carbon sink ( Strohbach et al 2012).

Noted

Belowground biomass may be estimated and reported at Tier 2
or 3 as discussed in Chapters 2 and 8.

Noted

Changes in C stocks are only estimated for Land Converted to
Other Land, but not for Other Land Remaining Other Landbecause these areas are typically exposed rock, glaciers orother similar areas without vegetation. Regardless, changed in
belowground biomass may be estimated for Land Converted to
Other Land using higher tier methods as discussed in thegeneric methods for Chapter 2 and additional guidance in
Chapter 9.

Noted

The removals are addessed in the soil C methods provided in
Chapter 2 and further guidance in each of the land use specificchapters for forest land, cropland, grassland, wetlands,
settlements and other lands.

467

Table 1.2: Other land (chapter 9). Below ground biomass might be apotential carbon pool in the subcategories of both Other land Remaining
468 other (OO) and Land converted to other land (LO).

469

Table 1.2: Managed soils (Chapter 11). Manged soils, depending on thetype of management and environmental conditions, can be both sourcesof emissions and potential greenhouse gas mitigation, e.g., no‐tillage,
application of biochar, animal manure and crop residues. Please consider
Norway470 both cases in the estimation of net carbon pools.

495

The use of allometric models for biomass estimation is written ingood details, meanwhile, it's still not easy to identify the best model
to be applied to assure that the model accuracy is equal or higher
than available default factors of Biomass Emission Factors (BEFs),
selection of the best model may steel in need for moreEgypt
542 improvements

Noted

As stated lines 495‐501 "The accuracy of the models may
be lower than e.g. available default factors or Biomass
Emission Factors (BEFs), so it is good practice to choose
the method with the higher accuracy". Guidance is thenprovided on how to select the best allometric model/s, inparticular lines 513 ‐ 531.

624

We think, and the text confirms it, that the use of biomass density maps
from remote data can only be accurate to estimate aboveground biomass.
Therefore, we ask for the inclusion of ABOVEGROUND in the title ofsection B. It would read "Using ABOVEGROUND biomass density maps
625 constructed from remotely sensed data for biomass estimation"
Spain

Accepted

We added "aboveground" in the title

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The text clearly says that aboveground biomass is the variable predictedfrom remotely sensed data, therefore, for estimating any other values,
root to shoot ratio SHALL be used, and not MAY be used. We urge tochange "may" by "have to", so the sentence would read "additional
information such as country specific data for root to shoot rations have toSpain
685 be used to estimate carbon stocks in other pools"

Accepted with
Modification

We changed the text to "are needed" to reflect this point

113

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1071

Table 2.2.: this table refers only to forests, therefore, it shall be moved tochapter 4, where it belongs. Keeping it here is not consistent with the
984 outline of the document or the structure of the chapters.
Spain
The stock change method, as Tier 1 method, continues being the default
method for estimating emissions and removals in SOC, therefore, wesuggest to add "(Default method)" at the end of the line 1066
Spain
1066
Delete the reference to "native lands" in the definition of reference
conditions. As they are defined it is impossible that there will be any
values for carbon stock in reference conditions, at least in Europe. Most of
the studies for determining carbon stocks in soils in the last decades havebeen developed in areas that have had some kind of human intervention
in the last centuries. Even SOCref referred in table 2.3. are mostly
comming from studies on "non‐native" lands. Therefore, we ask for thedeletion of "native lands" and its replacement by "before a change inmanagement"
Spain
1071

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add "direct" before "human activities and those that are..." in line 2410.
This would be consistent with ine 2437, where clearly indicates that thoseSpain
2411 direct human induced effects are the ones being discrimined.
Delete "and other scientific estimates of GHG balances". It is true thatthese data will be available and useful for other analysis different fromnational GHG inventories as such, but other scientific estimates are notSpain
2431 the aim of this refinement.

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2455

2455 add an "s" after wildfire. "natural disturbances, in particular wildfireS".

4

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Now is specified in the title of the section

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Accepted with
Modification

2

2

Country626

44Comments

in line with comment above, we ask for the inclusion of "ABOVEGROUND"
as first word in line 626, so the sentence would read "Abovegroundbiomass density maps are wall to wall....", and inserting the following
sentence after "trees.": " From these maps, other parameters can bederived". We need to make clear that the remote sensing technologies
will also produce aboveground biomass maps, and that, combining this
627 maps with other data sources, other estimations can be done.
Spain

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Rejected
Accepted

Accepted

The table is a refined version of the original table from the2006 GL that refered only to forest.
We agree that this change is needed because the heading is forboth the mineral and organic soils.

The sentence is altered to the following:"The reference condition for the Tier 1 method is defined asthat present in non‐degraded, unimproved lands under native
vegetation."

Rejected

The guidance does not aim to only disaggregate 'direct humaneffects' it aims to disaggregate natural disturbances fromhuman activities to reduce IAV contributed by non‐anthropogenic Natural Disturbances.

Accepted with
Modification

Text has been revised to state that this will make NIR estiamtes
more comparable with "other estimates of land‐related GHG
balances in the scientific literature"

Accepted

Text revised as suggested

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In this paragraph there is a clear difference between salvage logging andother management activites after natural disturbances, the difference
being that salvage logging can be considered harvested wood products
later, therefore, accounted twice if it is not explicitly identifiec in natural
disturbances reporting. Deforestation after NDs also needs a different
treatment, as emissions will need to be considered in the land conversion
lines in reporting tables. But for the other management activities (soilprotection, pests protection, seeding, etc.) there is no need todisaggregate emissions and removals. We propose to replace theparagraph by "if a country choses to disaggregate ND emissions andremovals, the it is good practice to disaggregate as anthrpogenic
emissions in NDs those resulting from salvage logging and defforestation,
Spain
2568 if applicable. "

2

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Stock difference with periodic measurements can often be used for thequantification of IAV emissions and removals and the drivers, and stock
difference with annual measurements can't always be used for thispurpose. We believe that this table is useles and missleading, and wesuggest its deletion, together with the explicative text below, that we also
Spain2512 find misleading and confusing.

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CH4 and N2O can be subject to subsequent removals in terms of CO2
equivalent, so the balance can be achieved to the total emissions
excluded on a CO2eq. basis. This should be reflected in the text. We
suggest replacing from "non‐CO2 emissions are not taken up by
vegetation" to the end of the paragraph by "non‐CO2 emissions will takelonger to be taken up by vegetation in terms of CO2eq, therefore, there is
expectatins that these emissions are to be balanced, but conversion
factors to CO2eq (i.e., GWPs) need to be taken into account. " This is how
European countries calculate their balance for natural disturbances. Not
only CO2 is taken into account, but also the N2O and CH4 emissions in
Spain
2620 CO2eq.
Second diamond box after start : Needs to distinguish between Land use
and management because a country may have reference C‐stocks fordifferent land use but not for management (which is more disaggregated).
In fact, it is unlikely that many country will have representative reference
stocks for different managements at national level, hence Box 2 would not
be used.
France1087
Third diamond box after start : Needs data on animal manure too

France1087

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Authors' notes
Text has been revised to further enhance the purpose of Table
2.6C.

Accepted with
Modification

It is well documented that stock difference with periodic
measurements at best provides a dampened measure of IAV
because each year only 1/n panels are measured (Röhling et al.
2016)

Rejected

The fact that emissions from human activities are consideredanthropogenic is the foundation of the IPCC GL. We therefore
reject the notion that some activities, e.g. those following anatural disturbance, could be considered non‐anthropogenic.
Note also that if a country chose to declare such emissions to
be natural (e.g. emissions from site rehabilitation after wildfire)then the subsequent removals would also have to beconsidered natural, as already outlined in the text.
The CH4 and N2O emisisons decay to zero in atmospherebecause of bio‐chemico‐physical process that are not includedin the NGHGI. Consequently, their balancing to zero cannot andneed not to be tracked within the NGHGI.

Accepted with
Modification
Noted

Accepted with
Modification

Although the original text has been revised with the followingchange to make it more clear: “… there is no expectation thatthese emissions will be balanced by removals because thebiological, chemical and physical processes that result in thecomplete decay of CH4 and N2O in the atmosphere are notcaptured
Reference stock refers to stock present non‐degraded,
unimproved lands under native vegetation (in essence underno management). The practices applied to managed soils haveno impact on the reference stock.

Given the decision to move the Tier 2 Steady State Modelling
approach to the Croplands chapter, it should no longer appear
in the generic discussion pertaining to soils. The third diamondhas beeen removed from the figure.

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Third diamond box after start : “if yes then use the steady state approach”(and for croplands use the Century based approach). This contradicts
l1334‐1339 where it is writing that it is possible (and not mandatory as I
understand from the decision tree) to use a steady state approach, butthat a prerequisite is that the model is evaluated country‐wise.

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Action: Remove the third diamond related to the Tier 2 SteadyState Modelling method from Figure 2.4

Rejected

The indicated references are not missing. They are present in
the list of references for soil organic carbon.

Noted

The method stated that “Tier 3 models may address the long‐term impacts of biochar on priming”, but did not specify thatthese fluxes must be included. It is accepted that priming iscurrently hard to predict. However, the intention was that theguidelines should be forward looking in thate sense that if
improved methods for predicting priming become available,
then inventory compilers should have the option to include
such calculations in a tier 3 assessment, provided that themethod used is explained, data‐driven, and scientificallydefended.

France1154
Proposing to account for biochar priming in the Tier 3 is not reasonable
nor feasible : (i) per se priming is not included in any of the IPCC
guidelines concerning biomass inputs, and this is correct as there is noevidence of long term major effect of priming on SOC stocks (while
priming is very important in the short term). So it is not coherent/
homogenous to introduce priming about biochar and (ii) There is noconsensus in the litterature on the priming induced by biochar as can befound in these published papers (Abbruzzini, T. F., et al. (2017), Azeem,M., et al. (2019). Bruckman, V. J., et al. (2015). Budai, A., et al. (2016).
Cely, P., et al. (2014). Cotrufo, M. F., et al. (2011). Cross, A. and S. P. Sohi
(2011). Cui, J., et al. (2017). DeCiucies, S., et al. (2018). Ding, F., et al.
(2018). Fang, Y. Y., et al. (2015). Fang, Y. Y., et al. (2017). Fischer, D., et al.
(2018). Gibson, C., et al. (2018). Jiang, X. Y., et al. (2019). Keith, A., et al.
(2015). Keith, A., et al. (2011). Kerre, B., et al. (2016). Liu, Y. X., et al.
(2018). Lu, W. W., et al. (2014). Lu, W. W. and H. L. Zhang (2015). Luo, Y.,
et al. (2011). Luo, Y., et al. (2017). Luo, Y., et al. (2018).Luo, Y., et al.
(2017). Maestrini, B., et al. (2015). McClean, G. J., et al. (2016). Mendez,A., et al. (2013). Naisse, C., et al. (2015). Purakayastha, T. J., et al. (2016).
Rittl, T. F., et al. (2015). Senbayram, M., et al. (2019). Su, P., et al. (2017).
Thangarajan, R., et al. (2014). Tilston, E. L., et al. (2016). Ventura, M., et al.
(2019). Ventura, M., et al. (2015). Wang, J. Y., et al. (2016). Wang, J. Y., etal. (2016). Wang, J. Y., et al. (2016). Watanabe, S. and S. Sato (2015).
Weng, Z., et al. (2015) Weng, Z., et al. (2018). Whitman, T., et al. (2014),
Woolf, D. and J. Lehmann (2012), Yu, Z., et al. (2018). Zheng, H., et al.
(2018). Zimmerman, A. R., et al. (2011). Zimmerman, A. R. and L. Ouyang(2019). Mention of biochar priming in Tier 3 should be deleted.

173

Accepted

France1087
Batjes (2010) and Batjes (2011) references are missing in the references
list.

171

Authors' notes
Action: Remove the third diamond related to the Tier 2 SteadyState Modelling method from Figure 2.4

France1087
Third diamond box after start : another option if you have disaggregateddata sufficient to run steady state approach is to use evaluated models toestimate disaggregated stock change factors for use in a stock change
factor Tier2 approach (as described lines 1361‐1366)

169

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Accepted

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In practice, data for model calibration (and for calibration of any relevant
process represented in the model) is often scarce and it is unlikely thatdata for both calibration and evaluation will be available. An alternative is
to use the data only for quantifying and modeling the bias and precisionof the model (see Box 2.2H) and include this statistical modeling in the
Tier 3 approach (more details in the Step 6, l.2257, and 7, l.2338, of theFrance2111 Tier 3 approach).

"Calibration data should, where possible, match the quality and scale ofdata sets used in the GHG inventory." the term "scale" is unclear. Does itmean here "spatial resolution" or "spatial perimeter"? Please consider
2111 rephrasing this term.

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Accepted with
Modification

Even in the case where an empirical model is developed toquantify uncertainty in the model, these data must be
independent from the data that are used to develop andparameterize the model. Otherwise, the uncertainties are
based on how well the model is calibated to the sites used in
the parameterization, and not how well the model predicts
emissions across the the spatio‐temporal domain of theinventory. Nonetheless, based on other comments the goodpractice text has been modified to be less specific.

Accepted with
Modification

Please detail the method (as it is done for the other steps of the varianceFrance2332 estimation)
This introductory paragraph in grey should introduce the term used inequation 2.24 for biochar amendments added to mineral soils

Accepted with
Modification
Accepted with
Modification

France

1024

Noted

It is good practice for the calibration data to be representativeof the environmental conditions occurring within the country.
In practice, this does not mean that all environmental
conditions are covered, but that the original calibration data
includes a range of the conditions existing in the country that isrepresentative of national circumstances.
A sentence has been added that the variance is estimatedbased on the two stage sample of the NRI and a reference isgiven more information. It is beyond scope of this guidance toprovide the full derivation of the two‐stage sample varianceestimation.
Action: The BCmineral equations from Equation 2.24 weremoved to Equation 2.25 to make it more clear that biochar has
been included just in the mineral soil section. A sentence forBCmineral has been included in the introductory paragraphfor Mineral soils.
This would add too much complexity for a Tier 1 method. Thisissue was already identified in the text and the fact that thelinear approach is an approximation was pointed out. The nonlinear dynamics can be addressed at higher tiers.

France1075
By contrast to the specific case of biochar addition to mineral soils, thisupdate does not provide improved guidance on stock change factors for
inputs of organic matter to mineral soils. Improved guidance on organic
amendments, their organic carbon contents and the long‐term fate of theadded carbon, depending on the nature of the organic amendment (e.g.
manures, slurries, composts, etc) would however be useful.

287

Authors' notes

FranceAssuming that soil organic C stock change during the transition to a new
equilibrium SOC occurs in a linear fashion over a period of 20 years is anapproximation. Numerous data point to non linear (e.g. exponential)changes with SOC being lost more rapidly in initial years after a change inmanagement leading to reduced SOC stock after 20 years.
E.g. Soussana et al., 2004. Carbon cycling and sequestration opportunities
in temperate grasslands. Soil use and management.
285

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Noted

France1102

Page 94

A literature review was conducted but there was not sufficient
data to update the input factors for other organic amendments.

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Most allometric equations (especially in Globallometry) are used to
calculate wood volumes. To switch to biomass, it is necessary to usewood densities (Réjou‐Méchain et al. 2017,https://doi.org/10.1111/2041‐210X.12753), a step to which
particular attention must be paid, particularly to reduce
uncertainties (Picard et al. 2015, https://doi.org/10.1007/s10310‐
015‐0510‐5). Global databases exist on this subject, including Zanne
et al. 2009's Global Wood Density Database(https://doi.org/10.5061/dryad.234/1) ‐ see also Flores andCoomes 2010 (https://doi.org/10.1111/j.2041‐210X.2010.00068.x).
This is a different issue from biomass density maps (section
2.3.1.1.3.B) so we suggest that additional explanations be provided
on aspects related to the use of wood densities in the section
France454 dedicated to allometric models (section 2.3.1.3.A).
We are doubtful about the treatment given to biochar in Chapter 2 ofVolume 4. Biochar is the subject of much scientific debate, which should
be assessed by the Special Report on Climate Change and Land (SRCCL).
Indeed research is still undertaken to know if there are not negative
impacts when used on agricultural soils, including in terms of GHG
emissions and removals. In view of these scientific uncertainties, we ask
that a careful review be carried out on all developments specific tobiochar. In particular, we consider that several points suffer from a lack of
information and should be improved, in particular the lack of coherence
between the assumed 1000 year time frame for measuring the fraction ofcarbon remaining unmineralized, and the non‐consideration ofinteractions between the fate of carbon and soil types or land
management. Also, the equations proposed do not include some
limitations of biochar, in particular the consequences on above‐groundand below‐ground biomass (via the plant growth) of the imbalance in theratios between carbon and other soil elements caused by the addition ofbiochar. On this topic, please consider the following article: Kavitha, B.,
Reddy, P. V. L., Kim, B., Lee, S. S., Pandey, S. K., & Kim, K. H. (2018).
Benefits and limitations of biochar amendment in agricultural soils: A
review. Journal of environmental management, 227, 146‐
154.(https://doi.org/10.1016/j.jenvman.2018.08.082).

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Noted

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Authors' notes

The importance of wood density is included in theguidance in Chapter 2.3.1.1. Refer also to section "The useof allometric models" lines 495 ‐542, where different
properties (volume, mass, C stocks) are referred to as
possible results of the application of allometric equations.
We are not endorsing biochar amendments as a best
management practice. The Special Report and other related
documents are the proper place to discuss merits and problems
with biochar amendments. However, it is an anthropogenic
activity that impacts soil C stocks, and accordingly addressed inthis report to estimate anthropogenic greenhouse gas
emissions and removals.
Incorporation of impacts of biochar type and chemical
attributes, soil type, climate and interactions on persistence
would move the method to Tier 2 or 3.

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TolineComments
We are doubtful about the treatment given to biochar in Chapter 2 ofVolume 4. Biochar is the subject of much scientific debate, which should
be assessed by the Special Report on Climate Change and Land (SRCCL).
Indeed research is still undertaken to know if there are not negative
impacts when used on agricultural soils, including in terms of GHG
emissions and removals. In view of these scientific uncertainties, we ask
that a careful review be carried out on all developments specific tobiochar. In particular, we consider that several points suffer from a lack of
information and should be improved, in particular the lack of coherence
between the assumed 1000 year time frame for measuring the fraction ofcarbon remaining unmineralized, and the non‐consideration ofinteractions between the fate of carbon and soil types or land
management. Also, the equations proposed do not include some
limitations of biochar, in particular the consequences on above‐groundand below‐ground biomass (via the plant growth) of the imbalance in theratios between carbon and other soil elements caused by the addition ofbiochar. On this topic, please consider the following article: Kavitha, B.,
Reddy, P. V. L., Kim, B., Lee, S. S., Pandey, S. K., & Kim, K. H. (2018).
Benefits and limitations of biochar amendment in agricultural soils: A
review. Journal of environmental management, 227, 146‐
154.(https://doi.org/10.1016/j.jenvman.2018.08.082).

Country

4

2

1725

Authors' notes
We are not endorsing biochar amendments as a best
management practice. The Special Report and other related
documents are the proper place to discuss merits and problems
with biochar amendments. However, it is an anthropogenic
activity that impacts soil C stocks, and accordingly addressed inthis report to estimate anthropogenic greenhouse gas
emissions and removals.
Incorporation of impacts of biochar type and chemical
attributes, soil type, climate and interactions on persistence
would move the method to Tier 2 or 3.

Noted

We are not endorsing biochar amendments as a best
management practice. The Special Report and other related
documents are the proper place to discuss merits and problems
with biochar amendments. However, it is an anthropogenic
activity that impacts soil C stocks, and accordingly addressed inthis report to estimate anthropogenic greenhouse gas
emissions and removals.
Incorporation of impacts of biochar type and chemical
attributes, soil type, climate and interactions on persistence
would move the method to Tier 2 or 3.

France1436
We are doubtful about the treatment given to biochar in Chapter 2 ofVolume 4. Biochar is the subject of much scientific debate, which should
be assessed by the Special Report on Climate Change and Land (SRCCL).
Indeed research is still undertaken to know if there are not negative
impacts when used on agricultural soils, including in terms of GHG
emissions and removals. In view of these scientific uncertainties, we ask
that a careful review be carried out on all developments specific tobiochar. In particular, we consider that several points suffer from a lack of
information and should be improved, in particular the lack of coherence
between the assumed 1000 year time frame for measuring the fraction ofcarbon remaining unmineralized, and the non‐consideration ofinteractions between the fate of carbon and soil types or land
management. Also, the equations proposed do not include some
limitations of biochar, in particular the consequences on above‐groundand below‐ground biomass (via the plant growth) of the imbalance in theratios between carbon and other soil elements caused by the addition ofbiochar. On this topic, please consider the following article: Kavitha, B.,
Reddy, P. V. L., Kim, B., Lee, S. S., Pandey, S. K., & Kim, K. H. (2018).
Benefits and limitations of biochar amendment in agricultural soils: A
review. Journal of environmental management, 227, 146‐
154.(https://doi.org/10.1016/j.jenvman.2018.08.082).

297

Responses
Noted

France1745

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TolineCountry
Land management after naturalComments
disturbances includes forest salvaging,but also many other activities, such as site rehabilitation, water erosion
prevention, removal of dead shrubs and dead non‐commercial trees,
replanting or seeding, etc. (as highlighed in Lines 2830‐2832). This
paragraph suggests that all management is to be consideredanthropogenic, but salvaging and deforestation are different from othertypes of management and should not be treated equally (that was theconsensus in KP accounting rules). The paragraph seems to suggest thatthe best course of action is to “do nothing” on burnt areas. This may wellbe the case in some remote areas, but it is certainly not in densely
populated areas and/or with actively managed forests and landscapes.
The difference mostly lies in the fact the salvaging will avoid emissions inother forestlands. Treating salvaging as non‐anthropogenic emissions
would lead to an imbalance in emissions reporting in forest land, i.e. the“extra” removals in non‐affected lands would count, but the “extra”
emissions in burnt areas wouldn’t. Deforestation does not guarantee any
future removals and is by nature a human induced decision and so it isconsensual that it should be treated as anthropogenic. On the other hand,
other types of management aim at speeding up post‐fire recovery and thequality of the future forest.
We suggest these nuances should be inserted into the text, as perfollowing editorial suggestion:“If a country chooses to disaggregate ND emissions and removals, then it
is good practice to disaggregate as anthropogenic the emissions andsubsequent removals. As discussed above, the non‐anthropogenic natureof the emissions can be determined by either non‐anthropogenic events
and/or non‐anthropogenic circumstances beyond the control and not
2568 materially influenced by a country. However, it is good practice to include France

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Authors' notes

The fact that emissions from human activities are consideredanthropogenic is the foundation of the IPCC GL. We therefore
reject the notion that some activities, e.g. those following anatural disturbance, could be considered non‐anthropogenic.
Note also that if a country chose to declare such emissions to
be natural (e.g. emissions from site rehabilitation after wildfire)then the subsequent removals would also have to beconsidered natural, as already outlined in the text. This
guidance is designed to estimate and report emissions andremovals and does not suggest any "course of action". The
purpose of the GL is not to incentivise or discourage specificactions but to estimate the emissions resulting from actions.

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2830

Land management after natural disturbances includes forest salvaging,but also many other activities, such as site rehabilitation, water erosion
prevention, removal of dead shrubs and dead non‐commercial trees,
replanting or seeding, etc. This paragraph suggests that all management is
to be considered anthropogenic, but salvaging and deforestation are
different from other types of management and should not be treatedequally (that was the consensus in KP accounting rules). The paragraphseems to suggest that the best course of action is to “do nothing” onburnt areas. This may well be the case in some remote areas, but it iscertainly not in densely populated areas and/or with actively managed
forests and landscapes.
The difference mostly lies in the fact the salvaging will avoid emissions inother forestlands. Treating salvaging as non‐anthropogenic emissions
would lead to an imbalance in emissions reporting in forest land, i.e. the“extra” removals in non‐affected lands would count, but the “extra”
emissions in burnt areas wouldn’t. Deforestation does not guarantee any
future removals and is by nature a human induced decision and so it isconsensual that it should be treated as anthropogenic. On the other hand,
other types of management aim at speeding up post‐fire recovery and thequality of the future forest.
France2832 We suggest these nuances should be inserted into the text.

2616

The balance of non‐CO2 gases emitted through natural disturbances on
managed lands cannot be reached on a gas‐by‐gas basis but can beconsidered on a CO2eq basis and/or a lower anthropogenicity in thesubsequent removals. According to the first option, GHG emissions,
including CH4 and N2O emissions, could be balanced by future CO2
removals, leading to an higher stock than the pre disturbed levels.
According to the 2nd option, using the of distinction between
anthropogenic and non‐anthropogenic, the additional CO2 balanceneeded to offset non‐CO2 emissions can be made by reducing theanthropogenicity of subsequent removals.
We suggest the following editorial suggestions:“In addition to CO2 emissions, natural disturbances may cause non‐CO2emissions, e.g. wildfires cause N2O and CH4 emissions. While CO2
emissions are assumed to average out across time because of vegetation
regrowth after disturbance, non‐CO2 emissions are not taken up by
vegetation and therefore balancing these emissions by removals can only
be made if there is a reasonable possibility for future forest C Stocks toexceed the pre‐disturbance levels by an amount equivalent to the non‐CO2 gas emissions and/or by reducing the share of removals consideredFrance2620 anthropogenic by a level equivalent to the non‐CO2 gas emissions.”

Page 98

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Rejected

Authors' notes

This paragraph only calls for documentation (and thustransparency) of the methods and assumptions made by acountry. This text makes none of the assupmtions specified by
the reviewer. In particular, there is no suggestion in the text inlines 2830 to 2832 about the course of action to take, or thatsalvage should be treated as non‐anthropogenic emission.
Earlier in the text it was stated that management activities suchas salvage logging or site rehabilitation of areas affected bynatural disturbances that cause emissions that are
anthropogenic and that subsequent removals on ND lands canbe used to balance these emissions.

The CH4 and N2O emisisons decay to zero in atmospherebecause of bio‐chemico‐physical process that are not includedin the NGHGI. Consequently, their balancing to zero cannot andneed not to be tracked within the NGHGI.

Accepted with
Modification

Although the original text has been revised with the followingchange to make it more clear: “… there is no expectation thatthese emissions will be balanced by removals because thebiological, chemical and physical processes that result in thecomplete decay of CH4 and N2O in the atmosphere are notcaptured2019 Refinement ‐ Collated Comments on Final Draft from Governments with Authors’ Responses

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The equation to take into account biochar effect is strange because it also
includes emissions relative to its production. It seems contrary to usual
methodologies which estimate actual emissions/removals when andwhere they occur. It seems much more logical to take into account CH4
and N2O emissions from biochar production in energy sector and carbon
storage in AFOLU. This equation looks like a life cycle analysis which isquite unusual in IPCC guidelines for emission/removal calculation.

Country

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Authors' notes
It has now been decided that emissions of non‐CO2 GHGs (e.g.
CH4 and N2O) during the heating process used to produce
biochar will be recorded in the Energy sector of national
inventories (see Volume 2, Chapter 4, Table 4.3.2.1 for values
associated with charcoal production).

Accepted with
Modification

Such changes to Equation 2.24 were discussed by the authorgroup. It was decided not to change the subscripts because
they are well known to inventory compilers and changing them
could cause uncertainty. However, it is accepted that thebiochar term creates an imbalance, and in fact, this practice ispart ofh the mineral soil C method. We therefore have moved
the biochar C term to the mineral soil C calculation in Equation
2.25.

France1216
This equation ΔCsoil = ΔCmineral ‐ Lorganic + ΔBC + ΔCinorganic is notvery balanced. As mentionned in the text, biochar could be included in
Δcmineral, there are other products which may lead to very stable carbon
in soil (it is likely that the IPCC won't change but it is proposed to name it
ΔCbiochar). Lorganic could also be ΔCorganic even if especially losses are
expected.

353

Responses
Accepted

France

1027

459

4

2

298

461

4

2

1236

463

4

2

2479

Please, delete sentence "Losses are always marked with a negative (‐)
sign." ‐ as with negative sign usually are marked not losses, but removals.
Additionally, saying that losses have negative sign bring a confusion for
eq.2.4 ‐ as losses are subtracted from gains and it is not clear if it is meant
Russian Federation Rejected
298 like: gains ‐ (‐losses)= gain+losses
The sentence seems unclear: The quantity of sequestered carbon will be
Accepted
greater than for times less than 1000 years, and very slowly decline below
Russian Federation
1237 FPERMP thereafter, with FPERMP .
The justification for usage of natural disturbances provisions only forsome land categories and not for another needs to be more robust. "Largecarbon stocks" are to be defined with numbers or a such limitation in
Russian Federation Accepted2483 usage of provisions should be deleted at all.

2479

As the proposed methodology includes disaggregation of natural andanthropogenic disturbances on managed land and if country would like toapply a such refined approach ‐‐ in that case it should be stated that
disturbances of unmanaged lands to be disaggregated as well as. And theeffects of all considered anthropogenic caused disturbances to be
Russian Federation Rejected2492 reported in the GHG inventory.

By definintion anthropogenic emissions and removals do notoccur on unmanaged lands. If they do the land should beclassified as managed. Moreover, there is no reporting
requirement for E/R on unmanaged lands.

2494

Not clear if emissions from ND will never balanced by removals on
particular unit of land ‐‐ should country report the difference once? Orshould document what activities have been implemeneted to ensure theestablishment of the same C stocks on that land as prior to ND? Though2498 these are natural disturbances, but the land is still MANAGED.

The current text clearly explain that in the absence of land usechange (deforestation) the expectation of balance is always inplace. If regeneration after disturbance fails, then there are no
removals to report. Countires should report emissions andsubsequent removals as they occur, even if in some cases theremovals can occur over a long period.

465

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Russian Federation Rejected

Changes in grey text not under refinement
The sentence was removed as it did not add anything
substantial to the text or interpretation.

Deleted reference to "large carbon stocks".

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Authors' notes
Non‐CO2 emissions from natural disturbances are
disaggregated (if chosen by the country) and reported in the
ND component of the MLP emissions and remvoals. Theirbalance over time is achieved through atmospheric processes,
not through removals in the ecosystem and these are notincluded in the NGHGIBoth natural and anthropogenic effects contribute to the annual
disturbances (see rows 2455 and 2456). However current methodology
only suggests fully excluding emissions and removals from disturbances
without reporting of the anthropogenic part of the effect. There is no
guidance on how always disaggregate such anthropogenic component ofemissions and removals caused by any disturbances. Please add thecorresponding guidance on estimation of anthropogenic component in
Russian Federation Rejected2592 emissions and removals when any disturbances occur.

WIP ‐ Authors appreciate the request of the reviewer. The
approach outlined on the separation of disturbance emissions
and removals into "anthropogenic and natural" is based on the
disturbance type and disturbance severity. Emissions fromdisturbances that are associated with managenent (e.g. slashand burn or fires on drained peatlands) are consideredanthropogenic emissions, while those due to wildfires (e.g.
caused by lightning stike or beyond the control of humans) areconsidered natural emissions. Thus for any individual
disturbance event, the guidance request to "place" allemissions into either the anthropogenic or ND component. It is
recognised that emissions from some disturbance events thatare considered natural, may contain an anthropogenic
component and conversely, some emissions from ananthropogenic component may be affected by natural effects.
This is why the guidance refer to the resulting estimates ofanthropogenic E/R as a second order approximation. A perfect
separation (i.e. guidance on estimation of anthropogenic
component in emissions and removals when any disturbances
occur) is not possible at the moment but it assume that themutual overlap cancels out, to some extent.

It should be clarified here about non‐CO2 emissions from natural
disturbances: following to the suggested logic these emissions should be2496 fully reported.

Suggest to also elaborate or describe the role of parameter "a" inthe allometric equation. Based on the equation, it seems that bothparameters "a" and "b" influence the proportionality between thePhilippines
488 relative increases of "x" and "y".
It seems the list of conditions is not complete, with missing bullets
Philippines
525 or a paragraph is missing.

Responses

Accepted with
Modification Text is revised and the parameters clarified
The list provided is indicative it does not intend to be
Notedcomplete

723

4

2

478

725

4

2

521

727

4

2

726

905

4

2

798

In Box 2.0E, the figure indicates a unit of "AGB Mg/ha". For consistency, it
727 is suggested that the unit be replaced by "AGB Mg C/ha"
Philippines
Format of the reference in the text should follow the same form to ensure
Republic of Korea
798 the consistency of the format.

907

4

2

655

Minimum spatial resolution needs to be further presented to ensure the660 accuracy of the data.

Republic of Korea

Accepted with
Modification

This section is about biomass maps and a unit in biomass units
is fine.
Formatting of references will be standardised (i.e. either "etal.," or "et al.") across all the docuement
We noted some inconsistency in the text and revised it toprovide clarity on optical sensors and their resolution in thesecond paragrpah of the box

909

4

2

818

819 A bracket omission of ")" should be added after Haron et al., 2013)")".

Republic of Korea

Accepted

Editorial fixing

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TolineComments

Country

The format of table 2.2 should be revised. The variation of the default
984 value shown in the table is too large to represent the data ability.
As the soil carbon maps presented as an activity data for this section are
made in a global scale, it may be appropriate to use Tier 1 level rather
1517 than Tier 3.

Republic of Korea

An Allometric Model, which is of great limitation in application, isonly suitable for small‐scale projects or stand level, but not for large
scale and national‐level greenhouse gas inventories. Due to thecomplexity of its application, this can not be regarded as a "goodpractice". Moreover, this section, which gives only a conceptual
description of “Allometric Models ", does not indicate how to use it
in inventory preparation. So it is suggested to give instructions inthis connection. If they are not available, it is suggested to delete
China
560 the mention of this model directly.

973

4

2

818

1073

4

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1216

2348

Comparison of model‐derived inventory estimates with the estimates ofthe previous submissions is not verification with independent data (ascaption says) but normal QA/QC, please remove ‐ unless different model
was used in the previous submission but that would need more guidance
Finland2349 to be clear to inventory compilers.

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Authors' notes

Rejected
Accepted

The format of table 2.2 was kept from the 2006 GL, but thecontent was revised, based on an substantial literature review.
The variation reflects the literature considered.
References removed

Rejected

The concerns are all addressed in the guidance. Allometricmodels are often used at national scales. Guidance isprovided at the level required for inventory compilers toundestand in which context they can be used and not
given concrete models or instructions how to constructthem. There is already a considerable body of work
available in the literature on the application of allometricmodels that can be consulted. As allometric models are incommon use in inventories in particular when tier 2 isused, some general guidance for inventory compilers wasconsidered necessary.

Republic of Korea

Considering the decomposition of dead wood, it is not appropriate to set
its Carbon Fraction (CF) at 0.5. So it is suggested that its CF be revised to
819 0.37 the same as Litter.
China
The equation 2.26A (New guidance) for estimation of annual soil C stockchanges associated with biochar amendments include terms "global
warming potential of methane and nitrous oxide produced during
pyrolysis in unit of CO2 eq". The meaning of these terms in equation is notproperly explained but indicate that CH4 and N2O emissions formed
during the pyrolysis process to produce biochar would be subtracted fromthe C stock changes when biochar is used as a soil amendment. This does
not seem consistent with general prinicples applied in IPCC Gls toestimated emissions of CO2, CH4 and N2O separately, and also to reportemissions where they occur. It could also lead to double counting ofemissions when these emissions would be reported in the energy sector(see Vol. 2, chapter 4). Please clarify the meaning and revise the equation,
as appropriate.
Finland1234

1075

Responses

Rejected
Accepted

RejectedThank you for the comment, we have clarified that this value isfor temperate tree species. Unfortunately there is very little
data on this topic so the values given here are default values, tobe used if no more detailed information is available. The
transition from wood to litter is gradual, as is the change in CF,
and setting the CF of dead wood equal to that of litter would beincorrect.
It has now been decided that emissions of non‐CO2 GHGs (e.g.
CH4 and N2O) during the heating process used to produce
biochar will be recorded in the Energy sector of national
inventories (see Volume 2, Chapter 4, Table 4.3.2.1 for values
associated with charcoal production).

The text does not suggest comparisons with previous inventory
estimates as a verification process. Rather we note that is it
possible to use other data sources, such as harvest statistics, tohelp verify the mdoel results, while noting the potential issues
when doing so.

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Authors' notes

Text in Chapter 1 has been revised to further clarify the
purpose of Chapter 2.6 in line with the 2019 Refinement ToR.
Nevertheles, authors disagree with the reviewer's suggestionthat is "best suitable for an appendix" and the assessment that"practically no methodological guidance for interannual
variability" was given.

1077

1079

4

4

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2

2382

Is the section on interannual variability in line with the Terms ofReference? The focus is on ND that are not mentioned in the TOR but very
little guidance is given for ND (best suitable for an appendix) and
2832 practically no methodological guidance for interannual variability per se. Finland

2454

Please place the draft guidance on ND to an appendix as there are notenough guidance given, no scientific method i.e. no mention what would
Tier 1 be (or assumptions of it to be zero) and in addition, the current
guidance appears to be a mixture of no guidance and some rules that canbe interpreted to be more accounting rules than IPCC guidance (examples:
proportion with which the subsequent removals should be allocatedbetween ND and anthropogenic activity, taking into account current
removals occuring on sites of the past natural disturbances (pre‐1990) tobalance out current ND losses). There is no guidance for taking into
account the carbon storage in soil as well as in DOM pools in case ofnatural disturbances which would be needed if this ND guidance were to
Finland2832 remain in Chapter text and not placed in an appendix.

Accepted with
Modification

Rejected

IPCC guidelines sets a strong precedent for enabling countries
to apply their own definitions and methods within theframework of good practice and this section continues thisapproach. This section provides inventory compilers with theframework for developing country specific estimates following
IPCC guidance, rather than dictating to countries how theymust implement their inventory.

The method proposed is not an additional methodological tier,to be applied. It is just a refinement that countries that wish to
do so can apply to refine the managed land proxy. Itsapplication does not impact any of the methodologicalguidance provided by IPCC on how to estimate GHG emissions
and removals from carbon pools (including soils) in land use
categories.
The term countries has beed used consistently throughout all
2019 Refinement to refer to countries collectively (generically)rather than individually.
Country examples are given in boxes with the caveat that boxes
are "for information only and neither adds guidance nor
overrules guidance provided”.

1081

1083

4

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2

2454

Please remove frequent references to countries in the text, i.e. theguidance should not be based on approaches or conditions of individual
countries but should consist of more generic guidance approved by the2832 experts and supported by literature.

Finland

Rejected

In addition, according to "instruction to Authors" within the2019 Refinement ToR "Lead authors must consider all recent
scientific developments and national methods used bycountries in their inventories”.

2407

IPCC Expert Meeting Report would be the correct title, as it is not aquestion of reviewed report compiled by experts but a meeting report asstated in the list of references as well and given as a citing
Finland2408 recommendation in the report in question. Please correct.

Accepted

Text revised as suggested

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TolineComments

Country

Please remove the example referring to savannahs. The example ispresented under natural disturbances but there is a strong component of
human activity in frequent burning of savannahs thus this example
should not included under heading of natural disturbances, especiallybecause of the definitions of natural disturbances that follow. Please see
for instance Laris et al. (2015). The Human Ecology and Geography of
Burning in an Unstable Savanna Environment. Journal of Ethnobiology. 35.
111‐139. 10.2993/0278‐0771‐35.1.111.for a reference on the
Finland2462 anthropogenic origin of frequently burning savannahs.

Responses

Accepted

Authors' notes

Reference to savannah has been deleted.
Text has been revised to enhance clarity.

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4

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2566

1089

4

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2595

1091

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2820

1093
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2820
2777

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1053

Please check the use of "proportionally" which is not supported by theexample following "proportionally". Subsequent removals that exceed
original losses allocated to ND and are thus allocated to anthropogenic
activity may exceed the original losses salvaged in salvage logging. The
example appears to be an accounting rule, not a emissions/removals
Finland2576 calculation guidance. Please reconsider the guidance.
In text and in Box 2.2L: The term of "Refined MLP" contradicts the conceptof the Managed Land Proxy. Please rename as the guidelines clearly
indicates that the approach of the MLP is maintained in the 2019
Finland2596 Refinement.
Box 2.2L and elsewhere: Please reject the term "total fluxes" and its
abbreviation CO2‐e as use of fluxes is not consistent with the rest of theFinland
2820 2006/2019 GL.
Box 2.2L: what does start year refer to? To ND events in the past (pre‐Finland
2820 1990) or what?
Finland2777 Box 2.2K: footnotes 27‐32 are missing from the pdf.
Recommend changing to 100 years. 1000 years is overly conservative andinconsistent with the permanence requirements for other sequestration
measures.
Australia

1053

Page 103

Accepted with
Modification

The user is correct that the removals are allocated"proprotionally" only until the ND emissoins are balance by ND
removals and we have added text to indicated this. Thereafter
all removals are allocated to the anthropogenic component.
However, authors do not consider this to be an accounting rule
but a specification required to ensure balanced allocation ofremovals to ND and anthropogenic components.

Accepted

We revised the text to replace the term "refined MLP flux" with"second order approximation of anthropogenic emissions andremovals".

Accepted
Accepted
Accepted
Accepted

Text has been revised to replace "fluxes" emissions
Start year refers to the first year in the inventory time series,
e.g. 1990. We have added a footnote to clarify.
Footnotes added
The permanence period has been changed to 100 years to beconsistent with the permanence requirements for othersequestration measures.

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Comment: We welcome the inclusion of guidance on calculation ofbiochar C, and largely agree with the approach. Ideally pyrolysis
temperature should not be the distinguishing factor for biochar
persistence but rather the elemental ratio H:Corg (at least to some extent
long residence time can substitute for lower temperature, in terms ofdegree of carbonisation). We acknowledge the need for the Tier 1 method
to be simple to apply, but are not convinced that it is easier to obtain dataon kiln temperature than chemical analysis of biochar. Also, theconsiderably higher stability assumed for higher temperature char does
not have strong basis, and may encourage gasification instead of slow
pyrolysis, with net reduction in biochar produced, and biochar with lower
agronomic value. Also, as noted at line 1053, 1000 years is overly
conservative as a "permanence period". 100 years would be consistent
with permanence requirements for other sequestration measures.

Country

Responses
Accepted with
Modification

Authors' notes
The calculation of Fperm has been changed from a linear
regression to heating temperature categories to account for the
known non‐linearity between pyrolysis temperature andbiochar C persistence. Justification for this change has been
added to Annex 2A.2. The Tier 1 methodology was based intemperature rather than biochar properties (such as thementioned H/Corg or O/C ratios) to facilite accounting in theframework of a Tier 1 method. H, O, and C analyses using
Dumas combustion requires specialized equipment that is notavailable in many countries. In addition, costs for analyses will
also constrain the applicability of the method. Mandating theuse of elemental ratios will reduce the ability to account forbiochar additon to mineral soils. Countries with the ability tomeasure biochar properties are encouraged to use therecommended Tier 2 and 3 methods; appropriate reference
was added to the method and appendix.
The text in Annex 2A.2 defining how Fperm was calculated wasrevised. The revised values of Fperm have been added to Table
2.3B. Text has also been added to Annex 2A.2 defining thepotential use of O/C and H/C ratios in higher Tier methods.

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Australia

1215
Recommend noting the possibility of measuring SOC stock change byequivalent mass rather than depth, as this requires consideration of C
stock below 30cm depth.

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1579

2499

The following sentence has been added:
For developing a Tier 2 method it would also be possible todefine reference SOC stocks and SOC stock change factors
using an equivalent mass approach (see Box 2.2B) rather thanan approach based on a fixed depth.

Accepted with
Modification

In point 2) the relationship between the measureable fractionsof SOC (particulate, humus and resistant) to the respectivemodel pools (resistant plant material, humus and inert) is
identified. The inert fraction is clearly identified. References
are provided that go into detail about this relationship andwhat the fractions and pools represent.
In point 5) the calibration of the model pools is discussed using
the terms applied to the model pools. However, in referring to
the resistant plant material pool, it was only labelled as
resistant which could cause some confusion.

Accepted

Examples were added for clarification.

Australia

1333
Recommend clarification: Three fractions are mentioned in line 1554:
particulate, humus and resistant. It is not clear whether "decomposable
and resistant plant materials" are included in one of these fractions.
Derivation of decomposition rates of resistant and humus fractions is
mentioned, but not for particulate fraction. Line 1585 introduces the term
inert fraction which is not mentioned previously ‐ is it different fromresistant?

1159

Accepted

Australia

1585
Recommend describing an example of regeneration failure: e.g. wildfire
that leads to loss of veg cover on steep slope; subsequent heavy rainfall
removes soil ‐ no capacity for regeneration in human timeframe.

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TolineComments
Recommend clarification: presumably this applies just to CH4 ‐ i.e. weneed auxiliary data to know whether the C loss detected by stock
2523 difference was emitted as CO2 or CH4.

Country

Australia

Responses

Accepted

Authors' notes
Text has been revised to indicate that non‐CO2 GHG here refers
to both CH4 and N2O emissions from fires.

The disclaimer is relevant to all boxes describing examples thatare given for information purpose and do not represent
guidance. In addition, is worth to clarify that the term “New
Guidance” has been used across headings of all proposed newboxes in the 2019 Refinement to indicate that the boxes
contain new text (compared to the current text of the 2006 GL)
introduced as a proposed refinement.
Text has been revised to remove the word "Guidance" from theboxes as these are examples of national methods, not"Guidance".

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General2 comment

1169

1225

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2625

Recommend clarificaiton: Is this disclaimer relevant to all the other boxes
describing examples? If so, explain this up front ‐ e.g. in Chapter 1, anduse a short‐hand form in the relevant Boxes ‐ e.g. "Informative"
Australia

3664

Comment: The examples and guidance on Tier 3 methods is welcomed, as
is the inclusion of guidance and methods for estimating biochar carbon. Australia
Recommend including the recent meta‐analyses showing reduction in
N2O eg Borchard et al found overall N2O reduction of 38%. These
additonal papers shodul be cited to support the case that it is highly
conservative to assume no effect of bicoahr on N2O.
Australia
3669

2385

Comment: Section 2.6 provides much needed guidance on inter‐annual
variability due to natural disturbance events such as wildfires, insect
infestation, extreme weather events, etc. It provides methodologicalapproaches to disaggregate natural and anthropogenic components withcountry examples. The gudiance is well balanced in the treatment of2684 natural effects with due consideration of managed land proxy principles. Australia

Accepted with
Modification

Noted
Accepted with
Modification

Noted

Clarification are also included in the Mapping Tables to clearly
indicate if the boxes is for information purpose only.

References to the Borchard et al and Liu et al papers have been
added to the "Nitrous oxide emissions from soil after biochar
amendment" section of Annex 2A.2. The Nguyen et al paper
did not report on nitrous oxide.

We appreciate the positive feedback.

Section 2.6 states in a number of places that the guidance inthe section is "voluntary" as suggested by the reviewer.

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2381

Volym 4 chp 2 Rad 2381 2.6 INTER‐ANNUAL VARIABILITY ‐ The issue ofinterannual variation is important and guidance would be useful.
However, the division of what is anthropogenic and what is not is still notvery resolved. If guidance is to be included this part, it should be voluntary
Sweden2381 to follow.

Page 105

Accepted with
Modification

The section as a whole adequately addresses thedisaggregation of antrhopogenic and interannual variability due
to natural disturbances, even if the division is not fully resolved(due to the fact that it will not be possible to completely
disaggregate all natural effects), it is an improvement over the
MLP without this additional disaggregation

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Country2381

The chapter should only focus on transparency elements for reporting on
Natural Disturbances (ND). Parties interested in using this voluntaryprovision should be encouraged to report disaggregated emissions andremovals in addition to the total emissions and removals. Yet, it is ofparamount importance that disaggregation does not affect the totalreported GHG emissions and that the sum of disaggregated elements isequal to the total GHG emissions and removals. Any quantification
provided for calculating ND must not be added to or subtracted from theEU
2832 total GHG emissions and removals.

2381

Use of the Managed Land Proxy Chapter 2.6 needs to state more clearly
that use of the Managed Land Proxy (which is recommended as goodpractice in the chapter) involves a country reporting total emissions frommanaged land. In several places, the chapter creates confusion byreferring to the concepts of ‘natural’, ‘human‐induced’ and‘anthropogenic’ emissions in an inconsistent manner. The addition of new
2832 terminology such as “refined MLP fluxes” further adds to this confusion. EU

Responses

Authors' notes

Accepted

The chapter does exactly what is requested by the reviewer.
The box on reporting outlines that countries that chose to
disaggregate are to report the total as well as the disaggregatedcomponents.

Accepted

Further clarification text added to reiterate 'all emissions andremovals on managed land'. However, we do suggest that theapproach outlined here is a second order approximation of theanthropogenic E/R in the managed land.

The term to fire was replaced by "wildfire" to distinguish iffrom fire associated with management actions.
Withoug further specification of what the reviewer considers to
be "unscientific statements" authors are not able to respond.

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Natural vs anthropogenic phenomena. Chapter 2.6 contains several
unscientific statements regarding whether specific phenomena are to beconsidered natural or anthropogenic. For example, line 2392 mistakenly
2832 refers to “fire” as a natural disturbance.

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EU

Accepted with
Modification

Moreover, the example given in line 2392 states "such as fire…"
it does not state that all fires are natural disturbances. And
throughout the boreal forest (and other forests of the world)
the primary cause of area burned is ignition from lightning
strikes.

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Country

Responses

Authors' notes

Text in Chapter 1 has been revised to further clarify the
purpose of Chapter 2.6 in line with the 2019 Refinement ToRand the outcomes of the May 2009 expert meeting on the MLP.
Nevertheles, authors disagree with the reviewer's
interpretation of the Expert Meeting outcome based on twoquotes from the report:

1461

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2381

This introductory section should clarify the purpose of Ch2.6 by making
explicit reference to the ToR and the outcome of the May 2009 expert
meeting on the Managed Land Proxy. In particular, this meeting agreed
that annual emission inventories should estimate the actual emissions in
the inventory year and that the aim of emission inventories is not to try to
remove or reduce the impact of inter‐annual variations (see conclusion 5
EU2418 in the expert meeting report).

1) "While the meeting agreed that annual emission inventories
should estimate the actual emissions in the inventory year, it
was also noted that there is a need to be able to identify the
impact of mitigation and management efforts even wherethese are obscured by inter‐annual variations in greenhousegas fluxes for example by the impacts of natural processes (e.g.
wildfire) or indirect human‐induced processes (e.g. climatechange impacts)"; andAccepted with
Modification

2) "The meeting hoped that further work by the scientificcommunity will result in more mature approaches which can beassessed at a later date."
Text has been revised to delete the last sentence of theparagraph in line with the assessment that “... it is impossible
by definition that existing inventories are following thisguidance”.
Nevertheless, authors disagree with the assessment of thereviewer that "Examples of the existing methods for separationof natural and anthropogenic effects in inventories should not
be included in this guidance”.

1465

1467

4

4

2

2

Examples are given in boxes with the caveat that boxes are "forinformation only and neither adds guidance nor overrules
guidance provided”.

2408

Examples of the existing methods for separation of natural andanthropogenic effects in inventories should not be included in thisguidance. Section 2.6 provides new material as far as inventory guidanceis concerned. Therefore, it is impossible by definition that existing
inventories are following this guidance. The last sentence of the2409 paragraph should therefore be deleted.

EU

Accepted with
Modification

In addition, according to "instruction to Authors" within the2019 Refinement ToR "Lead authors must consider all recent
scientific developments and national methods used bycountries in their inventories”.

2446

The terminology here is different from that of the chapter introduction.
This is confusing and needs to the corrected. While the chapter
introduction (lines 2398‐2418) refers to disaggregation of MLP emissions,these lines refer to refined approximation of the anthropogenic
component of emission & removals. We recommend that the terminology
such as refining approximation and second order approximation beremoved and the paragraph re‐phrased using the term disaggregation,
EU2453 which should be consistent throughout the chapter.

Accepted with
Modification

Text has been revised to removal references to "refined
estimates" but the terminology "second order approximation"(which is achieved through disaggregation) is maintained.

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1471

VolumeChapter44Fromline22

TolineComments

Country

2454

This subsection describes a mixture of natural and anthropogenic
phenomena, and discusses the relationship between them. Several of thereferences to Natural disturbances (including the title) are therefore
inaccurate and should be changed. We therefore recommend thefollowing:• This paragraph should make clear that effects can have a range ofnatural and anthropogenic influences. Anthropogenic factors cancontribute to effects of natural origin and vice versa.
• In lines 2468‐2492 (on definition of natural disturbances) it should bemade clear that the purpose of greenhouse gas inventories is to estimate
and report the actual emissions in the inventory year, without removing
the impact of interannual variations. The methodology supplied in thischapter for disaggregation of emissions and removlas into components on
the basis of variability of disturbances is made available to countries whowish to use it for other reporting purposes (such as transparency ofEU2502 commitments).

2536

This paragraph should clarify that applying the Managed Land Proxy(which is described as Good Practice) involves including all estimatedemissions and removals occurring on managed land during the inventory
period in the reported total emissions and removals. The second sentence
should either specify that the methodology for ‘further disaggregation’provided in this subsection may be used for purposes other than reportingof greenhouse gas inventories , or the words “from the total emissions
EU
2541 and removals using MLP should be deleted.

Responses

Authors' notes

The text referred to by the reviewer focusses on natural
disturbances as one of the factors that contributes to the IAV of
estimated and reported emissions. Thus the focus on natural
disturbances is appropriate. Contrary to the statement by thereviewer, the purpose of the GHG inventory is to estimate andreport the anthropogenic emissions and removals within the
managed lands. It is recognised by the IPCC that not allemissions and removals within the managed land are ofanthropogenic origin, and the IPCC has therefore called on thescientific community to advance the science of estimating
anthropogenic E/R within the MLP Proxy. The methods
outlined here and the numerical examples provided in thisreport can increase the transparency of reported GHG E/R.
Rejected

Accepted with
Modification

Text has been revised to further clarify that "It is good practicefor countries to apply the Managed Land Proxy (MLP) andestimate and report all emissions and removals that occur onmanaged lands"
The paragraph is just an example of estimation and not a"description of accounting".

1473

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2577

2583 This paragraph is a description of accounting which should be removed.

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EU

Rejected

The text clearly states that the disaggregation of removals tothe anthropogenic and natural components is in proportion to
the disaggregation of emissions to these two components. Thisis the guidance required to ensure that the disaggregation ofemissions is balanced by the disaggregation of removals to theanthropogenic and natural components. If the goal is todisaggregate emissions then removals also have to be
disaggregated.

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CommentID

1475

VolumeChapter

4

Fromline

22594

TolineComments

CountryThis is the key paragraph but unfortunately it is contradicting in itself:“The natural disturbance component is subtracted from the total estimateof MLP emissions and removals, yielding a refined estimate of theanthropogenic emissions and removals from managed lands.” is clearly an
accounting step. The following sentence makes clear that this information
is provided in addition to reporting total GHG emissions and removals:“This is the “refined MLP flux”, i.e. the second order approximation of theanthropogenic component of E/R from managed land and is reported inaddition to the total MLP emissions and removals.”
The idea of ‘subtracting’ natural disturbances from the MLP estimate ofemissions and removals is not consistent with this methodology’s stated
aim of ‘disaggregation’. We recommend that:• the term “refined MLP flux” be renamed. Since this flux is not consistent
with the MLP concept, it should have another name to avoid confusion.
• The paragraph should state more clearly that the all emissions andremovals are to be reported in MLP totals in all circumstances, and thenaturalboxes
disturbancecomponent
may thebe reported
addition.
EU
2599 Theseshould bedeleted fromguidanceinsince
they are not

Responses

Text has been revised to enhance clarity; including replacing
the term "refined MLP flux" with "second order approximationof anthropogenic emissions and removals".
In addition is important to recall that the paragraph (and thetable example provided Box 2.2L) clearly indicated that "allemissions and removals are to be reported" in addition to theother components.

Accepted with
Modification

convergent and are provided as guidance. They either intend to justify
that ND can be removed during reporting (example AUS) or they are notclear that the ND provision is applied during accounting (EU‐case), which
is outside the scope of this chapter.
The labelling of the boxes as both “new guidance” and “for information
only” is also extremely confusing.
There appears to be a discrepancy between the methodologies used andthe interpretation of the results. E.g., the approach presented in Box 2.2I,"natural disturbances" are defined as those "occurring in a year which isan outlier". Therefore, the disaggregation seems to be done on a purely
statistical basis (which is a reasonable approach to "inter‐annual
variability"). However, the resulting two components seem to be
attributed to purely natural and purely human‐induced causes, despite
causality hot having been part of the disaggregation. It is unclear whatevidence supports the attribution made. Moreover, even if this
attribution is supported by more detailed evidence for the country
concerned (not presented in the box), it remains unclear whether, or towhat extent, such evidence would be valid or relevant in other countries
wishing to apply this approach. The approaches presented in the othertwo boxes have similar limitations. The conflation of frequency withcausality ignores the possibility that human management could result in
irregular phenomena, although evidence for that exists from certain
regions (e.g., that fire suppression practices can change the fire regimeof fire‐adapted ecosystems from more regular small fires to lessfrequent, but bigger fire events).
1477

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2624

2777 Furthermore, we do not believe it is appropriate to present somePage 109

Authors' notes

Finally, the decision what is to be reported in the CRF tables is
to be made by the UNFCCC. The guidance provided here
outlines how the components estimates can be derived andthat the total and the two components are to be reported.

Text has been revised to remove the word "Guidance" from theboxes as these are examples of national methods, not"Guidance".
In presenting the examples of countries we have clearly
indicated that such examples are "for information only andneither adds guidance nor overrules guidance provided".

EU

Accepted with
Modification

As to the inapproriateness to present national examples ‐ theinstructions to the IPCC stated clearly that "Lead authors must
consider all recent scientific developments and national
methods used by countries in their inventories." LA havefollowed this request.

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CommentID

1479

VolumeChapter

4

Fromline

22643

TolineComments

Country““‘Natural disturbance’ emissions and removals are modelled on a spatial
basis and, consistent with the MLP, included in reporting after averaging
out initial carbon stock losses and subsequent recovery.” This could showthat total GHG for managed land is not reported “as seen by theatmosphere”. A justification to this decision is made with previous IPCC
guidance in a footnote and also Line 2441: “The natural effects “tend toEU2645 average out over time and space” (Vol. 4, Ch. 1)…””

Responses

Rejected

Authors' notes
IPCC GL are meant to estimate anthropogenic GHG

emissions and removals, which is not necessarily what the"atmosphere sees", otherwise it would be necessary toestimate E/R from all lands and oceans (managed andunmanaged). As agreed by IPCC, countries shall apply the
MLP as a proxy to estimate anthropogenic E/R. The
example of Australia (and others) are given to illustrate
how countries have applied the MLP together with countryspecific procedures to disaggregate the ND andanthropogenic component within the MLP. Is worth tonote that such procedure has been reported to andreviewed by UNFCCC.
Text has been revised to enhance clarity.

1481

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2782

1483

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2

2822

This section should confirm that, irrespective of whether countries choose
to apply the natural disturbance methodology described in thissubsection, it is good practice for countries to apply the managed land
proxy, meaning that an estimate of total emissions and removals frommanaged land during the inventory year should be reported in nationalEU2820 total emissions.
This sentence contains no verb and is therefore difficult to understand. It
EU2823 is probably a continuation of the bullet list.

This section (including Box 2.2L) clearly shows that thereporting should consist of the total and each of the two
disaggregated components. The MLP seeks to quantify theanthropogenic E/R on managed land, and this guidance offers
countries the option to estimate and report the total E/R andthe disaggregated components.
Accepted with
Modification
Accepted

As noted, this was the continuation of and to provide a verb we
added: It is good practice to provide ...

Rejected
Accepted

Authors can only propose refinments in accordance with the
ToR agreed for the 2019 Refinment.
Text has benn revised as suggested

This guidance, intended for users of the Guidelines outside the context of
the NGHGI, is most useful. It recognises the important role andcontribution of the IPCC guidance beyond its immediate purpose, andhelps practitioners adapt it to other contexts, to avoid the inadvertant
misapplication of methodologies.

1485
1487

4
4

2
2

342
352

It would be most useful to include similar new guidance also for otherparts of the Guidelines that are frequently used or referred to outside of
the NGHGI context, for example life cycle analyses or evaluation of
bioenergy projects. For example, inventory guidelines are often referred
to in the context of assessing the GHG benefits of bioenergy. Many of
those applications would be usefully informed by a similar guidance
pointing out the implications of differences in system boundaries, sectoralboundaries, timeframes and the like. Such guidance could be well placedEU
410 in Volume 2, Section 2.3.3.4.
EU
352 Insert "system" before "boundaries" to read "system boundaries.

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Fromline

TolineComments
Reference to the FAO classification is outdated. Please refer to the latest
version of WRB 2015. Definition of organic soils (Histosols) is reported on
page 85 of WRB 2015: Soils having organic material:
1. starting at the soil surface and having athickness of ≥ 10 cm and directly overlying:a. ice, orb. continuous rock or technic
hard material, orc. coarse fragments, the interstices of which
are filled with organic material; or
2. starting ≤ 40 cm from the soil surface
and having within ≤ 100 cm of the soil
surface a combined thickness of either:a. ≥ 60 cm, if ≥ 75% (by volume) of thematerial consists of moss fibres; orb. ≥ 40 cm in other materials.

Country

Responses
Noted

Although it may be desireable to update to the new IUSS
classification, the values for the soil organic carbon reference
stock were taken from Batjes (2011) who used the IPCC2006
soil classes. Updating would result in inconsistencies. The
following text resides in the Batjes (2011) paper from which thereference stocks were obtained:"The default IPCC2006 scheme for grouping climate and soil
classes was maintained for this study – proposing new criteria
for this would require the derivation of new reference carbon
stocks and stock change factors (IPCC, 2006), which is beyond
the scope of this study."

IUSS Working Group WRB. 2015. World Reference Base for Soil Resources
2014, update 2015
International soil classification system for naming soils and creating
legends for soil maps.
World Soil Resources Reports No. 106. FAO, Rome.
http://www.fao.org/3/i3794en/I3794en.pdf

1489

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2

989

Action: No change

EU

991
The definition of biochar provided here is equivalent to charcoal andsimilar products. For the sake of consistency, it may be preferable to referto them with the same term ("charcoal amendments"). Charcoal
amendments should be originating from biomass, not from any generalorganic material.

1491

4

2

1045

Authors' notes
The definition used was taken from the IPCC2006 scheme forgrouping soils and climate. In this scheme an organic soil isdefined as provided in Volume 4 Chapter 3, Annex 3A.5. The
statement that these soils have to have a minimum of 12% OC
is correct, but further constraints are applied in the definition
provided in Annex 3A.5). Previously this statement said that anorganic soil had to have a "minimum of 12 to 20% organic
matter" which was not correct given the IPCC definition. The
values should have been expressed in terms of %orgnaic
carbon rather than %organic matter.

http://publications.jrc.ec.europa.eu/repository/bitstream/JRC55799/jrc_b
EU1056 iochar_soils.pdf

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Accepted

Action: the following footnote has been added:"As defined biochar is equivalent to charcoal, but isdifferentiated and recorded separately on the basis of its use
and how it is accounted for in the inventory process."

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CommentID

VolumeChapter

Fromline

TolineComments
Please update table 2.3 using the most recent WRB 2015 classification
system and avoiding making reference to single National soil classification
systems, like US Soil Taxonomy(http://www.fao.org/3/i3794en/I3794en.pdf)

Country

Responses
Noted

Authors' notes
The IPCC soil classes have been used and this is noted in thesubtext to the table as well as the derivation of the classes. The
reference soil organic carbon stocks have been calculated using
this classification. For consistency the provided classificationmust remain as presented.
Although it may be desireable to update to the new IUSS
classification, the values for the soil organic carbon reference
stock were taken from Batjes (2011) who used the IPCC2006
soil classes. Updating would result in inconsistencies. The
following text resides in the Batjes (2011) paper from which thereference stocks were obtained:"The default IPCC2006 scheme for grouping climate and soil
classes was maintained for this study – proposing new criteria
for this would require the derivation of new reference carbon
stocks and stock change factors (IPCC, 2006), which is beyond
the scope of this study."

Noted

We are not endorsing biochar amendments as a best
management practice. However, it is an anthropogenic activity
that impacts C stocks of mineral soils, and accordingly it has
been addressed in this refinement.

Noted

We are not endorsing biochar amendments as a best
management practice. However, it is an anthropogenic activity
that impacts soil C stocks, and accordingly addressed in thisreport to estimate anthropogenic greenhouse gas emissions
and removals.

Accepted

References removed

IUSS Working Group WRB. 2015. World Reference Base for Soil Resources
2014, update 2015
International soil classification system for naming soils and creating
legends for soil maps.
World Soil Resources Reports No. 106. FAO, Rome.
http://www.fao.org/3/i3794en/I3794en.pdf

1493

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1153

EU

1154
Charcoal amendments to soil present large areas of uncertainty on its longterm environmental impact (including climate impacts not coonsidered in
the methodology, like albedo and black carbon) and implications forhuman health. It should not be not endorsed as standard good practice.
Please remove this section or convert it to a box as optional guidance for
information purposes only.
http://publications.jrc.ec.europa.eu/repository/bitstream/JRC55799/jrc_b
iochar_soils.pdf

1495

4

2

1209

EU

1269
Charcoal amendments to soil present large areas of uncertainty on its longterm environmental impact (including climate impacts not coonsidered in
the methodology, like albedo and black carbon) and implications forhuman health. It should not be not endorsed as standard good practice.
Please remove this section or convert it to a box as optional guidance for
information purposes only.

1497

4

2

1418

EU

1436
Please remove GlobalSoilMap.net, since no global soil database exists
from this project (project never completed) and also Soil Grid, since theproduct is not validated by National soil data centres. Please keep only 3)
FAO Global Soil Organic Carbon Map, as the only validated global soil
carbon stock data. The official FAO Global Soil Carbon Map is a fully
validated product endorsed by all FAO Members.

1499

4

2

1515

EU

1517

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CommentID

1501

VolumeChapter

4

Fromline21725

TolineComments
Charcoal amendments to soil present large areas of uncertainty on its longterm environmental impact (including climate impacts not coonsidered in
the methodology, like albedo and black carbon) and implications forhuman health. It should not be not endorsed as standard good practice.
Please remove this section or convert it to a box as optional guidance for
information purposes only.

Country

4

2

3635

Cattle, J., Singh, B., Kookana, R. S., Boersma, M., Macdonald, L. M., Butler,
G., … Kimber, S. (2014). Opportunities and constraints for biochar
technology in Australian agriculture: looking beyond carbon
sequestration. Soil Research, 52(8), 739. https://doi.org/10.1071/sr14112]

4

2

3694

Noted

We are not endorsing this technology, but are providing amethod for an anthropogenic practice that impacts C stocks ofmineral soils to which biochar has been applied.

Accepted with
Modification

The Fperm values in this methodology were calculated using
values from only those experiments that utilized isotopicallylabeled biochars allowing unambiguous attribution of evolved
CO2, as shown in (a) of Figure 2A.2‐1. The values in (b) areadded to provide decadal to millenial observational data;
however, due to the fact that these were not isotopicallylabelled (therefore, not allowing definitive attribution of stock
chages to different sources), they were not used to derive
Fperm values. For this reason the data shown in (b) cannot be
used to calculate actual Fperm values. We note, however, thatthe value calculated here (0.56) is below the values obtained
for studies that met the criteria for inclusion in the derivationof Fpermp values. The term 'char' was added to the descriptionof (b) in text and caption to indicate that these can be naturally
accumulating pyrogenic organic matter in addition to
purposefully added biochar.

EU

3722
The evidence base for the fraction of charcoal amendment that willremain after 1000 years may be partly inconsistent with the definition of"biochar" provided in lines 1045‐1056. According to Figure 2A.2‐1, anumber of sources relate to long‐term experiments (decadal to millenial
time scales). In the case of long‐term experiments, it cannot beestablished that the source of charcoal amendment excluded pyrolyticorganic materials that result from wild fires or open fires, which would notconstitute "biochar". In the case of terra preta, it is likely that such
sources were used (Cattle et al, 2014). Replacing the term "biochar" with"charcoal amendment" could facilitate consistency.

1505

Authors' notes
We are not endorsing biochar amendments as a best
management practice. However, it is an anthropogenic activity
that impacts soil C stocks, and accordingly addressed in thisreport to estimate anthropogenic greenhouse gas emissions
and removals.

EU

1745
The attention to charcoal application to soil ("biochar") in this chapter isabsolultly unbalanced given the current relevance of the technology. In
addition there is no single mentioning of the potential negative effects of"biochar" to the environment and human health. Pyrolisis of
inappropriate feedstocks can generate severe health effects on humens
and other species. Inappropriate application technologies can haveecffects on soil health and water quality. There are still large areas of
uncertainty on the systematic application of charcoal on soils that do notallow for an endosrement of the technolgy as an IPCC methodology. The
precautionary principle should apply in this case.

1503

Responses
Noted

EU

3706

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CommentID

VolumeChapter

Fromline

TolineComments

Country

Responses

Authors' notes

Text in Chapter 1 has been revised to further clarify the
purpose of Chapter 2.6 in line with the mandate given by the2019 Refinement ToR.

1561

4

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2381

The whole section on IAV and natural disturbances is concerning as itpresents generic, voluntary guidelines that may be interpreted by eachcountry differently. This is not the purpose of the IPCC guidelines, whichshould provide the best scientific methodologies for estimating emissions/ removals, rather than leaving countries to develop their own definitions.
Where is the mandate for this development of a generic approach fordisaggregating emissions and removals from natural disturbances? This
new set of guidelines is a step backwards from previous guidelines andguidance developed by the IPCC for estimating emissions / removals fromnatural disturbances. Adoption of this section at this stage would appear
Saint Lucia
2834 very questionable.

Nevertheless, the authors disagree with the assessment that
"this new set of guidelines is a step backwards from previous
guidelines and guidance developed by the IPCC for estimating
emissions / removals from natural disturbances".

Accepted with
Modification

The IPCC guidelines sets a strong precedent for enabling
countries to apply their own definitions and methods within
the framework of good practice and this section continues thisapproach. This section provides inventory compilers with theframework for developing country specific estimates following
IPCC guidance, rather than dictating to countries how theymust implement their inventory.
Text has been revised to enhance clarity.

1563

1565

1567

4

4

4

2

2

2

2482

Previously natural disturbances have been confined to only forest land.
Could we have some explanation of what natural disturbances are
anticipated on these other types of land, and why their inclusion isjustified? Is it easy to distinguish natural, non‐anthropogenic events on
2483 other types of land?

2550

The move to a country‐specific defintion of natural disturbances is a shift
away from the provisioning of good practice guidelines by the IPCC,
towards more generic guidance that different countries can interpret
differently. This risks jeopardising the scientific integrity of the IPCC'sguidelines. We are concerned that allowing countries to develop theirown definitions of natural disturbances will make it very difficult to track
what countries are and are not counting as anthropogenic vs. natural, andcreates the opportunity for Parties to choose a definition that benefits
their accounting balances. This is a serious concern for the integrity of
NGHGIs and our ability to collectively track progress in achieving the goals
Saint Lucia
2555 of the Paris Agreement.

2800

These transparency requirements are very vague and generic. For the new
guidance to be a useful addition to previous guidance, much more precise
Saint Lucia
2800 requirements should be listed here.

Page 114Saint Lucia

Accepted with
Modification

This chapter specifically refers to General Methodology
applicable to Multiple Land Categories. Disturbances listed in
the ND definition are not category‐specific, they may occur in
any of the land categories listed. Further, their occurrence canbe identified so far as the land category is not a man madecategory as e.g. cropland or drained peatlands since in this caseit would not be possible to consider any impact not materiallyinfluenced by human activities.

Accepted with
Modification

Text has been revised by stating that definitions of ND need tobe "Consistent with the generic definition". This removes
flexibility and by making it good practice to document theassumptions, it also increase transparency.

Rejected

Other comments have suggested that such requirements are
not necessary. In order to find a "compromise solution" the text
represents, in the authors' opinion, an appropriate balance
between transparency and not being perscriptive.

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CommentID

1569

VolumeChapter

4

Fromline

21045

TolineComments
Biochar: biochar was not mentioned in the report outline, so we are
surprised to see it here. We are concerned to see a tier 1 method forbiochar as we are not sure that there is sufficient robust scientificevidence to support this methodology. Furthermore, these guidelines do
not adequately address the risk of impermanence? According to Fuss et al.
2018, the residence time of biochar varies with temperature and soil type,and may be only a few decades. Additionally, we are concerned that the
total lifecycle emissions of biochar would not be adequately captured. It
should not be possible to report only the sequestration effect of biochar
without also reporting the emissions associated with producing anddeploying biochar.

Country

Responses
Rejected

Saint Lucia

1745
The addition of biochar to the 2019 Methodological Supplement is outside
the ToR and the Chapter Outline agreed at the Scoping Meeting and as
part of the mandate adopted by the IPCC plenary for the 2019
Methodological Supplement. Related to changes in carbon stocks in soils
the mandate included only the following three issues 1. Update reference
carbon stocks. 2. Develop new Tier 2 method for mineral soils that
requires less AD and 3. Elaborate Tier 3 Methodologies with case study
examples for soils. Therefore we request to delete the related sections on
biochar amendments and the terms in the related equations in chapter 2
referring to biochar amendments to mineral soils.

Accepted with
Modification

Authors' notes
Chapters 5 and 6 of Volume 4 include updates to the stockchange factors for mineral soils. The refinement was asked toaddress mineral soil stock change factors. Addition of Biochar
C to mineral soil is anthropogenic activity that impacts soil C
stocks, and as such the stock change factors needed to be
updated to address this impact. The development of thesefactors required a new calculation to address the influence ofbiochar on the C stocks of mineral soils given its very different
nature and stability against mineralisation in soil. To make it
more clear that the inclusion of biochar was to allow a moreaccurate assessment of C stock changes in mineral soils,
biochar has been removed from the general soil equation(Equation 2.24) and the biochar term and its derivation havebeen added to Equation 2.25 which is specific to mineral soils.
Inclusion of a method in Tiers 1 and 2 make less errors thanhaving no method at all. Excluding biochar from themethodology would reduce the accuracy of the method rather
than increase it. If a country produces biochar, then theaccuracy of its emissions inventory will always be improved byincluding the best possible estimate of the associated GHG
fluxes rather than ignoring them altogether.
The reviewer is correct that the mean residence time of biochar
varies with the temperature and soil type it is exposed to in theenvironment. The data in this methodology uses all publisheddata that met the stringent criteria for the period of time anddata density mentioned, including the study by Fang et al.
(2014) which the cited Fuss et al (2018) article bases its( 6 of hVolume 4 includeld d to thef stock
Chapters 5 andupdateschange factors for mineral soils. The refinement was asked toaddress mineral soil stock change factors. Addition of Biochar
C to mineral soil is anthropogenic activity that impacts soil C
stocks, and as such the stock change factors needed to be
updated to address this impact. The development of thesefactors required a new calculation to address the influence ofbiochar on the C stocks of mineral soils given its very different
nature and stability against mineralisation in soil.
To make it more clear that the inclusion of biochar was to allow
a more accurate assessment of C stock changes in mineral soils,
biochar has been removed from the general soil equation(Equation 2.24) and the biochar term and its derivation havebeen added to Equation 2.25 which is specific to mineral soils.
Action: Moved the BCmineral equations from Equation 2.24
to Equation 2.25 and moved all explanitory text pertaining tobiochar C to the text following this equation.

1667

4

2

0

Germany

0Page 115

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VolumeChapter

4

Fromline

20TolineComments
The biochar term is added to the calculation of C stocks in mineral soils
without appropriate justification and without taking into account the large
amount of literature questioning the positive and long‐term sequestration
effects of biochar addition. The section lacks a balanced scientificdiscussion of knowledge gaps and different scientific views related to theeffects of long‐term biochar application. Recent review e.g. summarized"Some fundamental mechanisms and the utilization of biochar in agro‐
ecosystems are poorly understood. These knowledge gaps mainly include
the following aspects: it is significant to understand the interactions
between biochar and soil microbial communities which may criticallyaffect the release of CH4 and N2O. The exact service life of biochar is still
rarely understood and (3) the maximum adsorption and desorption
capacity of biochar are needed to be determined in further research."
From this perspective it may be useful to add as a separate term in tier 3
approaches, but it is highly questionable whether it is good practice to
add biochar amendments as a separate term as a tier 1 method given theexisting knowledge gaps, lack of long‐term measurements anduncertainties. We propose to delete at least the tier 1 approach forbiochar addition. The method should request considerably morejustification through long‐term field measurements when biochar isincluded in GHG inventories in form of a separate biochar term.

Country

Germany0
Table 2.3B gives for low and undefined temperature biochars an Fperm
value of 0.13. A symmetric confidence interval of 0.04 ‐ 0.23 is given.
However, the Fperm value is a fraction and confidence intervals offractions are generally not symmetric. It seems very likely that proper
statistical analysis would indicate this value not to be significant, which
would support exclusion of low and undefined temperature biochars.
Inclusion of low and undefined temperature biochars should requirematerial‐ and process‐specific Tier 2 values for Fperm.

1671

4

2

1005

Responses
Accepted with
Modification

Accepted with
Modification

Page 116

95% bootstrap confidence intervals on the mean. This did notchange the conclusions, and even the bootstrap estimates wereclose to symmetric.
Action: No direct action was taken with respect to thiscomment. However, rather than using the regression line topredict Fpermp, all values within the temperature ranges (e.g.
350‐450, 450‐600 and >600 °C) were pooled to produce arevised set of Fperm values that have been entered into Table
2.3B. The uncertainties in these estimates were calcualted as
95% bootstrap confidence intervals and were close tosymemetric. Thus the approach of expressing uncertainty interms of ± a percentage deviation from the mean was retained.

Germany

1006

Authors' notes
Chapters 5 and 6 of Volume 4 include updates to the stockchange factors for mineral soils. The refinement was asked toaddress mineral soil stock change factors. Addition of Biochar
C to mineral soil is anthropogenic activity that impacts soil C
stocks, and as such the stock change factors needed to be
updated to address this impact. The development of thesefactors required a new calculation to address the influence ofbiochar on the C stocks of mineral soils given its very different
nature and stability against mineralisation in soil. To make it
more clear that the inclusion of biochar was to allow a moreaccurate assessment of C stock changes in mineral soils,
biochar has been removed from the general soil equation(Equation 2.24) and the biochar term and its derivation havebeen added to Equation 2.25 which is specific to mineral soils.
The available literature was carefully reviewed and all studies
that provided quantitiative experimental data pertaining to theretention of biochar C in soil were included in the analyses
completed. Qualitative studies or opinions were not included
Only experimental data that met the stringent quality criteriapresented in Appendix 2A.2 were included.
The references provided by the reviewer relate to the impactof biochar on soil fertility or crop yield. Recommendations
about the agronomic impact of different biochars in different
situations is outside the scope of the refinement. The
refinement does not endorse biochar amendment as a best
management practice.
However, addition of biochar C is an anthropogenic activity thatk revised tol asymmetricld intervals,
d l calculated as
The values were2019 Refinement ‐ Collated Comments on Final Draft from Governments with Authors’ Responses

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1673

VolumeChapter

4

Fromline

2

1241

TolineComments
Box 2.2A explains GHG emission sources related to biochar production,but only addresses where such guidance may be generically found.
However, a statement is missing that good practice requires theestimation of the emissions resulting from biochar production whenbiochar amendments are considered as part of sequestration in theestimation of C stocks in mineral soils. Please add in line 1241 after the
first sentence: "It is good practice that all GHG sources associated withbiochar production are carefully analysed, and that related GHG emissions
are estimated and reported in the GHG inventory when countries decideto estimate the effects of biochar C amendments to mineral soils. "Country

4

2

1261

Authors' notes
Suggested sentence was added.

Accepted with
Modification

The description of how Fcp was calculated was oversimplified
and not transparent. This non‐transparency gave the wrong
impression that values had simply been taken from thedatabase.

Germany1261
All default values in table 2.3A are sourced from ECN 2018. This is
however not a peer reviewed source, but a database with a disclaimer
saying that ECN and TNO cannot be held responsible for any errors or
inaccuracies. It is not transparent how the default values for Fcp havebeen compiled. E.g. for biochar from wood, the database provides values
much higher than 0.77 for all wood types apart from oak. In the databaseusers can directly access the exact feedstock material, e.g. the woodtypes. From this perspective it introduces considerable additional
inaccuracy and uncertainty to compile a value for wood or rice husks
instead of searching for the detailed values in the database that has beenused for this table. The database also does not clearly separate between
gasification and pyrolysis and it is unclear how this separation was done
for table 2.3.A. This is in particular an issue when the establishment of thevalues in table 2.3A cannot be tracked or understood when comparing
with the entries in the ECN database. It does not seem to be useful fromthe point of data available to derive parameters for a tier 1 method forbiochar amendments.

1675

Responses
Accepted

The calculation method in the revised text, both in the note for
Table 2.3A and in Annex 2A.2 has been revised by insertion of
the addional text.
Table 2.3A note: "FCp was calculated from the organic carbon
content of biochar from regressions by Neves et al. (2011),
corrected for ash content using biochar yield from Woolf et al.
(2014). Data on ash, lignin, and carbon content of biomass
feedstocks, which are parameters in these regression
equations, were taken from ECN (2018)."
Annex 2A.2 text: "The organic carbon content of biochar on a
dry ash‐free (daf) basis was calculated according to equation 14
from Neves et al. (2011), which was based on a regression(n=128) of data from 26 papers. This daf organic carbon
content was corrected for ash content of the biochar to provide
carbon content per unit mass of biochar using the regression
equation (n=146 from 18 articles) of biochar yield from Woolfet al. (2014). Data on ash, lignin, and carbon content ofbiomass feedstocks, which are parameters in these regression
equations, were taken from ECN (2018), which provides themost comprehensive collation currenly available of publishedvalues for biomass composition."
Germany

1262

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CommentID

VolumeChapter

Fromline

TolineComments
The definition of biochar requires heating above 300 °C throughgasification or pyrolysis (see lines 1049‐1050). The definition of a default
value for Fpermp for conditions of low (<450°!C) or uncontrolled or
unspecified pyrolysis temperature in table 2.3B is inconsistent with thedefinition of biochar in the beginning of the section. The default for low
temperatures should be defined as < 450 °C , but at the same time asnecessarily above 300 °C. Uncontrolled and unspecified pyrolysis
temperature should be deleted from the description of default factors as
in such situations it cannot be guaranteed that biochar is produced as it isexplained at the beginning of the section that temperatures > 300°C are
essential.

Country

1677

4

2

1268

1269

Germany

1679

4

2

1815

Please clarify the header of Table 2.4. To us, it is neither clear what is1816 meant by "Mean" nor by "SE".

Germany

Responses
Accepted

Noted

Authors' notes
The lower limit of heating temperature to produce a biochar
has been redefined as 350°C throughout the chapter and in
Table 2.3B the lowest temperature class has been relabelled
350‐450°C.

Table 2.4 was not subjected to the refinement. "Mean" is thearithmetric mean, "SE" refers to the "standard error".

Text has been revised to enhance clarity on the guidance
proposed.

1681

1683

4

4

2

2

2381

The text on natural disturbances does not include any detailed descriptionof methods, nor methods in line with a tier structure of methods in otherareas and is therefore inconsistent with the remaining methodologies.
This is not user‐friendly for inventory compilers as it is not explained how
the approach works with the different tiers provided in the other sections.
Only examples of possible methods are provided. It does not seem to becompatible with the generic approach of IPCC Guidelines that aquantitatively very important part of the emission estimation neither
provides for clearly described methods nor methodological tiers, but
defines good practice guidance in an extremely limited way. The section
mainly invites Parties to apply undefined country‐specific methods.
Without further improvement of effective guidance, it would be
preferable to delete the chapter. Effective guidance means clearly
described methods in a tier structure, clear definitions and the definition
Germany
2832 of good practice guidance.

2469

The footnote indicates that the definition for natural disturbances is from2014 wetlands supplement. However we could not find such definition inthis IPCC report. The definition is from IPCC KP Supplement, but thisdefinition refers to "emissions in forests" and not only "emissions".
Germany
2473 Please correct the reference and include 'emissions in forests".

Page 118

Nevertheles, authors disagree with the reviewer's assessmentthat "is not user‐friendly for inventory compilers as it is not
explained how the approach works with the different tiers
provided in the other sections... It does not seem to becompatible with the generic approach of IPCC Guidelines that aquantitatively very important part of the emission estimation
neither provides for clearly described methods nor
methodological tiers, but defines good practice guidance in an
extremely limited way".

Accepted with
Modification

IPCC guidelines sets a strong precedent for enabling countries
to apply their own definitions and methods within theframework of good practice and this section continues thisapproach. This section provides inventory compilers with theframework for developing country specific estimates following
IPCC guidance, rather than dictating to countries how theymust implement their inventory.
Footnote 15 refer to the KP supplement and not Wetland
supplement.
The footnote has been revised to indicate as additional
information rather than the place from which the definition
was derived (as it is slightly different).

Accepted with
Modification

The proposed voluntary guidance is applicable to multiple land
categories and is not limited to forests.

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CommentID

1685

1687

1689

VolumeChapter444Fromline222

TolineComments

Country2481

The text extends the definition of natural disturbances from forests toother land uses such as woody grassland, undrained wetlands orundrained peatland without providing any justification or explanation
what type of natural disturbances may occur on these land areas that are
non‐human induced and which cause non‐anthropogenic emissions being
beyond the control of and not materially influenced by a country. Pleaseprovide at least detailed examples and discuss what kind of justification isnecessary to demonstrate that the impacts are non‐human induced, non‐anthropogenic , non materially influences and beyond human control for
Germany
2483 all the other land uses introduced in the method.

2550

There should be a clear definition of natural disturbances in the 2019
methodological supplement and element 2 of the generic methodologicalapproach contradicts such clarity by allowing any country‐specificdefinition of natural disturbances. Due to these shortcomings, we cannot
accept an approach with a country‐specific definition of natural
disturbances. Certain parameters in the application of the natural
disturbances definition may be determined by countries. But this is not
the same as using a country‐specific definition. Please clarify the
relationship between the generic definition and any potential country‐
specific elements of such definition but delete the general reference
related to a country‐specific definition. Please also include the goodpractice requirements that have been used in previous IPCC guidelines
related to the definition of natural disturbances, e.g. it is good practicethat a Party demonstrates occurrences being beyond the control of, andnot materially influenced by the Party by demonstrating practicableefforts to prevent, manage or control the occurrences which led to theGermany
2555 application of the provisions.

2556

The description of the generic methodological approach lacks precision,
detail and the definition of good practice. In each step it should be
inserted what good practice is related to the steps provided. The text
should refer to "estimating the area affected by the disturbance" insteadof "identification of lands" which is not precise language appropriate for
IPCC Guidance. Inventory compilers should assess for each disturbancetype that either the proportion of affected area is assessed accurately, if aapproach is used at landscape level, or that each affected area is
identified as being disturbed with georeferenced location, year and typesof disturbances, when individual disturbed areas are assessed. Please also
add that Parties should demonstrate that methods and algorithms used
for detecting disturbances and disturbance type are suitable for theidentification of areas affected by disturbances in a manner consistent
with the Party's definition of forests and with the method how respective
Germany2592 area or areas of land be identified in subsequent years.

Page 119

Responses

Authors' notes

Rejected

This chapter specifically refers to General Methodology
applicable to Multiple Land Categories. Disturbances listed in
the ND definition are not land category‐specific, they may
occur in any of the land categories listed and they cancontribute to IAV that is not due to anthropogenic actions. And
the text already requires that countries that chose to
disagregate the MLP E/R document their methods andassumtions as requested by the reviewer.

Accepted with
Modification

Text has been revised by stating that definitions of ND need tobe "Consistent with the generic definition". This removes
flexibility and by making it good practice to document theassumptions, it also increase transparency.

Most of the information provided in this section describes steps
required to arrive at estimates of E/R which are explained in
more detail, including the good practice requirements, in later
chapters of the volume. Many of the requirements requestedby the reviewer are provided in the more detailed chapters(e.g. how to estimate emissions from ND). The text states
already that the land areas are to be identified (which clearly
implies that an area estimate can be derived and this isrequired to estimate emissions, as described in later chapters).

Accepted with
Modification

Nevertheless, text has been revised to include a footnote toindicate that "Methodological guidance on quantification of
associated emissions and removals are given in the chapterswith general guidance (chapter 2 and 3) as well in the category‐specific chapters (chapter 4 and 6)".

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Fromline

1737

4

2

656

1739

4

2

1219

TolineComments

Country

We would like to suggest adding "ALOS‐2" as an example of satellite
which can provide "fine resolution data with a pixel size smaller than 10m". ALOS‐2 was launched in 2014 and L‐band Synthetic Aperture Radar(PALSAR‐2) is onboard. The PALSAR‐2 is capable of observing day andnight, and in all weather conditions with 3m resolution. Please note thatas the Global PALSAR‐2 dataset is also listed in the Chapter3 Annex 3A.1
"Examples of International land cover datasets", the addition would likely
660 enhance consistency between chapters.
Japan
Regarding the values of 0.0110 (for CH4) and 0.000022 (for N2O) in
Equation 2.26A, it might be worth to indicating in footnote how thesefactors are derived from the respective default CH4 and N2O emission
factors presented in Table 4.3.2 for charcoal production (Volume 2,
Chapter 4).

1743

1745

4
4

4

2
2

2

1237
1237

1245

Accepted with
Modification
Accepted

Authors' notes

We added references to ALOS and Sentinel 1 and also to
upcoming space missions to be more specific here and also
added a reference to reflect that.
It has now been decided that emissions of non‐CO2 GHGs (e.g.
CH4 and N2O) during the heating process used to produce
biochar will be recorded in the Energy sector of national
inventories (see Volume 2, Chapter 4, Table 4.3.2.1 for values
associated with charcoal production).

Japan

1219
To make it more comprehensive, other GHGs, such as CO, NOx should be
added in Equation 2.26A. If they are not available, some explanations on
why they are not on should be provided in foot note.

1741

Responses

Accepted with
Modification

It has now been decided that emissions of non‐CO2 GHGs (e.g.
CH4 and N2O) during the heating process used to produce
biochar will be recorded in the Energy sector of national
inventories (see Volume 2, Chapter 4, Table 4.3.2.1 for values
associated with charcoal production).

Japan

1237
The subscripts with 'F' might be small letters, 'perm' and smaller 'p' (not1237 'PERM' and smaller 'p'). (typo)
Table 4.3.2 is on the different volume. So it would be kind to indicate it,like 'in Volume 2, Chapter 4,' after 'Table 4.3.2' in the footnote 8.

AcceptedJapan
Accepted with
Modification

Japan

1245

Page 120

It has now been decided that emissions of non‐CO2 GHGs (e.g.
CH4 and N2O) during the heating process used to produce
biochar will be recorded in the Energy sector of national
inventories (see Volume 2, Chapter 4, Table 4.3.2.1 for values
associated with charcoal production).

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CommentID

VolumeChapter

Fromline

TolineComments
In Table 2.3A, it makes it clearer if it is added what analysis method isused for this calculating biochar's organic carbon value of FCp should be
added because there are more than one major methods for it. This will
give a very useful information for countries determine country‐specificvalues for Tier 2 method.

Country

Responses
Accepted with
Modification

Authors' notes
The description of how Fcp was calculated was oversimplified
and not transparent. This non‐transparency gave the wrong
impression that values had simply been taken from thedatabase.
The calculation method in the revised text, both in the note for
Table 2.3A and in Annex 2A.2 has been revised by insertion of
the addional text.
Table 2.3A note: "FCp was calculated from the organic carbon
content of biochar from regressions by Neves et al. (2011),
corrected for ash content using biochar yield from Woolf et al.
(2014). Data on ash, lignin, and carbon content of biomass
feedstocks, which are parameters in these regression
equations, were taken from ECN (2018)."
Annex 2A.2 text: "The organic carbon content of biochar on a
dry ash‐free (daf) basis was calculated according to equation 14
from Neves et al. (2011), which was based on a regression(n=128) of data from 26 papers. This daf organic carbon
content was corrected for ash content of the biochar to provide
carbon content per unit mass of biochar using the regression
equation (n=146 from 18 articles) of biochar yield from Woolfet al. (2014). Data on ash, lignin, and carbon content ofbiomass feedstocks, which are parameters in these regression
equations, were taken from ECN (2018), which provides themost comprehensive collation currenly available of publishedvalues for biomass composition."

1747

4

2

1261

1749
1751
1753

4
4
4

2
2
2

1269
3103
3117

1755

4

2

3213

Japan

1262
Herath et al. 2014', this reference seems to be not correct. It should be1269 "Herath et al. 2015".
3104 This paper is on "191: 158‐167". Volume and should be corrected.
3122 The reference Herath et al. (2015) listed twice.
E' seems to be dropped from "Environmental Science and Technology".
3214

Page 121

Accepted
Japan
Japan
Japan
Japan

Accepted
Accepted
Accepted

Deleted second instance
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1793

VolumeChapter

4

Fromline

2

2503

1797

4

2

983

1879

4

2

1208

TolineComments
Country
In the chapters 2.6.2 to 2.6.4 (Volume4) methods are proposed toseparately identify/assess the anthropogenic and non‐anthropogenic
component of natural disturbance emissions. The proposed methods areclearly indicated as not‐binding since the assumption of the management
land proxy for all LULUCF emissions/removals shall be further used. The
question is therefore, for which purpose and on basis of which mandate
are these methods introduced in the GL refinement? Table 2.6.C lists
monitoring approaches and their potential to distinguish between direct
human and indirect human effects ‐ this table is not based on scientificevidence (and related citations) but on judgement and it is not generalapplicable for this question since several direct human and indirect
human effects exist which overlap in their effects. In addition, themethodological examples from the three selected countries differ inapproach and outcome and consequently are not able to represent a
general method to be applied by the countries with the aim to get“comparable” results (one of the main IPCC reporting principles). In
addition, the methods seem not to be a sound approach regarding thepossible real recognition of anthropogenic and non‐anthropogenic natural
disturbance emissions. For instance, the proposed approaches are basedon statistical parameters, e.g. that outliers above a certain "baseline" or"confidence interval" or "mortality levels" would automatically represent
non‐anthropogenic effects, while those below/within would represent
anthropogenic effects. There are serious doubts that such an approachbased on statistical parameters only is suited to distinguish between
anthropogenic and non‐anthorpogenic effects in natural disturbanceemissions. In fact, the magnitude of natural disturbance events depends
on various parameters and circumstances like weather conditions, access
2832 to the area, conditions for spreading/extinction (e.g. anthropogenic mono Austria

Responses

Rejected

Table 2.2 includes dead wood and litter default values from various
regions. There are some doubts on the appropriateness of these values
for the selected regions. For instance, according to this table litter C stocks
in temperate continental forests would be higher/similar to boreal forests,
those in temperate mountain forest systems much lower to temperatecontinental forests ‐ both results are unlikely. The default dead wood C
stocks are partly very high, e.g. for temperate mountain forests. It is
recommended to revisit the literature on this issue, particularly look forvalues from systematic surveys like forest and soil inventories for thelisted regions. In addition, presented means should be calculated without
Accepted withstatistical outliers originating from local studies.
Austria
Modification
AcceptedBox 2.2 (Updated): Paragraph below third table: Edit the sentence'However, estimates of annual changes of carbon stocks would generally
not be very different, as shown in this example', and change to 'However,estimates of annual changes of carbon stocks would not differ greatly, as United Kingdom (ofGreat Britain andshown in this example.'
Northern Ireland)
1208

Page 122

Authors' notes

WIP ‐ see word file "Comment_1793_san"Vlues from the tables are revised and are developed out of theliterature review (reference indicated), values are proposed as
default values in case the countries do not have their own
values with should be more approiated than the default values
for their estimations. The access to systematic surveys data andnot peer review literature (such as soil surverys) was limited toits open accesibility.

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CommentID

1881

1883

VolumeChapter44Fromline

2

2

1249

1425

1885

4

2

1970

1887

4

2

1980

1889

4

2

1981

1891

1893

4

4

2

2

TolineComments
Country
Responses
Box 2.2A (New Guidance): remove the 'associated with' after 'use' andAcceptedreplace with 'of' if it's applicable. The sentence is confusing as it stands
now, and it is unclear what it is trying to say. Please consider redrafting to United Kingdom (ofGreat Britain andremove the use of 'associated with' twice in the same sentence.
Northern Ireland)1250
Add 'years' after '1000'
Accepted
United Kingdom (ofGreat Britain andNorthern Ireland)1425
Add 'to' after 'lead'
Accepted
United Kingdom (ofGreat Britain andNorthern Ireland)
1970
Accepted
Change 'measures' to 'measurements'
United Kingdom (ofGreat Britain andNorthern Ireland)1980
Add 'be' after 'should not'Accepted
United Kingdom (ofGreat Britain andNorthern Ireland)
1981

1989

1989 Change 'measures' to 'measurements'

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

2622

Change 'for a European country' to 'for an EU country' if the aim is toinclude a general example that follows EU legislation/rules, or to 'Italy' if
2622 the aim is to be more specific (as this underlying data is from Italy)

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

Authors' notes
Sentence was changed as suggested.

Action: "years" added after 1000. Note that 1000 was changed
to 100 years as well.

Editorial

Changed all instances of 'measures design' to 'measurement
design'.
Editorial

Changed all instances of 'measures design' to 'measurement
design'.

Text revised as suggested (i.e. an EU country)
Text has been revised to enhance clarity

1911

2649

4

4

2

2419

General2 comment

Is the proposed approach to addressing interannual variability more
2834 relevant for accounting than reporting?

United Kingdom (ofGreat Britain and Accepted with
Northern Ireland) Modification

General comment: In spite of comments made on the SOD the guidanceon models and modelling in Volume 4 continues to be inconsistent withthe discussions of models and modelling in Volume 1. The most important
issues are related to the question of how to validate models, and the use
and need for validation against independent datasets. New comments
have been made on this subject.
CanadaPage 123

Noted

IPCC GL are limited to provide guidance on estimation methods
and reporting; therefore "accouting" is out of the scope of the
proposed refinement. The approach aims to enhancetransparency of national greenhouse gas inventories by
providing a voluntary guidance to disagregate E/R withinmanaged land and clearly state that all three components (i.e.
total, ND and anthropogenic E/R) are to be reported.

Please refer to specific comments responses

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CommentID

2651

2653

2655

VolumeChapter444Fromline22General comment: the whole chapter 2 is difficult to read and, hence, toapply. It also confuses guidance with examples of what some countries
have done, which is NOT guidance. Re‐write by clearly separating concreteand practical guidance on quantifying emissions and removals, fromexamples and information boxes. Examples ‐ which again should not be
confused with guidance ‐ should be provided together in an Annex.
Canada46

773

Reference is only made to drained organic soils. Organic soils may also be
excavated, impacted through compaction, changes in vegetation cover
resulting from various different land use changes. Since this is generalguidance, the guidelines should clarify whether or not the genericguidance is applicable to these situations related to organic soil impacts
Canada773 that are not “drainage” per se.

2

800

2659

4

2

1681

2

Country

Section 2.6 on Inter‐annual variability is part of the "additional guidance
for Tier 3 methods" (following from the "Additional generic guidance forTier 3 methods in Section 2.5), so would suggest for clarity that theSection title for 2.6 be revised as "Additional Guidance for Tier 3 Methods:
Inter‐annual variability". This would help to avoid any confusion as to
Canada46 whether this guidance applies to non‐Tier 3 approaches.

44Comments

General2 comment

2657

2661

Toline2023

This long list impacts readability and is not comprehensive in any case,807 please simplify and revise.
Appears to be somewhat repetitive from Chapter 3, Volume 1, pleaseassure that there is no repetition.

CanadaResponses

Authors' notes

Accepted with
Modification

The word guidance was removed from the boxes examples;
however the boxes are maintained within the main text tofacilitate reading

Rejected

The guidance proposed is not limited to Tier 3 approaches.

Noted

There is guidance on these issues in the 2013 IPCC Wetlands
Supplement, and it was beyond scope in the TOR to provide
further guidance on organic soils in this refinement.

Accepted with
Modification
Noted

The list is not intended to include all factors, but to show thecomplexity of the factors influencing decomposition processes.
Text was added to clarify this aspect.
This box provides examples of the approaches taken bydifferent countries to apply a Tier 3 approach to quantifying
soil carbon stock change so the context is not the same as
Chapter 3 in Volume, and so this box provides additional details
about the methods that were not discussed in the uncertainty
chapter.

Canada1698

Revised as: “In all cases models used in Tier 3 methods ensure higher
accuracy only when they have been effectively validated against an
independent data set, are correctly applied and capable of representing
the population of interest.” As is, the statement confuses precision of
output with accuracy. Models can provide very detailed and precise
2024 output that is completely inaccurate.

Page 124

CanadaAccepted with
Modification

We can agree (with the reviewer) and as per the initial text thathigher accuracy of Tier 3 methods requires that ".... correctly
applied and capable of representing the population ofinterest."However, that is the only requirement for higher
accuracy. Validating against another data set does not
influence the accuracy, but validation is of course useful as partof the process to develop a method that is more accurate. The
act of validation itself has nothing to do with the accuracy ofthe method. The steps for correct implementation of models
are outlined in the text following. Validation is included as a
step. the text has been slightly modified to highlight that
correct implementation is required and to achieve this thesteps following should be worked through.

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Authors' notes

2080

Higher accuracy can only be assured when models are "validated" Modify
sentence: only when they are correctly applied and validated, and are
Canada2082 capable of representing the population of interest."

Accepted with
Modification

We can agree (with the reviewer) and as per the initial text thathigher accuracy of Tier 3 methods requires that ".... correctly
applied and capable of representing the population ofinterest."However, that is the only requirement for higher
accuracy. Validating against another data set does not
influence the accuracy, but validation is of course useful as partof the process to develop a method that is more accurate. The
act of validation itself has nothing to do with the accuracy ofthe method. The steps for correct implementation of models
are outlined in the text following. Validation is included as a
step. the text has been slightly modified to highlight that
correct implementation is required and to achieve this thesteps following should be worked through.

2087

It is not clear how "provide estimates of uncertainty for the estimatedstock changes" could be considered a criteria of selection for a model.
2087 Remove and begin with: “uncertainty is reduced relative to…

Accepted with
Modification

restated that the model needs to be capable of quantifying
uncertainty

2667

4

2

2109

2669

4

2

2126

2671

4

2

2160

TolineComments

Country

CanadaCanadaAccepted with
Modification

There is bracketed text at the end of the sentence that clarifies
what the calibration data should be independent of.
Additionally the good practice text has been modified as aresult of this and other comments to say "Calibration data
should represent the population. In practice, this does notmean that all environmental conditions are covered, but thatthe original calibration data includes a range of the conditions
existing the country that is representative of national
circumstances."
Text have been edited to simply and concisly say; In all cases it
is good practice to document the calibration procedure andresults.

CanadaAccepted

Text removed

Data that is independent from what? When talking about validation (orevaluation data sets according to the authors wording) it is clear that thedata has to be independent from the data that is used in calibration. But
Canada2109 what should the calibration data set be independent of? Please clarify.
Please revise to say simply “countries should document calibration
2126 results”.
This paragraph is more about interpretation of research results than
2164 guidance, please revise or remove

Page 125

Accepted with
Modification

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2675

2677

2679

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4

4

4

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2

2

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Authors' notes

2388

The guidance in the introductory paras of Section 2.6 notes that "some" ofthe E/Rs from managed land are characterized by high IAV (line 2388),
and as a result, this can make it "difficult to gain a quantitative
understanding of the role of human activities compared to the impacts ofnatural effects" (Line 2398‐2399). In response, the IPCC guidance
presented in this section is aimed at reducing "high" IAV. However,evidence clearly shows that natural disturbances ‐ whether these result inhigh IAV of emissions and removals or not ‐ still affects the reported
estimates. See for example Kurz et al, 2018 ‐ Quantifying the impacts ofhuman activities on reported GHG emissions and removals in Canada's
managed forest. As currently written, however, the IPCC guidance does
not address circumstances where natural disturbances occur and are non‐anthropogenic in nature, but which are not characterized by high IAV ofemissions and removals. For example, when aggregating the impacts ofvarious types of natural disturbances at the national level for reporting in
GHG inventories, the process of aggregation may mask high IAV occuring
at the regional level. Therefore, any IPCC guidance aimed at clarifying theimpact of human actions on the reporteed estimates needs to not only
address high IAV related to natural disturbances, but all IAV related tonatural disturbances, provided that countries can show how humanimpacts are distinguished from natural impacts. Specific text
modifications have therefore been included below for lines 2388, 2398,
2413, 2455, 2464, and 2480 to clarify that there is evidence that IAV (i.e.
not "large IAV") results in distortions in the reported estimates and that
this can be effectively addressed by separating anthro from non‐anthro
Canada2388 impacts.

Rejected

According to the proposed guidance it is up to countries todefine the ND and consequently what IAV they consider high.

2388

Replace "high interannual variability" with "interannual variability", asthere is evidence that it is not just high IAV that affects the reported
estimates and the ability to discern human from non‐anthro effects. Seefor example Kurz et al, 2018 ‐ Quantifying the impacts of human activities
Canada2388 on reported GHG emissions and removals in Canada's managed forest.

Rejected

According to the proposed guidance it is up to countries todefine the ND and consequently what IAV they consider high.

2398

Replace "high interannual variability" with "interannual variability", asthere is evidence that it is not just high IAV that affects the reported
estimates and the ability to discern human from non‐anthro effects. Seefor example Kurz et al, 2018 ‐ Quantifying the impacts of human activities
Canada2398 on reported GHG emissions and removals in Canada's managed forest.

Rejected

According to the proposed guidance it is up to countries todefine the ND and consequently what IAV they consider high.

2413

Replace "high IAV" with "interannual variability", as there is evidence that
it is not just high IAV that affects the reported estimates and the ability todiscern human from non‐anthro effects. See for example Kurz et al, 2018
‐ Quantifying the impacts of human activities on reported GHG emissions
Canada2413 and removals in Canada's managed forest.

Rejected

According to the proposed guidance it is up to countries todefine the ND and consequently what IAV they consider high.

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Authors' notes

2455

Replace "large IAV" with "interannual variability", as there is evidence that
it is not just high IAV that affects the reported estimates and the ability todiscern human from non‐anthro effects. See for example Kurz et al, 2018
‐ Quantifying the impacts of human activities on reported GHG emissions
Canada2455 and removals in Canada's managed forest.

Rejected

According to the proposed guidance it is up to countries todefine the ND and consequently what IAV they consider high.

2464

Replace "large IAV" with "interannual variability", as there is evidence that
it is not just high IAV that affects the reported estimates and the ability todiscern human from non‐anthro effects. See for example Kurz et al, 2018
‐ Quantifying the impacts of human activities on reported GHG emissions
Canada2464 and removals in Canada's managed forest.

Rejected

According to the proposed guidance it is up to countries todefine the ND and consequently what IAV they consider high.

2480

Replace "large interannual variability" with "interannual variability", asthere is evidence that it is not just high IAV that affects the reported
estimates and the ability to discern human from non‐anthro effects. Seefor example Kurz et al, 2018 ‐ Quantifying the impacts of human activities
Canada2480 on reported GHG emissions and removals in Canada's managed forest.

Rejected

According to the proposed guidance it is up to countries todefine the ND and consequently what IAV they consider high.

Accepted

Figure have been resived to avoid problems with printing

Accepted with
Modification

For examples, please refer to boxes

2687

4

2

2435

2689

4

2

2453

Graphic ‐ if printed in black and white, opposed to colour, it is not clear
what is meant with the labels "managed" and "unmanaged" land whichappear below the illustration. Suggest reformatting so that this is clear in
Canada2436 black and white/grayscale as well.
It could be helpful to include an example here of where the 2nd orderapproximation method may still result in the inclusion of some effects ofCanada2453 IAV and natural disturbances.

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To avoid using language associated with accounting‐related decisions
from the Kyoto Protocol, which is inappropriate to reflect directly in IPCC
guidance, the language in this para should be modified to draw on theimportant concepts and definitions established through the KP, but in amore general way. Line 2469 should state that "natural disturbances arenon‐anthropogenic events or non‐anthropogenic circumstances." A
second sentence could then recall important concepts, e.g. that natural
disturbances result in emissions and removals that are beyond the control
of and not materially influenced by Parties. Consistent with proposedchanges to lines 2388, 2398, 2413, 2455, 2464, 2480 about the need toaddress all IAV associated with natural disturbances, and not only "highIAV", suggest removing the reference to "significant" emissions from line
2470.
Text has been revised to "avoid language" that could beperceived as "associated with accounting‐related decisions
form the Kyoto Protocol"; including the revision to thefootnote as additional information rather than the place fromwhich the definition was derived (as it is slightly different).

Footnote 15 should be also revised as follows: "Further information on
natural disturbance definitions and approaches can be found in IPCC
(2014), ....."

2691

2693

4

4

2

2

2469

Moreover, unlike the KP definition which was designed as accounting
guidance for forest‐related natural disturbances, the IPCC guidance should
not restrict application to only forest lands, as evidence supports theapplication of this approach to non‐forest lands as well. Removal of"defined" and keeping the reference to "in the context of AFOLU" in line
Canada2473 2469 help to clarify this.

Accepted with
Modification

2493

This section does not provide any guidance for addressing the balance ofemissions and subsequent removals in the instance where sequential
2502 natural disturbances occur on the same lands over time.

Accepted

CanadaAbout significant, since the method is about disaggregating
GHG emissions/removals with high certainty, such clause to besignificant is needed since insignifcant fluxes cannot be
identified/quantified with high certainty.
Added "In the case of repeated disturbances on the same land,
the time to reach balance is expected to increase." Note alsothat Kurz et al. 2018 does provide further information on theapproach.
The following paragraphs and table seek to document how
methodological choices affect the IAV in estimates of E/R.

2695

2697

4

4

2

2

2509

Not clear how the 3 methods (annual to periodic, averaged or
2509 disaggregated by drivers) relate to following paragraphs

2573

By using actual fractions (one third) the concept could be easily confused.
When suggesting mathematical constructs, authors should use
mathematical equations. In general, however, this section seems overly
prescriptive and it would be preferable if the authors were capable of2583 developing some rules of thumb, as opposed to mathematical constructs. Canada

Page 128

CanadaAccepted

Text was revised to improve clarity.

Rejected

The text clearly states that the allocation of removals to theanthropogenic and natural components is in proportion to theallocation of emissions to these two components. This is theguidance. What follows is merely an example.

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2699

4

2

2600

2701

4

2

2613

2703
2705

4
4

2
2

2672
2681

The “carbon balance” rule introduces a methodological bias and is notpractical. 1. The approach is not quantitatively sound: assume 2 stands
with the same biomass, one in the anthropogenic component, the otherstill in the disturbed component (because it has not reached its pre‐disturbed biomass yet). Harvesting those two stands in exactly the same
way will be reflected differently in the inventory, because the loss of thegrowing sink will be reflected in the first instance but not in the second
one. In addition, the significance of this discrepancy will vary depending
on stands’ pre‐disturbed biomass, which is arbitrary. This will not occur If
stands are considered as “anthropogenic” as soon as they are eligible for
harvest. 2. The approach is not practical: Foresters know when a tree isready to go to the mill, they do not know when carbon equivalency occurs(i.e. decades after a disturbance). Let's try to keep the guidelines practicaland applicable. Line 2494: Modify the sentence to: A fundamental
assumption of the MLP is that the Forest Land remaining Forest Land is
not being degraded or declining in productivity due to natural
disturbances. Therefore natural carbon stocks, if management was notoccurring would not change overtime. Line 2600 Modify the sentence
to: Given the expectation of the sustainability of the natural forest
ecosystem (Section 2.6.1.2), it is good practice to assure thatmethodologies are based on principles that will capture practices that
result in reductions in landscape scale standing volumes and ecosystemproductivity and the subsequent impact that these practices would haveon carbon stocks and/or emissions and removals. Lines 2603‐2608:
Canada2608 delete.
Meaning of the sentence is not completely clear: as written is it always
Canada2615 true?
Reformulate "background level of natural disturbances" which is a legacy
concept associated with rules under the Kyoto Protocol. Suggestion:
Canada2673 natural small‐scale forest mortality
Canada2681 Explain or specify the "re‐entry age"
Figure 2.6D in Box 2.2K seems to be confusing and inconsistent among thelegends and it might be mislabeled. The legend below the figure talks
about the left Y‐axis representing "annual total net GHG emission (GgCO2e) from managed forest land" and the dashed red line (right Y‐axis)
representing the "annual area burned (kha)". However, the two labels in
the chart refer to "anthropogenic GHG net emissions" associated to theblue bars and "GHG removals from ND" associated to the dashed red line.
Canada2725 Suggest to review it and correct the legends as appropriate.

2707

4

2

2720

2709

4

2

2746

2711

4

2

2770

2768 Footnotes 27, 28, 29, 30, 31 and 32 referred to in Box 2.2K are missing
Right axis is missing from the graph. No legends either. Also,''anthropogenic GHG net emission'' should be renamed ''anthropogenic
2771 GHG net flux''

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As stated in rows 2564‐2566 any C stock loss associated with anactivity that occur after the disturbance is anthropogenic; so
the example given at 1 is not correct. Regarding 2, forester may
harvest trees at any time, this is just on how estimating
associated emisisons and removals, this is not a guidance on
forest management. Regarding line 2494, the text proposed is
not consistent with the managed land proxy as described, so
we cannot agree the proposed change. Regarding line
2600/2603‐2608, this section deals with IAV, not with methods
to estimates GHG emissions and removals, those methods areprovided in other sections and chapters and remains
unchanged as well as the principles on which they are based.
This section deals with disaggregation of ND E/R only.

Rejected
Accepted with
Modification

Paragraph have been moved to Box 2.2J (Canada example)

Accepted
Accepted

Text revised as suggested
Text has been revised to improve clarity

Accepted

Figure have been revised

CanadaAccepted

Footnotes added

CanadaAccepted

Figure have been revised

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2

2776

2715

4

2

2792

2717

4

2

2800

2719

4

2

2802

2827

4

2

2381

TolineComments
The legend below Figure 2.6E mentions a right Y‐axis representing thedisaggregated emissions and removals from natural disturbances; thisright Y‐axis does not appear in the figure. Suggest to revise this figure as2776 appropriate.
Delete "Depending on the methodological Tier applied", as this section
requires use of Tier 3 methods. Replace with "Depending on the2792 approach used"…
The authors provide a series of good practice information requirements.
In keeping with the mandate of the IPCC please re‐state as: …” it is good2819 practice to document the following: …”

Country

CanadaFigure have been revised

CanadaRejected

It is not correct that Tier 3 methods are required for this.
Section 2.5 is specific to Tier 3 methods. Section 2.6 is about
IAV and this is not limited to Tier 3 methods.

CanadaAccepted

Text revised as suggested

Accepted

Text revised as suggested

Noted

We appreciate the positive feedback.

It is important to monitor the disaggregated carbon stock changes andemissions on managed land from anthropogenic and natural disturbances.
Suggest to modify this sentences as: "… it is good practice to document
disaggregated emissions and removals in the MLP, the approaches,
Canada2802 assumptions and methods used"
Brazil is in favor of the version presented in the final draft, that informthat the guidance is provided as an option that may be used by countries,
Brazil2418 not mandatory one.

Are these two values of C per tonne d.m. the only ones available? The
dead wood value is only fore temperate species? Table 2.2. gives C values
per ha for different climates. It could have another column with C per d.m.
for each of climate. If this data is available somewhere in the report andwe missed it then please add a reference. Alternatively please add an
explanation that no other studies for other climates are available orreference a study showing that these numbers remain the same for all
climates. The current presentation is rather confusing. The same variable
819 'CF' is also used in other equations, so it is important to be clear here.
Estonia
How would it be possible verify which temperatures where used? The C
content of charcoal does differ significantly depending on processing
temperatures (table 2.3B).

4

2

818

2897

4

2

1214

1215

Estonia

2590

It is not clear what this sentence tries to say; please rewrite so that2592 everyone can understand what is meant here.

Estonia42Page 130

Authors' notes

Accepted

2895

2899

Responses

Accepted with
Modification
Noted

AcceptedThank you for the comment, we have clarified that this value isfor temperate tree species. Unfortunately there is very little
data on this topic so the values given here are default values, tobe used if no more detailed information is available.
If biochar C applied to soil is to be included in the inventory,
then it would be a requirement of biochar producers to record
both the mass of biochar produced and the temperature usedin its production in a manner consistent with the categories
provided in Table 2.3B.

Text has been revised to improve clarity

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Text in Chapter 1 has been revised to further clarify the
purpose of Chapter 2.6 is not to provide "guidance on
accounting".

2901

4

2

2420

3541

4

2

653

Natural disturbances ‐ there should be more focus on IAV here and less onother timescales and accounting. Estimation of emssions from natural
disturbances is also not clear. Perhaps it´s worth to wait until the sciencedevelops here and clearer guidance could be given. Uncertainties related
to changes due to natural disturbances should be clearly highlighted here
and elsewhere. Also, ways of distinguishing between managed andEstonia
2832 unmanaged land seems to be rather not straightforward.
Box 2.0D appears to focus on satellite‐mounted LIDAR and SAR, but not
airborne (i.e. plane‐mounted) applications. Suggest either adding airborne
applications to the box, or making the box's focus on satellite applications United States of
672 Weclear.
Americahave significant concerns about inclusion of the new guidance on

2381

factoring out the inter‐annual variability of emissions/removals resulting
from natural disturbances on managed land. It may be that the intent of
the new guidance is only to assist countries in disaggregating
emissions/removals associated with natural disturbances on managed
land so that they can better understand the impacts of their management
activity. This seems fine and could be a useful exercise for some countries.
However, some parts of the chapter appear to suggest that thecomprehensive emissions/removals from managed lands associated withnatural disturbances need not be reported as part of inventory totals (e.g.,lines 2490‐2492, 2594‐2599, 2782‐2783, 2801‐2802, and others), thus
leading to underreporting. This is not acceptable and the authors shouldcarefully review the entire section to ensure use of this guidance will not
be construed in this manner. Factoring out the emissions/removals is anaccounting approach and is not consistent with inventory reporting inwhich the managed land proxy is used as the basis to separate natural andanthropogenic emissions/removals. Additionally, the new guidance does
not make it sufficiently clear that addressing/factoring out emissions andremovals from natural disturbances through accounting in the UNFCCC isalready a well‐accepted approach. While IPCC should not provide
guidance on accounting, the omission of this information makes it appear
as if the only way to address natural disturbances is through the GHG
inventory. In our view it is inappropriate to include guidance on
separating emissions/removals from natural disturbances fromanthropogenic emissions/removals. This is an accounting practice, and not
something that should be included in the IPCC inventory guidelines.
Additionally, as acknowledged in the current text of this section, human United States of2832 activities are one of the drivers strongly controlling natural disturbances America

3543

4

2

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Accepted with
Modification

Nevertheless, the authors disagree with the assessments madeby the reviewer; in particular because the estimation ofemissions from natural disturbances is covered in earlier
sections of the guidelines, and no changes are suggested in thissection to the basic methods for estimating emissions.
Estimation of uncertainties in E/R is also covered elsewhere in
the guidenace and not altered here. This section does notaddress the distinction between managed and unmanaged
lands (see Ogle et al. 2018) for a recent publication on thisissue.

Accepted

We added text to say that it can be both airborne andspaceborne instruments

Authors agree with the Reviewer's interpretation of the intent
of the disagregation methods.
Text of section 2.6.4 (and Box 2.2L) has been revised to makeclear that is good practice to report both the total MLP E/R andthe disagregated components.
However, the authors do not agree that it is appropriate tomove the guidance to an annex.
Accepted with
Modification

For more details ‐ see word document

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3545

4

2

2384

3547

4

2

2391

TolineComments

Country

insert words in CAPITALs to the sentence: "...this APPRAOCH is currently
recognised BY THE IPCC as…" This is necessary as other accounting andreporting entities/programs may use a different approach, so making this United States ofAmerica
2385 a unversially applicable statement is not appropriate.

3549

4

2

2392

We disagree that the first two causes are necessarily larger than the third
2397 cause mentioned in this section.
The distinction made between the two types of events may not be soclear. "Extreme events" such as hurricanes kill trees and result in
immediate emissions; severe and prolonged drought and pests can also
kill trees. These may also be considered natural disturbances. Suggest
2393 making this gradiation more clear.

3551

4

2

2405

2406 delete “long” and “major”

3553

4

2

2412

3555

4

2

2483

2412 Insert “these supplemental approaches” after "These"
The points made here and related country‐specific examples seem out ofplace here. Would be better suited to include these in intro parts of thisUnited States ofsection as part of explaining why this approach is deemed imporant to
America
2492 some countries/circumstances.

2499

The stand level discussion seems to make an argument supporting theidea that "The natural effects “tend to average out over time and space”(Vol. 4, Ch. 1)." As national GHGIs are indeed national, looking across thedifferent stands and different environmental conditions that either slow
down/speed up the time needed to achieve balance again would likely
come out in the wash ‐ especially over this larger/national scale and over
United States oftime. It seems this further weakens the scientific basic for including thisAmerica
2502 new guidance on factoring out IAV.

3557

4

2

United States ofAmerica

United States ofAmerica
United States ofAmerica
United States ofAmerica

Responses

Authors' notes

Accepted with
Modification

Accepted

Wording added to the sentence as suggested without using"capital" letters since is not according to IPCC editorial rules
We have revised the text to clarify that there are "three maincauses" without ranking them. In addition, we are refering to
the IAV in the emissions and removals due to human activities,
not the absolute amounts.

Accepted with
Modification

Text has been revised to clarify that it's refering to the IAV in
the emissions and removals due to human activities, not theabsolute amounts.

Accepted

Text revised as suggested

Accepted

Text revised as suggested

Accepted

The text has been moved to the introduction.

Rejected

The scientific data provided in the three country boxes clearly
demonstrate that the IAV due to ND does not average out overthe national scale and does not "come out in the wash". This
strenthens the scientific basis for attempting to disaggregate
the IAV due to NDs.

Rejected

This paragraph has nothing to do with credits or debits. It
states that if a country choses to disaggregate emissions andremovals using the approaches outline in the 2019 GL, thenremovals on lands affected by natural disturbances PRIOR to
the start year of the reported time series should also be
estimated and attributed to the ND component (even if theassociated emissions occured prior to the start year of the timeseries). Failure to do so violoates the assumption of balanceover time and space that is central to the MLP. Please also see
reponse to comment #229 for the question of incentivising
management actions.

3559

4

2

2600

Why is it good practice that removals on managed lands should be
excluded when emissions from natural disturbance are disaggregated?
This is an accounting question, not a reporting issue. What if management
actions are taken to enhance removals? What if a country wants to getcredit for the actions it takes to keep forest land as forest following a
United States ofAmerica
2608 natural disturbance?

3561

4

2

2710

Box 2.2K. The dashed line in the 1st graphic appears to be mislabelled in
2744 the key; the text says this is area burned, rather than GHG removals

United States ofAmerica

Accepted

Figure have been revised

3595

4

2

2391

The incipt refers to "two largest causes are" although then three causes
2397 are listed. Therefore, it is suggested to redraft as "three main causes"

Italy

Accepted

Text revised as suggested

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TolineComments
The word "direct emissions" here is misleading since in figure 2.6A this isassociated to anthropogenic effect/emisisons. I suggest to use the word
"abrupt" or "immediate" to explain that such emissions occur at time2393 when the disturbance occurs"

Country

Italy

Responses

Authors' notes

Accepted

Text revised as suggested (i.e. immediate)

3599

4

2

2412

3601

4

2

2453

In many places of the IPCC Guidelines it is written that methods appliedmust not impact the trends. Therefore the reference here to trends isextremely confusing. My suggestion is to replace the sentence as follows:"These approaches may be of interest to countries with large AFOLU
Italy
2413 sector emissions due to natural effects"
the anthropogenic component always include some natural effects, so it
would be more clear here to replace the word "disturbances" with
Italy
2453 "effects"

2466

As already noted, correction of trends is a very sensitive issue. It istherefore suggested to rephrase it as follows: "However, like interannual
variability, the inter‐decadal variability can also make it difficult to identify
Italy
2467 trends in emissions and removals that result from human activities"

Accepted

Text revised as suggested

The natural disturbances definition referred here was created for forest
land in developed countries under the Kyoto Protocol only. In that land
use in those countires, the only use within management practices of fires
is prescribed forest fires. However, this new definition of natural
disturbances is now applicable to other land uses and all countries.
Therefore the definiiton has to be improved as suggested: "...prescribedfires as well as any other fires associated with planned and unplanned
Italy2473 management practices e.g. slash and burn".

Accepted with
Modification

Text has been revised to include "slash and burn"

3603

4

2

3605

4

2

2473

3607

4

2

2483

3609

4

2

3611

4

2

3613

4

2

Accepted with
Modification

Text has been revised as follow: These supplementary
approaches may be of interest to countries with AFOLU sector
emissions where IAV due to natural effects is greater than that
due to human activities".

Accepted with
Modification

Text has been revised to insert the words "and other naturaleffects" after disturbances.

Italy

Accepted

The text has been moved to the introduction.

2508

This text is misplaced. This element is discussed in rows 2398‐2404. It is2492 therefore suggested to move this text just after row 2404
This sentence is quite unclear. Possible rephrase: "…with different
2509 temporal resolution and disaggregation of variables."

Italy

Accepted

Text revised as suggested

2555

As noted for row 2473, here the text could be revised as "…prescribed
2555 burning, planned and unplanned including slash and burn,.."Italy

Accepted with
Modification

Text has been revised to include "slash and burn"

2560

Identification of the land means something, while identification of theareas something else. For instance, the KP method identify the land i.e.
forest land but doesn't require to identify the areas or each specific area
since the identification of ND is done statistically at level of total
emissions; so that a fraction of the emissions caused by disturbances isqualified as subject to natural disturbances, not a fraction of areas. So,
this sentence implies that the KP method cannot be implemented as it is.
It is therefore suggested to redraft as follow: "Identification of the lands
affected by disturbances, as well as a description of the methods andItaly
2561 criteria applied"

Accepted with
Modification

Text has been revised as follow: Identification of the lands andarea of land affected by each disturbance, as well as a
description of the methods and criteria applied

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TolineComments

Country

Also for GHG fluxes information on criteria and approaches is important.
So we'd suggest: "For those lands, estimation of the emissions andsubsequent removals associated with natural disturbances only, e.g.
salvage logging emissions and associated subsequent removals are not
2563 included, as as well as a description of the methods and criteria applied" Italy
The "%" sign after the value "0.025" is an error. It should be either 0.025
Italy2582 (this is a proportion) or 2.5% (this is a percentage).
To enhance the understandability, it is suggested to add the word "entire"Italy2581 in front of "forest land".
The 1990 base year is an UNFCCC element of reporting guidelines. IPCC
guidelines have not such a time frame. We'd suggests to delete this para.
2615 Guidance in the previous para are clear enough.
2732 replace "forests" with "any forest land"
recalling comment on row 2393, it is suggetsed to replace "direct" with
2756 "abrupt"
delete the word "direct", since also lagged emissions seem to be included
2791 according to the subsequent para
the words "and/or magnitude" should be added to just after "likelihood",
since "preventative measures or modifying factors " refers also to the2818 "propagation"
366 should be point v) of the list

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Responses

Authors' notes

We have added the proposed text. We also point out that
Sectio. 2.6.4 provides additional information on documentationand transparency requirements.

Accepted
Accepted with
Modification

Text has been revised to replace “fraction” with “percentage”.

Accepted

Text revised as suggested

Italy

Accepted with
Modification
Accepted
Accepted with
Modification

Paragraph have been moved to Box 2.2J (Canada example)
Text revised as suggested
Text has been revised and word "direc" was replaced with
"immediate"

Italy

Accepted

Text revised as suggested

Italy
NorwayAccepted
Accepted

Text revised as suggested
Text has benn revised as suggested

Italy
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Responses

Authors'
notesthat may be used toApproach 2 and 3 refer toapproaches
represent areas of land‐use according to IPCC categories; andTier 2 and 3 refer to the level of methodological complexity
used to estimate emissions and/or revmovals; therefore there
are not "interchageable".
Nevertheless, authors have agree to introduce the following
definitions in the glossary:

3749

4

2

375

3751

4

2

457

3753

4

2

460

3755

4

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480

3757

4

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482

3759
3761

4
4

2
2

486
489

In the report, the terms "Tier 1, 2 and 3" and "Approach 1, 2 and 3" seeminterchangeable. The first term is clearly defined in the glossary (Glossary
711‐714). Please consdier explaining the term approach in the glossary as
Norway375 well.
Norway457 change to: "…country‐specific…"

Footnote 6: change to: "… "allometric equation" is also used...". i.e.
Norway460 reverse the word order of "…used also…"
The power function is incorrectly described in that "c" is not an
estimated parameter, but is instead the random error for themodel. Power Function (Allometric Function) has the form Y = aX^b
+ e. Where Y is biomass, a and b are parameters to be estimated,
Norway480 and e is the random error.
"c" is not an estimated parameter, it is the random error of the
Norway482 model.
The natural‐logarithm linearized form of the Power Function is ln(Y)Norway487 = ln(a) + b*ln(X) + ln(e). Please consider to correct
Norway490 Should read: "…tree height as a second predictor variable…"

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Accepted with
Modification

Approach 1
Represents land‐use area totals within a defined spatial unit,
which is often defined by political boundaries, such as acountry, province or municipality.
Approach 2
The essential feature of Approach 2 is that it provides anassessment of both the net losses or gains in the area ofspecific land‐use categories and what these conversions
represent (i.e., changes both from and to a category). Thus,
Approach 2 differs from Approach 1 in that it includes
information on conversions between categories, but is still only
tracking those changes without spatially‐explicit location data,
often based on political boundaries (i.e., locations of specificland‐use and land‐use conversions are not known).
Approach 3
The key defining characteristic of Approach 3 is that it is both
spatially and temporally consistent and explicit. Sample‐based,
survey‐based and wall‐to‐wall methods can be considered
Approach 3 depending on the design of the sampling/mapping

Accepted

Text fixed

Accepted

Text fixed

Noted

Text is revised and the parameters clarified

Noted

Text is revised and the parameters clarified

Noted
Accepted

Text is revised and the parameters clarified
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3765
3767

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4

2
2

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665

3769

4

2

726

3771

4

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773

3773

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799

TolineComments

Country

The message of this part of the box is not according to fieldinventory practise. This box correctly describes the possibilities ofusing terrestrial laser scanning (TLS) as a means to develop or
validate allometric biomass functions. However, the indicated lines
suggest that TLS could be used for inventory purposes ("biomass
predictions from TLS") and that the accuracy of such inventories
would be independent of complex canopy structures. To ourknowledge, this is not the case as occlusion effects do not allow theuse of TLS for example in dense understory. Also issues due toweather (scan are of lower quality in strong winds or under rainy
conditions), currently restrict the use of TLS to specific studies suchas the development of biomass models. We suggest that you
Norway622 consider to delete the indicated lines.

"variables" (as opposed to parameters) are usually said to be predicted
648 (not "estimated").
665 Should read: "…strength of the signal of the reflected…"

NorwayNorwayThis box describes a method for generating a biomass map which does
727 not seem to be published in a scientific journal. Please provide references. Norway
Figure 2.3: should Box 3 be named Tier 3 or Tier 2 & 3 since both Tiers are
Norway775 proposed.
Please consider associating this statement with the assumption of "theyear of event": "the carbon in biomass killed during a disturbance ormanagement event (less removal of harvested wood products) is assumed
to be released entirely to the atmosphere in the year of the event". (see807 line 732‐734).
Norway

3775

4

2

818

The default carbon fraction 0.5 might sometimes underestimate carbon
stock (Beets and Garrett 2018). Moreover, carbon fraction might dependon stand age. Thus, please consider including a flexible carbon fraction
819 (CF) of dry matter for both temperate and non‐temperate species.
NorwayHow is this sentence related to the fundamental assumption that theconventional factor that carbon comprises 58% of organic matter and theconventional conversion factor of 1.724?

3777

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991

Responses

Authors' notes

Accepted with
Modification Part of the sentence is deleted

Accepted with
Modification

In principle the reviewer is right on terminology. On the other
hand, I think we do estimate (and not predict) some quantities
in field. We predict biomass of individual trees, but we estimate
when we produce the plot value by aggregating across tree
predictions. So we used variables and parameters to be moregeneral.
OK change accepted
The following reference was added: Ometto, Jean Pierre; Assis,
Mauro Lúcio; Cantinho, Roberta; Pereira, Francisca; Gorgens,
Eric; Satto, Luciane; Siqueira, Emily; Tejada, Graciela (2018):
Biomass map of Amazon with a 250m pixel size, link to
GeoTIFF. PANGAEA,
https://doi.pangaea.de/10.1594/PANGAEA.891345

Accepted

Text fixed, applies also to Box 2.

NotedThis association is made beginning on line 777, text in grey
beyond scope of revision.

Accepted with
Modification
Accepted

Accepted with
Modification
RejectedThank you for the comment, we have clarified that this value isfor temperate tree species. Unfortunately there is very little
data on this topic so the values given here are default values, tobe used if no more detailed information is available.
The value of 12% C provided is that used in Volume 4, Chapter
3, Annex 3A.5 to define an oragnic soil. An organic soil does
not have to composed entirely of organic material, it cancontain mineral material as well, but it must meet theminimum organic carbon concentration requirements asprovided in Volume 4, Chapter 3, Annex 3A.5.
Action: No change

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21054

TolineComments
Consider to rephrase the sentence "Since the impact of biochar
amendments is included …" to "Since the impact of persistent biochar
amendments is included in Equation 2.24, it is essential that biochar witha persistence of 1000 years or more is not included as an organic
amentment in the estimates of ∆Cmineral".
Reasoning: Only biochar that will remain after 1000 years is accounted forin the term ∆BCMineral. Biochar that will not remain after 1000 years
should be treated like other organic amendments and should be includedin the estimates of ∆Cmineral.

Country

4

2

1054

3783

4

2

1086

3785

4

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1211

Authors' notes
Given the movement of the biochar component from Equation
2.24 to Equation 2.25 and the new use of a 100 year
permanence period, a portion of this comment no longer
applies.
A statement already existed within the text to ensure thatbiochar is not included as an organic ammendement elsewherein the inventory.

Accepted with
Modification

All that is required is for biochar production faciliites to record
the amount of biochar that ends up being applied to soil. The
value used for BCmineral can be the total amount of biochar
applied to soil in an inventory. It does not need to be spatiallytracked. Such an approach should allow separation of biochar
from other organic amendments. The following sentence has
been added.
" The BCmineral term in Equation 2.25 can be derived bydetermining the total mass of biochar carbon with apermanence >100 years that was applied to mineral soils.
There is no requirement to track the spatial allocation of thebiochar carbon applied to these mineral soils. "Accepted

Removed the third diamond related to the Tier 2 Steady State
Modelling method from Figure 2.4
The revision has been made in the footnote and the following
text has been added as a note at the base of Table 2.3B.
"The studies used in the derivation of Fperm values included
only cropland and grassland mineral soils. Thus the Fperm
values provided in Table 2.3B are only applicable to mineralsoils under those land uses. If biochar is added to mineral soils
associated with forest land, settlements, other lands or
wetlands, then country specific values would have to be
derived using a Tier 2 or 3 method."

Norway1056
It might be difficult to differentiate between biochar amendment andother organic amendments as there is no reliable measurement methodthat is able to differentiate between biochar and other organic
amendments. It could be clarified how this can be done.

3781

Responses
Noted

NorwayFigure 2.4: Editorial: Please check the term in the third box: It should be
Norway1087 plant "production".
Footnote 7 indicate that a Tier 2 or 3 method is needed for application ofbiochar in other land‐use categories (than cropland and grassland). Thereis, however, no description of methodology in e.g. Ch. 4 Forest. How thisis to be interpret is unclear. What is required to implement application ofbiochar in these land‐use categories? Please add more information.

1056

Norway1211

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TolineComments
The temperature thresholds allocating 1.5 times more stability to biochars
produced at above 600 °C are inappropriate. Please consider adjustments
to the text. Some studies show that a temperature threshold of 370 °C is
sufficient for producing stable biochar (Budai et al., 2016), and several
studies show an increase in biochar stability with pyrolysis temperature(comparing pyrolysis temperatures of 450 and 550 °C for example) (Fanget al., 2014). However, greater stability of biochars produced above 600°C compared to biochars produced in the range of 450 to 600 °C has notbeen documented and the source of data used here (Figure 2A.2‐1) is notconvincing of this trend either. There should not be a large increase in the
FPERMp factors for biochars that have undergone more intensive
carbonization. The categories (currently based on temperature ranges of
450 – 600 °C and >600 °C) should be eliminated or reduced: the FPERMp
factors for all biochars meeting a minimum threshold (O/Corg < 0.25
and/or H/Corg < 0.7) should be a single value (0.43). Most change inbiochar stability and reduction in biochar yield during production occurs
at low temperature gradients, not in the range of 600 °C. Results fromlaboratory studies on biochars produced under highly controlled
conditions indicate that an increase in persistence above a fairly low
temperature threshold (450 °C) is not very strong with individual studies
showing no difference (see Budai et al. 2016) or small differences in therange of 20%. The consequence of the current large difference is that
producers will favor higher pyrolysis conditions, while at this time theenvironmental benefits of high‐ and low‐temperature biochars is still
being investigated.

Country

4

2

1217

Authors' notes
The calculation of Fperm has been changed from a linear
regression to heating temperature categories to account for the
known non‐linearity between pyrolysis temperature andbiochar C persistence. Justification for this change has been
added to Annex 2A.2. The Tier 1 methodology was based intemperature rather than biochar properties (such as thementioned H/Corg or O/C ratios) to facilite accounting in theframework of a Tier 1 method. H, O, and C analyses using
Dumas combustion requires specialized equipment that is notavailable in many countries. In addition, costs for analyses will
also constrain the applicability of the method. Mandating theuse of elemental ratios will reduce the ability to account forbiochar additon to mineral soils. Countries with the ability tomeasure biochar properties are encouraged to use therecommended Tier 2 and 3 methods; appropriate reference
was added to the method and appendix.
The text in Annex 2A.2 defining how Fperm was calculated wasrevised. The revised values of Fperm have been added to Table
2.3B. Text has also been added to Annex 2A.2 defining thepotential use of O/C and H/C ratios in higher Tier methods.

Norway1215
In equation 2.26A the term accounting for methane and nitrous oxide
emissions (BCTOTp∙GWP‐CH4∙0.011)+ (BCTOTp∙GWP‐N2O∙0.011) during
pyrolysis should be omitted.
Reasoning:
1. In industrial pyrolysis plants syn gas (pyrolysis gas) is flared or used forenergy/fuel production. Emissions of methane and nitrous oxide of theseplants are neglectable. Values of 0.011 and 0.000022 in the equation are
based on small, low technological kilns studied by Cornelissen et al. (2016)
where syn gass is emitted without any treatment.
2. Emissions from pyrolysis plants should be taken into account ininventories for industry. Biochar, biooil and syn gass are the main
products from pyrolysis. Pyrolysis is an industrial process for energy andfuel production equal to waste incineration, and emissions should be
assigned to the industrial sector and not accounted for when biochar isused for carbon sequestration in soils.

3789

Responses
Accepted with
Modification

Accepted

Norway1219

Page 138

It has now been decided that emissions of non‐CO2 GHGs (e.g.
CH4 and N2O) during the heating process used to produce
biochar will be recorded in the Energy sector of national
inventories (see Volume 2, Chapter 4, Table 4.3.2.1 for values
associated with charcoal production).

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TolineComments
Footnote 8: Please add that the Table 4.3.2 is in Volume 2, Energy,
chapter 4.3.2.1 SOLID TO SOLID TRANSFORMATION PROCESSESCountry

4

2

1219

4

2

1227

4

2

1230

4

2

1232

Accepted

The permanence period has been changed to 100 years to beconsistent with the permanence requirements for othersequestration measures.
All permanence values were recalculated to 100 years and used
to replace values previously entered for a permanence periodof 1000 years. All references to 1000 years in the text havebeen changed to 100 years.
It has now been decided that emissions of non‐CO2 GHGs (e.g.
CH4 and N2O) during the heating process used to produce
biochar will be recorded in the Energy sector of national
inventories (see Volume 2, Chapter 4, Table 4.3.2.1 for values
associated with charcoal production).

Accepted

Norway1230
Need to add to explanation to N2O discounting: "if not used in abioenergy context": If pyrolysis is effciently used (as it should) for bothbiochar and bioenergy/syngas production, the emisison associated withthe bioenergy production need to be accounted in the energy sector, andnot in the Land / C sequestration.

3799

It has now been decided that emissions of non‐CO2 GHGs (e.g.
CH4 and N2O) during the heating process used to produce
biochar will be recorded in the Energy sector of national
inventories (see Volume 2, Chapter 4, Table 4.3.2.1 for values
associated with charcoal production).

Norway1227
The word "produced" needs to be changed to "released to theatmosphere": The release of CH4 TO THE ATMOSPHERE during pyrolysis is
a problem, but not its capture and use as bionergy (there it is beneficial
and only concerns the energy sector). With well engineered biochar‐pyrolysis systems, no CH4 is released to the atmosphere, but CH4 isproduced by the process, use in the bioenergy sector (where it is relased
to teh atm as CO2). This is why it is crucial to replace "produced" by"released to the atmosphere.

3797

Accepted

Norway1220
To be consistent with previous definition of permanent storage, why nottake 100 years for permanent storage (instead of 1000). Alternatively
please explain the choice of time horizon.

3795

Authors' notes
It has now been decided that emissions of non‐CO2 GHGs (e.g.
CH4 and N2O) during the heating process used to produce
biochar will be recorded in the Energy sector of national
inventories (see Volume 2, Chapter 4, Table 4.3.2.1 for values
associated with charcoal production).

Norway1218
Please add "Corrections for GWP of CH4 and N2O do not apply if syngas isused for bioenergy purposes".

3793

Responses
Accepted

Accepted

Norway1232

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It has now been decided that emissions of non‐CO2 GHGs (e.g.
CH4 and N2O) during the heating process used to produce
biochar will be recorded in the Energy sector of national
inventories (see Volume 2, Chapter 4, Table 4.3.2.1 for values
associated with charcoal production).

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TolineComments
It should be highlighted that C content factor for the different feedstocks
varies with pyrolysis temperature. Biochar produced at higher
temperatures contains higher C levels.

Country

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1418

Noted

The calculation of Fperm has been changed from a linear
regression to temperature categories to account for the known
non‐linearity between pyrolysis temperature and biochar C
persistence. Justification for this change has been added toAnnex 2A.2. The tier one methodology was based on heating
temperature rather than biochar properties (such as thementioned H/Corg or O/C ratios) to facilite accounting in theframework of a Tier 1 method. H, O, and C analyses using
Dumas combustion requires specialized equipment that is notavailable in many countries. In addition, costs for analyses will
also constrain the applicability of the method. Mandating theuse of elemental ratios will reduce the ability to account forbiochar use. Countries with the ability to measure biochar
properties are encouraged to use the recommended Tier 2 and3 methods; appropriate reference was added to the method
and appendix.

Accepted with
Modification

It has now been decided that emissions of non‐CO2 GHGs (e.g.
CH4 and N2O) during the heating process used to produce
biochar will be recorded in the Energy sector of national
inventories (see Volume 2, Chapter 4, Table 4.3.2.1 for values
associated with charcoal production).

Norway1269
If the term in equation 2.26A accounting for methane and nitrous oxide
emissions is not omitted (as suggested for Eq. 2.26A), it should at least beemphasized in tier 2 and 3 that methane and nitrous emissions can be
estimated based on measurements.

3805

Authors' notes
No temperature response is included in Table 2.3A (FCp). The
reason temperature was not included is as follows: Although
there is a modest increase with temperature in the carbon
content of biochar on an ash‐free basis, this is mediated by thefact that ash content of biochar (as a fraction of total weight)
also increases with temperature. These two effects
approximately cancel out, leading to only a negligible (muchsmaller than the uncertainty and not significant) change incarbon content as a fraction of total weight. Accordingly, notemperature response of FCp was used, because FCp is
expressed per unit total weight of biochar (including ash).

Norway1262
Elemental ratios should be the default measure of biochar quality, notpyrolysis temperature: Pyrolysis temperature is the most important
determinant of biomass conversion, but it is unreliable as a quality index
due to the difficulty of controlling and measuring it. This is especially true
at lower pyrolysis temperatures of 400 °C and below where exothermic
reactions are predominant (Budai et al., 2014). Heat transfer limitations
often result in uneven pyrolysis of the biomass, with exothermic reactions
remaining localized and measurements of the reactor temperature notnecessarily representing the actual temperature experienced by thematerial. Therefore, elemental ratios of H/C reflect much better thantemperature, the degree of carbonization (degree of biomass conversion)of the biochar and hence its quality. The suggestion is that measured
biochar properties (atomic ratios of O/Corg and/or H/Corg) be used todefine the FPERMp factors in Tier 1, not production temperature, as
production temperature is difficult to monitor. Temperature
measurements taken often do not reflect the actual temperatureexperienced by biomass in a reactor. Elemental analysis is a standard
measurement that can easily be included in biochar quality assessmentthat would need to be performed anyway to ensure product quality(heavy metal content for example).

3803

Responses
Rejected

Norway1436

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TolineComments
There is not given any reasoning why biochar with a persistence of morethan 1000 years should be assessed separately. Why not biochar with apersistence of more than 100 years? We think 100 years has beenassessed as a reasonable period for soil carbon sequestration in earlier
IPCC‐reports. Persistence models based on the ratio of hydrogen or
oxygen to organic carbon are highly uncertain.

Country

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2

1478

3813

3877

3879

4

4

4

4

2

2

2

2

Noted

Average erosion rates are likely already included in the land
management factors. It is not possible to exclude them fromthese factors. As a result, to include eroision would require
movement to a higher tier, derivation of new land
managmenet factors that exclude erosion and derivation of C
loss/gain factors in response to erosoion/deposition

Accepted with
Modification

The proposed reference (Dalsgaard et al. 2016) has been added
into the list of other references as follows:"Model has been extensively tested against independent dataon forest land (Dalsgaard et al. 2016; Lehtonen et al. 2016;
Rantakari et al. 2012; Tupek et al. 2016)"

Norway1497
Box 2.2D refers to Finnish and Swedish studies but not to Nowegian.
Tupek is cited (he documents an underestimation of stocks) but it is not
mentioned that this is the conclusions of the paper. It could be good to
add something like: “Yasso07 was found to be challenged in moist
environments when estimating soil C stocks (Dalsgaard et al. 2016)”. Fx.
line 1624 page 2.49 after sentence ending with “(2001)”.

3811

Authors' notes
The permanence period has been changed to 100 years to beconsistent with the permanence requirements for othersequestration measures.

Norway1436
The carbon stock change is sometimes associated with the rate of soil loss
rate and/or rate of soil formation (ton/ha/yr). Soil carbon loss /gain varies
with the type of land uses (see Lal 2008; SOC depletion of 10–20 Mg C
ha–1 for arable land, 5–10 Mg C ha–1 for pasture, 2–5 Mg C ha–1 forpermanent crops, and 5–10 Mg C ha–1 for forest and woodland). Pleaseconsider this default range of SOC information to address the issue ofcarbon loss due to soil erosion.

3809

Responses
Accepted

Norway

1598

1626

2258

Uncertainty analysis should not be confused with sensitivity analysis. In
order to avoid this please consider to add sensitivity analysis to the2261 glossary.

Norway2419

It would be nice to include information on if /how phenomens like e.g. El
Nino is to be included and considered. How is the principle that theemissions are "not materially influenced by, and beyond the control of, acountry" to be understood in the context of e.g. a year with El Nino? How
is this connected to the principles related to IAV and multi‐year periods,
Furthermore natural disturbances might also influence the removal bysinks. Please consider if this needs to be elaborated in section 2.6 e.g by
Norway2502 including removals in line 2470.

2481

Line 2481‐2483 lists categories where the methodolgoical guidance isapplicable. It mentions undrained wetlands and undrained peatlands.
Does this imply that the method is not applicable to drained wetlands anddrained peatlands? This is important to clarify as eg Indonesia has years
with large emissions from drained peatlands, and large interannual
Norway2483 variability in such emissions (the emissions are caused by fires).

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Rejected

The paragraph clearly describes the difference between
uncertainty analysis and sensitivity analysis. No further
definition / explanation is required.
The text deliberately focuses on natural disturbances . The
impact of drought (eg related to El Nino) was not included
because of the difficulty in dissaggregating emissions (orreduced) removals.

Rejected

In line 2470 we are not adding removals because the actual
disturbances (at the time) do not cause removals. However,elsewhere in the chapter we clearly state that removals
following natural disturbances must be treated consistent withthe treatment of natural disturbances.

Accepted

Human‐caused drainage of peatlands increases fire risks andincreases emissions in the case of fires. These systems are
therefore materially influenced by humans. Text has beenrevised to further clarify the application of the method

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TolineComments

Country

The text is a little unclear as to wether there must be subsequent
removals to equal the emissions, if the emissions can be consideredcaused by natural disturbances. Such an approach is easy to understandfor living biomass, but more difficult for soils. The text would benefit frombeing clearer on how to include or exclude emissions from soils in the
Norway2481 context of natural disturbances.

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264

131

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591

Boxes 2.2i, j and k: The text includes examples from three developed
countries. It would be instructive to include examples also from adeveloping (tropical) country, and also include an example to highlight
how to adress emissions and removals in the soil carbon pool in the
Norway2778 context of natural distrubances.
Box 3,1,A. in the line for "forest land" "reporting FL areas that in a specificinventory year or years fall below the country definition of FL", ad, at theend of the last paragraph ", legal instruments". There are countries wherelegal instruments define if a land is forest land even if it is not forested forSpain
265 a period of time.
replace, at the end of the line "unlikely" by "a challenge". We know that isdifficult to use data mentioned in an approach 3 context, but it is not
Spain
591 unlikely, it is challenging. It can be done.

1

The additions of explanations and examples in this chapter are welcome.
Insights on approaches and good practices when using different types ofdata (wall to wall, sample‐based methods…) and in particular the section
France1699 “combining multiple data sources” will be very useful.

3883

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473

475

477

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Responses

Authors' notes

Accepted with
Modification

Text has been revised to further clarify that refers to all pools.
Further details are in the paragraph below, and therefore theauthors did not consider it appropriate to duplicate the text
here. The methods build on estimates of emissions from allpools (including soils) derived using those methods outlined in
the IPCC GL and they need not be repeated in this section.

At this time we are not aware of any method that has been
implemented in a developing country ‐ but the methods listed
as examples in the boxes could be applied.

Rejected

The emission and removals estimates presented here alreadyinclude E/R from soil C pools because they are based on thegeneral estimation methods outlined in the GL.

Accepted

Added 'tenure' at the end of paragraph which captures thesuggested intent without being precriptive as this can beachieved with or without a legal instrument.

Accepted

This sentence has been revised as suggested.

Noted

Thank you for the positive feedback.

194

This is a policy relevant question, potentially causing conflicts between
reporting Parties. Meanwhile, political issues are not covered by the IPCC
mandate and shall not be the subject of any IPCC Guidelines. It should be
discussed and solved by the UNFCCC. By this reason we suggest to delete
the recommendation on "excluding lands lost due to changes in politicalboundaries from the entire time‐series; and including lands gained from
Russian Federation Accepted
195 changes in political boundaries for the entire time‐series".

See response to comment 3563.

203

Please, note that transfer of managed land to unmanaged may occur inthe reporting. Please, modify as following: If managed land become
unmanaged the legacy effects of past management can continue forextended periods, and associated anthropogenic emissions and removals
Russian Federation Rejected
205 should be reported during chosen transition period.

The discussion in this para refers to a situation where legacy
emissions from past management practice continue to occur
for extended period during which time it is not possible totransfer managed lands to unmanaged if anthropogenic
emissions continue to be reported.

It is not clear "….to lift the Approach to a higher level…" if it was stated
531 that Approaches are not in a hierarchical system (line 277).

Sentence re‐drafted as: These examples assume that only one
type of data and process is used. In many cases the data inputs
and processes can be combined resulting in a different
Approach than can be achieved with any one single data source

530

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In Table 3.6A and its footnote, non‐permanent sample units (e.g.
temporary inventory between two points in time)
are defined as adequate for Approach 2 under sample‐based methods
whereas the text on lines 617‐619 says that with only temporary sample
units, it is not possible to apply Approach 2 or 3 methods but incombination with other data it would be possible. Please clarify. In our
619 opinion, non‐permanent sample units are in line with Approach 2.

Responses

Authors' notes

FinlandAccepted

Table and the relevant text has redrafted to clarify use of
temporary samples units for Approach 2 and 3 methods.

EU

Accepted

The authors appreciate the suggestion of a more recent
reference and have included the suggested text.

EU

Noted

These two figures are from the existing 2006 guidelines and not
subject to review.

Accepted

Text has been modified based on the feedback to include only
general guidance to account and report if there are changes incountry area due to biophysicial or technical reasons.

Reference to the FAO classification is outdated. Please refer to the latest
version of WRB 2015. Definition of organic soils (Histosols) is reported on
page 85 of WRB 2015: Soils having organic material:
1. starting at the soil surface and having athickness of ≥ 10 cm and directly overlying:a. ice, orb. continuous rock or technic
hard material, orc. coarse fragments, the interstices of which
are filled with organic material; or
2. starting ≤ 40 cm from the soil surface
and having within ≤ 100 cm of the soil
surface a combined thickness of either:a. ≥ 60 cm, if ≥ 75% (by volume) of thematerial consists of moss fibres; orb. ≥ 40 cm in other materials.
IUSS Working Group WRB. 2015. World Reference Base for Soil Resources
2014, update 2015
International soil classification system for naming soils and creating
legends for soil maps.
World Soil Resources Reports No. 106. FAO, Rome.
1507

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1614 http://www.fao.org/3/i3794en/I3794en.pdf
Why proposing a National soil classification system (US Soil Taxonomy)
and a international standard (WRB) as possible alternatives (Fig. 3A.5 31640 and 3A.5 4)?

185

The area data of national statistics is sometimes updated due to theimprovement of accuracy of the low data reflecting the recent situationthat better quality of remote sensing information become available than
before. Such a change is caused by technical reasons and does not meansreal area change have happened, however, inventory compilers need touse this type of time series data. It is desirable to provide good practice on
how to address this type of change in guidance (for instance, provide
information on how this artificial data change is addressed in theJapan
195 inventory).

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1759

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1761

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1763
1765

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985
1476

Regarding the guidance of up‐scaling, It is hard to understand how thecalculation of highlighting mitigation potential (example in lines 861‐862)
can be used for up‐scaling and to obtain national average stratified land‐use data. More concrete guidance or procedure is necessary. Additional
information on how to do to the part of lines 867 to 875 is also consideredJapan
875 useful for compilers.
"lag emissions/removals" is better to be replaced as "lagged emissions
Japan
969 and removals" for editorial consistency.
The same sentences are seen in the previous paragraph. It would beJapan
990 better to remove this part to avoid duplication.
Japan
1476 "his refers to..." is to be changed to "This refers to..." (typo)1504

In terms of "guidance" prospect, it is more useful to provide the summaryof methods on how change can be confirmed from time‐series
information by the research by NIS‐LCCP than just explaining the fact thatJapan
1505 NIS‐LCCP gives the example of this.

1767

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206

186

Consistent with the comment to chapters 2.6.2 to 2.6.4 above it is also
recommended to delete these lines adressing good practice for reporting
Austria
209 lands related to natural disturbances.

The level of detail here is not necessary, and likely to lead to the type ofpolitical discussions that are not apropriate in an IPCC context. Delete
text starting on line 186 with "In some cases…" up through line 195
ending with "…entire time‐series." and replace with the following: "Whennational land areas change it is good practice to document the cause of
the change, and report the total country area throughout the reporting
period as the area for the last year of the inventory report by using
appropriate categories and sub‐categories to report lands that are newly United States ofAmerica
195 excluded/included in country reporting."

3565

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172

Clarity would be improved by inserting the phrase "categorized as" here:"...and to ensure that anthropogenic activities in unmanaged land result in United States ofAmerica
201 unmanaged land becoming CATEGORIZED AS managed."
add line break between "...available. If...", as this info does not pertain to
Norway172 Other Land but to all categories.

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267

Considering acidic soil as a soil strata for Tier 1 might be relevant,
268 especially in high rainfall areas, where leaching is a common incidence.

Page 144

NorwayResponses

Accepted
Accepted

Authors' notes

Text revised to clarify the intent and purpose of up scaling anddown scaling. Detailed guidance on up / down scaling methods
is beyond the scope of current revision.

Accepted
Accepted

Text edited as suggested.
Duplicate paragraph has been deteled. Thank you for pointing
out this.
Text edits made as requested.

NotedThis text is part of the Annex. Here we provided references topublications to obtain additional info on this topic. We have cut
down further discussion on remote sensing methods based oncomments from earlier rounds of review.

Rejected

It is importnat that land subject to natural disturabces are
identified since otherwise emissions and subsequent removals
could not be estimated! The intent here is to point to theexistence of IAV gudance in Chapter 2, Volume 4, therefore it is
not possible to delete these lines unless IAV sections are
removed entirely.

Accepted

Level of detail has been reduced as suggested. The authors
consider it relevant to povide general guidance as it is possible
to have change in the area of a country due to biophsysicalprocesses or technical reasons. Reference to good practice has
been re‐drafted as suggested: "When national land areaschange it is good practice to document the cause of thechange, and report the total country area throughout thereporting period as the area for the last year of the inventory
report by using appropriate categories and sub‐categories toreport lands that are newly excluded/included in country
reporting."

Accepted

Text edits made as requested.

Acceptedline break added as suggested.

Noted

No action required.

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355

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684

The table 4.5 on BCEF values were not refined, but the use of these BCEF
are very complex for countries. For exemple in many cases, by using thedefault BCEF the carbon stock changes are very diffferent according to themethod used (stock variation versus gains ‐ losses) which is not easy tounderstand. The values for the growing stock levels <20 m3 are very highand may lead to very strange results. Moreover it is not so clear toundestand how to use these BCEF, because they are provided by growing
stock levels and in many cases these growing stock level are not known (isit necessary to subdivide forest area ? is it possible to take into accountcarbon stock changes ?). It won't be possible to further develop this partbut it is just to mention that it is one of the main concern of countries
France676 when they develop their GHG forest inventory.
Due to the website accessing error to the 'Reference 80', there's no way to
Republic of Korea
685 confirm the data for the Table 4.7.

684

In regard to the default values based on the 'Reference 80', theuncertainty is relatively large.
Hence the possibility and feasibility of the default values should be
685 reconsidered (ex. Temperate ‐ Mountain ‐ North and South America).

688

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923

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Responses

Noted

Table 4.5 was not refined due to the lack of disgregated andcomparable information, the table is the same that is being
included in the 2003 GPG and the 2006 GL.

Accepted

The URL revised.

Republic of Korea

Accepted

The uncertaninty is corrected, it was a typo error. Now is 153.8.

Please make the description of the name of species consistent, as the text
here use both the scientific name and English name of the species and it's
689 rather confusing. I would suggest using scientific names. (ex. black locust) Republic of Korea

Accepted

Scientific names provides for genus and species

The 'range' in Table 4.10 seems to be incorrect (ex. Temperate domain ‐mountain ‐ North and south america "7" and "86") which requires re‐consideration and do some error corrections if any. If not so, more clear
statements on the range should be provided.(ex. Temperate domain ‐Republic of Korea
697 mountain ‐ North and south america "7" and "86")Use of terminology: The term used in the title and unit of Table 4.11 is not
Republic of Korea
702 clear whether it means "growth rate" or "growth".

Accepted with
Modification
Rejected672

In the Tables, it is suggested to add the defaulted Allometric Models. If thedefault value can not be given, it is suggested to delete all the words
China
Rejected
705 relevant to this model.
In table 4.4 the parameter R for some temperate forests assumes a very
high value (e.g. 1.4) for ‘Quercus’. Does this refer to cork oak and other
United Kingdom (ofMediterranean type forests? If so, this should be made explicit, as it
Great Britain andNorthern Ireland) Noted
672 should not be applied for all Quercus species.

132

The term forest management “regime” should be explained (e.g., such as…). For example, line 132 mentions “management actions or regimes” andCanada132 in line 223 “management intensity or regime”.

664

Authors' notes

Page 145

Accepted with
Modification

Single values are uncertainties, a footenote is added to clarify.
The term "rate" is correct, as the growth is given as meanannual increment" in m^3 ha‐1 y‐1.
The variability and availabilty of allometric models is far tolarge to give any default models that can be used in stead ofthe defult emission factors. Allometric models are considered
as models to be country specific and therefore generalguidance is provided as Tier 2.
It is not necessary to maked explicit, it is claer that the cited
literature Cotillas et al 2016 refers to oak coppice, this explains
the high value of "R".
The word "management regime" has been removed whenunnecessary and replaced with "management practices" whennecessary.

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Comments
Country
It's unclear why there is a line stating that it is not necessary to include
SOC changes on mineral soils if Approach 2 or 3 data is used? Under the
Tier 1 method you already state that soil C stocks do not change. It would United States ofAmerica
135 be helpful to clarify this.

81

Please consider revising the association of SOC and soil depth. To same
extent, the existence of soil carbon can be extended to a depth of 1‐ 2 m(Kirschbaum 2000). Thus, restricting of SOC to the plowing depth (30 cm)
may be applicable for cropland, but it might "underestimate" the amountof soil carbon pool in forest land and grassland. Depending on soil typeand its property, moisture, temperature, rate of mineralization, etc, SOC
decline with soil depth. The IPCC might consider developing emissions
factor (EF) for each interval along the soil profil to certain depth, forexample, 0‐30, 30‐50, 50‐100 cm+. It's likely to increase SOC in thesubsurface soil horizone due to deep placement and it classified as
Norway90 previously "unaccounted C" in the global budget (Lal 2008).

Responses

Noted

The paragraph following the commented sentence provides
further explanation on the question raised.

Rejected

We agree in principle that it would be an improvement toestimate impacts deeper in the profile, but there areinsufficient data at this time to derive C stock change factors at
deeper depths. In fact, it is not even feasible to estimate
default C stock change factors to a 30cm depth for forest land.

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228

Please consider specifying how conversion from cropland will tend to
decrease emissions. Does this assumption consider also rice farming as
well, paddy field? This is related to drainage status. Besides, it depends onfarming system, fallowing period/ no‐till farming, bio‐physical andchemical properties of the land drainage status, etc. Conversation fromfrequently plowed cropland use to grassland use are most likely to
Norway380 improve the status of SOC after some years.
in the table, it is indicated "“*** calculated” : please explain how thevalues have been calculated using the other field of the table, forFrance229 transparency and clarity purposes.

183
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448

Disagreement : in particular for estimating carbon inputs, detailed data on
France401 crop types, fertilization is required in the steady state approach.
France448 Ref. Paustian 1997b Not available

Noted
Accepted

1015

Excessive importance is given to biochar, compared to organic
amendments for which only manure is considered (nothing on composts,
digestates). This section on biochars should be shortened and a section onorganic manure should be added, showing the importance of these inputs
to soil carbon storage, and exhibiting the range of organic imput, fromdigestates to solid manures and composts (and thus the need to have aFrance1046 good characterization of these organic inputs).

Accepted with
Modification

187

189

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1222

1223 Which data was used for giving the 4.7 value?

FrancePage 146

Authors' notes

Rejected

Accepted

Accepted

The statement is that C stocks tend to increase, but not thatthey will always increase. The text here is consistent with theresults from meta‐analysis that was conducted for the land use
factor for cropland. See Chapter 5.
Edited table footnote: "*** calculated (Lmax = G * Maturity
cycle; Lmean = Lmax/2)". Also corrected an error in one tablevalue.
We agree that data on crop types is needed but many countries
collect such data routinely. However, there is no need to haveany specific data on fertilizer to apply the method.
This has been corrected to Paustian et al. 1997.
We did not realize that biochar C was given this level ofprominence, but after reflecting on your comment, we agree
that the methods should not be the focus of entire sections as
currently presented. Therefore, we incorporated thesemethods into the mineral soil C sections. Biochar C is part ofthe mineral soil C stock calculation and therefore should befound with this section. Organic manures are addressed in thissection as well, although manure is directly incorporated in theoriginal C stock calculations from the 2006 GL given the shorttime frame over which the changes occur. This is where
biochar C differs, and needs an additional calculation to be
included in the method.
Note added for clarification of the source of the data: "10 t dry
biomass (1996 Guidelines) and 0.47 carbon fraction (Table 5.8
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Comments
Country
the reference of Cardinael (agroforestry emission factors and biomassdata) is missing : Cardinael, R., Umulisa, V., Toudert, A., Olivier, A., Bockel,
L., Bernoux, M., 2018. Revisiting IPCC Tier 1 coefficients for soil organicand biomass carbon storage in agroforestry systems. Environmental
France3365 Research Letters 13(12).

Accepted

510

Indeed if D is different from 1 the method is not applicable (obviously, forlarge D values computed SOC values will be unrealistic). We suggest to
remove it from the equation, which avoids l.518 and any misuse of theFrance510 approach.

Accepted

536

Indeed if D is different from 1 the method is not applicable (obviously, forlarge D values computed SOC values will be unrealistic). We suggest to
remove it from the equation, which avoids l.518 and any misuse of theFrance536 approach.

Accepted

570

Indeed if D is different from 1 the method is not applicable (obviously, forlarge D values computed SOC values will be unrealistic). We suggest to
remove it from the equation, which avoids l.518 and any misuse of theFrance570 approach.

Accepted815

For applying Tier 1 default stock change factor for input(Fi) between
medium and highlevel, definition or range of supplemental organic matterin Medium level or medium C input in High‐with manure level should be
Republic of Korea
815 added in the description column.

Rejected

362

Considering the complexity of the "three sub‐pool steady‐state C model"
and the absence of calculation parameters, Tier 2 is not applicable. So it isChina
762 suggested to list Tier 3. Such a modification is requested.

Rejected

1108

The parametric values in this equation are not consistent with those given
in TABLE 2.3B, Chapter 2, Volume 4. According to TABLE 2.3B, theequation should be changed from"(2000∙0.38∙0.24+50000∙0.52∙0.38+15000∙0.49∙0.09)=10,723.9 tonnes C"
to "(2000∙0.38∙0.28+50000∙0.52∙0.43+15000∙0.49∙0.13)=12,348.3 tonnes
China1108 C". Such a check and revision is requested.

Accepted with
Modification

1101 Reference to Equation 2.25A should be corrected to Equation 2.26A.

Accepted with
Modification

1101

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Finland

Responses

Authors' notes

Included
We agree that it would be a problem to use for time steps ofmany years, so we replaced with 1 yr to maintain unit
consistency within the equation. The
V4_Ch5_Tier2_Steady_State_Method.xlsx spreadsheet was alsochanged to remove D.
We agree that it would be a problem to use for time steps ofmany years, so we replaced with 1 yr to maintain unit
consistency within the equation. The
V4_Ch5_Tier2_Steady_State_Method.xlsx spreadsheet was alsochanged to remove D.
We agree that it would be a problem to use for time steps ofmany years, so we replaced with 1 yr to maintain unit
consistency within the equation. The
V4_Ch5_Tier2_Steady_State_Method.xlsx spreadsheet was alsochanged to remove D.
The factors were derived based on a yes/no classification inwhich the amount of amendment is not needed, just whether
or not the soil is amended with organic matter. The
classification was done in this way to simplify for the activity
data requirements.
We agree that awkward wording of the differences between
the steady‐steady method and a Tier 3 model in box 5.1A could
contribute to misunderstanding that the Tier 2 steady‐statemethod is a process model. We reworded the sentences to beclear it is not a process model (L391‐406) so that it is clearer
now that it is not a complex model Tier 3 model. However, we
reject the comment that the model shoudl be Tier 3 because
calculation parameters are not provided because globally
aplicable values for the parameters are provided in Table 5.5A.

The fractions were revised based on comments in Chapter 2 to
a 100 year time horizon for permanence, and have been
updated as requested.

The equation number has been updated based on revisions to
Chapter 2. The equation number is now 2.25

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Country1108

In example: Carbon contents appear to be the same than defaults in Table
2.3A but the other coefficients presented in the example are not the same
as fractions remaining after 1000 yr in Table 2.3B. Please correct or please
Finland1108 explain what the other set of coefficients represent.

854

The parameter Ws has a value of 1.331 in Table 5.5A as well as Table 5A.3‐
2 line 3741. In the example provided as a supplementary file,
V4_Ch5_Tier2_Steady_State_Method.xlsx, the model parameter used in
the calculations is 1.331 however in first sheet 'Equations and Calculation
Steps', the text box containing the equation for wi in Equation 6: Soil
Australia
855 Water factor shows a value of 0.9303 for Ws.

612

629

868

1026

The equation for Wfac shows a multiplication of 1.5 which is used in thecalculations of the example provided as a supplementary file,
V4_Ch5_Tier2_Steady_State_Method.xlsx, however in first sheet'Equations and Calculation Steps', the text box containing the equation forAustralia
616 Wfac in Equation 6: Soil Water factor shows a multiplication of 0.15
The equation for Beta shows 0.85‐0.018*(LC/NC) which is used in thecalculations of the example provided as a supplementary file,
V4_Ch5_Tier2_Steady_State_Method.xlsx, however in first sheet'Equations and Calculation Steps', the text box containing the equation for
Beta in Equation 7: Calculation of intermediate values shows
Australia
635 0.832*(LC/NC)

Recommend clarification: Table 5.5 C The C/N ratio for sheep manure issurprisingly low ‐ should be closer to beef cattle, not same as swine. The
reference cited does not appear to contain this figure. Cite a more suitablesource. Lignin content of manure of pasture‐fed and lot‐fed cattle will
differ. That for sheep would be closer to grazed cattle than lot‐fed.
Australia

Recommend inclusion: Tier 2 will also require chemical composition of thebiochar so that the H/Corg method for estimating C stabilisation can be
Australia
1035 used.

Page 148

Responses

Accepted with
Modification

Authors' notes
The fractions were revised based on comments in Chapter 2 to
a 100 year time horizon for permanence, and have been
updated as requested. There is a detailed explanation of theseparameters in Chapter 2.
We thank the reviewer for the careful checking. The correct
value is 1.331, and the spreadsheet was corrected.

Accepted
We thank the reviewer for the careful checking. The value is
1.5, and the spreadsheet was corrected.

Accepted
We thank the reviewer for the careful checking. The equationin the text is correct, 0.85‐0.018(LC/NC). The spreadsheet wascorrected.

Accepted

Accepted with
Modification

We thank the reviewer for noticing the inconsistency. We
averaged the N content with that in 3 other articles, including
the one suggested byt the reviewer, and derived an average N
content of sheep manure of 3.26%. This very close to the
3.23% from the reviewer‐suggested reference and closer to thevalue for beef cattle manure. We modified the table.
We have added a sentence about H/Corg method and also
directed the compiler to Chapter 2 for more information. This
text has been added here as well as the Tier 2 section in Land
Converted to Cropland, Grassland Remaining Grassland andLand Converted to Grassland for consistency.

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Without any manipulation, we carried out a short, limited test of thesteady‐state model with data from two sites of the German Permanent
Soil Observation program. The results showed both locations inequilibrium, i.e. no changes with respect to the temporal trend andcarbon stocks calculated by the model deviated significantly from thelevel measured at the stations (ca. + 40%, respectively ca. ‐ 70%). Only byintensively manipulating the input data of the model (C‐Input) to reachthe actual initial C‐stock of the soil, we received results which correspondin trend and height approximately to the values of the measured values. A
small, additional test showed that also the temperature sensitivity of themodel does not seem very pronounced.
Admittedly, this was only a superficial and not at all comprehensive checkof the model. A comprehensive test would require to check significantly
more locations and to evaluate the uncertainties of the model. Suchadditional validation should be conducted before this model is included in
the guidelines. We also seek guidance, why specifically this model should
Germany
362 be endorsed by the guidelines as other models are also available.

Responses

Authors' notes
We appreciate the evaluation by the reviewers. As a non‐obligatory Tier 2 method, it will be up to each country to
determine if they want to adopt the method based on suchcountry‐specific assessments. The Tier 2 method provides
general estimates of C stocks given more country specific data
on C inputs, tillage, soil texture, and weather but does notinclude country‐specific data on initial soil C stocks. Therefore,
these C stock estimates are not expected to necessarily provide
an accurate estimate of soil C stocks of particular location. If a
country wishes to include the effect of measured initial soil C
stocks on estimates of C stock changes, then it would be best to
use a Tier 3 methodology. ANNEX 5A.3 provides the wide
range of location whose obsevation were used to fit themethod parameter values. We cannot provide a general
method uncertainty since that depends on the uncertainties of
the country‐specific inputs of texture, C input, and weather.
The uncertainties of the parameters are provided in Table 5.5A
and the compiler can use these with the those of country‐
spefici inputs to estimate the uncertainty of method for theircountry. We added a sentence in 5.2.3.1 where the method is
introduced (L365) that indicates the scope of use. It sufficiency
for that scope is the rationale for the selection of the particularmethod. Also, the three pool steady state solution has been
published in the literature. A country is not obligated to use it
and can choose to base C stock change estimates on any
veririfed model in a Tier 3 application.

Noted
Good point. We have a added a sentence to point out thisissue out to complilers.

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We understand that the possibility of using an asymmetric system withregard to the transitional period is introduced in order to avoid over‐ or
underestimation of land‐use change emissions from/ to cropland. This iscommendable but currently under the existing rules not applicable. Mostof the relevant literature refers to the "fast out ‐ slow in" ‐ principle (e.g.
Poeplau et al. 2011), mostly based on paired site studies. However, otherstudies do not show this asymmetry in carbon stock changes. Apart fromthe fact that we ultimately do not know what is the truth, against thebackground of other basic rules of the guidelines, this method does notseem practicable. For example: According to Poeplau et al. 2011, in thecase of land use change from, e.g., grassland to cropland, the carbon
losses occur within 18 years, whereas in the opposite direction thetransition period is in the range of 100‐200 years. As land use is usually
hard to trace back for the 20 default years, it seems impossible for 100‐
200 years. The compiler does not know, e.g., in the case of a LUC fromgrassland to other land, whether the area is in steady state or at what
Germany1404 time in the 200 year transition period.
Throughout chapter 5, no reference is made to this publication of Popken
Germany
1984 S., 2011. Please revise.

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Sent to Biomass C Subgroup
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Table 5.3: The citation "Canaveira, P. et al 2018" is missing in theGermany
241 reference list in the end of the chapter. Please add.
Coefficient Fpermp in the Example seems to be different from the number
on Table 2.3B. High temperature: 0.43, Medium temperature: 0.28, Low
temperature: 0.13. If there is the reason why using other coefficient, itJapan1109 should be explicitly explained.
There seems to be one missing reference (Table 5.5., source 6). It is ':Shirato, Y. & Yokozawa, M. (2005) Applying the Rothamsted Carbon
Model for long‐term experiments on Japanese paddy soils and modifying
it by simple mining of the decomposition rate. Soil Science and Plant
Nutrition 51(3): 405‐415.'
and would be preferable to be add between Line 3081: 'Shirato, Y.,
Yagasaki, Y. & Nishida, M. (2011)' and Line 3082 'Shrestha, B. M., Singh, B.
Japan
3082 R., Forte, C. & Certini, G. (2015)'.
To be more precise it is suggested to change the term in the brackets into
the following: (at maximum ‐ afterwards C stock changes are accounted
Austria
1167 in the remaining subcategory)
The figure legends are not explained in the immediate text. For example, C
Canada437 input, beta are not explained.
Canada606 Is this air temperature or soil temperature? Please specify.

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821 "profile to below the tillage depth (refs)." Please insert references.

CanadaAccepted

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"This may be consideration to chaise of depth." Ambiguous sentence,
821 poorly worded. Please revise to clarify.

CanadaAccepted

828"However, it is important to realize that all data used to derive stockchange factors across all land uses must be on an equivalent mass basis if
this method is applied". E18This seems incorrect. Equivalent masscalculations require only soil C concentration and bulk density. What do
the authors mean by "all data"? Presumably, this sentence is intended
merely to indicate that if an equivalent mass approach is adopted, it
Canada829 should be applied uniformly across all land uses. Please correct.

Accepted

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Toline"This will be challenging…" This statement seems to discourage the use of
the equivalent mass approach, implying grave difficulties. In fact, theequivalent mass approach is not unduly complicated and avoids someCanada830 potentially serious errors in estimating soil C stocks.
Table 5.5B. Please specify the units for N content and lignin content. For
example: g N (g residue)^‐1? Also, presumably these concentrations are
Canada864 on a dry weight basis?
"five carbon stocks" to "five carbon pools" ensures consistency with text
Canada1184 and table 5.7

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Responses
Accepted

Accepted with
Modification

Authors' notes
Problems with missing references and refernced papers thatare no longer cited to be fixed.
The fractions were revised based on comments in Chapter 2 to
a 100 year time horizon for permanence, and have been
updated as requested.
We thank the reviewer for their careful checking. The missing
reference added to reference list

Accepted
Accepted with
Modification
Accepted
Accepted

Text redrafted in line with the comment
We added description of the terms shown in the figure within
the boxcorrected so states it is air temperature
These two references were added along with another (Gal et al.
2007) of depth‐tillage effect interaction.
Sentence was revised to be more specific that deeper depths
can be warranted to estimate tillage system effect of soil C
stock.
Good point, replaced data with "soil C stocks" in sentence andso now clearer what is meant

Good point, it is not challenging if a country has all thenecessary data to do the calculations. Replaced "bechallenging" with "require necessary soils data".
Accepted
Table was clarified
Accepted
Accepted

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Country1409"However, it is important to realize that all data used to derive stockchange factors across all land uses must be on an equivalent mass basis if
this method is applied" . This seems incorrect. Equivalent masscalculations require only soil C concentration and bulk density. What do
the authors mean by "all data"? Presumably, this sentence is intended
merely to indicate that if an equivalent mass approach is adopted, it
Canada1410 should be applied uniformly across all land uses. Please correct.

1410"This will be challenging…" This statement seems to discourage the use of
the equivalent mass approach, implying grave difficulties. In fact, theequivalent mass approach is not unduly complicated and avoids someCanada1411 potentially serious errors in estimating soil C stocks.

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111

In Table 5.3, under tropical cropping system, coffee based agroforestry
India
241 and cocoa based agroforestry can be added
In Table 5.1, the agroforestry system in temperate and tropical conditions
can be reclassified as i) Agrisiviculture, ii) Silvopastoral, iii) Boundary
Planting, iv) Improved fallows, v) Shadow systems, vi) Home gardens andIndia
229 viii) Wood lots.
Norway442 Typo: the "2" in CO2 should be displayed as subscript
Mentioning that Equation 5.0H could be used in abscence of country
Norway678 specific parameters could help here
We anticipate that you are referring to Equation 2.26A and not Equation
Norway782 2.27 which is in Section 2.4 Non‐CO2 emissions
France111 We suggest to write " priming effect"

122

Table 6.2 : the new default number is quite low (0.9), in average 0.06
point lower, this mean also that even if we have intensive grazing none of
the improvements (eg manure) can compensate this. A default value suchFrance123 as (0.92) would have allowed a small compensation

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Responses

Authors' notes
Good point, replaced "data" with "soil C stocks" in sentence
and so now clearer what is meant

Accepted
Good point, it is not challenging if a country has all thenecessary data to do the calculations. Replaced "bechallenging" with "require necessary soils data".
Accepted

Rejected

Rejected
Accepted
Accepted
Accepted
Accepted

Accepted with
Modification

Table 5.3 is for monocultures. Coffee and cocoa‐based
agroforestry values can be found in Table 5.1 and Table 5.2("shaded perennial"). Insufficient data was found for pure(unshaded) coffee and cocoa crops.

The classification system used in the Table is the one used in
the meta‐analysis that provides the table data.
Corrected
We added a reference to the equation that can be used in theabsense of country‐specific methods.
Corrected to equation 2.26A
Changed to the reviewer's suggestion
The decision flow chart was revised so that intensive grazing isonly relevant for grasslands that have don't have productivity
above native conditions.

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Table 6.2 : "Moderate degraded grassland" categorie for FMG was in2006 splits in 3 climate zones in the new guideline this category is
replaced by "intensity grazing" ( without climate division ) and overall
decreased from 0.96 to 0.90. This change is little justified with referenceFrance123 in the text: lack of analysis.
In order to keep the citations contextually consistent,Line 105: It is suggested that "Equation 2.27" be replaced with "Equation
2.26A"
Line 250: It is suggested that Tables 2.4 and 2.5 be replaced with Tables
2.3A and 2.3B.
Line 331: It is suggested that "Equation 2.25A" be replaced with "Equation
2.26A"
Line 421: It is suggested that "Equation 2.27" be replaced with "Equation
2.26A"
Line 547: It is suggested that Tables 2.4 and 2.5 be replaced with Tables
China
547 2.3A and 2.3B.

337

The parametric values in this equation are not consistent with those given
in TABLE 2.3B, Chapter 2, Volume 4. According to TABLE 2.3B, theequation should be changed from "(30500∙0.38∙0.24) + (150000∙0.52∙0.38)= 32,421.6 tonnes C " to "(30500∙0.38∙0.28) + (150000∙0.52∙0.43) =China
337 36,785.2 tonnes C ". Such a check is requested.

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Responses

Accepted with
Modification

Authors' notes
We added sentences to Annex 6A.1 that the categorization wasrevisited with the literature and concluded that the moderately
degraded management factor had been determined from a non‐rigorous and non‐reproducible interpretation of scientific
literature to categorize particular grazing regimes into“moderately degraded” and comparative “non‐degraded”
states. The original paper authors almost entirely did not referto or define either the non‐degraded or moderately degradedstates, only the grazing intensity in terms of light, moderate,and heavy. This was different from the severely degraded state
where there several papers that referred to severely degradedpasture and it was clear this referred to the state of both thevegetation and soil. In fact, outside of severely degraded, there
was only few studies that reported a grassland vegetation statefor each grazing regime to develop a relationship between
grassland vegetation and soil C stocks. Therefore, we redid theanalysis using the grazing intensities as defined by the original
paper authors to derive a factor for high intensity grazing
versus light to moderate grazing. The high grazing intensity
factor is more scientifically defensible than the moderately
degraded state factors in the 2006 GL. There was insufficient
data to reliably derive the high ‐intensity grazing factor fordifferent climates. Regarding activity data, for policy purposes,
many countries collect data to know if they have too little or
too much livestock for their grassland areas so may haveactivity data on grazing intensities relative desired grazing
intensity and so can identity areas with high intensity grazing.
hlllCorrected as suggested

Accepted
Corrected as suggested. We thank the reviewer for the carefulchecking.

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Comment: (not just specific to the referenced lines) It is going to bedifficult to distinguish high intensity grazing from Improved‐High input
grazing. If graziers have undertaken multiple improvements ‐ fertiliser,
species improvement ‐ then there is high stocking capacity, so will usually
have high grazing intensity. ie would not be decribed as "nominally ormoderately grazed" But if well‐managed, will not show signs of "change in
species composition" ‐ so is it "High intensity grazing" or "Improved
grassland"? It is likely that such a system will have same SOC as a lower‐
input system (eg Young et al, 2016) ie will overestimate SOC if classed as
Improved grassland but will underestimate if classed as High intensity
grazing. There should be an additional class of "High intensity, notdegraded", with a factor of 1.0. Otherwise, revise the description of high‐intensity to remove all reference to degradation and change in species
composition, to ensure that all high intensity grazing is allocated a factorof 0.9, to avoid overestimating SOC in improved pastures that are
Australia
194 managed with high intensity.

Responses

Authors' notes
We agree that the way the decison tree is presented thecompiler could be confused about having to make a grazing
intensity decision for high productivity improved grasslands.
We addressed this by changing the order of the flowchart sothat decision on high intensity grazing is made after thegrassland productivity decision so that high intensity grazing
decision is only required for unimproved grassland. We also
improving the definition as: "High intensity grazing is defined asgrazing that deteriorates the condition and/or long‐term
recovery capacity of the vegetation compared with thevegetation state under nominal to moderate grazing intensity.
High intensity grazing does not refer to stocking rate andduration only, but to the stocking rate and duration in relation
to grassland productivity and resilience. This may be called amoderately degraded condition but high intensity grazing does
not lead to the severe degradation such as is caused byrelentless overgrazing. High intensity grazing also includes land
where vegetation is frequently cut and removed equivalent tohigh intensity grazing and without application of any animal
manure."Accepted with
Modification
Good point. We have a added a sentence to point out thisissue out to compilers.

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201

We understand that the possibility of using an asymmetric system withregard to the transitional period is introduced in order to avoid over‐ or
underestimation of land‐use change emissions from/ to cropland. This iscommendable but currently under the existing rules not applicable. Mostof the relevant literature refers to the "fast out ‐ slow in" ‐ principle (e.g..
Poeplau et al. 2011), mostly based on paired site studies. However, otherstudies do not show this asymmetry in carbon stock changes. Apart fromthe fact that we ultimately do not know what is the truth, against thebackground of other basic rules of the guidelines, this method does notseem practicable. For example: According to Poeplau et al. 2011, in thecase of land use change from, e.g., grassland to cropland, the carbon
losses occur within 18 years, whereas in the opposite direction thetransition period is in the range of 100‐200 years. As land use is usually
hard to trace back for the 20 default years, it seems impossible for 100‐
200 years. The compiler does not know, e.g., in the case of a LUC fromgrassland to other land, whether the area is in steady state or at what
Germany
468 time in the 200 year transition period.
Norway201 Please update the current version of the link.

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Accepted

Change to greyed text.

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The average change in soil carbon stock of a land use depends on thelength of conversion and it's used as factor in estimation of averageannual change in soil C stock. First, why is 20 years consider as a Default
396 factor? How is irregular change handled in this case?

Norway

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Other flooded land do not exhibit necesseraly "low oxygene levels", it will
depend on water column. But it is true that at interface water sediment,
consumption of dissolved oxygen leads to low oxygen level surrounding
France207 sediment (few mm as explain in L1752)

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239

239 add "inflow water quality" after "hydrology"

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France283 Figure 7.2 is not readable in the version
Figure 7.4: The two back black arrows below "Factor out emissions …" areFrance294 not clear.
"Unmanaged wetlands act as sinks for CO2" add "as well as someFrance319 managed wetland" controlling by inflow water quality.

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Noted

Accepted
Accepted with
Modification

Accepted
Accepted

improved for clarity

Accepted

Inserted the text as requested

Rejected

Whilst an adjustment factor could in principle be developed, inpractice none of the methods presented for different wetland
categories in the Wetland Supplement included an adjustment
factor based on trophic status, so we do not have amethodological basis for doing this here

Accepted

Text added on line 990‐991. These Efs correspond to the total
emissions attributable to the reservoir. See annex 7.1 fordetails.

Eq 7.17 proposes to include an "emission factor adjustment", but to be
555 congruent, eq 7.18 should also include this "emission factor adjustment"
Previously net CO2 emission was defined and applied. In the section
7.3.2.1, is it question of "total" or "net" co2 emission (CO2 consumption
934 by aquatic biomass)? And in table 7.16, is "net" or "total"

France2189 Please, see supporting document

Russian Federation Noted
Russian Federation Accepted

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481

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156 Please explain “methanogenic production of CH4” (what it means)

Inserted "may have low oxygen levels"
added "water quality"
There was a problem when converting the Word (andillustrator embedded figure) into PDF format. We havecorrected this problem.

510

FranceAuthors' notes
This suggestion is within the greyed text that is outside of thescope of the 2019 Refinements. Note the 20 year default is aconsistent simplification within the Tier 1 method that balances
between faster changes that occur in the tropics and slower
changes in temperate regions.

We changed to the words "methane production".
Methanogenesis is described in the appendix

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This sentence may be understood as stating that nutrients loading ishigher for small natural waterbodies than for constructed waterbodies. It
Russian Federation Accepted
170 is Likely that authors meant the opposite.

485

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282

282 Figure 7.2 is not complete.

Russian Federation Accepted

Rearranged the sentence to increase clarity
There was a problem when converting the Word (andillustrator embedded figure) into PDF format. We havecorrected this problem.

487

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1117

1117 Replace “Nb reservoir” with "Number of reservoir"

Russian Federation Acceptedchanged text as requested

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1872

Regarding at least carbon budget of unmanaged natural lakes thisstatement is not true, as more sophisticated models are available in theliterature. They include 1D (vertically resolving) simulation of coupledphysical and biogeochemical state of natural lakes (McCullough et al.,2018; Kiuru et al., 2018; Stepanenko et al., 2011; Stepanenko et al., 2016;
Tan et al., 2015; Tan et al., 2017). Although, it is likely no attempt has
been performed to apply same kind of models to artificial reservoirs, I
suggest the authors of Guidelines to encourage the development ofmodels of the same complexity and their application to artificially flooded
Russian Federation Noted
1873 land.

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1954

1954 The relevance of reference to Figure A1 is not clear

Russian Federation AcceptedLine 1873 removed. The models described by the reviewer
require large amounts of data not generally available tocompilers are not currently applicable to a large number ofreservoirs.
corrected the text ‐ ..worldwide "as shown in the map in Figure
A2."

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2097

2097 Figure A4 → Figure A6?

Russian Federation Accepted

Corrected text to A6

495

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2114

2115 Should the “remineralization” be changed to “mineralization” here?

Russian Federation Accepted

Corrected to mineralization

657

659

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245

"Factoring out" is an accounting term that has been used specificallyunder the KP, therefore suggest rewording to apply the same language as
used in IAV section of Chapter 2 "disaggregating" emissions that would
have occurred if land was unmanaged, and reporting separately.
New Zealand

245"Factoring out emissions (removals) that would otherwise occur from
Unmanaged Land without conversion to Managed Flooded Lands". Onceland is managed, the emissions that would have occurred anyway are notfactored out for any other land use. It is inconsistent to apply this practiceto the Wetland category only. Suggest this is disaggregated and reported
separately as comment above to ensure consistency across the chaptersof this Volume
New ZealandComment on Decision tree diamond "is there a significant increase insurface area?". "Significant" requires definition e.g. increase is greaterthan x% of original and with a minimum size threshold (at least x ha insize). As an example Chapter 12 provides the following: "Furthermore,countries are encouraged to make the country‐specific HWP commodity
classes broad enough to capture significant carbon volumes contributing
to the HWP pool. As a guide, the volumes of these commodity classes may
be deemed significant if they represent at least 5% of the total HWP
volumes as described by the particular approach selected by the country.
"
New Zealand

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283 Figure 7.2 should be double checked as it is omitted.
Please ensure the consistency with the description of Equation and
340 Variations as it is difficult to identify the Equation.

Page 155

Rejected

We have followed the terminology given in the TOR from the
IPCC Panel.

Rejected

We agree that the general issue of emissions associated withconversion of unmanaged land to managed land is not uniqueto flooded lands. However, have provided a clearer justification
for this approach for flooded lands in the Introductory section.
We were mandated by the IPCC Panel in the TOR to develop"consistent methodologies that take into account factoring outof emissions that would otherwise occur in the absence of theflooded area for estimating CO2 and CH4 emissions fromflooded lands". There was no guidance to do this for other land
uses.

Republic of Korea

Accepted

We have indicated that >10% change is considered "significant". At L265 we have added (where there has been a significant
change in surface area and/or residence time, for example by >10%)
There was a problem when converting the Word (andillustrator embedded figure) into PDF format. We havecorrected this problem.

Republic of Korea

Noted

We have checked equations accordingly

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Country
Consider adding: Country‐specific conversion periods may be applied
Finland202 under Tier 2 and Tier3 methodology.
It is mentioned that seasonally flooded agricultural land can be considered
Flooded Land. Accoring to 2006 GLs, a land area can be classified only in
one of the six land use categories in a year. Please, clarify the guidance
how to prioritize land use categories, e.g., should the land mentioned in
the text be classified as cropland/grassland or flooded land under
Finland
225 wetlands category.

245

2019 Refinement introduces a new concept in the GHG inventory to factor
out emissions (removals). It is not clear, if this method is intended to be
optional or mandatory for a country which is going to included emissions
from flooded land in its inventory (in lines 276‐277: ... with practicalconsideration for application of the methods by compilers). If it is optional
to factor out emissions that would otherwise occur from unmanaged land
without conversion to managed flooded land, this guidance shall be
preferably placed in appendix to this Chapter. Whether it is optional or
not to apply this method, more justification for it is needed, because it is
not in line with GHG inventory principle to report actual
emissions/removals. Factoring out emissions/removals means that amethodology to estimate emissions/removals from unmanaged lands
would have to be developed ‐ thus the 2019 Refinement should provide
the appropriate guidance at the same time with guidance on flooded landfactoring out. Also, the method is not consistent with the managed land
proxy. Factoring out is not used for other land use categories or
emissions/removals from other sources. Thus, the emissions from flooded
Finland
281 lands would be counted differently even under wetlands category.

198

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It is mentioned that factoring out is not applied to flooded land which has
been managed land before the conversion as they are included in theinventory from the baseline year. What does 'baseline' year mean? Baseyear? The base year can differ between countries, so how this should betaking into account? For many Annex I countries the base year is 1990. If amanaged land is converted to flooded land e.g. in 2020, it is possible that
275 the same land was unmanaged land in 1990. Please, clarify this section. Finland
Please revise "> 20 years prior to inventory" to "> 20 years prior to
Finland463 reporting year"

679

Under Tier 2 CH4 emissions due to wastewater inflow can be estimatedand factored out. Box 7.2 states that at Tier 3 level it is good pratice tofactor out these emissions. That is not mentioned in the text for Tier 3
level. As the wording 'good practice' obligates a inventory compiler, allthat kind of guidance should be in the actual text. Please clarify the text.
Finland
712 Note the title of Box 7.2 Additional information...

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Responses

Authors' notes

Accepted

Suggestion already noted in line 391‐392

Noted

We agree that the land can only be classified as one land use
and the decision will depend on national circumstances. Even
if the land is classified as cropland or grassland the emissions
should still be addressed by the compiler.

Accepted

We agree that the general issue of emissions associated withconversion of unmanaged land to managed land is not uniqueto flooded lands. However, there was a mandate in the TOR todevelop these methods, we have provided a clearer
justification for this approach for flooded lands in the
Introductory section. The following sentence has been added:"Inventory compilers may choose to report total emissions
from Flooded Land, in accordance with the Managed Land
Proxy, or to factor out emissions and removals associated with
Unmanaged Lands that occurred before conversion to Flooded
Land. "

Accepted

Text modified in line 295. No reference is now made to baseyear.

Accepted

Revised as suggested

Accepted

We have improved the Tier 2 and Tier 3 text and the text in the
Box to provide more information as requested.

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It is left to inventory compiler to choose whether to report emissions fromdrainage ditches within flooded land (wetlands category), or under othermanaged land categories. If the ditches are an essential part of the landarea, like it is in the case of drained forest land/cropland, the emissions
from ditches should be reported in forest land/cropland category and not
Finland
770 under wetlands. Please, reconsider the text.

899

It is discussed about how to estimate the area of ditches in agriculturallands. Is it suggested to report the emissions from ditches in wetlands
category? Some countries may have so wide ditches on
croplands/grassland that it is practical to report separately the fields andthe ditches. If this is the case, could it be clarified in the text. Normally the
Finland
901 ditches are reported under cropland/grassland categories.

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Biomass removed from an area before impoundment shall be reported
according to the guidance given in Chapter 2 (e.g. 2.3.1.2 estimatingchange in carbon stock in biomass), not according to the guidance given
for HWP. To avoid missunderstanding, it would be useful if in the text it
were mentioned that these emissions from removed carbon stocks shallbe reported under flooded land category. Thus, the emissions in the yearof conversion can be different from the emissions in the subsequentFinland
976 years.

Default emission factors for CO2 emissions are given in Table 7.16. It is
unclear what emissions these EFs covers. It would be useful for inventory
compilers, if a more detailed description would be given in the text onwhat emissions are included in these EFs (biomass, DW, SOM?). Do data
behind model (that has been used to derive EF's) include situations when
woody biomass for instance has been removed before flooding andsituations when woody biomass has been left as it is? Do data behind EF's
make a distinction between different soils (mineral, peat) and groundvegetation covers? Please give guidance to inventory compilers in linewith 'the EF's in Table 7.16 represent following cases: woody biomass
Finland1080 left/removed, soil is mineral/peat, dead organic matter stock..."Please revise "flooded <= 20 years prior to inventory" to "flooded <= 20
Finland1151 years prior to reporting year"
Equation 7.22: Please revise "reservoirs < 20 years" to "reservoirs <= 20
Finland1156 years"

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Responses

Authors' notes

Noted

This decision depends on national circumstances and therefore
needs to be remain flexible.

Accepted

The following text has been added: "For these areas, inventory
compilers may choose to report these emissions within theappropriate land category, or separately in the Flooded Lands
category. "Accepted

Accepted, the reference was corrected; the methodology forCO2 emissions and removals with LUC is indeed described inVol. 4 Chp.2. It is important that C transfer and emissions prior
to flooding be reported and not double counted. Carbon losses
due to disturbances or transfered to another pool (e.g. HWP)
are tracked with methodologies describe in Vol. 4 Chp.2. We
believe that it is more efficient to track theses changes in theland use prior to flooding and that emissions due to flooding
start at flooding than to modify the accounting of flooded land
to consider these pre‐flooding changes.

Rejected

The methodology and its rationale are explained in more detail
the Annex. More specifically A7.1.2.2 (l.2085‐2126). At tier 1
level, there is no distinction between soil types, however,climatic zones contraint somewhat the values. While different
organic matter pool contribute to the surge of CO2 following
flooding, their contribution is not individually modelled. theabudnant amount of reservoir emission measurements forreservoirs has made possible to develop estimates of net post‐
flooding CO2‐C emissions taht are scaled to yearly values. The
anoxic conditions felow a few mm and the lack of knowledge
on the degradation dynamics of individual OM pools in thereservoir have prevented the development of a more specificappraoch at Tier 1.

Acceptedchanges text as requested

Acceptedchanges text as requested

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Accepted

Recommend checking Table 7.10. The Table has the same average values
for EFCH4 age>20,j , but a significantly lower 95% CI range than reported
in the previous version of the SOD.
Australia

Accepted

Accepted

Clarification has been added as suggested

Accepted

Added the following text: Emissions from ponds are separated into
Freshwater Ponds with water column salinity < 18 ppt and Saline
Ponds with salinity of > 18 ppt, consistent with the 2013 Wetlands
Supplement (Chapter 4, Annex 4A.1 salinity based definitions).

Noted

Authors have developed default factors based on the best
available data, consistent with other sources. Parties areencourged to use higher tier methods to improve the accuracyof their estimates, particularly key categories. This is guiding
principle for all sources including flooded land.

Noted

Authors have developed default factors based on the best
available data, consistent with other sources. Parties areencourged to use higher tier methods to improve the accuracyof their estimates, particularly key categories. This is guiding
principle for all sources including flooded land.

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Authors' notes

Clarified by inserting CO2 emissions and removals ‐ 'Seasonally
flooded agricultural land may be coastal or inland, on mineralor organic soils, and relevant guidance for CO2 emissions andremovals from these categories is provided in the 2013
Wetlands Supplement (Chapters 3‐5, see Table 7.8 for details)."
For consistency with rest of chapter, uncertainty is reported as
95% confidence limits on the mean (standard error of themean). In SOD, the 95% confidence interval was on theindividual observations.

651

1191

Responses

Recommend clarification on guidance on factoring out CH4 emissions,which also captures CH4 removals. It is not clear whether this should bealso capture CO2 removals to account for the loss of carbon sequestration
potential with the loss of pre‐inundated habitat.
Australia

77Country890

4

4Comments

The guidance for AD collection needs improvement, especially in relations
to agricultural ponds which can be very small in area (according to theguidance 40% of the emissions come from ponds < 0.1 ha) and notcovered by national data bases. The use of satellite data or rather unclear
methods in the many references provided are not pragmatic for all
countries, especially developing countries. Please provide pragmatic
Finland
904 guidance applicable to all.

1185

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Recommend clarification of whether this refers to Chapter 2, drained
763 inland organic soils, specifically Section 2.2.2 and Annex 2A.2 Table 2A.1. Australia
Recommend clarification of Table 7.15. The EF CH4 value for saline ponds
is 30 kg CH4/ha/yr. Please provide a salinity range over which this applies,
or else it will be in conflict with the 2013 Wetlands supplement in which
Tier 1 default CH4 emissions are zero for water with salinity greater than
18ppt.
Australia

906

Comment: The issue of materiality regarding methane emission estimates
under Other Flooded Land (constructed ponds etc, including farm dams)
exists as the estimates may not be accurate for many Parties, and allvalues have high levels of uncertainty associated with them. See related
Australia
907 comments #1 ‐ #4, below:

906#1: Table 7.15 provides EF values with broad 95% CI’s that are based on a
restricted number of studies across a subset of possible environmental
and climatic conditions. Therefore estimates of methane emissions from
Other Flooded Land using Tier 1 models and EF values may not reasonably
represent (in accuracy and/or level of uncertainty) their contribution to aAustralia
907 Party's account, under normal circumstances.

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Accepted

We have expanded the text to refer to Sentinel 2 data as apotential freely‐available high‐resolution data source.

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Responses#2: Additionally, Tier 1 emission estimates for Other Flooded Land appear
to be based on system capacity, that is the assumption that all structures
under Other Flooded Land are filled to capacity throughout the year, andemission estimates are then based on that. This approach may result in an
over‐estimated methane emission value. Could additional guidance be
provided on the application and range of values for a Tier 1 "correction
factor" to account for system utilisation?

1195

1197

1283

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906

136

System utilisation accomodates temporal changes in pond/ditch waterlevel and area (and therefore methane emissions) associated with
907 weather/climate variablity, usage and seepage losses.

#3: could the references to Tier 2 and 3 models identify systemutilisationas an important factor to account for temporal variability ofemissions due to observed and/or modelled changes in pond level
907 associated with weather/climate variability, usage and seepage losses.

Australia

Australia

A clear definition of what a wetland is ‐ needs to be provided. The current
definition states land that is "Flooded Land is comprised of ‐‐‐‐‐‐land area
flooded…." But it is not clear for how much period if inundated, it can be
India
139 considered as a wetland

Authors' notes

Accepted

The following text has been added to the activity data section
we have also added "If waterbodies vary substantially in their
spatial extent through the year, the annual average (rather
than annual maximum) inundated area will provide the mostappropriate basis for flooded land area estimation"

Accepted

The following text has been added under Tier 2: "Additional
management‐related factors may be considered if these affectemissions, for example if waterbodies are subject to large
seasonal or short‐term changes in water level and area, thismay produce different CH4 emissions that a waterbody withthe same average surface area but more constant waterlevels."Accepted

A more comprehensive definition of the types of Flooded Landconsidered in the chapter has been provided, with reference tothe definition given in the 2006 Guidelines. We have clarified
the distinction between flooded lands and other wetlands, andreferred to the 2013 Wetland Supplement for guidance on thelatter.

Rejected

We have provided methods for estimating the total emissions
from flooded lands that are consistent with the Managed Land
Proxy. To increase transparency we have modified the text andreporting tables to include both total and net emissions.

Guidance for estimating total flooded land emissions and removals should
be consistent with the managed land proxy. Therefore, the total
emissions reported should reflect the actual GHG fluxes that occur inlands classified as “managed”.

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Additional methodologies for estimating emissions and removals thatwould occur if the flooded land remained unmanged ("factoring out")
should be provided as an option that may be used by countries thatchoose to consistently and transparently report such counterfactual
emissions and removals. Such methodologies should be provided for
information only, and it should not add guidance, nor overrule guidance
1269 provided.

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The chapter describes a factoring out methodology. It mainly focuses on
including unmanaged land into the GHGI. Even though factoring out was
requested in the mandate for drafting this chapter it seems the wrong
guidance for reporting. If considered at all, it will be part of an accounting
guidance, but this is not within the scope of this Refinement.
The section seems to touch upon a general issue when unmanaged land
becomes managed land, but this is not specific for flooded land. The
justification for high carbon loss/gain is also not a specific criterion forflooded land, only. What about previously unmanaged forest land
becoming included into managed land? GHG removals in unmanaged
forests are enormous.
Strict adherence to the Managed Land Proxy should be maintained for
estimating emissions and removals for the inventory for flooded land
reported in greenhouse gas inventories. Therefore, if the report retains
methodologies for factoring out of emissions and removals that would
occur on unmanaged land in the absence of flooding, it must be clarified
that such methodologies are provided only for reporting purposes otherEU
2189 than the reporting of national greenhouse gas inventories.

332

Equation 7.10 for CO2 (same as 7.14 for CH4) is the essence of factoringout. First, the message is wrong as reporting should not look at the net,
expressed as a difference, but as the total, hence the sum of different
components. If this equation is kept if should say F(CO2‐tot) = F(CO2‐
net+F(CO2‐otherwise). Equation 7.14 should be adjusted accordingly.
This equation (7.10) also reveals a different aspect. Assuming F(CO2‐tot)
to be 0 due to the steady state of flooded land the emissions from F(CO2‐otherwise) become the inverse for F(CO2‐net), hence turning a reported
sink into a reported source or vice versa just because the allocation of thatland changed from unmanaged land to managed land.
The report should also state clearly that each of the elements of Equation
7.10 & 7.14 (net, total and ‘otherwise’ annual emissions) should beEU
334 reported separately when reporting using this methodology.

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Responses

Authors' notes

Rejected

We agree that the general issue of emissions associated withconversion of unmanaged land to managed land is not uniqueto flooded lands. However, have provided a clearer justification
for this approach for flooded lands in the Introductory section.
We disagree with the comment that we have not followed the
mandate given in the TOR. We have provided methods
consistent with the guidance provided in the TOR. To increasetransparency we have modified the text and reporting tables toinclude both total and net emissions.

Accepted with
Modification

The reviewers suggested approach does not comply with
commonly accepted mathematical conventions. Theseequations specifically show how to compute the net emissions.
There are no defining equations for F_CO2_net or F_CH4_net;
we derive the net flux from the defined total flux and definedother flux. F_CO2_tot and F_CH4_tot are defined inconventional Tier 1 EF formats as explicit equations (7.20 and
7.14, respectively). Additionally we have added text to say thatreporting Net and Total emissions is appropriate and modified
the reporting tables accordingly.

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Total emissions should be reported solely on the basis of the managed
land proxy. Factoring out of emissions that would otherwise haveoccurred had the flooded land remained unmanaged is not consistent
with the principles of the managed land proxy. The guidance should nottherefore promote the use of such factoring out as good practice forinventory reporting. These methodologies should only be retained in thereport if it is clearly stated that it is there to provide information in caseParties wish to use it for purposes other than reporting of greenhouse gas
EU
255 inventories.

Responses

Authors' notes

Accepted with
Modification

We accept that it is good practice to report emissions using themanaged land proxy, and have inserted text stating thisguidance. We have also added text that addresses reporting ofboth Net and Total emissions as well as modifying the reportingtables. The following sentence has been added: "If a factoringout approach is applied, it is good practice to provide
transparency by reporting both total and net emissions;otherwise the country should report the total emissions if net
emissions are not estimated. Furthermore, if inventory
compilers choose to factor out natural CH4 emissions fromwetlands, it is also good practice to simultaneous factor out theloss of any natural CO2 sink in the that would otherwise haveoccurred if the land remained unmanaged.. " How thisinformation is used for reporting by parties to the UNFCCC is a
decision that will need to be made in the negotiations of theconvention. We are only providing estimation methods and aframework for reporting in this guidance.

Accepted with
Modification

We have added text that addresses reporting of both Net andTotal emissions as well as modifying the reporting tables toincrease transparency. TThe following sentence has been
added: "If a factoring out approach is applied, it is goodpractice to provide transparency by reporting both total andnet emissions; otherwise the country should report the total
emissions if net emissions are not estimated. Furthermore, if
inventory compilers choose to factor out natural CH4 emissions
from wetlands, it is also good practice to simultaneous factor
out the loss of any natural CO2 sink in the that would otherwise
have occurred if the land remained unmanaged.. "Accepted

added this box as requested“For transparency, the methods are applied so that the total emissions(removals) from flooded lands are estimated based on the managed land
proxy, and then the net emissions are determined based on emissions(removals) that would occur if the flooded land remained unmanaged.”
This is a clear description for accounting as it looks at the net emissions
and not the total emissions.

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Total emissions should be reported solely on the basis of the managed
land proxy. Factoring out of emissions that would otherwise haveoccurred had the flooded land remained unmanaged is not consistent
with the principles of the managed land proxy. The guidance should nottherefore promote the use of such factoring out as good practice forinventory reporting. These methodologies should only be retained in thereport if it is clearly stated that it is there to provide information in caseParties wish to use it for purposes other than reporting of greenhouse gas
EU
279 inventories.
Figure 7.3 lower left box: It should say Estimate emissions using country‐
EU
287 specific emission factors (tier 2), or tier 3 methods.

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TolineComments

CountryThis section on factoring out should clearly state that total
emissions/removals from flooded lands based on the managed land proxyshould be reported as part of national greenhouse gas inventories,
regardless of whether Parties also choose to report emissions/removals
EU
281 that would occur if the flooded land remained unmanaged.

Factoring out of emissions that would otherwise have occurred had theflooded land remained unmanaged is not consistent with the principles ofthe managed land proxy. The guidance should not therefore promote theuse of such factoring out as good practice for inventory reporting. Thesemethodologies should only be retained in the report if it is clearly statedthat it is there to provide information in case Parties wish to use it forEU
930 purposes other than reporting of greenhouse gas inventories.

1840

This box should be labelled as for information only. As described above,
guidance for inventories should be based on the managed land proxy. The
methodology described in this box could be used for other purposes suchas accounting but reporting in greenhouse gas inventories should beEU1858 based on strict adherence to the Managed Land Proxy.

245

We are concerned that the new guidance on how to factor out emissions(removals) that would otherwise occur from unmanaged land is not in
keeping with the IPCC's guidelines for other sub‐sectors, and is more
relevant for accounting than for reporting. The IPCC should not beproviding guidance on such accounting methods, and we are notconvinced that the methods provided are sufficiently scientifically robust,especially given that the definition of managed land can be interpreted indifferent ways by different countries. If this guidance remains in theSaint Lucia
281 refinement we fear that the integrity of NGHGIs will be compromised.

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Authors' notes

Accepted

We have added text that addresses reporting of both Net andTotal emissions as well as modifying the reporting tables. The
following sentence has been added: "If a factoring out
approach is applied, it is good practice to provide transparency
by reporting both total and net emissions; otherwise thecountry should report the total emissions if net emissions are
not estimated. Furthermore, if inventory compilers choose tofactor out natural CH4 emissions from wetlands, it is also goodpractice to simultaneous factor out the loss of any natural CO2
sink in the that would otherwise have occurred if the landremained unmanaged.. "Accepted

The following text has been added before Figure 7.2: "If afactoring out approach is applied, it is good practice to provide
transparency by reporting both total and net emissions;otherwise the country should report the total emissions if net
emissions are not estimated. Furthermore, if inventory
compilers choose to factor out natural CH4 emissions fromwetlands, it is also good practice to simultaneous factor out theloss of any natural CO2 sink in the that would otherwise haveoccurred if the land remained unmanaged.."Rejected

We were mandated by the IPCC Panel to develop "consistentmethodologies that take into account factoring out ofemissions that would otherwise occur in the absence of theflooded area for estimating CO2 and CH4 emissions fromflooded lands". We consider that the issues raised here are amatter for the IPCC plenary, and do not relate to therobustness of the science.

Rejected

We were mandated by the IPCC Panel in the TOR to develop"consistent methodologies that take into account factoring outof emissions that would otherwise occur in the absence of theflooded area for estimating CO2 and CH4 emissions fromflooded lands". We consideedr that the issues raised here are amatter for the IPCC plenary, and do not relate to therobustness of the science.

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The inclusion of emissions (removals) from uncultivated land to calculate
net emissions from land use change to "flooded land" respectively"flooded land remaining flooded land" is inconsistent with the rules forother land use categories in the guidelines. We feel the discussion of thiscase is not convincing and lacks substance. How are land use changes oforganic and mineral soils (SOM rich) from unmanaged wetlands forexample to grassland, cropland or managed wetlands dealt with? In thiscase, the justification given for flooded lands applies in exactly the sameway. However, in the guidelines, it is neither a consideration nor apossibility, although the magnitude of emissions is much higher (10 Mg C
ha‐1 a‐1). We strongly urge the authors to revise this approach, because it
Germany
281 is not consequent and it results in a consistency issue.
Table 7.8 is inserted in the middle of sentence and make it a little hard toread the relevant sentence. It seems there is no reason of putting Table
7.8 in the current location. It is suggested that Table 7.8 be allocated at
Japan
221 the bottom of the page.

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225 "methane" can be stated as "CH4" for editorial consistency.

Japan

Accepted

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283 Figure 7.2 is not shown. The complete version needs to be provided.

Japan

Accepted

Changed "methane" to CH4, except at the start of sentences orwhen hyphenated to other words, e.g. methane‐rich.
There was a problem when converting the Word (andillustrator embedded figure) into PDF format. We havecorrected this problem.

286

The first choice of the decision tree in Figure 7.3 is "Are water body is a
key category" and then select Tier.1 when the answer to this question is
NO. From the point of view of the inventory compiler's work flow, thistype of consideration is possible only when at least tier 1 level of
estimation is implemented first. Therefore, it is better to start one more
286 box like "Estimate based on tier 1" in the beginning of the decision tree.

Japan

Accepted

added this box as requested

369

Chapter 3 and 4 of the 2013 Wetlands supplement are referred here, but
chapter 5 would be also necessary to refer here. This is because somemethods of chapter 5 of the 2013 Wetlands supplement is relevant in this369 section, for example Table 7.9 includes EF of inland wetland mineral soil. Japan

Accepted

We have added reference to Chapter 5.

Accepted

We have added reference to Chapter 5.

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Chapter 3 and 4 of the 2013 Wetlands supplement are referred here, but
chapter 5 would be also necessary to refer here. This is because somemethods of chapter 5 of the 2013 Wetlands supplement is relevant in this408 section, for example Table 7.9 includes EF of inland wetland mineral soil. Japan
Subscript "J" of "MJ" would be unnecessary in the title of Table 7.17
because "j" is used as parameter of climatic zone classification and theJapan1117 real parameter must be "M" here.
"good practice" instead of "typical" is the appropriate expression of theapproach
Austria

Page 163

Noted

We agree that the general issue of emissions associated withconversion of unmanaged land to managed land is not uniqueto flooded lands. We have provided further justificaiton for ourapproach (Introductory section). We were mandated by the
IPCC Panel to develop "consistent methodologies that take into
account factoring out of emissions that would otherwise occur
in the absence of the flooded area for estimating CO2 and CH4
emissions from flooded lands". No mandate was given for theother land uses. We consider that the issues raised here are amatter for the IPCC plenary, and do not relate to therobustness of the science.

Accepted

Reformatted and moved text to join with the paragraph before
the table.

Accepted
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General comment: The wetland chapter introduces for the first time in the
LULUCF sector methods of factoring out emissions which would naturally
occur before an unmanaged land is converted to a managed wetland. It is
recommended to strictly stay within the managed land proxy in the waythat all emissions at managed lands are considered as human induced andcounted (no factoring out of natural emissions) in order not to represent a
precedent for other such cases. A decision of possible and principal
factoring out of previous natural emissions would require a thoroughanalysis of the whole issue including unintended side‐effects (alsoconcerning other subcategories and ‐sectors) and a related generaldecision and mandate. Since this does not exist, it is recommended toleave out any ways of factoring out emissions in the IPCC GL refinement. It
Austria
7 General comGeneral comis recommended to redraft the whole chapter accordingly.

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Authors' notes

Rejected

282

Figure 7.2 is only partly visible and could not be checked

Austria

Accepted

In principle, we agree that it would be useful to consider the
implications for all land uses, but in practice, the TOR did notgive the authors this broad scope, requesting a factoring out
method only for flooded land.
There was a problem when converting the Word (andillustrator embedded figure) into PDF format. We havecorrected this problem.

285

Two comments to Figure 7.3: 1) The identification of a key category
requires at least a Tier 1 estimate first. The decision tree immediately
starts with the key category assessment before preparing an emission
estimate for the category. It is suggested to redraft the decision treeaccordingly. (The same problem exists for other such decision trees in the
LULUCF chapters.) 2) Why is the general principle of applying higher tiers
for key categories not applied for the estimate of emissions from water
bodies? It is recommended to apply this general principle also for thiscategory and to adjust the decision tree accordingly.
Austria

Accepted

added this box as requested

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Explanation for SOC in Equation 7.21 refers to the use of default SOC
values only. The approach should also allow the use of country specific
SOC stocks, particularly since it represents a Tier 2 approach.
Austria
Accepted
It would be better to apply this approach to all unmanaged land being
converted to managed land categories, to ensure consistency and because
United Kingdom (ofif this is a valid approach for flooded land, it is valid for other land too.
Alternative approaches are discussed in the scientific literature (e.g inGreat Britain andNorthern Ireland) Noted
266 Ciais et al. 2013).
Refer to glossary to ensure consistency regarding the definitions of the139 constructed water bodies mentioned in table 7.7.
Add citation to support the affirmation that GHG from drawdown zones
are significant and similar per unit area to the emissions from the water
196 surface.

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Change was made in the description of parameter SOCjk, Eq.
7.21
We agree that the general issue of emissions associated withconversion of unmanaged land to managed land is not uniqueto flooded lands. However, this was beyond the mandate in the
TOR from the IPCC panel.

CanadaAccepted

We have consolidated freshwater and Saline Ponds to single
entry "Ponds" because this is the term in the Glossary

CanadaAccepted

References added

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General comment on chapter 7: The guidance in the Final Draft It is notconsistent with the treatment of emissions and removals in the rest of the
AFOLU guidance. The Factoring Out approach would lead to comparability
issues if countries did implement it and as such can certainly not beprovided as default methodology: see lines 2384‐2385 of chapter 2,
stating that "... the Managed Land Proxy... is the only universally
applicable approach to estimating anthropogenic emissions and removals
in the AFOLU sector". There are two options to maintain the integrity of
the IPCC guidance in this 2019 MR, in spite of these inexplicable"Factoring Out" provisions.
1. Return to the approach used in the SOD and put the factoring out in a
box as an example and not as guidance.
2. Group all factoring out in a new section "Basis for future
methodological development" ‐ allowing for such a time in the futurewhen improved scientific understanding and quantification of"anthropogenic emissions and removals" will allow a scientifically credible
implementation in inventories.
As stated in chapters 1 and 2 of volume 4, the science currently does not
Canada907 support such "factoring out" approach as is proposed here.

7

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204 What's the difference between drainage channels and ditches?

44Comments

204

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CanadaGeneral comment on chapter 7: if the goal is to better reflect the impactof activities on the atmospheric concentration of GHGs, then the"factoring out" of methane emissions from un‐managed wetlands should
be limited to one decade, that is the average time it takes for methane tooxidize in the atmosphere. Factoring out of methane emissions should
Canada0 certainly not be applied to "flooded land remaining flooded land".
Re‐phrase so it is consistent with chapter 1 and 2 of volume 4: "However,
it is typical good practice for the greenhouse gas emissions in the AFOLU
sector…."
CanadaDelete the two sentences starting with "Special considerations…." : 1st
sentence: there is absolutely no scientific basis supporting a blanket
statement on higher pre‐flooding emissions specifically on un‐managed
land. 2n sentence: the point of the entire IPCC guidelines is to provide
guidance on quantifying emissions, not make gross and unverifiableassumptions on when land‐use change have a large or small impact on
260 emissions.

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Authors' notes

Accepted

We have followed the Ramsar definition of linear human‐madewaterbodies here, which appears as either 'canals and drainage
channels, ditches' or 'canals and drainage channels or ditches'.
We consider the last two categories to be largely
interchangeable and for simplicity have therefore (apart fromreferring to both categories in the definition) amended theguidance to refer to ditches only.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we were mandated by the IPCC Panel in the TOR todevelop "consistent methodologies that take into accountfactoring out of emissions that would otherwise occur in theabsence of the flooded area for estimating CO2 and CH4
emissions from flooded lands". We consider that the issues
raised here are a matter for the IPCC plenary, and do not relate
to the robustness of the science.

Noted

While CH4 can oxidized in the atmosphere on the time scale ofa decade, the emissions themselves can occur over a much
longer period. The 20 year threshold is used for consistency
and to reflect the different emission rates in these two time
periods.

Accepted

Inserted "good practice"

Accepted

The sentences referred to have been removed, and theparagraph has been revised to make it clearer which pre‐flooding emissions and removals are relevant to the 'factoringout' issue.

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Box 7.1 does not provide sufficient guidance in to implement a
methodology. Rather, provide a brief discussion of the challenges inquantifying the emissions and removals in sedimentation in the
Canada599 uncertainty section, not in the methodology portion.
Assure that it is clear what equations or parameters apply to what "otherconstructed waterbodies" For example the title of Equation 7.19 is"annual emissions from other constructed waterbodies", but theparameter, "FCH4other" is labelled as the total annual flux of methane
Canada929 from ponds and channels.

1040

It's not clear how this is related to the presence of a river prior to1041 inundation or if the reservoir is a small expansion of a natural lake.

Brazil is in favor of the version presented in the final draft. The proposed
methodology fully meets the mandate set by the 44th plenary session of
the IPCC in 2016, which prescribes that the refinement exercise should"update the CO2 emission factors for lands converted to wetlands anddevelop‐ based on a comprehensive review of the available literature andmethodology‐ consistent methodologies that take into account theemission factor and removal that would occur in the absence of theflooded area to estimate CO2 and CH4 emissions from wetlands (bothland converted to flooded land and flooded land remaining flooded). In
order to reinforce this position, recent studies show that it would alreadybe possible to discount the permanent burial of carbon in the sediment of
the reservoirs using a lower Tier (2) than that proposed in thisBrazil296 methodology.

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282 Figure 7.2 ‐ present a clear figure please.
The guidance from this point onwards is very technical and not easily
understandable and perhaps also not straightforward to apply, any
simplification if possible (also in language) and further discussion on
uncertainties would be appreciated.

Page 166

CanadaResponses

Authors' notes

Accepted with
Modification

The intention of box 7.1 is not to provide the methodology toestimate carbon burial. The box reports the challenges toestimate the portion of the carbon burial that can be attributed
to the reservoir construction. The box has been improved. For
higher Tiers the box brings some information for thecompilers: "For the development of higher Tier methodologies
for carbon accumulation in reservoirs, an important guiding
principle is that only the portion of the carbon permanently
buried in reservoir sediments that would not have been stored
elsewhere in the hydrological network (including the coastal
ocean) could potentially be considered as an offset to reservoir
greenhouse gas emissions."

Accepted

We have check and updated equations accordingly

Rejected

The comment indicates that the proportion of the area that is
newly flooded can vary greatly among reservoirs. The EF isdependant on the soil C stock of the newly flooded land.

Noted

Estonia

AcceptedBox 7.1 has been improved.
There was a problem when converting the Word (andillustrator embedded figure) into PDF format. We havecorrected this problem.

Estonia

Noted

During the revision process we increased clarity where
possible.

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Rejected

United States ofAmerica

Accepted

Rejected

Most of the total emissions attributable to the reservoir are
emitted in the first years. For consistency with other land
conversion, the 20 year threshold was used but also include theresidual emission occurring after years.

Rejected

Both the 'stock change' method for mineral soils (in thisguidance), and the 'flux based' methods for organic soils (2013WS) account for the conversion of riverine carbon to CO2. In
the stock change method this is implicit (all C lost from the soil
is emitted as CO2, regardless of whether this occurs directlyfrom the land surface or indirectly via the river network). In the'flux‐based method', additional organic carbon transferredfrom managed organic soils to the atmosphere is estimatedand resulting CO2 emission is calculated. Construction of areservoir may change the location at which carbon
transformation (emission as CO2, burial as sedimentary C)
takes place, but there is insufficient evidence to show that theconstruction of a reservoir changes the overall amount of CO2
emitted from riverine carbon in a consistent or quantifiableway. Therefore we have not been able to include guidance toestimate the effects of reservoir construction on the fate ofcarbon from upstream sources.

3569

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3571

4

7

282

284 Figure 7.2, part of the decision tree graphic appears to be missing.

969

It is not clear why the full estimated emissions over a 100‐year lifetime ofa reservoir would be reported over a 20‐year period. It would make far
more sense to assume the emissions factors will be high for the first ~10
years, slightly lower for the next ~10 years, and then (once reported as
United States of"flooded land remaining flooded land") maintain a steady low level ofAmerica
972 emissions over the remaining lifetime of the reservoir.

235

Nevertheless, the proposed methodology within the managed land proxyfails in properly quantifying the anthropogenic component of the GHG net
emission in flooded land. Indeed, in absence of the water reservoir, thecarbon components dissolved within the river water would naturally
follow a path to GHG emissions (CO2 and CH4) that is different from thepath they are following because of the reservoirs (more CH4 less CO2).
Therefore, a proper quantification of the impact of the activity of flooding
land should factor out such GHG emissions from organic matter in thewater under a “natural” condition from that one occurring asconsequence of the reservoir construction. Such symmetry in the method
is needed because the IPCC methods do not estimate the GHG emissions
from the organic matter in the water flowing in the river while the new
method for the flooded land will do. This factoring out has nothing to dowith the previous use of the land, since the factoring out, as per IPCC
plenary decision, must be applied to the organic matter within the river's
water, not to the emissions from land C pools, and it has to be applied
under both conditions: lands previously managed or unmanged. It is
Italy
244 recommended to revise accordingly the methodology.

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Authors' notes

We agree that the methods are inconsistent with the othersource categories, possibly with the exception of the IAV for
natural disturbances. We have strengthened the justification
for the factoring out in the Introductory sections. We disagree
that the methods are not scientifically‐based. We haveevaluated the emissions sources that would contribute toemissions without flooding, and developed emissions toaddress those sources. Additional references are provided forthe basis of our decisions. We are not sure why the method
would create an incentive for flooding areas because theemissions are greater after the flooding, in addition to the factthat the contructing dams is an expensive endeavor, which is
not likely to be implemented solely for the purpose of
converting unmanaged land into managed land.
There was a problem when converting the Word (andillustrator embedded figure) into PDF format. We havecorrected this problem.

The guidance contained in Chapter 7 on factoring out emissions/removals
that would otherwise occur in the absence of flooding has no scientificbasis for its inclusion and is inconsistent with IPCC good practice and how
the MLP is applied for all other land uses/conversions. By including thisfactoring out approach the IPCC is sending a message to countries thatthese additional methodological steps are necessary in order to beconsistent with good practice, which they are not. This approach could
also create incentives to flood unmanaged lands for reservoir
construction by offsetting some of the GHG emissions that come from the
new reservoir, which would be a perverse outcome. We therefore
request that all the emission factors and/or guidance on “factoring out” United States ofAmerica
1276 be removed from the Wetlands chapter.

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The factoring out approach proposed for flooded land on previous
unmanaged land is inconsistent with the approach implemented for any
other conversion of an unmanaged land to any other land use category. It
is worth nothing that also other types of unamanged land are relevant
sources of emissions and that their conversion is not factored out, e.g.
conversion of natural peatlands to drained agricultural lands. If the
proposed factoring out is accepted, it will require the redrafting of the
managed land proxy approach, since reporting of conversion of
unmanaged land to managed land will be based on a comparison ofcurrent emissions under management vs potential emissions under anunmanaged land scenario.
As implemented in the current text, the factoring out approach seems
designed for an accounting methodology of mitigation actions where thecurrent GHG net emission is compared to a BAU GHG net emission, i.e.
GHG net emission that would otherwise occur in a scenario where thecurrent activity is not implemented, to account for its mitigation impact.
However, such accounting is not within the scope of a national GHG
inventory under the UNFCCC.
Italy
279 Consequently, text in these rows must be deleted

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Authors' notes

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

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555 according to comment on rows 247‐279 delete this text

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Italy

Italy

Responses

Authors' notes

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

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Authors' notes

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We accept that it is good practice to report emissions using themanaged land proxy, and have inserted text stating thisguidance. We have also added text that addresses reporting ofboth Net and Total emissions as well as modifying the reportingtables. The following sentence has been added: "If a factoringout approach is applied, it is good practice to provide
transparency by reporting both total and net emissions;otherwise the country should report the total emissions if net
emissions are not estimated. Furthermore, if inventory
compilers choose to factor out natural CH4 emissions fromwetlands, it is also good practice to simultaneous factor out theloss of any natural CO2 sink in the that would otherwise haveoccurred if the land remained unmanaged.. " How thisinformation is used for reporting by parties to the UNFCCC is a
decision that will need to be made in the negotiations of theconvention. We are only providing estimation methods and aframework for reporting in this guidance.

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720 according to comment on rows 247‐279 delete this text

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Italy

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Authors' notes

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

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815 according to comment on rows 247‐279 delete this text

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Italy

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Authors' notes

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

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858 according to comment on rows 247‐279 delete this text

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Italy

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Authors' notes

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

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Italy

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Authors' notes

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We were mandated by the IPCC Plenary to develop "consistentmethodologies that take into account factoring out ofemissions that would otherwise occur in the absence of theflooded area for estimating CO2 and CH4 emissions fromflooded lands". We consider that the issues raised here are amatter for the IPCC plenary, and do not relate to therobustness of the science.

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Italy

Italy

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Authors' notes

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

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Italy

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Responses

Authors' notes

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

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Authors' notes

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

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Italy

Italy

Italy

Responses

Authors' notes

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

Rejected

We agree that this method creates an inconsistency with otherland uses, and also that there may be other relevant emissions
that could be factored out with conversion to those categories.
However, we have strengthened the justification for thisapproach in the Introductory section. Additionally, there was amandate from the IPCC panel in TOR to include factoring out
for this source, and only this source. Countries may ask for a
redrafting of the managed land proxy if they decide this isneeded. However, this method could be used in a restricted
way or for accounting depending on decisions in the UNFCCC.
We only dealing with estimation methods in this guidance. We
complied with the scope in the TOR that the IPCC has made inthis case, which did not include factoring out across all land
uses and sources.

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198

What is the net effect of land converted to flooded land on carbon sinks?
Please consider including the role of flooded land on carbon
sequestration. Assuming the "blue carbon principle, out of all thebiological carbon captured in the world, over half is captured by marine
living organisms hence it is called blue carbon". Artificial water reservoirs
Norway135 might also have a significant contribution of carbon captured.
Please consider if the double counting issues are related to all N2O
emissions produced in wetlands and other water reservoirs. Moreover, it
is likely that canals, ditches, freshwater ponds and saline pond produce
Norway183 CO2 (Bridget R. et al. 2016).
Please justify why 20 years age is considered as a boundary to classify
flooded land remaining flooded land (FF) and Land Converted to Flooded
Norway202 Land (FO).

270

When the landscape of managed lands are intensively modified using
advanced machines to construct flooded land, emissions might be emitted
due to (1) excavation and loss of originally accumulated soil carbon (per‐flooding emission), and (2) flooded land. Pre‐flooded emissions are most
likely to relate to the size of excavation ( e.g., volume), etc.,Thus, pleasetake into account "double emission accounting" by estimating thepotential loss of carbon from the excavated area/volume (V) it'd be
Norway273 estimated and reported in a parallel to factor out.

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What is the time limit to determine unmanaged land for factoring out ofemissions/removals? The per‐flooded land uses might be passed thoughdifferent land use changes at different time interval, e. g., wetland ‐‐→forest ‐‐→unmanaged grassland‐‐‐→other land uses (e.g., cropland)
during inventory. It's most likely to classify all per‐flooded land uses as
unmanaged, specially wetland and unmanaged grassland. The selected
type of unmanaged land use can under/overestimate both factoring out
and net emissions/removals. Moreover, please consider defining, in the
323 glossary section, what factoring out is referring.
Research paper by (McPherson et al. 2013) should be added, as it is114 currently left out from the reference list (p8‐12)

Authors' notes

Rejected

This was mandated in the TOR.

Noted

Box 7.1 addresses the role of reservoirs in trapping sediments
and carbon burial providing information to develop amethodology at higher tiers "For the development of higher
Tier methodologies for carbon accumulation in reservoirs, an
important guiding principle is that only the portion of the
carbon permanently buried in reservoir sediments that would
not have been stored elsewhere in the hydrological network(including the coastal ocean) could potentially be considered as
an offset to reservoir greenhouse gas emissions."
Test added at Line 183. Compilers may address local sources ofAccepted

Accepted

Text added in line 301

Accepted

We have improved the text. Explanations are provided l. 942‐
948 and l.973‐980; the emissions or transfer to another carbon
pool due to distrubance prior to flooding are taken into
consideration using IPCC methodologies (see Chapter 2 Generic
Methodologies Applicable to Multiple land‐use Categories.)

NorwayAccepted

Note inserted in text of Table 7.9 and 7.14." The selection of
appropriate EFCH4_luc j,r should reflect the land at the time offlooding."

Republic of Korea

Accepted

McPherson et al. 2013 is added in the reference list

Rejected

Unfortunately, good data was not found in recent research. In
addition, it was clarified that the default numbers in Table 8.2
of 2006GL were prepared based on forest trees and the data
has not summarized as a paper. Therefore, they are removed
from the updated Table 8.2.

Regarding the Table 8.2, number of the tree species have been reduced
compared to 2006 GL. Default values by tree species are neccessary to be
168 presented as shown in 2006 GL .
Republic of Korea

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The authors agree with taking 2.8 as the default, becase thisvalue is based on the sound science.
Updated table 8.1 and the text under Tier.2 are modified.

FranceAccepted

FranceAccepted

FranceAccepted

FranceAccepted

FranceAccepted

83

129

239

Accepted with
Modification

Authors' notes
It is correct. The unit modified to "(ha crown cover)‐1".
Ones in lines 102, 103 111, 113 116 and 132 also should bechanged in the final editorial process.
The authors considered the current text is already providing
references to several papers, informing on how urban
conditions affect tree growth and mortality.
But the text is slightly modified for clarity.

Not clear how we are supposed to take into account urban conditions,such as local air quality, to assess tree growth. Maybe add a reference for
89 guidance.
Canada8

10Country"t C ha‐1 crown cover‐1 yr‐1" – the unit of value for CRW ‐ in lines 111,
116 113 and 116 should be changed to " t C (ha crown cover) ‐1 yr‐1".

4

4Comments

111

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Toline1511

Even if no significant difference is observed between the original study
and the updated value, we should use 2.8. The study is more recent and
131 double the sampling size.
MCF spreadsheet, Maybe give a header "Input data : Temperature " OR
28 "Temperature "MCF spreadsheet, Maybe give a header "Other Input data " OR "Specific
66 inputs" OR "Constants and other input parameters "MCF spreadsheet, suggest to precise "Monthly model inputs and outputs
116 over a three year period".
MCF spreadsheet, suggest to precise a bit what can be seen in panels :"top panels Temperature in °C ( column C) and K ( column D), coeffient(column E), VS excreted ( column F )and VS loaded ( column G) …..;
121 middle panels idem
MCF spreadsheet, suggest to precise "Example of monthly patterns in
123 Year 3: manure temperature …"China

MCF spreadsheet, suggest to reword to make the phrase simpler " Theterm “VS Consumed” does not represent a conceptual degradation of VS
but a quantity VS going from the liquid/slurry storage into
France139 biomethane potential at 35°C (i.e. to produce the B 0 )MCF spreadsheet, suggest to reword to make the phrase simpler :"Though this is convenient for modeling, and consistent with the B 0 , thisdoes not is not represent the reality. "France144 in a liquid/slurry storage.2
Table 10.1 : Growing swine under free range is missing in the table for low
France475 productivity systems
add the reference of Sauvant and Nozière, 2016 (Sauvant, D., Noziere, P.
(2016). Quantification of the main digestive processes in ruminants: theequations involved in the renewed energy and protein feed evaluation
1191 systems. Animal, 10 (05), 755‐770. , DOI : 10.1017/S1751731115002670)
Animal waste management system : corresponds to each step of the
manure management (building, outdoor storage, grazing, treatment).
Maybe it would have been less confusing if storage was replaced by
1435 manure management technique.

1511 erase in manure management system S

Accepted

Rewrote as: The term “VS Consumed” does not represent thereal VS degraded but a conceptual quantity of VS removed
from the liquid/slurry storage and placed into the
Accepted with M biomethane potential at 35°C (i.e. to produce the B0 ).
Rewrote as: Though this is convenient for modeling, and isconsistent with the B0, this does not represent the physicalAccepted with M reality the liquid/slurry storage
The category of 'swine under free range' was added into the list
Acceptedpresented in Table 10.1

FranceNoted

FranceAccepted

FrancePage 180

Responses

Rejected

The information presented in the reference source was not
used in the elaboration of the information reported in Chapter
10. It is not clear what the reviewer is requesting.

It is not clear why the reviewer wants to remove this text that is
consistent with the text around other parameters in theequation. We did remove the repeated comma in this line.

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TAM: is it Typical animal mass at the middle of the growing period or
1561 mean Typical animal mass ?

FranceResponses

Authors' notes

Accepted with
Modification

The weight that is used is dependant on the production system ‐values in this table were derived from the information that iscontained in the Annexes of the Chapter, Table 10A.1 to Table
10A.5. In the case of dairy cattle, live weights are used. In thecase of other cattle, weighted live weights are used that are
based on the relative proportion of different animal
subcategories during annual production. As a general rule meatproduction systems, use the median weight of the animal
during its growth to slaughter. Animals that are kept for the
production of products (milk, eggs), draft or other uses ofmature animals use live weight.
The following line has been added:"The TAM should be consistent with median weight of theanimal during its production stage. Typically, for animals usedin meat production systems, this is the median weight of theanimal during its growth period. Animals that are kept for the
production of products (milk, eggs), draft or other uses would
use the typical live weight of the animal herd."

In the second order draft, emission factors were provided for
all the possible combinations of manure management system
and animal categories and there were multiple comments
stating that the method was far too complicated and there was
far too much information in the document.

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Table 10.14 : For the different kind of storage (inside building or outdoor
storage) duration should be clearly indicated, as level of emissions varies
in function of storage duration. For cattle, it is necessary to consider also :
liquid storage under animal confinment (<1 and > 1 months), deep
bedding, manure scrapping . For swine, liquid /slurry (outdoor storage),deep bedding; For poultry, litter system, outdoor liquid slurry sorage,
manure drying indoor and outdoor. For all species,
France1592 pasture/graze/paddocks should be added,

Page 181

Rejected

We have provided emission factors for the default information
about manure management systems that is provided by the
FAO. For countries that have country specific manure
management system data, they can use the Tier 2 methodology
to calculated their emission factors for systems that are notincluded here. The Tier 1 methodology cannot take into
account all potential combinations of manure management
system but take into account the information necessary to
calculate directly for the defaulat information. It is noted in the
Tier 1 emission factor how an emission factor for a specificsystem, assuming that the country has additional information
for some management systems could be calculated(MCF*B0*0.67).

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As mentioned in the text, bedding materials are used in solid
manure management systems, when as a general rule methane
emissions are lower than in liquid systems. Line 2624 refers
specifically to large biomass inputs into biodigesters intended
to increase methane production through the addition ofmaterial rich in carbon, and in the case of energy crops that
could also be relatively rich in nitrogen.

245

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As Nitrogen from bedding and additional N entering the system (Line2624, co‐digestates) can be accounted for, Carbon from bedding should
1611 be accounted for in C manure (VS).

1627

equation 10.23: to calculate annual emission factor for livestock category
the number of days should be a parameter and specific of the manure
managment system and not considered to 365. For instance : how taking
into account in CH4 emissions calculations of dairy cattles that spend 6
months in building and 6 months in pasture ? or how to take into accountof the periods of emptiness of buildings between the differents flocks forFrance1627 animal in confinments ?

1780

examples of calculations with the different cited examples would have
1789 been apreciated.

FranceFranceRejected

Further measurements of methane emissions on whichmethane emission factors are based, typically don't
differentiate bedding from volatile solids, therefore thedifferentiation of bedding based methane and volatile solid
based methane is not possible. For this reason, the carbon
inputs from bedding to the methane production system are notexplicitely quantified in the methodology.

Rejected

The distribution of VS among different manure management
systems is done through the AWMS fraction and not throughthe number of days of VS production. Likewise, though a barn
may be empty it is assumed that the animal is still producing
VS, whether in the barn or outside. If there are situations inwhich the animal may not be producing VS throughout theyear, this should be taken into account in Equation 10.1.

Accepted with
Modification

We have not provided specific examples in this case, but wehave expanded the information that would need to beconsidered in carrying out these calculations. These type of
calculations would not be considered as the prescribed Tier 2,
but would be considered a country‐specific application of theTier 2 and therefore we wish to avoid confusion about what thedefault guidance is by providing a full example of thecalculation.

Composting systems are treated in the same way as manure
heaps. The MCF applies to the full fraction of the annual VS
that is tranferred to the composting system on an annual basis.
The MCF is not differentiated based on the length of compost(retention time), as was done for the liquid systems because
there is not evidence that methane emissions vary based on
retention times in the same way liquid systems do.

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Table 10.17: duration of storage should be indicated for composting and1792 systems with litter

Page 182

FranceRejected

The deep bedding systems are differentiated based on theirlenght of storage, but only for less than one month and greaterthan one month.

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1843

Table 10.18: this table should be presented differently to facilitate the use
and the understanding. Definitions of systems should be regrouped infunction of the manure management step (ie building, storage, grazing,treatment). Systems wtih frequent manure removal from building (several
times per day) are not defined in the table. Same for deep bedding withadditives. This table should also include new systems that allow
France1843 mitigation to take into account of the mitigations in inventories.

Rejected

FranceFranceRejected
Accepted

255
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2161

Equation 10.25: NbeddingMS should be accounted in this equation. EF3
for systems with bedding have been assessed by measurement on thewhole biologic system (animal excretion and litter). The emitting
processes and emissions level are not the same for slurry only and solid
manure. The mass balance approach should be prefered to consider
emissions at each manure managment step (building, sotrage, grazing,treatment) and be more accurate and relevant even with the tier 1
approach. For instance how caculating with this equation emissions for
systems with deep bedding and solid outdoor storage and grazing ?
1947 (see all the published papers dealing with solid manure)2161 N intake kg Nanimal‐1day‐1 and not kg Nanimal‐1y‐1

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2188 Dmi kg of DM.animal‐1Day‐1

FranceAccepted

2261
2317

This sentence seems not correct. "For the calculation of theNretention_frac(T), the daily N retention can be calculated by dividing theresult of equation 10.33A by the number of days from parturition to
France2261 parturition (as mentionned in equation 10.33A).
France2317 Ngain not Nper gain?

Accepted
Accepted

261
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Authors' notes

The IPCC guidelines have been based on grouped systems since
their initial implementation. To implement manure stages
would be a significant deviation from the guidelines and would
be beyond the scope of this refinement, which was to update
emission factors and parameters, align methodolgies, but notdevelop entirely new methodologies, unless significant issues
were identified with those as they stand. Grouping of systems
was reviewed in earlier versions of the refinement; thecollation of manure management systems and review of
emission factors has been completed and reviewed in earlier
versions of the refinement; there is no default emission factor
for "deep bedding with additives" as additives comprise a very
wide variety and act very differently; We were not able todevelop a default series of emission factors that are specific tofrequency of manure removal based on the current available
literature; Country‐specific mitigation measures can be carriedout as a part of a country‐specific Tier 2 methodology when
information on the impact of specific management proacices
are known and parties are encouraged develop higher Tier
inventories by using national data, systems and emission
factors.
It is correct that EF3 has been assessed for whole systems (i.e.
manure excretion and beeding), but then the emission
measured in these full systems were related to the original N
excretion rates. This means that the Efs include the effect of
the bedding material, but are given in relation of animal N
excretion; bedding quantities are highly variable inexperimental results and in practice and add to the uncertaintyof the measurement, but based on our analysis of the data,
should not be included in this equation. Further the IPCC Tier 1
does not distinguish between housing and storage and therefinement did not have the mandate to include major changes
to the IPCC methodology; it is however noted that thismethodological change would be desirable in future updates.

Text was included to make the description easier tounderstantand

see response to comment 1715

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Figure 6 : MCF spreadsheet, what is the unit of the figure in the middle
2904 (???kg, m3??)

The Nitrogen from the bedding should be included in equation 10.25 as1950 EF3 has been assessed for the whole system ie excretion+litter.

Country
FranceFrance1993

equation 10.26 : NbeddingMS should be accounted in this equation :N*awms (Nex + NbeddingMS) +Ncdg (same in eq 10.25) as fracgasms has
France1993 been assessed on litter+excretion.

2265

In equation 10.33C, calculation is as follow : (Bwfinal ‐Bwinitial )*Ngain(BWfinal), why not using Bwfinal*Ngain(Bwfinal)‐
Bwinitial*Ngain(Bwinitial) (solution 2). Moreover calculated N retention
with Ngain provided in table 10.20B are very low for growing pigs
compared to those calculated with more recent models like the model
developed by Dourmad et al. and used in Dourmad et al. (2015)
Underestimation of retention will lead to overstimation of excretion andemissions.
Cf. : Dourmad J.Y. (coord.), Levasseur P.(coord.), Daumer M.,Hassouna M.,
Landrain B., Lemaire N., Loussouarn A., Salaün Y., Espagnol S.,
2015.Évaluation des rejets d’azote, phosphore, potassium, cuivre et zinc
France2280 des porcs. RMTElevages et Environnement, Paris, 26 pages.

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Accepted

Rejected

It is correct that EF3 has been assessed for whole systems (i.e.
manure excretion and bedding), but then the emission
measured in these full systems were related to the original N
excretion rates and it is rare that bedding N was included in theestimate of the emission factor. This means that the Efs include
the effect of the bedding material, but are given in relation ofanimal N excretion; Bedding quantities are highly variable anddifficult to assess. It was not possible to develop default values
for bedding quantities due to the variability of bedding under
different systems. Because default values could not beprovided, it was judged that it was better not to include
bedding in the calculations. It is however noted that thismethodological change would be desirable in future updates.

Rejected

It is the opinion of the panel, that since mineralization of
nitrogen compounds in beddings occurs more slowly comparedto manure and the concentration of ammonia fraction inorganic beddings is negligible, both volatilization and leachinglosses during storage of bedding are assumed to be zero. N in
bedding is relevant to estimate the amount available forapplication ‐ see Eqn 10.34. Further, due to the variabiity in theuse and source of bedding it was not possible to develop
default values to include in the equation and as a result it waspreferred to not include it in the Tier 1 methodology.

Rejected

We have reviewed the Dourmad method and noted that it
requires an additional parameter, muscle percentage, which
has an influence on both the trend in N retention and theabsolute amount. We feel this value could vary widely acrossthe world and further could vary over the growth period. We
further verified if the use of the Dourmad equation resulted insignificant changes in total N excretion for a production cycleand noted that the values were within 5%. Therefore it is thepanel's decision to maintain the values in the Table as is. The
suggested equation also ignores the use of the subscript "i"which indicates the growth stage for which the Ngain values
should be applied, therefore modifications to the equation are
not required.

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Table 10.21: systems should be classified by manure magement step :building, storage, treatment. Durage of storage should be indicated anddifferent EF should be proposed in function of the storage duration. Thisfactor have an influence on the measured emissions level. In annex 10B, it
is mentionned line 4032, given EF are expressed as kf of N2O‐N kg of
initial N‐1. Initial N is not N excreted. Initial N is N coming to storage after
building that means (Nexcreted ‐N emissions in buiding). These EF values
have been reported in table 10.21 but not with the same unit (kg N2O‐
N.kg nitrogen excreted). This should be corrected as it can lead to a hugeoverestimation of emissions. All the values in table 10.21 should bechecked considering that that kind of mistakes could have happened in
France2382 other cells.

Rejected

Rejected

N in bedding is relevant to estimate the amount available forapplication. Eqn 10.34 is correct. N in bedding material will flow
directly to NMMS_avb (see comment 269). The approach isbased on the assumption that the organic N in bedding will
make its most significant contribution to emissions after field
application.

Accepted

Table 10.22. "%" have been removed from the table andequations have been ammeded accordingly. FracGas_MS
considered in IPCC (2019) includes N losses from housing andstorage all together. Values have been taken from current
EMEP/CORINAIR (2016) for categories present in
EMEP/CORINAIR (2016). EMEP EF values, which are expressed
per TAN excreted have been re‐calculated to be expressed as afuntion of total N considering the mass balance flow between
the different manure management phases prior to manure
application (housing, yards, storage). For other categories notpresent in EMEP we used Pardo et al. (2015) relative EF´sdifferences between conventional solidwaste against
composting, etc. as the basis (for the storage phase) toestimate EFs for the manure management phases prior tomanure application (Includes housing). We assumed no N2O or
N2 losses prior to storage. Some text has been added in thesolid manure Annex to clarify this.

FranceAccepted with
Modification

The equations were checked and corrected, but Nbedding wasmaintained in the same position based on the response tocomment 269, i.e. that N bedding is considered specifically intransfers to the field, but considered indirectly in manurestorage emission estimates.

FranceAccepted

equation 10.34 : NbeddingMS should be reformulated regarding
2436 modifications suggested for equation 10.26 and 10.25

2521

Table 10.22 : to avoid confusion in calculation % should be removed fromthe table. Fracgas‐MS, Fracleach are divided /100 in equations 10.27 and10.26. For storage and treatment Fracgas_MS should be corrected
because they are not consistent with literature and not to Pardo el al 2015
because of a unit error. Emissions will be calculated regarding equations
10. 26 and in this equation FracgasMS corresponds to the fraction of Nexc
that volatises as NH3 and NOx. The value given in table 10.22 correspondto the fraction of incoming N (for storage) as given by pardo et al. 2015.
The incoming N for storage is (Nexcreted ‐N losses in building). All thevalues in table 10.22 should be checked and corrected regarding thisinformation to avoid huge overestimation and inconsistancy with NH3inventories. To avoid this kind of mistake a mass balance approach evenfor tier 1 should be preferred. Applying the volatilisation coefficient
directly to N exc for storage and treatment is not relevant because itmeans that we do not consider what occured in the building before theoutdoor storage. Usually EF assessment is not express in function of Nexc,
that means the conversion of the EF /kg of Nexc required some data thantFrance2521 are not directly available in the paper.

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The IPCC Tier 1 methodology does not distingush in the steps"housing" and "storage"; so initial N is N excreted, see theresponse to comment 253. The proposed change involves a
modification that is beyond the scope of this refinement.
Further, it is the panel's position that while this may be adesireable future improvement, with the current level ofknowledge about emissions from steps and national
information about manure management, this would be difficult
to implement globally and would not necessarily result in an
improvement of emission estimation accuracy.

2436

Figure 10.5: Nbedding has to be moved at the same level than N ex N
codigestate with an arrow from Nbedding to Nmanure stored andmanaged; the number of the equations that are indicated should be2661 checked. Some are wrong.
Equation 10.A.27 : NbeddingMS is the kg of litter/animal. Nex should be3229 removed from equation

Responses

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Chickens produced in intensive systems need no more than 35 d to growuntil final slaughter weight of 2 kg. In 'SIQO' production system includingorganic systems, minimal period to grow chicken is around 80 d.
Increasing part of organic system has to be acounted for. Cf.
http://www.klimatmarkningen.se/wp‐content/uploads/2009/12/2009‐6‐
France371 chicken.pdf

Noted

The comment refers to unmodified text used as an example inthe 2006 GLs that is intended to illustrate how to calculateannual average population. It is unclear what the reviewer
wants changed in this text.

429

Sheep prodution fr meat has to be separated into 'low productivity
systems' (grass‐fed) and 'high productivity systems' (concentrate‐fed). As
a onsequence, a Tier‐2 approah could be considered as suggested in line
469‐469, but not described in table 10.1.
Cf.
https://www.viandesetproduitscarnes.fr/index.php/fr/processtechnologie
France430 s/468‐la‐production‐dovins‐viande‐en‐france‐1ere‐partie

Accepted

Table 10.1 was modified

Noted

While the proportion of concentrates in a diet is strongly
correlated to the NDF, depending on the definition and type of"concentrates" the value of NDF will vary among different
dietary regimes and therefore we feel more confident using thedirectly measured parameter rather than the surrogate.

601

Recently revised INRA system for ruminant have included ruminal proteinbalance into a more precise prediction of feed digestibility. Cf. INRA,2018.
INRA feeding system for ruminants. Wageningen Academic Publishers,
France603 Waeningen, the Netherlands,640pp

Rejected

A full refinement of the GE model was not part of the scope of
this refinement. Further, the cited document is from 2018
which would not have provided the author team with time tointegrate such major changes into the refinement. The model
parameters were verified against the most recent NRC
publication and no important changes were noted to berequired in the methodology.

658

In Equation 10.3 and 10.4 and 10.5 (and others..) as well as in table 10.4 ,Cf and Ca must be expressed MJ day‐1 (kg metabolic weight) ‐1) and not
France698 kg ‐1 (consistency of the units)

Accepted with
Modification

We have put the units in where they are missing., however forclarity the units were maintained as MJ day‐1 kg‐1 to avoid
confusion for compilers as equations refer to live weight.

696

In table 10.1, maintenance requirements may be defined accordingly todays in milk (dairy females) because of changes in BW due to lipid stores
mobilization. Cf. INRA,2018. INRA feeding system for ruminants.
698 Wageningen Academic Publishers, Waeningen, the Netherlands,640pp

Noted

A full refinement of the GE model was not part of the scope of
this refinement. Further, the cited document is 2018 which
would not have provided the author team with time tointegrate such major changes into the refinement.

FranceRejected

FranceAccepted with
Modification

501

TolinePercentage of concentrate in the diet can be more easily estimated than
502 NDF and is as accurate as NDF

317

4

10

709

Predition of NE fo gain has been recently reviewed either by INRA (2018)
or by Norfor sytem with a greater acuracy than NRC 1989. Cf.
746 http://www.norfor.info/; INRA 2018 cf above

319

4

10

788

Estimation of milk fat content for goats is overestimated for most of790 european breeds

Page 186

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Authors' notes

A full refinement of the GE model was not part of the scope of
this refinement. Further, the cited document is from 2018
which would not have provided the author team with time tointegrate such major changes into the refinement.
Rewrote as: Milk fat vary largely among breeds. Compilers areencouraged to use country‐specific milk fat content to derive
EVmilk when available.

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Revision of Feed Unit System for Ruminants include now the CP in the867 prediction of REM and REG

FranceResponses

Rejected

Authors' notes
A full refinement of the GE model was not part of the scope of
this refinement. Further, the cited document is from 2018
which would not have provided the author team with time tointegrate such major changes into the refinement.
This point appears to be a request for clarification, so we havenoted it and provide here clarification:

323

325

4

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10

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1197

2103

Ym of dairy cows as well as cattleis recognized to be affected by additives.
How is it accounted for? Only through a specific Tier‐3 approach? Or
partly through table 10.12 assuming than addidtives affects feed
digestibility? Or through lines 1361‐1369.
France1198 Cf. Knapp et al. 2014. J. Dairy Sci. 97 :3231–3261

N excretion rate prediction does not account for quality' of CP, i.E theamino ‐acid profile of diet in its ability to better match amino‐acidrequirement for growth in pig species. This may increase artificially N
excretion. Moreover, in numerous developped countries, phase feedingaccording to spcific requirement for protein in th successive growth phase
France2280 is not accounted for.

327

4

10

2280

349

4

10

2231

357
675

4
4

10
10

2244
347

N excretion rate prediction does not account for quality' of CP, i.E theamino ‐acid profile of diet in its ability to better match amino‐acidrequirement for growth in poultry species. This may increase artificially N
excretion. Moreover, in numerous developped countries, phase feedingaccording to spcific requirement for protein in th successive growth phase
France2317 is not accounted for.
The equation 10.33A is not so clear because it is mentionned that Ngain isfrom parturition to parturition. Maybe it would be clearer to say fromparturition to the end of gestation (but before next parturition), or to sayjust during gestation which is a bit different but corresponds to theFrance2231 calculation proposed.
The title of the equation 10.33B is similar to equation 10.33C. It would be
more logical to have "N RETENTION RATES FOR PIGLETS (NEWFrance2244 EQUATION)"New Zealand
347 typo, "this sourcs"

573

Could there be more information on the regions where making an
576 adjustment for cold temperatures could be appropriate?

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New Zealand

Noted

The treatment of the use of additives that impact the methane
conversion factor are treated in lines 1361 to 1369 in the text.
According to this text countries must provide scientificevidence of their efficacity and evidence of the uptake of thetechnology. Table 10.12 does not account for methane
reducing additives, but there is an acknowledgement thatcertain animal production systems may use additives that
impact feed efficiency. These do not directly affect methane
production.

Noted

We acknowledge the validity of this comment. However, there
is not sufficient information to model nitrogen excretion to thislevel of detail in different regions of the world, specially thatfrom low productivity systems. Nonetheless, guidance isprovided in several sections of these guidelines to encouragecountries that are able to do so, to move to tier 2 or tier 3
approaches to more precisely estimate N excretion under their
specific conditions.

Noted

We acknowledge the validity of this comment. However, there
is not sufficient information to model nitrogen excretion indifferent regions of the world, especially in low productivity
systems. Nonetheless, text is provided in several sections ofthese guidelines to encourage countries that are able to do so,
to move to tier 2 or tier 3 approaches to more precisely
estimate emissions for their country‐specific conditions andthe information that is available to their inventory compilers.

Accepted with
Modification

Appropriate text was added to clarify

Accepted
Accepted
Accepted with
Modification

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1018

1018 replace full stop after the word "emission" with comma

1091

Could an example be provided showing how tier 1 enteric fermentation
emission factors should be calculated for animals where the actual
estimated liveweight is significantly different to the liveweight in table
10.10? e.g. what would be the guidance for calculating emissions from1122 ostriches with a liveweight of 200kg?

1091

Could this text and/or table 10.10 have some explicit text saying that1122 enteric fermentation emissions from rabbits should not be considered?

1321

could Ym also be affected by genetics/breeding of animals selected for1327 low Ym characteristics?

Could an example calculation be shown after this paragraph for how to1581 estimate total VS for a particular animal with a particular weight?

687

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1581

689

4

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1843

691
693

4
4

10
10

2197
2521

695

4

10

697

4

699

Rejected

Authors' notes
The comment refers to the text of the 2006 GLs, which was not
updated.

Accepted

A footnote was added referring compilers to Section 10.2.4
where it is explained how to derive EFs if weight is different
from those reported in table 10.10

New Zealand

Rejected

It is not possible to develop a fully comprehensive list of all
domesticated livestock globally as information is not always
available. Section 10.2.4 of the GLs describes how to consider
and adjust EFs for animal species not listed in table 10.10 if it ispossble to compare a species to another known emission factor
based on their digstive characteristics. If default emission
factors are not listed for animals with comparative digestivesystems, compilers should consult the scientific literature or
carry out country specific research if it is judged that a species
not listed here makes an important contribution to theiragricultural emissions. Compilers should document
assumptions made in making this determination.

New Zealand

Accepted with
Modification

Breed or genotype variation was added in this list, further,reference to breeding for Ym reduction was added to thediscussion of methane yield modifying factors (line 1197)

New Zealand

Accepted with
Modification

We have provided more explicit text in Section 10.4.1 todescribe how the calculation is carried out, but not a specificnumeric example, as the equation is quite straightforward.

New Zealand

Rejected

To conform with the Table of Contents defined by the IPCC
Pleanary, the Table will remain where it currently is placed.

New Zealand

New Zealand

Responses

New Zealand
New Zealand

Accepted
Accepted

2662

1844 Could this table be moved further up near the start of the chapter?
Could an example calculation be shown for how to estimate total Nex for
2198 a particular animal with a particular weight?
2522 Typo on footnote 4, "Uncertain"
good diagram, could it also show which emissions are direct and which
2663 are indirect?

New Zealand

Accepted

10

2736

2737 the goat (eastern europe) numbers in table 10 A.8 don’t add to 100%

New Zealand

Accepted

4

10

2740

do "mean annual temperature" and "mean annual precipitation" have a2771 precise scientific/meterological definition? If so, could this be provided?

New Zealand

Accepted

715

4

10

338

717

4

10

1001

Should there be reference to consistency across the time series, or referall
New Zealand
340 to time series consistency methodology where this is not possible?
This seems like a complex way to describe methanogenesis, perhaps
New Zealand1003 reword to a simpler sentence?

Page 188

A brief example calculation was included in the document

It is noted in the text now that the data is the annual averages
from the 30 year period in the cited data source

Accepted
Accepted

The desctiption presented in tbe 2006 GLs was put back.

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1059

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1063

4

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1791

1065

4

10

522

1067

4

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557

Table 10.17. MCFs by climate zone is missing deep bedding for other thancattle and swine. Please add MCFs for deep bedding for sheep, goats,
Finland1792 horses and poultry, for which deep bedding is also used.
We suggest an addition: Slaughter weights can be utilized in live weight
estimations if slaughter ages, dressing percentages and growth curves are
Finland
530 also available
Please specify the temperature range for the months ('cold months') for
Finland
576 which the Equation 10.2. is applicable.

711

Please clarify in the text whether different mature weight values should
be used for females, castrates and bulls ‐ in addition to the difference
created by the coefficient differing from 1 for these cattle subgroups. Thisis an important issue because of the great difference in mature weights
between sexes. Calculation examples for a bull and a heifer would make
726 sure that inventory compilers understand the guidance as it is intended. Finland

4

1199

4

1201

4

10

Accepted with
Modification

Table 10.17, subscript 1: thick, dry crust. A description of conditions
favourable for formation of thick, dry crust should be added to the text orfootnote to assist inventory compilers to choose a correct factor in case of
Finland1792 insufficient or partial activity data.

1537

1069

Responses

Accepted

10

10Country

2421

4

4

Comments

New Zealand
1537 add: based on … "measurements of" … dry matter intake
Reference to EEA 2016. EMEP/EEA air pollutant inventory has changed its
recommendations on bedding: in the inventory guidebook 2016,volatilization losses are no longer assumed to be zero. Please remove theFinland2422 reference to EEA 2016.

719

1061

TolineComment: it is good to see that the chapter has been updated based oncomprehensive analysis of literature for cattle and some other livestockcategories. However, the values for sheep, especially in relation tomanure‐related emissions, do not appear to have strong justification fromliterature. In many cases their derivation is unclear, especially whengrouped with "other". At least, the basis and justification for the values
must be provided, especially where they are substantially different from
Australia
10 General comGeneral comother ruminant livestock.
Recommend clarifying: Table 10.13A Footnote 5 Annex 10B.3 only
considers goats. There is no information on how figures for sheep (orturkeys, ducks, horses, donkeys or camels) are derived. Recommend
Australia
101653
1653 providing a description and justification.

Page 189

Accepted with
Modification

Authors' notes
As DMI may come from surveys or measurements that are
applied at the national scale the panel feels it is best to use theword estimate

The articles that were cited were related to cattle and swine.
We have added a suggestion for compilers to use these values
as surrogates if other animals are using deep‐bedding systems
for their production. We further corrected some minor issues
with footnotes and column labels, specificall, the climate zone
for Tropical Montane that was improperly labelled and therepetition of footnote 5 that was missing from footnote 1.

Accepted
Accepted

Accepted with
Modification

The clarification was added. An example was not provided,
because full examples are provided and are available tocompilers in the supplemental material where all Tier 1
calculation spreadsheets are provided.

Accepted with
Modification

The reviewer is correct to point out that less focus was placedon emissions from the Sheep category, mainly due toprioritization decisions of the IPCC Panel. Based on thereviewer's comment we have reviewed the 2006 values for VS,
liveweight and N excretion. The revised sheep values have been
modified according to information based on GLEAM modelfrom FAO. N excretion and VS have been modified and values
are much smaller and similar to new values for goats. An
independant verification of the GLEAM values suggested thatthey were more accurate than the 2006 guideline defaults.

Accepted

A footnote was added specifying that values are taken from2006 Guidelines

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2446

Comments
Country
Recommend clarification: should this say cattle, sheep and goats?
Otherwise, where is the equation for these livestock, and why does line
2185 refer to cattle, sheep and goats?
Australia
Recommend clarification in Table 10.19: Why are the values for sheep somuch higher than goats everywhere except North America? There is no
information about how these figures are derived. The cited annex has noAustralia
2302 data for sheep.
Australia
Recommend correction: it should refer to equation 10.34A

Accepted
Accepted

Accepted

1323
1325

4
4

10
10

1612
1844

It is confusing how to allocate the emissions from anaerobic digestion(both from storage and application). These emissions are generally small,but it complicates the inventory work if the emissions of different
substances from the same source should be allocated to different sectors.
According to the 2019 refinements the emissions from digested manure
should be allocated to 3.B. Moreover, the following is stated (vol 4, ch10,
row 1612), "CH4 emissions from co‐digestion of organic resources (cropresidues, food waste, energy crops) need to be reported under the source
category ‘3.B(a).5 – Co‐distestates’". I.e., not only emissions from digested
manure, but also from food waste etc, should be reported in 3.B. On theother hand, in the waste chapter, biological treatment of solid waste(2006 GL, vol5, ch 4), it is suggested that the emissions from ”anaerobic
digestion of organic waste, such as food waste, garden (yard) and park
waste and sludge” should be reported in the waste sector.
Finally, in the chapter about estimating emissions from manure
management systems, the EMEP/EEA Guidebook (2016 and the 2019draft) says, "Emissions from biogas facilities i.e. from during the storage ofslurry before anaerobic digestion and the storage of digestate after biogas
generation, are calculated and reported in Chapter 5B2. Hence, any
manures used as biogas feedstocks need to be subtracted before
calculating emissions from storage and application to land". It would be
Sweden1613 very useful to clarify the allocation in the final version.
Sweden1844 The footnote is missing.

1327

4

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2502

It is not clear which values the GL refer to. It would also be useful to2503 considere to include information on the exact table/paragraph

Page 190

SwedenResponses
Accepted with
Modification

Accepted with
Modification
Accepted

Authors' notes
The title of the equation was changed as calculations can be
carried out based on this equation and the values in Table
10.20.
N excretion sheep values have been modified according to
information based on GLEAM model from FAO. New values do
not show such large differences amongst regions, see theresponse to comment 1199.

Text was included to better indicate where and how emissions
are reported among the different sectors from manure andcodigestates in the introduction to Section 10.4. all references
to the reporting of waste emissions in the Chapter 10 were
removed to avoid confusion and text was added to indicate
emissions from the combusion of biogas should be included in
the energy section.

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TolineComments

Country

It is confusing how to allocate the emissions from anaerobic digestion(both from storage and application). These emissions are generally small,but it really complicates the inventory work if the emissions of different
substances from the same source should be allocated to different sectors.
According to the 2019 refinements the emissions from digested manure
should be allocated to 3.B. Moreover, the following is stated (vol 4, ch10,
row 1612), "CH4 emissions from co‐digestion of organic resources (cropresidues, food waste, energy crops) need to be reported under the source
category ‘3.B(a).5 – Co‐distestates’". I.e., not only emissions from digested
manure, but also from food waste etc, should be reported in 3.B.
On the other hand, in the waste chapter, biological treatment of solid
waste (2006 GL, vol5, ch 4) it is suggested that the emissions from”anaerobic digestion of organic waste, such as food waste, garden (yard)
and park waste and sludge” should be reported in the waste sector.
Finally, in the chapted about estimating emissions from manure
management systems, the EMEP/EEA Guidebook (2016 and the 2019draft) says, "Emissions from biogas facilities i.e. from during the storage ofslurry before anaerobic digestion and the storage of digestate after biogas
generation, are calculated and reported in Chapter 5B2. Hence, any
manures used as biogas feedstocks need to be subtracted before
calculating emissions from storage and application to land". W would like
Sweden1613 to see the problem with allocation solved in the final version.
There is still an inconsistent use of how B0 is written. Sometimes B0 and
Sweden1699 sometimes BO (i.e with a zero or the letter O).
Sweden1844 The footnote is missing
It is not clear to me which values the GL are referring to. Could be good toSweden2503 also include information on the exact table/paragraph
Emission factor for methane should also be based on the ration fed toanimals. For nitrous oxide emission, some consideration should be given
Saint Lucia
326 to the fixation of nitrogen when manure is deposited on soils.
Since in table 10.12 there is no "MY" but "EF_DMI" with a different unit
(gCH4 kg DMI‐1), please change the term "MY = methane yield, kg CH4 kg
Germany1291 DMI‐1 (Table 10.12)" accordingly.

Page 191

Responses

Accepted

Authors' notes

Text was included to better indicate where and how emissions
are reported among the different sectors from manure andcodigestates in the introduction to Section 10.4. all references
to the reporting of waste emissions in the Chapter 10 were
removed to avoid confusion and text was added to indicate
emissions from the combusion of biogas should be included in
the energy section.

Accepted
Accepted
Accepted

Noted

Accepted

It is not clear what the reviewer is requesting in terms ofspecific changes to the document, and we feel that these issues
are covered adequately in the methods proposed.

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Country

Table 10.14. Since the EFs are given in g CH4 PER kg VS, we see thefollowing logical problem. For example, we do not understand, why aslurry system that stores manure from "high productivity systems" shouldfeature an EF that is nearly twice as high as the EF for the same slurrysystem storing manure from "low productivity systems"? Differences in VS
excretion per animal might occur dependent on high or low productivity
systems, but we feel that EFs of identical manure storage systems related
Germany
1593 to VS (in the same climate zone) should be identical.

Responses

Rejected

For the most part, these emission factors have been developed
directly from the information in the 2006 guidelines, the B0
values for developing countries were used for the low
productivity systems and the developed countries for the highproductivity systems. The B0 value drives these differences. In
cases where we did not find information that could effectively
confirm or reject the values published in the 2006 guidelines
we maintained the existing values. It is the hope of the hope of
the panel that the presentation of Tier 1 emission factors on a g
CH4 per kg VS basis will encourage researchers will begin to
publish comparative measurements based on VS that will leadto significant improvements when there is an opportunity torevise the values again.

Rejected

The current manure management methodology is based on amodel that was developed for anaerobic digestion. It is the
position of the panel that the concept of using an anaerobic
digestion model is probably not appropriate for grazing
situations, where warm temperatures can dry dung pats andwet conditions can dilute the dung. Even so, we calculated MCF
based on the animal‐specific B0 values. The current results are
based on a compilation of experimental results and the results
showed no statistical difference between animal categories. A
similar non‐significant result was found for cattle and sheep EF
values. On this basis, it was decided that a single value for EF
and for B0 was appropriate.

1707

4

10

1742

1709

4

10

1791

From our point of view, it would provide a more consistent approach to
keep animal‐specific default Bo values for all MM systems. The animal‐
independent value suggested for the management system "grazing" does
not follow the current systematic approach (animal‐specific Bo, manure
management system specific MCF) in the guidelines and seems like a step
Germany
1750 backwards.
The citation referred to in Table 10.17, footnote 25 ("calculations basedon Haenel et. al (2018)") is missing in the reference list in the end of theGermany
1792 chapter. Please add.

1711

4

10

1988

1988 Please correct the numbering of "Equation 10.26A" to Equation 10.26.

Germany

Accepted

1713

4

10

2014

2014 Please correct the numbering of "Equation 10.26" to Equation 10.27.

Germany

Accepted

Page 192

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Authors' notes
The N intake is not in fact per year, it is per day and therefore
the 365 is required to be consisten tiwh the application of N
excretion in the emission factor equations. We have corrected
the unit for intake.

1715

1717

4

4

10

10

This comment has however identified an important
inconsistency that was futher resolved in this revision.
Equations 10.33 to 10.33E all calculated N retention in as aquantity and not a fraction (note that this issue existed alreadyin the IPCC 2006 Guidelines). Therefore, further calculations
were required in order to calculate an N retention fraction suchas is presented in Table 10.20 and would be applicable inEquation 10.31. We have resolved this issue by including an
additional equation, Equation 10.31A in which the N excretionis calculated based on the difference between intake andretention. Further, in the case of Swine, instructions areprovided to calculate daily N retention to make thesecalculations consistent with equations 10.31, 10.31A and10.32,10.32A

2157

Please correct Equation 10.31: If both terms Nex(t) and Nintake(t) arealready normalised over one ("kgN animal‐1 year‐1"), the multiplication
2163 with 365 is wrong.

2163

Footnote 4: The citation Rösemann (2017) is missing in the reference listin the end of the chapter. Please add. Besides that, without any further
clarification what approach is suggested by this reference, the footnote
will not help the reader, because the publication Rösemann (2017)consists of roughly 400 pages. Instead this publication, we suggest to cite
the current version of the methods description for the German
agricultural emission inventory (= Haenel et al. (2018)) and add therespective chapter numbers. We think the chapters 3.1.2.2.1 to 3.1.2.2.3
Germany
2163 contain helpful discussions.

1719

4

10

2357

1899

4

10

398

Germany

Accepted with
Modification

Accepted

Please clarify the following: "However, emissions factors and N transfers
should be corrected based on the time spent in each system…" and add
information for which time in the respective systems the default EFs inTable 10.21 have been designed. This will help inventory compilers to do
Accepted withGermany
Modification
2358 the correction.
Do cows have to be genetically improved to be ranked in the high‐prodsystems? I thought that Friesian‐Holsteins cattle used in Europe/UK are
not genetically improved, byut are definitely high producing. If the latter isUnited Kingdom (oftrue than cattle do not have to be genetically improved to be ranked in
Great Britain and Accepted withthe high‐prod systems. Please change accordingly. The same applies to
Northern Ireland) Modification
398 line 412.

Page 193

Changes were included in the footnote (current location offootnote page 10.84)
It is beyond the scope of this refinement to develop guidance
for all combinations of staged manure management, thoughcountries are encouraged to develop country‐specificmanagement specific emissions. We have developed a brief
text to state points that are important to consider in thedevelopment of these emission factors.

We have clarified that genetic improvement is occurring
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412

Regarding the text "Animals are genetically improved…" ‐ Do cows have tobe genetically improved to be ranked in the high‐prod systems? I thoughtthat Friesian‐Holsteins cattle used in Europe/UK are not genetically
United Kingdom (ofimproved, byut are definitely high producing. If the latter is true thanGreat Britain and Accepted withcattle do not have to be genetically improved to be ranked in the high‐Northern Ireland) Modification
412 prod systems. Please change accordingly

545

If you strive for international 'ease of understanding', please consider
545 changing the phrase 'draft animals' into 'work animals'.

United Kingdom (ofGreat Britain andNorthern Ireland) Rejected

The term was implemented in the 1996 GLs and has been usedalready for more than 20 years.

598 Please change 'range lands' into 'land used for grazing' for clarity.

United Kingdom (ofGreat Britain and Accepted with
Northern Ireland) Modification

A footnote was added specifying the notion of rangelands. The
important differentiation here is that these are lands that are
not being highly managed and improved for increased biomass
production and feed quality.

598

1907

4

10

735

735 The g in 'NEg' should be in subscript

United Kingdom (ofGreat Britain andNorthern Ireland) Accepted

1969

4

10

1267

1267 Equation 10.21 it is not updated

Uruguay

Accepted

1111
2455

Line 1111: "To select emission factors from Tables 10.10 and 10.11
identify the region most applicable to the country" but the information it
Uruguay
1122 is not presented by region in table 10.10
Uruguay2456 Please check the title of equation 10.34A

Accepted
Accepted

1971
1973

4
4

10
10

2767

4

10

1653

2769

4

10

2257

Table 10.13A: the VS for North America seems low, please verify the
Canada1653 source.
"In estimating N excretion by breeding sows (Equation 10.33B)…".
Equation 10.33B relates to N retention in growing pigs. Suggest to re‐word
to reference N retention (Eqn.10.33A) as part of the estimation of N
Canada2257 excretion (Eqn. 10.31)

2277

In Table 10.20B, the value for growers in the 40‐80 kg weight class is not
reproducible using the equation provided in the table. The equation
returns a range from 0.023 to 0.021 from 40kg to 80kg, respectively,
whereas 0.024 is listed in the table. The value for finishers seems high aswell ‐ the equation returns a range of 0.021 to 0.019 for animal weights ofCanada2278 80kg to 120kg, respectively, whereas 0.021 is listed in the table.

Accepted

2404
347"Nitrogen in manure is present both as organic nitrogen (Norg) andmineral nitrogen, called ‘Total Ammonia Cal Nitrogen’ (TAN)...." Suggest to
Canada2415 re‐word to account for nitrate in mineral nitrogen.
Mexico347 typographical error "sourcs" corrected "sources"

Accepted with
Modification
Accepted

2771

2773
2821

4

4
4

10

10
10

Authors' notes

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Noted

We have clarified that genetic improvement is occurring
through selective breeeding in these cases

The term was corrected
The heading for the equation was corrected. 'Updated' wasremoved.
Footnote 1 to table 10.10 specifies the regions that should beconsidered under the both systems (low and high). However,the footnote was replaced from Table heading directly low‐ andhigh productivity columns.
It is not clear what values are being questioned, for what
animal category. The sources of country specific values areeither those derived from the feed analysis for cattle, from the2006 Guidelines or from GLEAM. Note that values must be
taken in context with the default values provided in Table
10A.5

Accepted

A very valid comment. We also included data from otherresearch, such as Poulsen & Kristensen (1998) and FAO (2017).
That information has now been included in that Table.

Changed the wording slightly to say, of which the majority is
TAN

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Revised methane emissions factors and spatially distributed annual
4404 carbon fluxes for global livestock

2823

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4404

701

4

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189

703

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240

What is the meaning of the cross‐hatching is some of the boxes? (e.g.
190 Biomass Burning, Fossil Fuel Combustion)
Could there be more information on what is a dry or wet climate? What
243 countries or regions do these include?

248

Could there be more information on what is a dry or wet climate? What249 countries or regions do these include?

705

4

11

Responses

MexicoNoted

Authors' notes
The article noted has been reviewed, but is not citedspecifically in the document and therefore is not in thereference list. It is not clear what the reviewer is requesting asa modification.

New Zealand

Noted

Acknowledged but this box was not revised. This is out of scopewith approved table of contents by the IPCC plenary.

New Zealand

Accepted

A footnote was added to provide the definition of climate

New Zealand

Noted

Climate definition is provided in Table 11.1, section "Notes",
and also in a footnote that has been added in the paragraphabove the table discussion disggregation by climate type.
Unfortunately it is not possible to provide default values forevery single annual or perennial crops. We recommend using
the generic values or developing country‐specific estimates forthese crops.

New Zealand

Accepted

A footnote was added to provide the definition of climate

New Zealand

Noted

707

4

11

329

709

4

11

658

Could the text and tables in this section provide information on crop
residue emissions from crops such as apples, avocados, and grapes? Or
445 should these crops use the generic default values?
Could there be more information on what is a dry or wet climate? What659 countries or regions do these include?

711

4

11

206

Could this chapter provide guidance on estimating emissions using
225 geographic information systems (GIS) methodologies and data?

New Zealand

Rejected

Acknowledged but this is out of scope with approved table ofcontents by the IPCC plenary.

713

4

11

501

501 Expert opinion in place of expert advice?

New Zealand

Accepted with
Modification

We replaced "expert advice" by "expert judgement" to beconsistent with terminology in Volume I of this guidance.

Noted

The climate classification is based on Figure 3.A.5.1 in Chapter
3 of Vol. 4, and this reference has been added. Climate
definitions are provided in Table 11.1, section "Notes", and in afootnote in the paragraph above the table in the discussion
about disaggregating data by climate type.

987

4

11

248

In Table 11.1, it is suggested to add a source of referenced parameters ofChina
249 wet and dry climate, namely, Figure 10A.1, Chapter 10, Volume 4.

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On EQUATION 11.6
1．According to the report, the summation sign in the first equation
should be followed with a bracket to sum the latter two parentheses. That
isCountry

Responses

2．According to the unit of variables given in the present report, the units
on the left and right sides of the three equations of Formula 11.6 are not
identical: The left unit in the first equation is kgN yr‐1, while the right unit
is kgN ha‐1. The left unit in the second and third equations of the formula
is kg d.m. ha‐1, while the right unit is kg d.m.yr‐1.
3．The CropT and BGRT in the third equation are inconsistent with the
BGR(T) in the first equation and the Crop(T) in the second equation interms of presentation.

The equations were checked and corrected as per sugestions:
1) Brackets were added in the first equation; 2) The unit of AGR(T) and BGR(T) were changed to kg d.m. yr‐1 on lines 363 and371, respectively; and 3) BGRT and CropT were changed to
BGR(T) and Crop(T) in equation 3. 4) However, the combustion
factor was maintained as it is needed because 100% of theresidue does not necessarily combust in a fire. 5) Also, an
equation was added to estimate aboveground residue dry
matter, AGDM(T) on a kg per ha‐1 basis, and then added toCrop(T) to estimate BGR(T).

These problems are suggested to be modified as appropriate.
1) It is suggested that the expression of the first equation be checked.
2) The unit of AGR (T) in Line 363 be changed to kg d.m.yr‐1, while that of
BGR(T) in Line 371 be changed to kg d.m.yr‐1.
3) CropT and BGRT in Line 357 be changed to Crop(T) and BGR(T)respectively.

989

4

11

349

In addition, in line 354, it is not necessary to multiply the combustion
coefficient Cf when straw crops are used as fuel.
Since Frac Remove（T）+Frac Burn（T）+Frac Returning =1, it is381 suggested to replace 1‐Frac Remove（T）‐（Frac Burn（T）•Cf

Page 196

Authors' notes

China

Accepted with
Modification

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TolineComments

Country

In Table 11.3, the EF for NH3‐N + NOx‐N from urea is 0.15. In the
EMEP/EEA guidebook the corresponding EF for NH3‐N only is 0.20 (whenconverted from NH3 to NH3‐N). These two guidelines should preferebly
Sweden688 be consistent, or differences motivated, or commented.

Page 197

Responses

Noted

Authors' notes
EMEP guidelines do not guarantee constancy in time as the
EMEP/EEA air pollutant emission inventory guidebook is a living
document and, therefore it is subject to ongoing changes. The
latest version dates back from Nov 2016. In table 3.2 of crops
section of EMEP (2016) the NH3 EFs for different fertiliser types
and soil pH and temperature conditions are indicated (range forurea: 15.5‐21%).
https://www.eea.europa.eu/publications/emep‐eea‐guidebook‐2016?utm_medium=email&utm_campaign=EMEPEEA%20guid
ebook_CRM&utm_content=EMEPEEA%20guidebook_CRM+CID_dccb33f00685c6c9d615dcd46f004610&utm_source=EEA%20
Newsletter&utm_term=Read%20more
To support the updated methodology in the EMEP/EEA Air
Pollutant Emission Inventory Guidebook we were in contact
with some authors of this chapter, who indicated that they are
currently reviewing these values through re‐analysing the raw
data from Bouwman et al (2002) and Pan et al. (2016).
Unfortunately, the study has not yet been published nor
released and could not be used in this IPCC report. Instead, weanalyzed the same data from Bouwman et al. (2002) and Pan etal. (2016) (273 studies as indicated in Annex 11A.7) and opted
to use median instead of the mean value due to skewed
distribution to the right. Bouwman et al. (2002) obtained amean of 0.210 and a median of 0.140. Similarly, for Pan et al.
data median is also close to 0.14, which is lower than the rangeof values proposed by the latest EMEP guidelines (15.5‐21%).
Revised NH3 EF values in the EMEP/EEA Air Pollutant Emission
d b k
d ff f()dd

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Country

In Table 11.3 the EF for NH3‐N + NOx‐N from urea is 0.15. In the
EMEP/EEA guidebook the corresponding EF for NH3‐N only is 0.20 (whenconverted from NH3 to NH3‐N). The two guidelines should preferebly be
Sweden688 consistent.

The proposal from the previous version of distinguishing EFs fromsynthetic fertilizer and other inputs has been maintained. The requested
clarification from the previous review comments on differentiating EFs
from organic amendments has not been included. In reality much of the
manures (including slurries and digested manures) that are used inintensive agriculture have high contents of mineral N. The proposed EFs
for wet climates provided very large differences (0.006 for other N inputs
and 0.016 for synthetic fertilizers). In reality there will for liquid based
manures mostly be very little difference between EFs for these manures.
This is a problem for using these EFs in wet climates with intensive
EU
11 General comGeneral comagriculture.
Table 11.1, second column: Could you please clarify the calculations thatyield a value for EF1 aggregated of 0.010 (as found in Annex 11A.2). Our
calculation of the weighted mean of the disaggregated values for EF1
Germany
11
248
249 results in 0.012.
Please correct Footnote 14 by including a "not": "This term is included in
the equation to account for lower N release rates in grasslands that are
Germany
11377
377 NOT replanted annually…"

Page 198

Responses

Noted

Authors' notes
EMEP guidelines do not guarantee constancy in time as the
EMEP/EEA air pollutant emission inventory guidebook is a living
document and, therefore it is subject to ongoing changes. The
latest version dates back from Nov 2016. In table 3.2 of crops
section of EMEP (2016) the NH3 EFs for different fertiliser types
and soil pH and temperature conditions are indicated (range forurea: 15.5‐21%).
https://www.eea.europa.eu/publications/emep‐eea‐guidebook‐2016?utm_medium=email&utm_campaign=EMEPEEA%20guid
ebook_CRM&utm_content=EMEPEEA%20guidebook_CRM+CID_dccb33f00685c6c9d615dcd46f004610&utm_source=EEA%20
Newsletter&utm_term=Read%20more
To support the updated methodology in the EMEP/EEA Air
Pollutant Emission Inventory Guidebook we were in contact
with some authors of this chapter, who indicated that they are
currently reviewing these values through re‐analysing the raw
data from Bouwman et al (2002) and Pan et al. (2016).
Unfortunately, the study has not yet been published nor
released and could not be used in this IPCC report. Instead, weanalyzed the same data from Bouwman et al. (2002) and Pan etal. (2016) (273 studies as indicated in Annex 11A.7) and opted
to use median instead of the mean value due to skewed
distribution to the right. Bouwman et al. (2002) obtained amean of 0.210 and a median of 0.140. Similarly, for Pan et al.
data median is also close to 0.14, which is lower than the rangeof values proposed by the latest EMEP guidelines (15.5‐21%).
Revised NH3 EF values in the EMEP/EEA Air Pollutant Emission
d b k
d ff f
(
)d
d

Noted

Thank you for this important comment. The authors
acknowledge the potential difference in EF between liquid andsolid forms of organic fertilisers. However, there is insufficient
data to disaggregate the EF1 into liquid manure and solid/slurry
manure. This would therefore require development of country‐
specific Tier 2 values. The text was amended before Table 11.1.
The calculation of the aggregated EF1 was not based on aweighted mean. It was computed as the mean of 3000 values
generated by bootstrapping, as indicated on lines 1143‐1145 ofAnnex 11A.2

Accepted

This is correct and the text was amended.

Accepted with
Modification

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TolineComments

Country

Table A2‐2, last 3 columns: Our calculations applying weighted mean
(weighted with sample size) result in: [(509 * 0.016) + (110 * 0.006) +(200* 0.005) ] / ( 509 + 110 + 200) = 0.012. If another calculation method
was applied resulting in EF1 aggregated = 0.010, we suggest to mention it.
Germany1174 Otherwise we kindly ask to correct this value.
Table A4‐1: Calculation of disaggregated EF3PRP for cattle (wet): The
calculation method explained in lines 1236 and 1238 results in 0.0078 *0.66 + 0.0013 * 034 = 0.00559 for EF3PRP, which does not correspond to
the 0.005 for disaggregated EF3PRP for cattle (wet) displayed in Table
11.1 (page 11.11). Please correct EF3PRP for cattle (wet) or provide theGermany1238 description of the calculation method.
Please add the methodology applied to calculate the EFPRP for cattle andsheep and clarify that there are not disaggregated EF3PRP values forGermany1238 sheep displayed in Table 11.1 anymore.

1787

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363

1789

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371

It seems that the unit of AGR (T) is not "kg d.m. ha‐1" but "kg d.m.". In
addition, the equation (AGR(T) = Crop(T)* Slope(T) + (Intercept(T)*1000))in Table 11.2 needs to be revised by "AGR(T) = Crop(T)* Slope(T) +(Intercept(T)*1000)*Area(T)*Fracnew(T)" and the unit of AGR(T) needs tobe "kg d.m.". We suggest the unit and equation be checked and revised, if
Japan
364 necessary.
It seems that the unit of BGR (T) is not "kg d.m. ha‐1" but "kg d.m.". TheJapan
371 unit be checked and revised, as appropriate.

242

The phrase suggests that the disaggregation can be performed wheneither climatic or fertilizer type information is available. Based on the
Table 11.1 this could pose ambiguity when one part of the information isavailable. For example, if they know all of the N applied is organic without
the climate information, disaggregated values may not be useful. Thus,
Canada243 the statement should say “activity data by climate and fertilizer type”.

1217

The uncertain range is extremely small for this parameter. I believe thatthe use of bootstrapping for this is underestimating the uncertainty.
Bootstrapping attempts to reproduce the standard error of the
population. As note in Volume 1 Chapter 3 on uncertainty, there arecircumstances when the standard error should be used and there aretimes when the standard deviation should be used to define the uncertain
bounds. In this case, it should be the standard deviation as this is a simple
sample of the emission factors. The use of bootstrapping and therefore
the development of standard error estimate underestimates theuncertainty as it would apply to a country that is applying that emission
factor in their inventory. For the other EFs, though the range is not nearlyas small as EF3, it should be clarified how the uncertain range were
derived and assure that the approach used is consistent with the guidance
Canada1219 in Volume 1 Chapter 3.

2775

2777

4

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Responses

Noted

Accepted

Authors' notes

The calculation of the aggregated EF1 was not based on aweighted mean. It was computed as the mean of 3000 values
generated by bootstrapping, as indicated on lines 1143‐1145 ofAnnex 11A.2

Accepted

The EF3PRP for cattle (wet) has been corrcted to 0.006
Text has been added to Annex 11A.4 to clarify the methodology
and that there are no disaggregated sheep excreta EF3PRP
values.

Accepted with
Modification

The unit was corrected to kg d.m. y‐1 . However, given changes
to estimate aboveground residue dry matter in Equation 11.6
based comment 989, it was not necessary to change thecalculation in Table 11.2 to estimate kg dm. The multiplier of1000 in the equation given in Table 11.2 was removed
following these checks because it was not needed.

Accepted

The unit for BGR (T) was corrected as kg d.m. yr‐1.

AcceptedThank you for the suggestion, this is correct and the text wasamended as suggested.

Accepted

For consistency with guidance in Vol. 1 Chapter 3, theconfidence interval of the aggregated EF1 was recomputed
using the standard deviation of the mean. This led to a slighlylarger confidence interval. Formerly the low and highuncertainty values had been assigned the 2.5th and 97.5th
percentiles of the dataset generated by bootstrapping; they
were not based on the standard error. The updated confidence
interval of [0.001; 0.018] seems reasonable in comparison withthe uncertainty of [0.003; 0.03] in the 2006 guidelines, given
the much larger dataset used for producing the EF1. The
uncertainty ranges for EF3 have been revised by adopting themethod outlined in Vol1 Chapter 3. This has resulted in a larger
range of EF3 values that are more representative of thepotential range of mean values that could be determined byindividual countries.

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TolineComments
Country
Suggested to rephrase “Field measurement data with chemical N
application as well as studies with a focus on mitigation technologies,
such as nitrification inhibitors or urease inhibitors were excluded from thisCanada1337 analysis”
Table 11.1. The revised factors properly represent the accumulated
evidence published since the 2006 guidelines were derived. In particular,
the disaggregated factors make sense and are defensible based on resultsfrom field studies. The revised uncertainty ranges are also reasonable andconsistent with observations. The only concern is the lower bound of therange being negative for EF1 in the disaggregation of 'All N inputs in dry
climates'. This seems counter‐intuitive because it implies that as N inputs United States ofAmerica
249 increase N2O could decrease.
It would be useful to add some general elements to the introduction todefine HWPs (see Lines 340 and 341: The term “harvested wood
products” is based on a concept consisting of the two separate elementsof “forest harvesting” and “wood products” (Brown et al. 1998; UNFCCC
2003).) and to clarify that carbon captured and stored in solid chemicals
or gases is excluded (see Lines 1498‐1499).

4

12

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268

Accepted
Rejected

The text was rephrased as per suggestion.

Thank you for noting this and we found that this was an error.
The lower bound of the range is zero and not ‐0.001, its higher
bound is 0.0011 and not 0.0012 and the sample size is 207
instead of 200; as indicated in TABLE A2‐2 ‐ Disaggregation by
rainfall for Dry climates in the final order draft.
We have not made the change suggested to include further
discussion of the concept of HWP “up front”. Although we
agree that the points referred to are very important, they are
only certain points amongst many that have such importance,
and we feel it is inappropriate to give these specific points
undue profile over others. For the sake of clarity, we feel weshould stick to presenting all aspects following the carefully
developed chapter structure, We note that the text has beenclearly identified by the review where it currently in Section
12,4,1.1 and this gives us some reassurance that the points areclearly expressed. We have responded to the request to clarify
where biomass‐derived gases and chemicals are included but
not in the way envisaged by the comment. We added text to
Section 12.4.1.1 to specify that harvested wood biomass
carbon captured and stored in the form of solid chemicals orgases is excluded is in fact excluded from HWP.

Accepted with
Modification

On the subject of the reporting of emissions in the AFOLU and
Energy sectors, we have added some text and a cross‐reference
to Section 12.5. On the subject of the possibilities for double‐
counting or non‐counting of emissions depending on theselection of approaches by countries, relevant text is alreadyincluded in in the penultimate paragraph of Section 12.3.2.

Noted

Noted.

France218
The sentence about double counting and/or non‐counting when different
countries are using different approaches should be kept: this is very
relevant information that countries should keep in mind as they
implement or improve their reporting system on HWPs.

333

Accepted

Authors' notes

France99
This section should also highlight that the different approaches used for
HWPs have implications for the calculation and reporting of emissions andremovals in the AFOLU sector and the Energy sector (see Lines 1546‐1548)
and that there are issues of double counting or omissions when countries
are using different approaches (see Lines 265‐269).

331

Responses

France269

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TolineComments
We welcome the use of the wording "assumption of steady‐state HWPpool" which is a more appropriate and less confusing than the previous
wording "instant oxidation assumption" used in previous IPCC guidance(see lines 513‐515). We suggest that the differences between the two be
briefly explained here (with a reference to section 12.4.1.2 lines 505‐522.)
and to write that the new wording should be preferred now.

Country

4

12

662

4

12

983

4

12

992

4

12

1230

Rejected

Emission factors (i.e. half‐life or service life) information on the
duration of the use of wood in use in relevant markets is
independent from any information relevant for estimating
above ground biomass and vice versa. Wood density ofprocessed wood (i.e. wood commodities as covered bystatistics) on the other hand (relating to activity data notemission factors) do NOT relate to standing timber /above
ground biomass in forests – especially not in the case ofcomposites, such as wood‐based panels (consisting of different
feedstocks incl. glue and additives).

Rejected

To our understanding, there are no widely‐applicable
alternative sources of relevant information, presented
according to an internationally consistent defined standard.
The international standards provided by ISO are an acceptedsource of information which has already been referred to inprevious IPCC guidance (IPCC 2006 GL Vol 2 or KP Supplement).
To our understanding, the development of alternative methods
would also incur costs and the deployment of resources.

Rejected

It would be inappropriate for us to provide the requested
information because this could be interpreted as the guidance“taking a view” on the relative merits of selecting amongst thevarious approaches, which is still under discussion by SBSTA,
hence being prescriptive about the choice of approach.
However, we would note that the information in Table 12.5
could be rearranged easily by a reader, to find out therequested information.

France992
Table 12.5 is useful and should be kept. Would it be possible to specify theconsequences in terms of double counting and omission resulting fromthe use of different approaches by different countries? (see Lines 265‐
269).

343

We have modified the text discussing Equation 12.5 in the lightof the comment. This includes explaining what the twocomponents are, immediately after mentioning them.

France983
It may seem unappropriate to base IPCC guidelines on a private and fee‐based access standard (ISO). Would it be possible to consider an open andfree‐access alternative, ideally from UN statistics or database?

341

Accepted

France663
Please consider the opportunity to add some further developments on theconsistency to be ensured between country‐specific emission factors for
HWPs and other parameters used in Tier 2 methods to estimate
aboveground biomasses (see section 2.3.1.3 of Chapter 2, Volume 4). In
particular, it could be expected to some extent that consistency should beensured regarding the use of wood densities to estimate change in above‐
ground biomass carbon stock and HWPs carbon stock.

339

Authors' notes
We have included a brief clarification in a footnote and haveadded to the discussion in Section 12.4.1.2.

France276
We suggest improving the clarity of this sentence by explicitly giving thetwo components of Equation 12.5 to which reference is made.

337

Responses
Accepted with
Modification

France1237

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1552

TolineComments
Specify that 44/12 is the fraction resulting from the molar masses of CO2
and C, and useful to switch from a measurement in tC to a measurementin teqCO2.

Country

4

12

1

4

12

1

4

12

170

The direct use of roundwood or logs in end‐uses is covered by
the commodity class “other industrial roundwood” as part of“industrial roundwood”. The use of these datasets is coveredby Tier 3 methods as explained in Section 12.4.1.1. Please notethat the commodity class "industrial roundwood" excludes e.g.
telephone poles; the use of such datasets representing end‐
uses requires country‐specific information on end‐uses andmethods, i.e. not to be combined with default FOD‐function).
We have amended Section 12.4.1.1 by adding the definition of“other industrial roundwood” to the list of definitions provided.
We have also referred to “roundwood used directly in theconstruction of buildings” in the preceding discussion of the
difficulties in using data on other industrial roundwood in
conjunction with Tier 1 and Tier 2 methods.

Rejected

We agree that it would be useful to provide standard
calculation worksheets. However, experience from developingthe 2006 GL suggests that is a major undertaking andunfortunately there was insufficient capacity and time for thiswork as part of this refinement. Please note that the authors
provide a calculation example on how to implement the FOD
default method (i.e. Equations 12.2 and 12.4) in Box 12.1.

Rejected

The text referred to in the comment is explaining a generalprinciple about the important purpose behind the definition of
approaches. It does not offer any view on whether the available
defined approaches actually lead to double‐counting or non‐counting of emissions. The text simply explains that one of the
purposes of defining approaches is to avoid these sorts ofoutcomes.

Russian Federation

1719
There is no possibilities for "non‐counting of emissions and removals"
with various Approaches. Only double‐counting is possible. Please, delete"non‐counting".

501

Accepted with
Modification

Russian Federation

1719
Would be useful to develop excel calculation sheet for HWPs as well as it
is done e.g. for Tier 2 Steady State Method499

Authors' notes
A cross‐reference has been added to “Vol. 4 Ch. 2 Section
2.2.3”. The application of this conversion factor is not unique to
HWP and relevant text is included in Chapter 2 of the Volume
4, IPCC 2006 GL: “The conversion to CO2 from C, is based on
the ratio of molecular weights (44/12). The change of sign (‐) isdue to the convention that increases in C stocks, i.e. positive (+)
stock changes, represent a removal (or ‘negative’ emission)from the atmosphere, while decreases in C stocks, i.e. negative(‐) stock changes, represent a positive emission to theatmosphere.”France1552
Chapter 12 considers only semi‐finished wood products (sawnwood,
wood‐based panels and paper& paperboard) as Harvested Wood Products. However, Roundwood is often used in some countries for constriction ofbuildings, private houses and that is the best option for long‐lived carbon
storage in HWPs. Unfortunately a such option is not considered within thechapter 12 at all. Please, add some guidance of estimation of such HWPs,
how to avoid double‐counting etc.

497

Responses
Accepted with
Modification

Russian Federation

170

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1580

TolineComments
Recommend removing the Rüter‐sourced figures and rely on the box‐and‐arrow diagrams, and remove the qualifications around their accuracy inlines 1569 & 1604. Alternatively, it could be qualified that the element ofconcern in the Rüter‐sourced figures represent carbon capture andstorage technology which may be developed in the future, but it not yet inuse. However, this could require a more extensive discussion of carbon
capture and storage / negative emissions technologies in the context of
HWP methods which we believe is outside the scope of this review

Country

4

12

1252

2781

2783

4

4

4

12

12

12

265

139

164

Rejected

The proposed inclusion of this point would be consideredprescriptive. The guidance cannot prescribe how countries
decide to report CO2 emissions for information purposes.

Noted

Noted.

Accepted

The text has been amended as recommended in the comment.

Accepted

The text has been amended as recommended in the comment.

Australia

1252
Comment: The statement here is commendable and represents feedback
from a number of parties. It does a very good job at ensuring parties areunder no illusion about the international comparability of estimates under
differing system boundaries, but without prejudicing the decision‐making
processes in other fora.

1213

Authors' notes
A note has been added to each of the figures in question, to
explain that the vertical ‐/+ arrows appearing at the top of eachdiagram show where additions, deductions or transfers ofcarbon are involved in a given approach. This clarifies that the
diagrams do not represent carbon capture and storage
technology. The authors decided to maintain the presentationof the figures, including the illustration of the functionality ofpresented default methods. The first set of figures illustrates
how the approaches are meant to be implemented by means of
the presented default method. The second set of figures (i.e.
box‐and‐arrow diagrams) have been included to further clarify
differences in the relevant system boundaries.

Australia

1583
Recommend including a qualifying statement on Good Practice andtransparency related to emissions of any imported biomass for
combustion which lie outside the scope of a country's national emissions:"Where a consuming country is directly combusting harvested woodbiomass which has been imported from another country, it is still goodpractice to identify and report the emissions arising from this activity forwhich the producing country would be responsible"

1211

Responses
Accepted with
Modification

Australia
The 2006 IPCC Guidelines actually provides two examples of approaches
that, conceptually, involve tracking carbon or CO2 fluxes (atmosphericflow and simple decay), not just one as indicated here. To correctly referto the 2006 IPCC Guidelines, the text should refer to "examples" rather
Canada143 than "example".
For clarity, suggest the following: "An “approach” includes a conceptual
framework for the estimation of CO2 emissions and removals (see interalia Brown et al. 1998; UNFCCC 2003; Cowie et al. 2006). An approach also
defines the particular system boundary referred to when calculating
quantities of carbon entering, retained in and lost from the HWP pool."
Canada167
269

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VolumeChapter

4

12Fromline

206

TolineComments
Line 100 states that this chapter maintains the existing approaches
covered in the 2006 IPCC Guidelines: in doing so, this chapter should seek
to build on the existing approved guidance in the 2006 IPCC Guidelines
and should be careful to not ignore or misrepresent that guidance. The
2006 GL includes the simple decay approach, and this approach should be
represented accurately. A more accurate text is "Approaches identified in
the 2006 IPCC Guidelines are the ‘stock‐change’, ‘production’,‘atmospheric‐flow’ and 'simple decay' approaches. As explained below,
these approaches have differences in terms of their conceptual
frameworks and the system boundaries employed for calculations(Section 12.2)."

Country

4

12

206

4

12

209

Accepted with
Modification

The text in the relevant section and also in Annex 12.A has
been amended extensively following very careful review andreconsideration of this subject. The ‘simple‐decay’ approach is
discussed more fully, and the point (and spirit) requested to beaddressed in this comment has been covered, although thewording is different, mainly for the sake of clarity.

Accepted with
Modification

The text in the relevant section and also in Annex 12.A has
been amended extensively following very careful review andreconsideration of this subject. The ‘simple‐decay’ approach is
discussed more fully, and the point (and spirit) requested to beaddressed in this comment has been covered, although thewording is different, mainly for the sake of clarity.

Canada215
This text misrepresents the 2006 IPCC Guidelines on the subject of thesimple decay approach, and our previous comments on this point havenot been adequately addressed. The 2006 GL clearly states that the simple
decay approach does not have the same conceptual framework as the
production approach, in the sense that "conceptual framework" isdescribed in section 12.3.1 as either 1) changes in carbon stocks within
defined HWP pools or 2) actual CO2 fluxes to and from the atmosphere.
Specifically, the 2006 GL (volume 4, page 12.30) states: "The Simple Decay
Approach differs from Production Approach in that HWP pool isconsidered to be related to activities in the forest and hence does notassume instant oxidation of wood in the year of harvest." The text should
be changed to read: "In this guidance, the 'simple decay' approach istreated as having the same system boundary as the production approach
but a conceptual framework that focusses on quantifying actual CO2
fluxes, applied in conjunction with a country‐specific calculation method.
Further discussion of country‐specific methods is presented in Section
12.4.4 on Tier 3 methods. Detailed information about the 'stock‐change','production' and 'atmospheric‐flow' approaches are provided in Annex
12.A."

2789

Authors' notes
The text has been amended to read: “The 2006 IPCC Guidelines
considered four approaches known as the ‘stock‐change’,‘production’ ‘atmospheric‐flow’ and ‘simple‐decay’approaches”.

Canada208
Even though the 'simple decay' approach is similar to the 'production'
approach in term of the system boundary, there is a fundamental
difference clearly noted in the 2006 IPCC Guidelines that should be noted
as well in this 2019 refinement. This is the difference as noted in the 2006
guidelines: "The Simple Decay Approach differs from Production Approachin that HWP pool is considered to be related to activities in the forest andhence does not assume instant oxidation of wood in the year of harvest.".
This text should be maintained in this refinement and should be added tothe text in this paragraph.

2787

Responses
Accepted with
Modification

Canada2015

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VolumeChapter

4

12Fromline

212

TolineComments
While the simple‐decay approach is a variant of the production approach,
it is important to distinguish why it exists. As the simple‐decay variant
estimates a release of carbon to the environment after the useful life of
the product it is more easily compatible with the gains‐loss approach,rather than the stock change approach of forest reporting. I agree thatthe authors don't need go into a great deal of detail throughout the
document to provide specific guidance about simple‐decay, but clear
indications of where it differs and when it is applicable should be included
when the Production approach is being discussed.

Country

4

12

227

4

12

240

2799

4
4

12
12

The text in the relevant section and also in Annex 12.A has
been amended extensively. The ‘simple‐decay’ approach is
discussed more fully, and the point requested to be addressedin this comment has been addressed.

Accepted

Accepted with
Modification

The word has been deleted as requested. Please also note thatthe discussion of the ‘simple‐decay’ approach has been revisedand extended.
The text has been amended as requested, but with somedifferences in wording, mainly for the sake of clarity.

Accepted

The word “three” has been deleted as requested.

Canada240This guidance should seek to build on existing approved guidance in the2006 IPCC Guidelines and should be careful to not ignore or misrepresent
that guidance. The 2006 GL discuss the boundaries of the simple decay
approach and explains how the boundaries of the approaches compare(see volume 4, page 12:30). Add the following paragraph after theparagraph on the atmospheric flow approach: "The ‘simple decay’approach estimates fluxes of CO2 from and to the atmosphere from HWP
from wood harvested in a country. In other words, when applying the‘simple decay’ approach the producing country reports fluxes from HWP
produced by that country, regardless of where the HWP are consumed
and used." As well, clarity would provided by adding the previously
agreed sentence in the 2006 GL that explains the relationship among the
HWP approaches and their boundaries: "Just as the Production Approachdiffers from the Stock‐Change Approach (for the production approach all
stock changes are accounted for and reported by the producer and for the
Stock‐Change Approach all stock changes are reported by the country
where they occur) the Simple Decay Approach (SDA) is similarly related to
the Atmospheric Flow Approach (for the Simple Decay Approach all CO2
release is reported by the country where the HWP was harvested and for
the Atmospheric Flow Approach all CO2 release is reported by the country
where the release occurs)."

2797

Accepted with
Modification

Canada229
Given that there is also a simple decay approach, remove the word
"three".

2795

Authors' notes
The text in the relevant section and also in Annex 12.A has
been amended extensively following very careful review andreconsideration of this subject. The ‘simple‐decay’ approach is
discussed more fully, and the point (and spirit) requested to beaddressed in this comment has been covered.

Canada215
According to the 2006 IPCC Guidelines, the simple decay approach has thesame conceptual framework as the atmospheric flow approach (seevolume 4, page 12.30).

2793

Responses
Accepted with
Modification

259

260

Canada265

Given that there is also a simple decay approach, remove the word
265 "three".

CanadaPage 205

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2801
2803

2805

VolumeChapter

4
4

4

12
12

12

Fromline

474
637

1242

TolineComments
The definition of the feedstock "Recovered Paper" should note thepotential risk of double counting when using this feedstock anddepending on the estimation approach, given that the material included inthis commodity may have been already counted under wood pulp. A
recommendation should be given to the inventory compiler to exercise
caution when considering this type of post‐processing material.

Country

4

12

1295

Authors' notes“Recovered paper” is not “counted” under “Wood Pulp” as it isa different commodity class used as a feedstock. The
estimation (i.e. presented default method) does not track andtrace carbon molecules, but estimates the input
volumes/masses of different feedstock categories into the
manufacturing process of commodity classes, which enter the
HWP carbon pool, such as “paper and paperboard” (i.e. at thelevel of paper mills). The amount of feedstock commodity inthe commodity classes “Recovered paper” + “Wood pulp”
never exceed 100% (see Equation 12.7). If country‐specificmethods (not “approaches”) are used (i.e. other than Equation
12.7), the risk of double‐counting is not exclusive to thecommodity class of “Recovered paper”.

Accepted

The cross‐reference has been amended to refer to Equation
2.2.
The paragraph has been rewritten in the light of the commentand now reads, “The CO2 emissions from burning ‘unutilized
wood harvest residues’ without energy recovery, generated aspart of harvesting, are included as a component of the CO2
emissions and removals estimated for forests and other wood
producing land categories and are reported by the producing
country”.

Canada482
This line should refer to Equation 12.2 (where the k decay constant is
637 actually used and explained) instead of Equation 12.3
Depending on the method tier/approach used and on the AD available,
emissions from biomass burnt on harvesting sites may be included in"Biomass burning", therefore we suggest to add the text "or as part ofbiomass burning emissions" after the text "harvesting sites"

CanadaAccepted with
Modification

Canada1242
The statement given in these lines implies that if a country estimates CO2
emissions from burning woody biomass for information purposes in the
Energy sector (consistently with the non‐CO2 emissions estimated andreported by the consuming country in this sector) and also estimates andreports CO2 emissions from burning woody biomass in the AFOLU sector
following a specific approach chosen by the country, these two estimates
may not be consistent between themselves depending on the approachand estimation method used by the reporting country for AFOLU. Suggest
to note this potential inconsistency in this paragraph.

2807

Responses
Rejected

Accepted

Canada1298

Page 206

A statement along the lines suggested by the comment has
been added.

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CommentID

2809

VolumeChapter

4

12Fromline

1509

TolineComments
Line 100 states that this chapter maintains the existing approaches
covered in the 2006 IPCC Guidelines: this chapter should seek to build on
the existing approved guidance in the 2006 IPCC Guidelines and should be
careful to not ignore or misrepresent that guidance. The 2006 GL includes
the simple decay approach, and this approach should be represented
accurately. It is incorrect to say that specific guidance on implementationof the simple decay approach was not given in the 2006 IPCC Guidelines.
Guidance was provided on the approach in the 2006 GL: see volume 4,
page 12.30 and page 12.24 which explain which HWP variable to use forthe approach, with the calculation of the variable explained earlier in thechapter. Replace this paragraph with: "The 2006 IPCC Guidelines defined
how to calculate emissions and removals of CO2 associated with HWP forthe ‘stock‐change’ approach, ‘production’ approach, ‘atmospheric flow’
approach and ‘simple decay’ approach. A detailed supporting description
is provided in this annex for the first three. The ‘simple‐decay’ approach isalso maintained in this updated guidance by recognizing it as having asystem boundary like that of the production approach but using a
conceptual framework based on identifying and quantifying actual CO2
fluxes to the atmosphere, in combination with a specific (essentially Tier3) calculation method. The general guidance on Tier 3 methods in themain chapter (Section 12.4.4) may be referred to.”Country

4

12

1528

2815

2817

4

4

4

12

12

12

1539

1567

1602

Accepted with
Modification

The text in Annex 12.A has been amended extensively following
very careful review and reconsideration of this subject. The‘simple‐decay’ approach is discussed more fully, and the point(and spirit) requested to be addressed in this comment has
been covered.
The text in Annex 12.A has been amended extensively following
very careful review and reconsideration of this subject. The‘simple‐decay’ approach is discussed more fully, and the point(and spirit) requested to be addressed in this comment has
been covered.
The sentence that caused confusion about the ‘box‐and‐arrow’
diagram has been deleted.

Canada1529
To reflect the simple decay approach, say "(i.e. atmospheric flow andsimple decay approaches)"

2813

Authors' notes
The text in Annex 12.A has been amended extensively following
very careful review and reconsideration of this subject. The‘simple‐decay’ approach is discussed more fully, and the point(and spirit) requested to be addressed in this comment has
been covered, although the wording is different, mainly for thesake of clarity.

Canada1520
Include simple decay approach.

2811

Responses
Accepted with
Modification

CanadaThe box‐and‐arrow diagram looks conceptually complete and accurate. If
not, then it should be explained how it is not complete or entirely
accurate, or the diagram should be modified to make it complete andCanada1570 accurate.
The box‐and‐arrow diagram looks conceptually complete and accurate. If
not, then it should be explained how it is not complete or entirely
accurate, or the diagram should be modified to make it complete andaccurate. Figure 12.A.3 is not completely clear: the HWP C‐pool in use
should indicate it is from domestically harvested wood.
Canada1605

Accepted with
Modification

1539

Page 207

Accepted with
Modification

Accepted with
Modification

The sentence that caused this confusion regarding the box andarrow diagram has been deleted. Figure 12.A.3 is retained.
Having evaluated Figure 12.A.3, the authors confirm that itcorrectly reflects that the timber originates from forest within
the reporting country borders.

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CommentID

2819

VolumeChapter

4

12Fromline

1528

TolineComments
The box‐and‐arrow diagram looks conceptually complete and accurate. If
not, then it should be explained how it is not complete or entirely
accurate, or the diagram should be modified to make it complete andaccurate. Figure 12.A.5 is quite confusing ‐ why not simply show theapproach based on its actual conceptual framework as opposed to trying
to mix the conceptual framework with methods for estimation involving
carbon stocks? Or at least start with a figure that shows the conceptual
framework so that it is clearer what the approach is meant to do.

Country

3577

3579

3581

4

4

4

4

12

12

12

12

640

103

Authors' notes
The sentence that caused confusion about the ‘box‐and‐arrow’
diagram has been deleted. Figure 12.A.5 is retained. Having
evaluated Figure 12.A.5, the authors decided to maintain thepresentation of the figures, including the illustration of thefunctionality of presented default methods. The figure
illustrates how the atmospheric‐flow approach is meant to be
implemented by means of the presented default method. The
objective of the guidelines is to provide practical guidance on
how to implement the approaches by means of method – notto only present concepts. The figures thus complement eachother.

Accepted with
Modification

We have added a footnote to Box 12.1 to explain that thecalculation of the carbon stock change in year t does not
require fore‐knowledge of Ct+1, because of the formulation of
Equation 12.2. However, the specifics of the comment appear
to be based on a misunderstanding. The spreadsheet
calculation example in Box 12.1 has been thoroughly checked
and appears to comform exactly with Equation 12.2. The stockchange year (i) is calculated as the carbon stock in year (i+1)
minus the carbon stock in year (i), i.e. cell D8=cell C9‐cell C8.

Accepted

The sentence referred to has been deleted.

Rejected

We agree that it would be useful to provide standard
calculation worksheets. However, experience from developingthe 2006 GL suggests that this is a major undertaking andunfortunately there was insufficient capacity and time for thiswork as part of this refinement. Please note that the authors
provide a calculation example on how to implement the FOD
default method (i.e. Equations 12.2 and 12.4) in Box 12.1.

Accepted

We agree that the meaning of this sentence was unclear. The
paragraph has been re‐written to clarify the meaning.

Canada1529
Box 12.1 MS Excel equations for stock change values are wrong; forexample, C9‐C8 should be C8‐C7 while carbon stock change = Ct+1 ‐ Ct

2911

Responses
Accepted with
Modification

Hungary
The encouragement to use the refinement, as opposed to the 2006 GL,
seems inconsistent with the approach taken in every other chapter, andUnited States ofappears to suggest that Chapter 12 be treated differently than other
America
103 chapters. Suggest deleting this sentenceHas a new HWP calculation worksheet been made available as part of therefinement? If not, the inability to use the 2006 worksheet may be a real
challenge for some countries.
646

United States ofAmerica

105

106

244

Lines 244‐246 state that under all approaches changes in carbon stock arereported by the "producing country." Lines 247‐249 state that under astock‐change approach carbon stock changes are reported by the"consuming country." Similarly, Lines 256‐269 explain that emissions andremovals from HWP are reported by the "consuming country." Please
United States ofclarify these apparently contradictory statements.
America
259

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3583

3843

3845

VolumeChapter

4

4

4

12

12

12

12

Fromline

1205

333

333

3847

4

975

1731

4 Annexes

3077

3849

4 Annexes

1590

651

4 Cover page1

TolineComments
It is good that this section has this basic statement on the reporting of
biomass used for energy. However, it is not detailed or strong enough tocover this crucial point which is very often misunderstood and/or
misconstrued (e.g., when people use this construct as a basis todetermine biomass emissions as neutral. Specifically, this paragraphshould also include additional text that puts more emphasis on how thisreporting practice (of assigning the biogenic emissions associated withbiomass use for energy to AFOLU) ONLY works whenassessing/inventorying emissions across all or at least both the AFOLU andenergy sectors. It should also assert that when looking at individual
sectors (e.g., assessing energy sector without also assessing AFOLU), thisreporting method for assigning biogenic CO2 emissions to AFOLU does nothold because the biogenic CO2 contribution from AFOLU‐based biomass
combustion/conversion is not accounted for. It is imperative that theseimportant disctinctions be made to eliminate further confusion on how
the IPCC views biogenic CO2 emissions.

Country

Responses
Accepted with
Modification

Authors' notes
We have added an additional sentence which goes some way
to addressing the spirit of this request. However, it should be
noted that the primary purpose of GHG inventories is fornational GHG reporting and not, for example, for the purposesof assessing the impacts of current or future policies (e.g. withregard to bioenergy). Other types of assessment and tools are
more appropriate for this purpose.

Accepted

Text has been added to the relevant box in the decision tree togive consistency.

Rejected

FAOSTAT provides generic data for many countries, while acountry specific data source will permit a country to make amore detailed or refined calculation. Therefore, availability of
FAOSTAT activity data does not imply the availability of country‐
specific data. The supporting discussion of Step 3 in Section
12.4.1 refers the reader to Sections 12.4.1.1 and 12.4.3 where
detailed guidance and explanation is given.

Accepted with
Modification

The text has been amended to explain that it is highly desirable
for data sources to be publicly available and that confidential
data sources are likely to be unsuitable for use unless they canbe shared for the purposes of transparency and verification.

United States ofAmerica

1208

Figure 12.1: Minor: It would be helpful for the inexperienced user if thetext in the step 3 box mirrored the text line 316 (emission factors vs. half‐
Norway333 lives).
Figure 12.1, step 3 box: When a country has FAOSTAT activity data for thethree HWP default categories Yes is the intuitive answer here. Pleaseconsider to revise/add one more choise (box) to reflect the data needed
as mentioned in 12.4.3 (i.e. data on sub‐categories is needed).

NorwayThe use of HS categories only provide the Tier 2 data on import andexport. It would be very helpful with guidance on how Tier 2 activity dataon national production could be collected for sub‐classes of the threedefault HWP commodity classes since the data might be scattered and/or
kept confidential. Please spesify if e.g. annual national surveys could be
Norway982 accepted.
We suggest to replace the reference to "Rösemann et al. 2017" byGermany3078 "Haenel et al. 2018".
333

Norway1590 Annex 3A.5: "2" in N2O needs to be put in subscript (two accounts).
General editorial comment on all chapters in Volume 4: Emissions andremovals are referred to inconsistently across the chapters ‐ e.g. Chapter
1 and Chapter 4 refer only to "emissions and removals", Chapter 2 refers
to "emissions and removals" and "emissions/removals (E/R)", Chapter 3
and Chapter 12 refers to "emissions and removals" and"emissions/removals", Chapter 7 refers to "emissions and removals" andNew Zealand
1 "emissions (removals)".

Page 209

Accepted

Changes were included in the footnote (current location offootnote page 10.84)

Accepted

Text edits made as requested.

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103

67

VolumeChapter

Fromline

4 Cover page1

TolineComments
Country
General editorial comment on all chapters in Volume 4: when "it is goodpractice" is stated sometimes it is italicised and sometimes not, so pleasecheck for consistency throughout volume. We do find it useful to italicise
New Zealand
1 this material.

Responses

Noted

4 General

Comment on Volume 4, AFOLU: We have expressed before our concernswith respect to the references to the 2013 supplement on wetlands inrelation to organic soils. As Government department and as inventory
compilers, we want this 2019 refinement to be adopted by the COP
and/or CMA as mandatory basis for the elaboration of GHG inventories
under the UNFCCC. 2013 supplement is only for voluntary use,governments didn't manage to adopt it as mandatory for the elaborationof GHG inventories under the Convention, and we fear that the references
to the supplement in the refinement could jeopardize the adoption of the2019 refinement under UNFCCC as methodological guidance to be used
for inventories in the future. Therefore, we suggest to delete thosereferences, or replace every reference with a neutral language: "2006 GLs
on organic soils were complemented by 2013 supplement on Wetlands.
This document does not preempt which of these guidance are to be
used."
Spain

Rejected

General
4 Comment

The IPCC guidance has to be developed in a simplified way to enable allcountries to estimate their corresponding ghg emissions taking into
account shortage of data and national capacities and expertise
Meanwhile, the way the guidelines is developed is somehow written indifficult way to be understandable in some parts (particularly AFOLU), so
it needs to be taken into account more simplifying the GL language infuture refinements

Noted

Page 210

Egypt

Authors' notes

Organic soils and wetlands in general were out of scope forrefinement, with the exception of flooded lands. The 2013
Wetlands Supplement provides the latest guidance associatedwith wetlands, which has been reviewed and approved by the
IPCC plenary. The decision about using this guidance fornational inventory reporting is made in the UNFCCC. This
refinement just points to the latest guidance on wetlands,
which has been approved by the IPCC process and is available
for reference.

The acttion is outside the scope of the agreed refinements
listed in the ToR. To be further considered by IPCC

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VolumeChapter

Fromline

TolineComments
No refinement was foreseen for Chapter 1, therefore no comments can beprovided in the form. However, there are substantive and significant new
texts that need revision.

Country

Responses

Authors' notes

The sentence in lines 111‐112, should make it clear that the mixing ofanthropogenic and natural causes (which cannot be consistently
separated) is the reason behind the use of the MLP. The following
sentence:"In the AFOLU sector, the application of the Managed Land Proxy (MLP)
means that IAV can be caused by both anthropogenic and natural causes."should be revised as:"In the AFOLU sector, the managed land proxy (MLP) is used because
emissions and removals, including their IAV, are caused by bothanthropogenic and natural causes, which cannot be consistently
disaggregated."

1515

4 General Comment

In line 112, "The two largest causes" should read "The three largest
causes".
In line 114, "and" should be deleted before (2)In line 116, "The third cause" should be a continuation of the previous list,
as "respiration, and (3) the variation in the rate...".
EU

Text has been revised to make reference to 3 main causes of
IAV.
Accepted with
Modification

No refinement was foreseen for Chapter 1, therefore no comments can beprovided in the form. However, there are substantive and significant new
texts that need revision.

1517

4 General Comment

Lines 118‐124 should be deleted or should address inter‐annual variability
only, without making assertions about the disaggregation of causes.
"disaggregating MLP emissions and removals into human and naturaleffects" would be desirable, but it is currently not possible, and no
guidance is provided for that. The guidance in Chapter 4 under IAV does
not provide sufficient guidance to identify causes of variability.
EU

Page 211

The reason why MLP is used was already explained in previous
paragraphs

Text has been revised to clarify that is referring to "interannual
variability in emissions and removals due to natural
disturbance".

Accepted with
Modification

In addition, additional text was introduced in Section 1.4 tobetter explain the guidance provided, including its limitation:"The reason that the Guidelines have limited the disaggregation
to E/R from ND is because scientific methods to quantify all‐natural effects are currently not available"

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VolumeChapter

Fromline

TolineComments

Country

Responses

Authors' notes

No refinement was foreseen for Chapter 1, therefore no comments can beprovided in the form. However, there are substantive and significant new
texts that need revision.
Lines 130‐132 should be deleted or should be rewritten as follows:"Optional guidance that may be used by countries that choose to
disaggregate AFOLU emissions and removals into those that areconsidered to be linked to irregular extreme events beyond the control of
the country from other, more regular effects."

1519

4 General Comment

This is because the term "natural disturbance" does not necessarily imply
non‐anthropogenic origins (e.g., most forest fires, both on managed andunmanaged land, are ignited by humans and many major disturbances on
managed land are materially inlfuenced by management), and because
the guidance does not disaggregate "natural disturbances" (from otheremissions and removals on managed land), but major (exceptional)
disturbances from smaller ones, irrespective of causality.
EU

Rejected

The guidance is not limited to " irregular extreme events
beyond the control of the country from other, more regulareffects."

No refinement was foreseen for Chapter 1, therefore no comments can beprovided in the form. However, there are substantive and significant new
texts that need revision.
The sentence in lines 405‐407 should be deleted or revised as follows:"In addition, Chapter 2 provides an optional guidance that may be used bycountries that choose to disaggregate AFOLU emissions and removals into
those that are considered to be linked to irregular extreme events beyond
the control of the country from other, more regular effects."

1521

4 General Comment

This is because the term "natural disturbance" does not necessarily imply
non‐anthropogenic origins (e.g., most forest fires, both on managed andunmanaged land, are ignited by humans and many major disturbances on
managed land are materially inlfuenced by management), and because
the guidance does not disaggregate "natural disturbances" (from otheremissions and removals on managed land), but major (exceptional)
disturbances from smaller ones, irrespective of causality.
EU

Page 212

The guidance is not limited to " irregular extreme events
beyond the control of the country from other, more regulareffects."
Accepted with
Modification

Nevertheless, additional text was introduced in Section 1.4 tobetter explain the guidance provided.

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CommentID99

Volume5

Chapter2

Fromline

TolineComments
For Table 2A.1 page 2.15: Municipal
Solid Waste (MSW) Generation andManagement Data, we propose to use Singapore’s total waste generation
data which includes industrial and commercial waste as MSW data. We
suggest that the IPCC use the following data instead:‐Country

1) Year 2000 Population, 4.03 million, according to Singstats.
2) Year 2000 Total waste generated, 4.64 million tonnes, from Data.gov.sg
3) Year 2000 Total waste landfilled, 0.36 million tonnes, from Data.gov.sg4) MSW Generation Rate Values (tonnes/cap/year) for Year 2000: 1.15
(i.e., 4.64 divided by 4.03)
5) Fraction of MSW disposed to SWDS for Year 2000: 0.08 (i.e., 0.36
divided by 4.64)
6) Year 2010 Population, 5.08 million, according to Singstats7) Year 2010, Annual Report of EPD, Page 63, Table 20, Amount of non‐incinerable waste directly landfilled at Semakau Landfill.
8) Year 2010 Total waste generated, 6.52 million tonnes, from Data.gov.sg
9) Year 2010 Total waste recycled, 3.76 million tonnes, from Data.gov.sg10) Year 2010 Total non‐incinerable waste landfilled, 0.17 million tonnes,
from Data.gov.sg11) Year 2010 Total incinerable waste, 2.59 million tonnes, from
Data.gov.sg12) Composting = 013) MSW Generation Rate Values (tonnes/cap/year) for Year 2010: 1.28
(i.e., 6.52 divided by 5.08)
14) Fraction of MSW disposed to SWDS (Open dumped) for Year 2010: 0
15) Fraction of MSW disposed to SWDS (Disposed to landfills) for Year
2010: 0.03 (i.e., 0.17 divided by 6.52)
16) Fraction of MSW incinerated for Year 2010: 0.40 (i.e., 2.59 divided by Singapore

Page 213

Responses

Authors' notes

Accepted withmodification

We thank for data provision from Singapore. Waste
generation rate, and fraction of MSW treated including
disposal to open dumping, landfill, incineration and other havebeen updated for the year 2010. However, values in the year
2000 is the data from 2006 IPCC Guidelines, therefore there is
no change. In addition, in case that country has their own
specific value, country may consider to use as appropriate.

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Composition, we propose to use the2016 waste composition which can be found in the 14th Annual Report ofEnvironmental Protection Division (EPD) of the National Environment
Agency (NEA) ‐ Page 42, Table 7.1, "Types and Amounts of Waste
Disposed of and Recycled in 2016"

Country

Responses

Authors' notes

2

1) Food waste: 0.10 (i.e., 791,000 divided by 7,814,200) ‐ based on "Foodwaste" as stated in EPD‐NEA Report2) Garden (yard) and park waste: 0.04 (i.e., 320,500 divided by 7,814,200) ‐based on "Horticultural Waste" as stated in EPD‐NEA Report
3) Paper and cardboard: 0.15 (i.e., 1,183,100 divided by 7,814,200) ‐based on "Paper/Cardboard" as stated in EPD‐NEA Report
4) Wood: 0.07 (i.e., 530,700 divided by 7,814,200) ‐ based on"Wood/Timber" as stated in EPD‐NEA Report
5) Textiles: 0.02 (i.e., 150,700 divided by 7,814,200) ‐ based on"Textile/Leather" as stated in EPD‐NEA Report6) Nappies (disposable diapers): ‐ (Not available)
7) Rubber and leather: 0.004 (i.e., 32,700 divided by 7,814,200) ‐ based on"Scrap Tyres" as stated in EPD‐NEA Report
8) Plastics: 0.11 (i.e., 822,200 divided by 7,814,200) ‐ based on "Plastics"
as stated in EPD‐NEA Report9) Metal: 0.19 (i.e., (1,357,500 + 97,200) divided by 7,814,200) ‐ based on"Ferrous Metal" and "Non‐ferrous Metals" as stated in EPD‐NEA Report10) Glass (and pottery and china): 0.009 (i.e., 72,300 divided by
7,814,200) ‐ based on "Glass" as stated in EPD‐NEA Report11) Other: 0.31 (the rest including "Construction and demolition waste","Used slag", "Ash & Sludge", "Others (includes stones, ceramics & rubber"as stated in EPD‐NEA Report)
Singapore

Accepted withmodification

We thank Singapore for the updated information and we
considered its reliability. Correction in Table 2A2 has been done
to include the addition of reference. Changes are based on
calculation of values in the provided reference.

Noted

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5

2

1

525

The set of default data (generation rate, MSW composition, management
data…) has been improved a lot : more recent data are provided (allowing
an evolution along the time series), more detailed data (much moreparties are documented). Moreover, open dumps are now considered in
the default data (management data). On the basis of this new set of data
concerning MSW, all parties should be able to identify data adapted totheir national circumstances or to check the national data.
More information is provided concerning sludge.
France

571

5

2

234

237

Tables 2.4 and 2.5 are missed in the new version.

Russian Federation Noted

Page 214

We thank reviewer for kind comment.
No action can be taken because comment is out of scope of2019 Refinement.

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1219

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Australia

Accepted withmodification

Referring to provided reference ‐ National Waste Report
workbook on 'other national data' ‐ waste composition ofAustralia in Table @2A.2 has been changed.

Uruguay

Rejected

Reference provided is of April 2019 which is after the literature
cut off date of 25 June 2018 for the 2019 Refinement

Noted

No action can be taken because comment is out of scope of2019 Refinement.

Rejected

We thank for the additional reference suggestion. However,this paper is published on 15 December 2018 which is after theliterature cut off date of 25 June 2018 for the IPCC 2019
Refinement. Therefore, it is unfortunate that we can not
combine this reference in the IPCC 2019 Refinement.

Noted

Reference has already been in the FD.

Accepted

Reference has been added.

Rejected

We thank for the additional reference suggestion. However,this paper is published on 15 December 2018 which is after theliterature cut off date of 25 June 2018 for the IPCC 2019
Refinement. Therefore, it is unfortunate that we can not
combine this reference in the IPCC 2019 Refinement.

484

3

363

Recommend incorporating two papers published since the second reviewof the Guidelines. The papers have suggested new DOCf factors for woodand wood products.
Australia
Recommend including two additional references: Less decomposable
wastes include tree branches and harvested wood products such as sawn
and engineered wood materials.
Australia
Recommend including one additional reference: The biodegradation yieldof the waste component under anaerobic condition varies greatly
depending on the material type, ranging from minimal yield for wood andwood products
Australia

Recommend including one additional reference: Meanwhile, biogenic
carbon conversion of paper products varies greatly (21% to 96%)
depending on the type of paper.

Page 215

Authors' notes

Rejected(All Tables) Recommend reviewing data relating to Australia, including
zero waste composted and composition of MSW containing zero plastic
and metals. Would suggest that both AU and NZ data is reviewed. The
data presented for waste generation in Australia and New Zealand are notaccurate. Better numbers, at least for Australia (which is 80% of Australia
and New Zealand) are: MSW generation 0.57 t/person; fraction open
dumped 0; fraction to landfill 0.58; fraction incinerated 0; fraction
composted 0.21; fraction to other 0.21.
Australia

A new type of SWDS has been added in the 2019 Refinement: active‐
aeration. The practice of implementation of active aeration of solid waste
disposal site (SWDS) is very limited (Appendix 3A.2, chapter 3, Volume 5).
On the other hand, the case of "bioreactors" is still not consideredalthough it may correspond to an important part of SWDS in some Parties,
such as France.
France5

Responses

We thank for your comments. Table 2A.1 showed the waste
generation and management data in the year 2000 (from 2006
IPCC Guidelines) and in the year 2010. The values are in thesame year for every countries with the aims to be consistentand comparable among countries and regions. We havechecked the reference of Australia National Waste report 2016,
table 12 (provided for comment 1229) and found that thevalue in 2010‐2011 is 0.61 t/capita which is in line with our
proposal in the refinement. In addition, National Greenhouseand Energy reporting ( measurement) Determination wascompiled on 1 July 2018 and registered on 25 July 2018 whichis after the cut off date (25 June 2018).

290

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1221

Country(All tables) Recommend considering data relating to Australia for inert
waste fractions that can be derived from the national waste report
workbook ('other national data'): metals 0.03; plastics 0.12; glass 0.04.
MSW Generation and Management Data (Table 2A1) presented for
Uruguay is not correct. The correct values are (SOURCE: MVOTMA):
Generation rate 0,35 ton/cap.year; MSW disposed in SWDS 82 %; Open
dump: 0% ; Other managment:18 % (includes compost, recycling andothers)294288Comments

Australia

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Recommend including one additional reference and new text as follows toreflect more recent literature: "For the engineered wood products, theDOCf was low for key product types such as particle board, medium‐
density fiber board and plywood, ranging from 0.7‐1.6% (Wang et al 2011;
Ximenes et al 2018a). There is some evidence that bamboo products may
decay to a greater extent in landfills than engineered wood products, witha suggested carbon conversion of 11.3 % (Ximenes et al 2018a)"
Australia

Waste categories are not defined and do not seem to match with those of
the Basel Convention. Hence some questions: do industrial waste include
partially or totally hazardous waste? Category "fossil liquid waste"
appears in table 5.2, but is not mentionned in lignes 71‐72.We suggest
adding definitions of each waste categories refered to in the guidance.
FranceResponses

Rejected

We thank for the additional reference suggestion. However,this paper is published on 15 December 2018 which is after theliterature cut off date of 25 June 2018 for the IPCC 2019
Refinement. Therefore, it is unfortunate that we can not
combine this reference in the IPCC 2019 Refinement.

Rejected

The 2006 IPCC Guidelines have defined waste goes into
incineration include MSW, Industrial wate, harzadous waste
and sewage sludge. Detail of each categories are explained inchapter 2 section 2.2.3 for industrial waste, section 2.2.4 forhazardous waste and clinical waste. The 2006 IPCC Guidelines
focused on some hazardous wastes that are incinerated andcan contribute to the fossil CO2 emissions from incineration
which is do not match with Basel convention. Both contents inline 71‐72 and table 5.2 on fossil liquid waste is originally in the2006 IPCC Guidelines and is out of scope of the refinement.

The phrase "sludge produced in primary treatment is not accounted for inthis category" is confusing ‐ because it can be considered that such sludge
is not contain BOD (according to the Table 6.6a(new) it is not true) so we
don't need to include it into the calculations. Also there is no clear
explanation where sludge produced in primary treatment should be
accounted. For example, such sludge can be composted or incinerated on‐site and then relevant emissions should be included in the wastewater
treatment sector.
Russian Federation Accepted
It should be better to move phrase "Some sludge is incinerated before
land disposal." (line 185) after the words " and drying." (line 182). Also
better to add "digestion" after words "Land disposal, composting, " (line182) because this process also considered in the Chapter 4 together withAccepted withthe compostion.
Russian Federation modification

509

5

6

189

200

511

5

6

195

196

It should be clear explained how to distinguish on‐site and off‐site sludge
Accepted withtreatment or to write that the final decision is on experts.
Russian Federation modification
Arrows and lines for "Wastewater" and "Sludge" flows are not clearly
distinguished from each other when printed.
Russian Federation Accepted196

It should be better to change words "reported" to "considered" in theboxes "Incineration", "Composting", "Landfilling", and "Land application"
because emissions from these processes can be reported in the Chapter 6
or relevant chapters depending on offsite or onsite sludge treatment.
Russian Federation Rejected

513

5

6

195

Page 216

Authors' notes

The text in quotes has been removed from the text. Primary
treatment sludge was considered in the development of theemission factors, and the text has been clarfied to say thatemissions from sludge, other than from the anaerobic digestionof sludge at WWT plants, is reported in other sections ofVolume 4 and 5.
The sentence was moved to improve the text, but the word
digestion was not added because emissions from anaerobic
sludge digestion at wastewater treatment plants must be
considered in Chapter 6.
Additional text has been added to specify that only anaerobic
digestion of sludge at wastewater treatment plants should bereported under this chapter. In addition, the terms onsite andoffsite were reviewed and removed when unnecessary.
Further differentiation of lines was incorporated.
Emissions from incineration, composting, landfilling, and land
application are not to be reported in Chapter 6; therefore, nochange to the figure was made. Further text revisions weremade to improve the clarity of this reporting, and confirm that
only emissions from anaerobic digestion of sludge at
wastewater treatment plants should be considered andreported in Chapter 6.

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Comments

Country

Responses

Probably worth adding explanation about biogenic CO2 emissions fromsludge anaerobic treatment (from gas recovery) and incineration as such
emissions should be included in the inventory (NIR) (as information items
if they are in the Energy sector).
Russian Federation Rejected

As explained in Volume 1, Section 1.1, CO2 emissions ofbiogenic origin are not included in Waste sector since any net
changes in carbon stock of biogenic origin is covered in the
AFOLU sector. CO2 emissions from biomass combustion sources
are reported in the Energy sector as a memo item.

It was commented in the previous expert review round in
response to comment number 6218 that for MCF there is noneed to distinguish factors between "well managed" and "notwell managed" plants; indeed an explanation was provided forthis refinement in the Final Draft on line 231‐234 and again online 520‐524 (i.e. "If country‐specific data are available todifferentiate whether systems are overloaded or not wellmanaged, these situations should be reflected in thecalculation of TOW (for inflow overload) or Smass (for systems
that are not well managed and therefore not achieving the
expected removal of sludge"). We consider the literature data
insufficient to be able to accurately distinguish the emissions
profiles of "well managed" and "not well managed" plants.

See response to comment 509.

517

5

6

253

256

The 2006 IPCC Guidelines previously provided different emission factors
for “well managed” and “not well managed” centralised aerobic
treatment systems not only because the quantity of organic in the systembut on the idea that in the "not well managed" system anaerobic
conditions may be formed (in places). Please consider a possibility tomaintain the disaggregation among “well managed” and “not wellmanaged”.
Russian Federation Rejected

519

5

6

303

324

Please add some explanation how to distinguish on‐site and off‐site
sludge treatment or to write that the final decision is on experts.

521

5

6

326

339

523

5

6

334

335

525

527

5

5

6

6

344

385

Authors' notes

Accepted with
Russian Federation modification

Information in the Table 2.4A (new) for sludge DOC content in fraction canlead to mistakes, because despite DOC data in the Equation 3.7 (Volume 5
Chapter 3) is in fraction, similar information in the Tables 2.4 and 2.5(Volume 5 Chapter 2) is given as percentages. Also other data in the Table
2.4A (new) are given as percentages. Please harmonize it if possible.
Russian Federation Accepted
Please add "compostion" after the words "incineration, landfills," (line
Accepted with
335).
Russian Federation modification

356

More clear explanation that component R in the Equation 6.1(updated)refers only to CH4 recovery from anaerobic processes, different fromsludge digestion (methantanks), is needed. Also, more direct reference tomethodology for estimation emissions from methane combustion for
Accepted withenergy generation can be useful (Volume 2 Chapter 2 Sludge Gas).
Russian Federation modification

386

Please consider adding calculating emissions from other onsite sludge
treatment processes as another step.

Page 217

Russian Federation Rejected

We agree with comment. Fraction of DOC in Table 2.4a arechanged to percent as suggested.
We have added the word "composting."

R refers to all CH4 methane recovered from wastewaterWW
treatment, such as methane captured on filters exhausted fromcovered (anaerobic) treatment ponds, as well as CH4 recoveredfrom or anaerobic sludge digestion. The approach to estimationof emissions from wastewater WW treatment in this chapter
covers all emission sources and sinks (recovery) on‐site ofat awastewater treatment WWT plant. This includes the commonlyused flaring or combustion of biogas generated from sludge
stabilisation but also methane captured on filters exhausted
from covered (anaerobic) treatment ponds.
Emissions from other sludge treatment processes are
considered as negligible and were not changed during work on
this refinement.

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Authors' notes442

It should be noted, that despite correct, the Equation 6.1 (updated) can be
confusing then calculating, because in proposed steps this equation ismore suitable to estimate only emissions from treated wastewater, notfrom discharge pathways. It is especially evident as in the Equation
6.1A(new) there are two special components to calculate emissions fromwastewater effluent discharged to environments. Additional explanations
or text reorganization may be useful.).
Russian Federation Accepted

The fact that CH4 emissions from both discharge pathways andtreatment systems have to be considered in the inventory has
been emphasised in the document. In particular a list oftreatment systems and discharge pathways has been added in
the text before Equation 6.1 (UPDATE).

423

It can be useful to add explanation about checking in calculations that
TOW input (both as a whole and at the every one considered wastewater
treatment system) should be consistent across the wastewater pathways
and at the end with TOW output to the environments taking into accountorganics removal including loss to sludge and biological decomposition.
Russian Federation Rejected

TOW input and TOW output do not have to be equal, and infact won't be equal due to conversion of TOW into CH4 and into
CO2 and other NMVOC. The information on how to estimate
TOW is provided in Section 6.2.2.3 ‐ Choice of Activity Data,
including an example of application.

444

Units for CH4 emissions in the Equation 6.1A(new) (and others equations)in kg can be a reason for mistakes, because the final emissions data for
NIR should be in Gg (kilotons). Please, check these units again.
Russian Federation Accepted

Equation 6.1A(New) has been modified to result in final
emissions in Gg.

455

There are two special components to calculate emissions fromwastewater effluent discharged to aquatic environments in the Equation
6.1A(new). It is noted, that wastewater effluent discharged to (wet) soil is
excluded from the equation despite the same origin and produced
methane emissions (see Table 6.3 (updated)). Please, add such emissions
Accepted withas additional coponent of the equation or explain why it is omitted.
Russian Federation modification

A simpler version of Equation 6.1A (NEW) is now proposed
which is simply the sum of methane emissons from alldischarge pathways and treatment systems. Some additional
discussion has been added to the text before Equation 6.1(updated) to note that this equation has to be applied to alltypes of discharge (discharge to reservoirs, lakes and estuaries;
discharge other than to reservoirs, lakes and estuaries; anddischarge to sewers) which includes discharge of treated anddischarge of untreated wastewater.

455

If TOWEFFtreat is only for discharged treated wastewater effluent thanuntreated wastewater effluent is missed despite it also can be discard to
Accepted withdifferent environment (as %Tiers 1 and 1A). Please consider the possibility
to add untreated wastewater effluent or clearly explain how it is included. Russian Federation modification

Untreated wastewater effluent should use TOW, since noremoval of organics happens before discharge. We have added
an explanation in Equation 6.3A to clarify this.

455

The components %Tier 1 and 1A in the Equation 6.1A(new) can be
confused with the component FWTk from the Equation 6.3D(new). Also it
is a source of mistakes if experts already have used FWTk for wastewater
treatments systems, differentiated by discharged wasterwater effluents
Accepted withreceiver types. Please add some explanations and quidance.
Russian Federation modification

In response to comments, the components of % Tier 1 and 1A
have been removed.

455

Please consider reorganizing Equation 6.1A(new), for example, as a sum ofemissions from water discharge to the environment, untreated system,and treated system (according to the Table 6.3(updated)) with additional
equation espeсially for emissions from discharged wastewater effluents. Russian Federation Rejected

Please see response to comment 535. There is no reason to
propose two separate equations for dischage pathways and fortreatment systems as the equation 6.1 (updated) can beapplied to both cases and, moreover, there is no need to report
separately discharge and treatment emissions.

Page 218

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Comments
Country
Responses
The 2006 IPCC Guidelines previously provided different emission factors
for “well managed” and “not well managed” centralised aerobic
treatment systems not only because the quantity of organic in the systembut on the idea that in the "not well managed" system anaerobic
conditions may be formed (in places). Please consider a possibility tomaintain the disaggregation among “well managed” and “not wellmanaged”.
Russian Federation Rejected
In the Table 6.3(updated) type of pathway "Discharge other than toreservoirs, lakes, and estuaries" could be better to change to "Discharge
to other aquatic environments than to reservoirs, lakes, and estuaries" (ormake a according remark) because now it can be a reason for confusion
with discharge to soil.
Russian Federation Accepted544

In the Table 6.3(updated) type of pathway "Discharge to soil" (wetclimate) wasn't marked as particular tier, as were marked pathways"Discharge other than to reservoirs, lakes, and estuaries" and "Discharge
to reservoirs, lakes, and estuaries". It would be better marked as Tier 2
and added to the Equation 6.1A (new).

546

There is some inconsistence between information about discharge to soil
and septic tank with land dispersal field. According to the Table 6.3
discharge to soil is a source of CH4 in wet climate, whereas for septic tankindicated that negligible emissions come from land dispersal field. Also
this situation arose same question for latrines, that often have land
Accepted withdispersal field. Please check for any inconsistencies.
Russian Federation modification

See response to comment 547.

594

It can be useful to add information, that these T data is referred only tothe first stage of wastewater treatment or discharge (for example,
discharge to the sea after aerobic plant do not take into account).

Russian Federation Accepted

A footnote has been added to the example.

610

It should be noted, that despite additional guidance on how to estimate
organic component removed as sludge, there is no correlation between
BOD and DOC in sludge in the Chapter 6 and Chapter 2 (Volume 5), so it
prevent from making consistent calculation for sludge emissions acrossthe sector. Additional explanations on this issue may be useful.

Accepted with
Russian Federation modification

There is no correlation between BOD removed from waste
water and DOC in sludge, as this varies depending on thewastewater treatment process and on the subsequent
treatment of the sludge. Volume 5 Chapter 2 (Section 2.3.2
Sludge) provides guidance on estimating DOC of sludge.

Yes, the TOWREM data reflect the chain of treatment processes,
and the table text was modified to reflect this.

The text has been updated.

547

549

551

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Russian Federation modification

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664

665

It looks like TOWrem default data for secondary and tertiary treatments in
the Table 6.6b are not for separate processes but for a chain of them(from primary to tertiary). Please make an additional verification or/add
explanation, because they can be considered as different wastewater
treatment types in calculations so separate data may be needed.
Russian Federation Accepted

557

5

6

608

610

According to the Equation 6.3b(new) and Table 6.6A (new) it would bebetter to change "per ton" to "per kilograms" (at the end of the line 609). Russian Federation Accepted

Page 219

Authors' notes

See response to comment 517.

Changed to 'aquatic environments'.

We determined that wastewater discharge to soil was out of
the scope of the Chapter 6 refinement and have removed the
MCF from the table. Associated emissions from wastewater orsludge applied to soil should be considered under Volume 4.

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BOD, or biochemical oxygen demand, is not the mass of organic
constituents in the sludge. Rather it is a value that describes thestrength of the waste (literally by estimating the amount ofoxygen microorganisms require to metabolise the organic
material). Essentially it is a proxy indicator of the quality (ororganic content) of the waste, but it is not a direct massmeasurement of the organic content. Just as the mass ofoxygen in carbon dioxide is greater than the mass of carbon, it
is feasible for the BOD of a carbon‐containing molecule toexceed 1 when the molecule is metabolised to carbon dioxide.

559

561

5

5

6

6

621

648

629

652

563

5

6

650

660

565

5

6

650

665

In the text and in the Table 6.6A(new) there are Krem factors that are
more than 1 (more than 1 kg of BOD in one kg of sludge). It is not clear
how it is possible. Please make an additional verification or/add
explanation.

Russian Federation Rejected

The titale of Equation 6.3D(new) is "Total organics in the treateddomestic wastewater effluent" as the text above it indicated that it is "fordischarges of wastewater from treated or untreated systems". In our view
this equation should be better marked for both type of system andAccepted withindicator TOWEFFtreat renamed.
Russian Federation modification
The component FWTk is referred to the Table 6.5, but it is for T (DEGREE
OF UTILISATION OF TREATMENT, DISCHARGE PATHWAY OR METHOD FOR
EACH INCOME GROUP, is depend on U), also used in the Equation 6.3A
(new). The situation is the same for treatment types k and j. Are theydifferent from each other? Additional explanation or correction is needed. Russian Federation Accepted
It would be useful to add default TOW rem for discharges of wastewaterfrom untreated systems. It can be 0 in most cases, but according to theTable 6.3 for stagnat sewers (they emit CH4, see table 6.3), this data canbe different.
Russian Federation Accepted

Page 220

The Krem values indicate how measured BOD changes for atonne of sludge during different levels of treatment. So a valueof 0.5 means that the value of the BOD measurement of thetreated waste has reduced by 0.5 kg of oxygen consumed(which is a surrogate for organic content) compared to theuntreated waste. Data usually available for inventory compilers
concerning sludge removed is usually expressed in mass.
Equation 6.3B (new) is provided in order to convert into kg of
BOD removed as sludge at all stages of the process (Saerobic)
as necessary for the application of Equation 6.1 (updated).
The authors agree with your remark concerning theinconsistency between the text line 648 and the title of theequation (i is a mistake). However, the equation does
correspond to the estimation of TOW effluent from treatedwastewater. Therefore the text above the equation should be"For discharge of treated wastewater, inventory compilers
should […]" and will be corrected in the final version.

We have removed the use of FWTk and k throughout thechapter and have more directly tied these parameters to T andj.

A line has been added to the table with a zero default.

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There is no explanation in the text what is biological decomposition.
Please, add some explanatory information.
Please make an additional verification for the TOWrem to the "Latrines‐
regular sediment removal for for fertilizer. In or view with regularremoving of sludge TOWrem should be higher.
General: the guidance on WWT is clearly improved with regards to moredetailed and complete guidance, including more disaggregatedparameters and EFs. The guidance also defines tiers for the estimation.
However, guidance for methods, AD and parameters to use does not
apply the tier structure and is therefore unclear. Please improve thestructure, taking into account the tiers defined.

6

Russian Federation Rejected

FinlandAccepted

Additional discussion and guidance has been added to clarify
the tier structure.

Accepted withmodification

Please see response to comment 535.

Rejected

Please see response to comment 541.

Accepted

Additional modifications were made to Figures 6.2 and 6.3 tomore closely align with the set up in Figure 6.4. Please notethat the underlying rationales and tier structures for CH4(morphological) and N2O (trophic condition) are different, so it
does not make sense to make these figures match exactly.

Accepted

Additional modifications were made to Figures 6.2 and 6.3 tomore closely align with the set up in Figure 6.4. Please notethat the underlying rationales and tier structures for CH4(morphological) and N2O (trophic condition) are different, so it
does not make sense to make these figures match exactly.

Rejected

The activity data for methane emissions should not be the BOD
load to the plant, as the MCFs and emission factors weredeveloped using the activity data specified in the chapter.
Regarding values for well and poorly operating treatment
plants, see response to comment 517.

Russian Federation Rejected

1129

5

6

441

443

1131

5

6

371

481

368

Please modify Figure 3. 6.2. (to resemble Fig. 6.4) so that even whenmethane emissions from domestic wastewater are a key category, steps
to indicate the need to estimate the emissions from discharges towaterways are included in the decision tree.

725

Please modify Figure 6.3 (to resemble Fig. 6.6) so that even whenmethane emissions from industrial wastewater are a key category, steps
to indicate the need to estimate the emissions from discharges towaterways are included in the decision tree.

439

Activity data for methane emissions should be the BOD load to plants
without sludge removals. As major part of methane is formed in sewers
the removed sludges have no effect on that. Please consider giving values
for well and poorly operating treatment plants in Table 6.6B (for thosecountries without measured emission data on discharges loads).
Finland

1135

1137

5

5

5

6

6

6

368

725

424

Page 221

Authors' notes
The only reference to this term in the document is in definitionof parameter TOW_REM in line 663. This is a straightforward
term (i.e. "wastewater organics decomposition that occurs
through biological means, either aerobically or anaerobically")
and some basic background knowledge is assumed for thosereading the document. It is impractical to define every suchterm used herein, especially those used only once.
This row has been removed from Table 6.6B(New) and Table
6.3(Updated). Emissions from sludge applied to agriculturalland is reported in Volume 4.

The equations 6.1 (updated) and 6.1 (new) are to be used to estimate theCH4 emissions from WWT. How these equations should be applied needmore explanations, e.g. with regards to eq. 6.1 it would be good tosummarize where the guidance for estimating emissions from sludge
removed can be found. In relation to 6.1 (new) the link to eq. 6.1(updated) should be clarified, e.g. to avoid double counting of emissions.
Also how the default for parameter % Tier 1 and % Tier 1a have been
Finlandderived should be explained.
It would be much better if the guidelines distinguished emissions fromtreatment and discharge clearly from each other and e.g. do not refer totreatment/discharge pathways.
Finland1133

Responses

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CommentID

VolumeChapter

Fromline

TolineComments

Country

1139

5

6

289

289

Discharge emissions should not be limited to primary treated discharges.
Evidently, discharge emissions should be calculated also from secondaryor tertiary treated wastewaters (Equation 6.3D and Table 6.6B).
Finland

1141

5

6

720

720

Figure 6.1 should be Figure 6.3

719

Chapter 6.2.3 Industrial wastewater is incomplete. Equation 6.6 does notexist. Also, there is no equations for wastewater discharge (Figure 6.3 andTable 6.8 indicate that there should be equations). The Worksheets for
Finlandindustrial wastewater are incomplete, also. Please correct.

1143

1145

5

5

6

6

718

298

298

FinlandPlease add seas and oceans to the text (line 298) and to Tables 6.3 and6.8.

Finland

1147

5

6

902

902

1149
1151

5
5

6
6

1013
1002

1015
1002

There is only one default EF for centralised, aerobic treatment plant. Is
this valid for all those plants (in second‐order draft there were two default
values)? Please check and justify.
FinlandPlease add a default EF for industrial wastewater plants or indicate what
to use in case there is no default EF to give.
Finlanddomestic should be industrial.
Finland490

Dishcarged BOD values are even lower for "new" processes such as the
MBR process. It usually generates discharged concentrations of BOD < 2
mg/L. This is also common in well managed conventional activated sludge
processes. A comment stating that really low BOD values (<2 mg/L) are
not that uncommon in well managed modern plants would seem to beneeded here.
Sweden

1313

5

6

490

1315

5

6

371

371

1317

5

6

976

976

1319

5

6

612

612

he numbering of the steps is confusing: should all steps 1, 1A AND 1B be
conducted, or can 1A and/or 1B be skipped if step 1 is conducted? It isdifficult to distinguish here the difference between a step with only a
number (eg. Step 1) and a step with both a number and a letter (eg. 1A).
This would be good to clarify.
SwedenPlease specify if NREM always be taken from Table 6.17, even if morecountry specific data is available?
SwedenSome of the values in the table 6.5 are close to 20 years old. An update
would seem to be called for, with more up‐dated figures.
SwedenPage 222

Responses

Authors' notes

Accepted

Rejected

The word "primary" has been deleted as suggested.
The reference to Figure 6.1 is correct, as this figure shows thepotential discharge pathways and treatment systems thatshould be considered in the inventory.

Rejected

Equation 6.6 is located in Section 6.2.3.3 of the 2006 IPCC
Guidelines and is not refined as part of this document.
Inventory compilers should refer to the original 2006 GL forthese unrefined sections of the chapter.

Accepted

We replaced "most freshwaters are highly supersaturated" with"surface marine waters are typically supersaturated (Conrad
and Seiler, 1988; Ward et al, 1987) and freshwaters highly
supersaturated with CH4 (Stanley et al, 2016)".

Rejected
Accepted
Accepted

We considered the development of two EFs for BNR and non‐BNR processes, as proposed in the Second‐Order Draft.
However, following comments received from reviewers, we
conducted additional statistical analysis of the data and foundthat there is no significant difference in EFs of BNR and non‐BNR systems. Therefore, only one EF for all centralised, aerobic
treatment plants has been proposed in the Final‐Order Draft.
Please see Annex 6A.5 for more details on the analysis.
A reference to Table 6.8A (New) has been added to the
explanation of EF.

Rejected

We used the word "typically" which is appropriate for a global
guideline. Many plants do better, but it does not appear
necessary to make the text more extensive.

Accepted

To improve clarity, the steps have been renumbered to only benumbers with no letters.

Rejected
Noted

See response to comment 1391.
No action can be taken because comment is out of scope of2019 Refinement.

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CommentID

1321

Volume5

Chapter

6

Fromline

198

Toline198

Comments
In Table 6.1, it looks strange to only state "N2O is generated", for the"Non‐aquatic environment (soils)" treatment type. Some explanation forwhere it is formed or similar, should be incuded.

Country

Responses

Authors' notes

SwedenRejected

Rejected

This pathway (discharge to soil) is now excluded from Volume 5
Chapter 6 and instead is covered in Volume 4 Chapter 11.
It is clearly stated in the definition of the parameter: maximum
CH4 producing capacity, kg CH4/kg BOD. A value based on COD
is also provided in Table 6.2 for use with industrial wastewater
discharges.

Accepted

The text has been updated.

1331

5

6

481

481

1333

5

6

550

550

It is a little confusing that B0 is listed per both BOD and COD in Table 6.2,
whereas in the eq. 6.2 and in the text below it is strictly in per BOD. It
could be clarified in eq. 6.2 that it is to be per BOD, eg. with an extra suffix
B0 (BOD).
SwedenPlease specify in Eq. 6.3 that it is BOD5 that is to be used (as somecountries apply BOD7, it is good to specify this here, see e.g. Table 6.4
which specifies BOD5).
Sweden725

In Figure 6.3, in the first decision box "Identify major industrial sectors…",
it might be good to refer to the bullet list in the beginning of the chapter
for examples of major industrial sectors of CH4 emissions.
SwedenAccepted

913

Please specify that N loss to the atmosphere can be both as N2 and as
N2O, where N2 is the dominant and wanted fraction and N2o is lessdominant and unwanted.

SwedenRejected

Text added.
Basically, this is just an explanation for N loss during transport
and tretment processes. The proportion of N2 and N2O does
not matter. It is very common for everyone that N2O emission
is not desirable.

490

Dishcarged BOD values are even lower for "new" processes such as the
MBR process. It usually generates discharged concentrations of BOD < 2
mg/L. This is also common in well managed conventional activated sludge
processes.I think a comment stating that really low BOD values (<2 mg/L)
is not that uncommon in well managed modern plants, would be suitablesomewhere here.
SwedenRejectedSee response to comment 1313.

Sligthly confusing with the numbering of the steps; should all steps 1, 1A
AND 1B be conducted or can 1A and/or 1B be skipped if step 1 isconducted? It is difficult to distinguish the difference between a step with
only a number (eg. Step 1) and a step with both a number and a letter (eg.
1A). We would like to see this clarified.
SwedenAccepted

1335

1337

1387

5

5

5

6

6

6

725

913

490

1389

5

6

371

371

1391

5

6

971

976

1393

5

6

612

612

1395

5

6

198

198

1397

5

6

198

198

1409

5

6

481

481

Should NREM always be taken from Table 6.17, even if more country
specific data is available? Please specify.
Some of the values in the table are close to 20 years old which would
motivate an update. We would like to see the table 6.5 updated withmore up‐dated figures.

SwedenRejectedSee response to comment 1315.
It is always recommended to use country‐specific data if it isavailable. This concept can be found in the decision tree (Figure
6.4 (New)).

SwedenRejectedSee response to comment 1319.

Rejected

This pathway (discharge to soil) is now excluded from Volume 5
Chapter 6 and instead is covered in Volume 4 Chapter 11.

In Table 6.1, it looks strange to only state "N2O i generated." for the "Non‐aquatic environment (soils)" treatment type. No explanation to where it isformed or similar, as is given for other treatment types?
SwedenIn Table 6.1, a bullet point (.) is missing between words (system) and
Frequent, for treatment type "Septic system".
Sweden
It is a little confusing that B0 is listed per both BOD and COD in Table 6.2,
but in the eq. 6.2 and in the text below it is strictly in per BOD. Could beclarified in eq. 6.2 that it is to be per BOD, eg. with an extra suffix B0(BOD).
SwedenPage 223

Accepted

RejectedSee response to comment 1331.

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CommentID

1411
1413
1415

Volume555Chapter66
6Fromline

550
595
601

Toline

550
595
601

Comments
Please specify in Eq. 6.3 that it is BOD5 that is to be used (since somecountries apply BOD7 it is good to specify this here, see eg. Table 6.4
which specifies BOD5).
An s is missing after component.
An s is missing after component.

Country

SwedenSwedenSweden

1417

5

6

725

725

1419

5

6

913

913

In Figure 6.3, in the first decision box "Identify major industrial sectors…"
it might be good to refer to the bullet list in the beginning of the chapter
for examples of major industrial sectors of CH4 emissions.
SwedenPlease specify that N loss to the atmosphere can be both as N2 and as
N20, where N2 is the dominant and wanted fraction and N20 is lessdominant and unwanted.
Sweden

1791

5

6

902

902

Since the definition of "Nutrient‐impacted and/or hypoxic" in the newtable 6.8A seems unclear, countries could be confused when they selectan appropriate methodology. Therefore, it would be better to provide aquantitative criteria of "Nutrient‐impacted and/or hypoxic" in the table
6.8A.

2913

5

6

145

146

The sentence should be "Treatment and discharge systems can sharply
differ between countries and for rural and urban areas." remove the rest. IndiaJapan

The first sentence should be "Sewer systems may consist of networks ofopen channels or closed underground pipes." The following sentence
should be " Occasional stagnant conditions and heat provide favourable
anaerobic condition for methane generation in closed and open sewers." India
Shift the whole paragraph after line 155. The following sentence shouldbe " The pits are used alternatively and the contents used as manure afterfew months usage."India
The sentence should read like " Secondary treatment consists of biologicalprocesses that degrades organic matter in the waste water throughmicroorganisms. The next sentence should start with " Thebiodegradation is conducted across various bioreactors viz. aerobic
stabilisation ponds......"
India

2915

5

6

147

148

2917

5

6

163

168

2919

5

6

171

172

2921

5

6

189

194

2923

5

6

208

208

2925

5

6

210

210

Shift the whole paragraph at the bottom of Figure 6.1
India
After 'processes.' insert the sentence " In some countries simple
disinfection process concludes tertiary treatment." Remove the existing
sentence " Treatment processes….nutrient removal."
India
Start the line with the sentence "It can be achieved throughbiodegradation, volatalisation, adsorption, absorption and sedimentation
process."
India

2927

5

6

233

243

Remove the whole paragraph, since it is a repetition of para between theIndialines 201 to 212.

Page 224

Responses

Authors' notes

Accepted
Accepted
AcceptedSee response to comment 1333.
The text has been updated.
See response to comment 1413.

AcceptedSee response to comment 1335.

RejectedSee response to comment 1337.

Accepted withmodification

Two paragraphs of text are devoted to the fact that manydifferent kinds of evidence can be used to identify the nutrient
impacted or hypoxic conditions (all of 886 to 904 in theprevious draft) consistent with the reviewer's point including
several quantitative criteria. We added a cross reference backto the text to try and make the connection more obvious.

Accepted

Accepted

Accepted

Accepted withmodification

We have revised this text slightly to improve clarity.

Rejected

The authors believe this text is an appropriate introduction to
the Figure 6.1 and have not shifted its position.

Accepted withmodification

We have revised this text and other associated text in thisparagraph, for improved clarity and to reduce duplication.

Accepted withmodification

The suggested text has been included at the end of the final
sentence in this paragraph.
This information was not a duplication of that provided inparagraph line 200‐212, so it has been retained but also
merged with another adjoining paragraph for improved
readability.

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CommentID

2929

5

6

248

249

2931
2933

5
5

6
6

250
272

251
276

Comments
Country
The sentence should read as " Hence refinements are requested to
introduce new MCFs associated with centralised wastewater treatment
systems."
India
The sentence should read as " Occasionally wastewater treatment system
could be hydraulically or organically overloaded, and results in lower
performance of the plant."
India
The whole paragraph should be shifted after line 284
India

2937

5

6

397

400

Remove the paragraph as it is repeated between line 305 and 308.

India

3215

Fugitive CO2 emissions from coal mining have been reported for the firsttime in 2019 IPCC refinement report. These emissions constitute a
reasonable amount of GHG emission from coal mining activities. The
methodology, activity data and emission factors, although not very
definitive, should be retained in the refinement guidelines to provide
guidance to national inventory compilation.

India

594

In table 6.6, other fresh waterbodies are not addressed under discharge
system for urban high and low income into which is important fordeveloping countries.

2943

3589

3591

Volume55Chapter

6

6Fromline

1

593

294

Toline557 General

6
General298

59 General

GeneralThe 2006 GL Software needs to be updated according to the 2019refinements, and it's at most important for countries, particularly
developing countries, to be provided with necessary capacity building toassure the correct and efficient use of the new refinements

147 General

GeneralThe 2019 IPCC refinements would bring in some cases, more precise
guidance which may be useful for better harmonisation between Parties.
E.g. emissions from oil refining, QAQC procedures (use of models, QC
checklist forms…), many examples of good practice implementations.

India

Reference is needed for the statement. Otherwise may consider deleting. India
The 2019 Refinements provides a well established guidelines for GHG
emission estimation, and it includes more enhancements for the 2006 GL,
so the Government of Egypt is accepting it as presented

Responses
Accepted withmodification
Accepted withmodification
Accepted
Accepted

Authors' notes

We have revised the text to increase clarity.
We have included aspects of the suggested modification andedited this text for improved readability.

Rejected

This table is simply intended to be an example of the type of
distribution of treatment system or discharge pathways that
may be present, and is not intended to reflect all possible
scenarios.

Accepted
Noted

We replaced "most freshwaters are highly supersaturated" with"surface marine waters are typically supersaturated (Conrad
and Seiler, 1988; Ward et al, 1987) and freshwaters highly
supersaturated with CH4 (Stanley et al, 2016)".
Noted with thanks.

Egypt
Noted

Egypt
Noted

FrancePage 225

The software is out of scope of this refinement work, and noaction can be taken at this moment in time to address thiscomment. However, this comment is well noted for future
work by TFI; once the 2019 Refinement is adopted by IPCC
plenary.
Noted with thanks.

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CommentID Volume
503 General

Chapter

Fromline

TolineComments
According to the Minsk_Scoping_Meeting_Report Table 2 New guidance
for Category 1.A.1.c (issue #1 Table1) was proposed to be treated in new
section 4.3 on fuel transformation of V.2 Ch. 4. However, in the Final Draftof the 2019 Refinements section 4.3 provides methodology only for"Fugitive Emissions from Fuel Transformation". While methodology for
estimation of stack emissions from fuel combustion and the carbonisation(fuel transformation) of coal is provided in the IPPU V.3 ch.4 section 4.2.2.
It is noted in the V.3 ch.4 section 4.2.2 that stack emissions estimated by
the suggested methodology should be reported in category 1.A.1.c
Manufacture of solid fuels of Energy sector. The Energy volume (v.2) does
not provide any references for new guidance developed for the category
1.A.1.c as well as any explanations in which case and for which fuels thisnew guidance should be used. This situation is unacceptable, because it
will lead to misunderstanding of the Refinements quidelines and possible
double‐counting or underestimation of emissions. Please, consider
providing in V.2 ‐ Energy a reference for new guidance developed for the
category 1.A.1.c and explanations in which case this new guidance should
be used.

Country

Responses
Rejected

Authors' notes
This comment is out of scope of TOR (Decision IPCC/XLIV‐5)and the Draft TOC elaborated at the scoping meeting in Minsk.
In fact, what the reviewer points was included in item #1 oftable 1 (not table 2) of the Minsk report, which is the list ofissues considered but this issue was not finally included forrefinement as indicated in p.17 of the Scoping report and in thedraft TOC of that report.

Noted

IPCC decided to prepare a “2019 Refinement to the 2006 IPCC
Guidelines for National GHG Inventories” (2019 Refinement),
which will not replace the 2006 IPCC Guidelines; it will be usedin conjunction with the 2006 IPCC Guidelines. Consolidating all
methodological guidance into a single report would require a
new IPCC decision, subject to be discussed in the IPCC plenary.

Russian Federation
663 General

General1

1 General overall comment ‐ provide a single set of guidelines thatcombines the unchanged 2006 text with the 2019 refined guideline text toassist inventory compilers intending to implement the 2019 Refinement.

New Zealand

Page 226

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CommentID Volume
935 General

Chapter

Fromline

TolineComments
The Chinese government thanks the members of the Bureau, the leadauthors and the Technical Support Unit (TSU) of the Intergovernmental
Panel on Climate Change (IPCC) for 2019 Refinement to the 2006 IPCC
Guidelines for National Greenhouse Gas Inventories (2019 Refinement)
for their hard work in preparing this methodology report. In order to havea more science‐based, comprehensive and balanced IPCC assessment
report with fully reasonable and actionable findings when applied,
Chinese government has made the following comments on this draft in
the hope that they will be adopted in its revision process.

Country

Responses
Accepted withmodification

For 2), the comment has been accepted. Errors have beencorrected where they were found.
For 3), citation errors, typographical or grammatical errors will
be corrected during the final copyedit before the publication ofthis report . Cosmetic improvements will be also made during
the final copyedit, including improvement of presentation of
figures/pictures. Substantial inconsistencies (not just editorial
or typographical), where found, have been corrected.

1. On accounting fugitive emissions from coal exploration. As amethodology report that will be widely used, the accounting method
described therein should be rigorously science‐based, sufficiently
informed with reference and highly actionable. There being few studies
on how to account for fugitive emissions from coal exploration, there is aclear lack of literature support in this connection, which leads todifficulties in data availability. Therefore, it is suggested to relocate thetext on the accounting of fugitive emissions from coal exploration in
Section 4.1.6, Chapter 4, Volume 2 to the annex of this Volume.

1285 General

2. On the formulation and presentation of formulas in the report. As an
important part of the accounting method, the accuracy of the formulas isparticularly important. Some of the formulas in the report are inconsistentin quotation and incorrect in dimension as found, for example, in Lines
259‐402, Chapter 4, Volume 1; lines 2891‐2892, in Chapter 4, Volume 2;
Lines 369‐380, Chapter 4, Volume 3; Line 1108, Chapter 5, Volume 4;
Lines 337, Chapter 6, Volume 4; Lines 349‐381, Chapter 11, Volume 4. It is
d f hfor riceh kcultivationdd fandhagricultural soil is very well
The methodology

GeneralFor 4), the comment has been noted. Consideration of different
national conditions is already addressed by the tiered approachand decision trees. About provision of new/updated default
emission factors, developing country data/EFs as well are
already covered, for example, for coal, charcoal and biochar in
Energy Sector (Vol.2).

China
Noted

written by the various experts. I wish some publications from India
specific work was added to nitrous oxide from agricultural soils. There isno literature at all for emission coefficients from Indian conditions in themethodology chapters.
1379 General

General1965 General

General

all

all

India
We appreciate the hard work of the authors, and others who have
Noted
Swedencontributed to the preparation of the report.
Noted
The approach to generating a standalone document to be used inconjunction with the existing 2006 GLS is very confusing and will make thejob of compilers, especially inexperienced compilers in countries that are
not Annex 1 countries, extremely difficult and inefficient. It would be far
preferable for the Refinement and 2006 GLs in future to be integrated into
ONE set of inventory compilation documents. Compilers should not needto have two sets of complex technical materials to work with, and have toconstantly cross‐reference using mapping tables and hints throughout theRefinement text ‐ it will lead to inconsistencies in application of theguidelines, reducing the quality of the dataset available to the UNFCCC
United Kingdom (ofand IPCC, and also be resource‐intensive to work in that manner.
Great Britain andNorthern Ireland)

Page 227

Authors' notes
For 1), the comment has been accepted.

The authors did not find published studies specific to the Indian
conditions in the literature review, and no specific articles werebrought to their attention during the reviews. However,inventory compilers can use country‐specific data whendeveloping Tier 2 or 3 methods.
Noted with thanks.
IPCC decided to prepare a “2019 Refinement to the 2006 IPCC
Guidelines for National GHG Inventories” (2019 Refinement),
which will not replace the 2006 IPCC Guidelines; it will be usedin conjunction with the 2006 IPCC Guidelines. Consolidating all
methodological guidance into a single report would require a
new IPCC decision, subject to be discussed in the IPCC plenary.

2019 Refinement ‐ Collated Comments on Final Draft from Governments with Authors’ Responses

63b9088a

CommentID Volume2833 General

Chapter

Fromline

TolineComments
It is difficult to understand the meaning of many sentences throughout
the chapter because the English grammar and style still need to be
fixed/refined (i.e. lines 206‐207 should be "The material can be used bothby countries establishing a data collection strategy for the first time andby countries..."; lines 209‐211 should be "the progress of emission trading
programmes or climate change policies have the potential..."). (Disregard
this comment if it's planned to have another edit to fix the English).

Country

Responses
Accepted withmodification

Authors' notes
The text has been revised and English checked. Specifically, for
the indicated lines 206‐207, the text does not seem to have any
problem and has been mantained the same. The text in lines
209‐211 (which are to be read 940‐941) has been slightly
changed to increase readability.

Noted

Noted with thanks.

Noted

As clarified in the explanatory note which accompanied the
Final Draft circulated for the final government review, after the
adoption/acceptance by the Panel, the 2019 Refinement will be
published without grey highlight. The purpose of grey highlightin the draft is solely to facilitate the review and the differences
accross different chapters/sections reflect the "amount" ofrefinements proposed. Therefore, is expected that "sometimes
there are entire sections of grey text, with a minor phrase or
one to two new paragraphs (in white) included. Sometimes
there is no grey text".

Noted

IPCC decided to prepare a “2019 Refinement to the 2006 IPCC
Guidelines for National GHG Inventories” (2019 Refinement),
which will not replace the 2006 IPCC Guidelines; it will be usedin conjunction with the 2006 IPCC Guidelines. Consolidating all
methodological guidance into a single report would require a
new IPCC decision, subject to be discussed in the IPCC plenary.

Belgium
2883 General

GeneralWe thank the authors for their hard work on providing the refinements tothe 2006 IPCC Guidelines for National GHG Inventories.

2949 General

GeneralThe inclusion of text from the original 2006 Guidelines (in grey in the draft
Refinement) appears to be inconsistent. Sometimes there are entire
sections of grey text, with a minor phrase or one to two new paragraphs(in white) included. Sometimes there is no grey text; it is difficult tounderstand in these cases where the new text fits in. Volume 4 (especiallychapter 2) contains entire sections of grey text. Consistency should besought between all volumes and chapters to improve usability byinventory compilers

Estonia

United States ofAmerica
2951 General

GeneralMaintaining the new text separate from the original 2006 Guidelines is notuser friendly. It requires reading three documents at once: the relevant
chapter in the 2006 Guidelines, the relevant chapter in the Refinement,
and the annex mapping the relationship between sections. Far easierwould be to incorporate the new text into the 2006 Guidelines in a new
document, highlighting or underlining the new text. This would greatly
assist not only review, but ultimately the likely uptake by inventory
United States ofcompilers.
America

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CommentID Volume2953 General

Chapter
GeneralFromline

TolineComments
Most new examples presented in the Refinement seem to come from A1
Parties. Using examples from a broader variety of Parties may help makethe Refinement more accessible to a wider range of countries.

Country

Responses
Noted

Authors' notes
Efforts were made to include data and information fromdeveloping countries or non‐Annex I counties under the
UNFCCC, and a number of examples of such data/information
were already included in the Final Draft. For example:‐ In Chapter 2 of Volume 4 (AFOLU), Box 2.0e (New Guidance)
using a biomass map for GHG estimation: An Example from theBrazilian Amazon.
‐ Volume 2 (Energy) has application for and draws emission
factors from non‐annex‐1 countries at many places. For
instance, the fugitive emissions from coal mining (section 4.1)
where in data and emission factors include those from large
developing countries; section 4.3.2.1 on charcoal and biochar
production especially tables 4.3.2 and 4.3.3 (emission factors
and uncertainty estimation), and Appendix 4a.2 (Fugitive
Greenhouse Gas Emissions from Wood Pellet production).
Such efforts will be continuously made in the future work by
TFI.

United States ofAmerica
3851 General

GeneralDifferent land uses, such as agricultural, grassland, forest, etc may be used
to produce bio‐energy/fuel. In this refinement, the approaches ofGreenhouse Gas emissions accounting in relation to bio‐energy should be
explained. Please consider including how double accounting is avoided.

Noted

Treatment of CO2, CH4 and N2O emissions from combustion of
biomass or biomass‐based products is explained in detail in
Chapter 1 of Volume 1. By this, and also by relevant guidance
given in relevant chapters in sectoral volumes, the final draft of2019 Refinement already provides guidance to avoid double
counting of GHG emissions within a country's inventory.

NorwayWe suggest that this paragraph briefly highlight some of the other specificdevelopments in Chapter 2 of Volume 4 of the 2019 Refinement 2019, inparticular on the consistency between AFOLU projects or activities andthe IPCC inventory guidelines (Box 2.0A), on the use of allometric models
for biomass estimation (Section 2.3.1.3.3.A) and on additional genericguidelines for Tier 3 methods (Section 2.5). These developments are
particularly relevant for the implementation and improvement ofreporting for all countries.
Delete "Thailand" from the end of the line

289
593

Overview_ChOverview_Ch 277
Overview_ChOverview_Ch 78

277
78

595

Overview_ChOverview_Ch 163

166

597

Overview_ChOverview_Ch 193

204

Not clear if the table in Box 2 is supposed to be complete ‐ it isn't; but thisis OK if the intent is to only have part of the table for illustrative purposes
The IPCC is commended for including this essential guidance on national
greenhouse gas inventory arrangements and management tools as part of
the refinement exercise.

599

Overview_ChOverview_Ch 335

335"from active aeration landfill" should be "from active landfill aeration"

Page 229

New Zealand

The discussion about consistency in AFOLU projects and theinventory guidelines is provided for information purpose in a
box and it is not guidance, so it is not appropriate to highlight it
here. Highlight on allometric equations is already included in
the bullet on "bimass estimates". A new bullet on Tier 3 model
Accepted with m has been added.
Accepted
The intent is to only have part of the table for illustrative
purposes, indeed. Therefore the title clearly says it is just an
example, which shows readers what to find inside the thevolumes of the 2019 refinement.
Noted

New Zealand

Noted

New Zealand

Rejected

FranceNew Zealand

Noted with thanks.
Active aeration landfill is a type of landfill . This sentence refers
to the type of landfill, not to the operation condition of thelandfill.

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601

603

721

855

VolumeChapter

Fromline

Overview_ChOverview_Ch 366

Overview_ChOverview_Ch 373

Overview_Chapter

302

Overview_ChOverview_Ch 328

TolineComments

Country367

Reporting of national greenhouse gas inventories is an essential
component of reporting information that is used for compliance against
commitments. The sentence could be modified as follows to reflect this:"While reported inventory estimates are an essential component of
information used to assess compliance against commitments, the 2019
Refinement does not provide specific guidance on information necessary
to assess compliance."

374

Suggest the last part of the sentence (for which any metrics can be used)
is rephrased as not all metrics are designed to convert GHG emissions into
CO2 equivalent.

New Zealand

Accepted

303

Between lines 302 and 303, suggest to add refinements made on the“methane rice section” of Volume 4 AFOLU, using the text from Volume 4
Annex1_FD (Mapping Table) in lines 278 to 283.

Philippines

Accepted

New Zealand

The last setence of this bullet has been replaced by thefollowing sentence.
"The 2019 Refinement is relevant but not prescriptive withrespect to the reporting of national inventories underinternational agreements, and the use of reported information
Accepted with m under these agreements."
The sentence has been modified to read: "… for whichinventory compilers may use any metrics that are designed toconvert greenhouse gas emissions into CO2 equivalent."
The text should be "Tier 1 factors have been updated for thebaseline emission factors, scaling factors for water
management regimes before and during cultivation periods,
and conversion factors for organic amendments. Default
cultivation periods have also been added for estimating annual
emission factors."

330

This sentence needs to be revised for clarity.

Sweden

Noted

SwedenAccepted
Accepted with m The titles of the decisions have been moved into footnotes.
This information is necessary to clarify when and where the
TFB28 was held.
Rejected
This part could have been written as "… generally did not meetthis criterion" which might be clearer than "… may not meetthis criterion". However, the Box 1 shows the criteria that wereactually used. It is factual information, and therefore cannot bechanged.
Noted

1343

Overview_ChOverview_Chapter

1345

Overview_ChOverview_Ch 66

66

1347

Overview_ChOverview_Ch 71

81

Could omit the long titles of the decision, in order to improve readability.

Sweden1349

Overview_ChOverview_Ch 77

77

Could omit "which was held…scoping meeting"

Sweden1351

Overview_ChOverview_Ch 93

93"may not" is unclear. Suggest: "Sweden110
114

This text is probably very possile to omit. Much is said elsewhere, and it
does not add much information.
Could remove "(e.g…. Report)"

Overview_ChOverview_Ch 103
Overview_ChOverview_Ch 113

Authors' notes

The sentences have been modified to read:‐ Waste generation, composition and management: The 2019
Refinement updates key parameters used in the first orderdecay (FOD) method including waste generation rate and waste
composition by countries and region using UN classification.
The 2019 Refinement also provides default values anduncertainty of carbon content, nitrogen content anddegradable organic carbon (DOC) of domestic and industrial
Republic of Korea Accepted with m sludge. (Chapter 2)

The overview chapter contains some duplications and language that could
be simplified to further advance its aim to provide concise introduction tothe overal report. For example, specific examples may not always beneeded, but left to the chapters and sections of the full report.
Could remove "(e.g. …)" ‐ it is not necessary and confuses more thanprovides key information.

1353
1355

Responses

Page 230

SwedenSwedenRejected
Accepted

Improvement has been made where it is deemed necessary as
appropriate.

This text is necessary to clarify how the outline was developed
and why the table of contents of the final product is not exactly
the same as the initially developed outline.

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Fromline

Toline1357

Overview_ChOverview_Ch 131

132

1359

Overview_ChOverview_Ch 136

136

1361

Overview_ChOverview_Ch 155

155

Comments
The "The guidance.. are provided." is clear from the context, and could beomitted.

Country

Responses

SwedenRejected

Authors' notes
The fact explained here is not well known to new comers.
Therefore it is better to keep this sentence.

Could delete "As stated… above"
The sentences in ()s in the first two entries under "Explanation" in thetable could be deleted. They are just duplicating the information above inthe same cells.

SwedenRejected

The sentences following these words are intentional repetitionof those in Section 1. These words are necessary to clarify that.

SwedenAccepted
In the context of refinement of Chapter 3 of Volume 1, it isnecessary to refer to the history of development and use of theconcept "good practice".
To improve the clarity of the meaning of this paragraph, it has
Accepted with m been modified.

1363

Overview_ChOverview_Ch 169

170

Change "has been defined" to "is defined", and delete "since 2000… wasintroduced"‐

Sweden1365

Overview_ChOverview_Ch 173

173

Suggest "… inventory development, as "a set…"

Sweden1367

Overview_ChOverview_Ch 168

182

These two paragraphs largely carry in essence the same information.
Could consider streamlining.

SwedenTo improve clarity of the sentence, this part has been modified
Accepted with m as "… inventory development. This definition can be also …"
The first paragprah is to explain the definition of the concept"good practice", and the second paragraph is to explain why
such concept is key.
To improve the clarity of the meaning of the first paragraph, it
Accepted with m has been modified.

1369

Overview_ChOverview_Ch 207

207

Replace "has also the advantage" with "is also"

SwedenAccepted

SwedenThe sentence has been changed to read: "A new methodology
for non‐linear interpolation analysis has been added in the
Accepted with m 2019 Refinement, along with an example."

SwedenAccepted

Change implemented as proposed

Rejected

It is important to specify which GHGs have been identified in
the Fourth and Fifth Assessment reports vs. other references
because GWPs and other weighting metrics are available for
the GHGs in AR4 and AR5, but may not be available for GHGs
that are known through other references.

1371

Overview_ChOverview_Ch 230

230

1373

Overview_ChOverview_Ch 253

253

1375

Overview_ChOverview_Ch 270

Delete "with an example"
Don't need units here, can delete "(percent carbin by mass)", "percent of"and "(by mass)".

271

Suggest "… identified. Such greenhouse gases include, for example, …".
The report names are already stated above.

SwedenRejected

The example is provided to show that some of the GHGs
included in the Fourth and Fifth Assessment Reports, but notearlier Assessment Reports, are commercially important.

Saint Lucia

Rejected

The Box 1 shows the criteria that were actually used. It is
factual information, and therefore cannot be changed.

Rejected

The authors believe that it is important to emphasize how"inventory compilers" as main targeted users should use this2019 Refinement.

1377

Overview_ChOverview_Ch 272

273

Could omit the "(a perfluoropolyether… manufacturing.)", as it does notseem to be needed here in the introduction.

1559

Overview_ChOverview_Ch 89

101

Information from other sources such as FAO to meet data gaps.

155

Is it necessary to use the term "inventory compilers" in Table 1? It makes
the table more difficult to read. Suggest to change these sentences to thepassive voice. Example: "The chapter/section/subsection in the 2019
Refinement should be used instead of the corresponding
chapter/section/subsection in the 2006 IPCC Guidelines."

2835

Overview_C
hapter154

The proposed change makes the sentence more readible.

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CommentID

Volume2837

Overview_C
hapter2839

Overview_C
hapter2841

Overview_C
hapter2843

Overview_C
hapter2845

Overview_C
hapter

Chapter

Fromline

Toline207

Comments
Suggest to fix the English: should be "The material can be used both bycountries establishing a data collection strategy for the first time and bycountries..."Disregard if it's planned to have another edit to fix theEnglish).

209

185

Country

Responses

Authors' notes

Belgium

Accepted

211

Suggest to fix the English: should be "the progress of emission trading
programmes or climate change policies have the potential..."). Disregard if
it's planned to have another edit to fix the English).

Belgium

Accepted187"some boxes" (line 187): which boxes? Suggest to cite specific examples(e.g. by page number) or change the word "some" to be more descriptive.

Belgium

202

Line 202 repeats the same information already stated in line 195. Suggest
to modify this line. ("The tools presented in this new guidance should also
not be considered prescriptive.)

Belgium

197

198

Suggest to change this line to "provides approaches and examples of goodpractices in national greenhouse gas inventory arrangements that are
based on the best scientific information available."

Belgium

Accepted with m The sentence has been deleted as it is not necessary.
Text " As it is the case for the provided guidance on national
GHG inventory arrangements, the management tools
presented in this new guidance …" has been added at the
Accepted with m beginning of the sentence.
The current text recognises that the best available examples
but there is no scientific methodology to develop to date that isused to distinguish between scientifically robust national
systems. National systems tend to depend more on national
circumstances.
Noted

Belgium

Accepted with m The text "and inverse modelling" has been added at the end.

Noted

206

2847

Overview_C
hapter233

240

Atmospheric observations and inversion models giving an estimate ofsources are independent of government declarations and cover both averification aspect as well as a possibility to to have data for non reporting
countries. (Add at the end of line 240: "and modelling").

2849

Overview_C
hapter258

260This is important, as abandoned or unconventional extraction facilities
have a large chance to be unreported. We support this text!

Belgium

154

The difference between "Update" and "New Guidance" is unclear. The
instructions are basically the same. Provide clearer language that
demonstrates the difference between them.

United States ofAmerica

Noted with thanks.
The explanation of "New Guidance" has been replaced with
"Recognizing that there is no guidance in the 2006 IPCC
Guidelines, inventory compilers should use theAccepted with m chapter/section/subsection in the 2019 Refinement."235

As there have been particular sensitivities around external stakeholders"verifying" country‐reported data using atmospheric measurements, itwould be useful here to specify that the verification contemplated is done
by/with inventory compilers and understood in the inventory sense (asexplained in Box 6.1 of Volume 1 Chapter 6), as opposed to done byexternal stakeholders and understood in the carbon markets‐relatedsense. (A different term, such as "validation," might also be considered.)United States ofAmerica

The text "verifying national emissions" has been replaced by
the text "improving national greenhouse gas inventories. These
approaches can be used to provide additional scientificverification of inputs and results for particular categories andgases, and therefore help countries to target areas ofAccepted with m uncertainty."

288This section suggests that the guidance on interannual variability isintended to help Parties disaggregate emissions/removals from natural
disturbances in their inventories, but not to avoid reporting them in theinventories. We would support this. However, the actual guidance inVolume 4 does not make this clear, and appears to suggest theseemissions/removals could not be reported. (See comments on Interannual
variability in Volume 4, Chapter 2)

United States ofAmerica

Noted

2957

2959

2961

Overview_ChOverview_Ch 154

Overview_ChOverview_Ch 234

Overview_ChOverview_Ch 278

Page 232

This comment has also been made in Chapter 2 of Volume 4,
and has been addressed by the LA in the respective chapter

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VolumeChapter

Fromline

TolineComments

Country2963

Overview_ChOverview_Ch 303

309

As reflected in our comments on Volume 4 Chapter 7, we have strong
concerns about the proposals to factor out emissions and removals thatwould have otherwise occured in the absence of flooding (i.e., converting
unmanaged land to managed by flooding). This approach contradicts theprinciples behind the managed land proxy. Based on the information
provided, and the available literature, there is no scientific basis forfactoring out emissions and removals on unmanaged lands that would
otherwise occur in the absence of the flooded area. We request that the
text reflect this (thereby “taking it into account”), and the sections on“factoring out” be removed from the Wetlands chapter.

3863

Overview_ChOverview_Ch 91

93

Box 1: The authors should consider explaining what significance ofsources/sinks is referring to and why it is global based not country based.

3865

Overview_ChOverview_Ch 250

250

3867

Overview_ChOverview_Ch 254

263

3869

Overview_ChOverview_Ch 264

276

Please include an explanation of non‐biogenic in the Glossary
Please consider to include more detailes in the description of the updates.
The information provided for Volume 2 and 3 seem to be much moreaggregated than for Volume 1, 4 and 5.
Please consider to include more detailes in the description of the updates.
The information provided for Volume 2 and 3 seem to be much moreaggregated than for Volume 1, 4 and 5.

Page 233

Responses

Authors'
The proposed refinement
providesnotes
a method using themanaged land proxy in addition to a method for factoring out.
In fact, we have included the factoring out method because it
was specifically requested in the TOR from the IPCC panel tothe authors for this report. Both total emissions using the MLP
and net emissions from factoring out are reported based on thereporting tables that we have provided. We have revised thetext to state that for transparency, it is good practice to report
both the total emissions and net emissions if net emissions are
estimated; otherwise the country should only report total
emissions if net emissions are not estimated.
The method is based on science and the methods provided in
the IPCC guidance. It has been well‐established in the scientific
literature that non‐saline water bodies and wetlands emit CH4
when they are unmanaged. Conversion of unmanaged
wetlands or water bodies to flooded lands does increase theemissions, but a portion of these emissions would continue tooccur if the land was not converted to flooded land, and thisportion is factored out. In contrast, unmanaged forest land andgrassland are typically a sink for CH4, and the net flux is
considered non‐anthropogenic even for managed forest land
and grassland. Therefore there is no need for guidance tofactor out this portion of the CH4 flux.
For CO2 fluxes, there is a net uptake in unmanaged wetlands
that would occur continue to occur if the land remained
unmanaged. Therefore this portion is factored out. In contrast,

United States ofAmerica

Rejected

NorwayRejected

NorwayRejected

The Box 1 shows the criteria that were actually used. It is
factual information, and therefore cannot be changed.
The word "biogenic" is just an ordinary word, and "non‐biogenic" is self‐explanatory, so it is not necessary to include itin the glossary.

NorwayAccepted

For Volume 2, more details in the description of the updates
have been included.

NorwayAccepted

For Volume 3, more details in the description of the updates
have been included.

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VolumeChapter

Fromline

TolineComments

Country

3871

Overview_ChOverview_Ch 323

326

Please note that the Production approach is "mandatory" under the Paris
agreement (if HWP is reported). You may therefor consider to change thetext. Regarding footnote 10: Please consider to include the following
about the ruels under the Paris agreement (the existing text only refers to
the climate convention): "It should be noted that decision ‐/CMA.1 on theenhanced transparency framework under the Paris agreemnt states thatin the case of a Party using an approach to reporting emissions andremovals from harvested wood products in accordance with IPCC
guidance other than the production approach, that Party shall also
provide supplementary information on emissions and removals fromharvested wood products estimated using the production approach".

3873

Overview_ChOverview_Ch 352

352

Please include an explanations of abiogenic in the glossary

3875

3885

3887

Overview_ChOverview_Ch 360

Overview_ChOverview_Ch 217

Overview_ChOverview_Ch 37

NorwayNorwayThere is no need to add the reference to Decision 4/CMA.1
since this relates to accounting and the 2019 Refinement
provides guidance on how to estimate emissions and removals
Accepted with m by any of the approaches.
The term "abiogenic" has been replaced by "non‐biogenic" inthe text of 2019 Refinement. Therefore it is not relevant to theglossary any longer.
Rejected
Section 1 is introduction, and Section 2 is background. It is not
appropriate to put this Section 6 between these two sections.
Instead, Section 6 has been moved to after Section 2, and thetitle has been changed to "CLARIFICATION ON KEY CONCEPTS
IN THE 2019 REFINEMENT UNCHANED FROM 2006 IPCC
Accepted with m GUIDELINES".

Please consider to move the information in section 6 upfront after section
1.

Norway223

We would suggest using the term "uncertainty assessment" in the lines
221 and 222 instead of "uncertainty analysis" as it is preferably used in
the chapters (Volume 1 Chapter 3). For easier cross‐reference with the2006 Guidelines, the title in the line 217 may not be changed.

Madagascar

37

Introduce the following sentences: "The 2019 Refinement are intended
for a broad range of users, including countries and inventory compilers
setting out to prepare inventory estimates for the first time. It uses theoverarching framework and the concepts of the 2006 IPCC Guidelines. It
presents a step‐by‐step guidance on how to compiling a greenhouse gas
inventory (See Volume 1 Chapter 1 2006 IPCC Guidelines). Inventories rely
on a few key concepts for which there is a common understanding. This
helps ensure that inventories are comparable between countries, do notcontain double counting or omissions, and that the time series reflect
actual changes in emissions. The 2019 Refinement do not contain any
accounting element."

3889

Overview_ChOverview_Ch 63

63

3891

Overview_ChOverview_Ch 122

122

Page 234

Authors' notes

Footnote 10 has been deleted.

378

Write: "…and empirical knowledge related to GHG as well as to newtechnologies and production processes published since 2006 …"
At the end of the sentence, a reference on these matters to theappropriate chapter of the 2019 Refinement would be usefull.

Responses

Accepted

The changes have been implemented as proposed.

Switzerland

Accepted withmodification

The following sentences have been added in Section 6 (which
has become Section 3 in the amended Final Draft), instead of
Section 1. "The 2019 Refinement is intended for all countries
and national greenhouse gas inventory compilers, including
those setting out to prepare inventory estimates for the firsttime. It uses the overarching framework and the concepts
consistent with the 2006 IPCC Guidelines. National greenhousegas inventories rely on a few key concepts for which there is acommon understanding (see Chapter 1, Volume 1). This helps
ensure that inventories are comparable between countries, do
not contain double counting or omissions, and that the timeseries reflect actual changes in emissions."

Switzerland

The sentence has been modified to read "…and empiricalknowledge related to sources and sinks of greenhouse gases as
Accepted with m well as inventory management published since 2006 …"

Switzerland

Accepted"(see Chapter 7, Volume 1)" has been added at the end.

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3893

VolumeChapter

Fromline

Overview_ChOverview_Ch 183

Toline1833895

Overview_ChOverview_Ch 198

198

3897

Overview_ChOverview_Ch 202

202

3899

Overview_ChOverview_Ch 233

244

3901

Overview_ChOverview_Ch 262

262

3903

Overview_ChOverview_Ch 278

3905

Overview_ChOverview_Ch 360
605 General
Glossary

189

607 General

Glossary

287

609 General

Glossary

431

611 General

Glossary

643

288

378

Comments

Country

Write: " … of anthropogenic GHG emissions …"

Write: "… in particlar for reporting GHG emissions by sources andremovals by sinks under international agreements."
Write: " As it is the case for the provided guidance on national GHG
inventory arrangements, the management tools presented in this new
guidance …"
The guidance provided on inverse models is an important progress thatthe 2019 Refinement contains

Page 235

Authors' notes

Switzerland

Instead of inserting "GHG" as suggested, "of greenhouse gases"
Accepted with m have been added at the end of the sentence.

Switzerland

Noted

Authors' view is that the proposed text goes beyond the scopeof the 2019 Refinement in so far as reporting. The purpose of
the guidance is to provide methodological guidance onemission estimates as well as more relevant in this case,examples of insitutional arrangements and tools necessary foremission estimations. To give clarity to the sentence, thefollwoing words have been added at the end of the sentence.
"in establishing greenhouse gas inventory arrangements".

Switzerland

Accepted

Implemneted as proposed.

Switzerland

Noted with thanks.
Text has been modified as "… charcoal production, biochar
Accepted with m production …"

Write: "… from charcoal and biochar production, …"
Switzerland
For clarity and in order to avoid ambiguity, it would be better to use
always the same expression when refering to e.g. fire, insects, windthrow,and ice storms, instead of two: "natural effects" and "natural
disturbances". The one that will be retained should then included in the
Glossary.
Switzerland
Section 6 "Clarification on kex concepts in the 2019 Refinement" should
be moved after line 81 as it explains key concepts introduced and used in
the following sections.
Switzerland
190 Suggest the sentence be shortened to: "A barrier constructed to hold backwater." The remainder of the sentence (in the context of national
greenhouse gas inventories for the AFOLU sector) would seem to be
New Zealandirrelevant.
287 "used to quantifying greenhouse gas emissions" should be either "used toquantify greenhouse gas emissions" or "used in quantifying greenhouse
New Zealandgas emissions"433 Suggest the definition of "Manure" is revisited, as manure is produced
regardless of whether or not it can be managed for agricultural purposes.

643 Change "downstream of the dam" to "downstream of a dam"

Responses

New Zealand
New Zealand

Noted

Accepted

Accepted
Accepted withmodification

Text has been revised to "use always the same expression" andterminologies consistent with section 2.6 of Chapter 2,
volumen 4

Accepted change but included in a reservoir for context.
Changed to "An artificial structure that is barrier used to holdback water in a reservoir."Accepted

The sentence has been replaced with "… used to quantify …"

Accepted

The definition has been changed to read: "Waste materials
produced by domestic livestock (vegetative material such as
green manures are considered to be crop residues or compost).
The term ‘manure’ is used here collectively to include bothdung and urine (i.e., the solids and the liquids) produced bylivestock."

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CommentID Volume2955 General

ChapterGlossary

Fromline
103

TolineComments
111 The FD definition of "Carbon dioxide equivalent emission" needs to berevised. Currently, the definition goes too far in its statements that carbon
dioxide equivalent emissions and carbon dioxide equivalentconcentrations are unrelated.
We recommend replacing the last two sentences with the following:"CO2‐equivalent emission is a common scale for comparing emissions ofdifferent GHGs but implies only approximate equivalence of thecorresponding climate change responses over the selected time horizon.
Because GHGs have widely varying atmospheric lifetimes, CO2‐equivalentconcentrations cannot be calculated from CO2‐equivalent emissions
without knowing the identities and quantities of the GHGs emitted."
In addition to making the definition more accurate, this change will makeit more consistent with how the IPCC describes metrics in its Assessment
Reports.

Country

Responses
Accepted withmodification

Authors' notes
The last two sentences have been deleted.
The definition included in the Final Draft is identical to that
included in the Glossary of Special Report on 1.5oC (SR15)
which was already accepted by the IPCC. The suggested
replacement of the last two sentences will lead toinconsistency between SR15 and 2019 Refinement. Instead,deletion of the last two sentences is more appropriate as thedefinition without them works well for inventory compilers'
work.

Accepted

Added definition, "Energy derived from any form of biomass."

United States ofAmerica
3853 General

Glossary

65

67 Please clarify if the terms "biofuel" and "bioenergy" are interchangebale
and consider including the defintion of bioenergy in the glossary.

3855 General
3857 General

Glossary
Glossary

833859 General

Glossary

Please consider tp include å definition of Managed Land Proxy (MLP) in
the glossary.

3861 General

Glossary

Please consider to include "below ground biomasse" in the glossary

NorwayNorway83 Should read: "…statistical method which…"
Please consider to include unmanaged forest and unmanaged land in theglossary.

Accepted
Accepted withmodification

A definition of managed land has been included in the glossary:"Managed land is land where human interventions andpractices have been applied to perform production, ecologicalor social functions. All land definitions and classifications
should be specified at the national level, described in atransparent 93 manner, and be applied consistently over time."(extracted from the current 2006 Guidelines text ‐ Chapter 1 ‐Volume 4). Therefore, what is not defined as "managed land"
by a country should be classified as unmanaged.

NorwayAcceptedA definition of the MLP has been included in the glossary: For
the AFOLU Sector, anthropogenic greenhouse gas emissions
and removals by sinks are defined as all those occurring on‘managed land’. This approach, i.e., the use of managed land as
a proxy for anthropogenic effects, was adopted in the Good
Practice Guidance for Land Use, Land‐Use Change and Forestry(2003) and that use is maintained in the 2019 Refinement".

Accepted withmodification
Rejected

It is clarified in the term "Biomass" that living biomass includes
above and below ground biomass.
The word "biogenic" is just an ordinary word, and "non‐biogenic" is self‐explanatory, so it is not necessary to include itin the glossary.
The term "abiogenic" has been replaced by "non‐biogenic" inthe text of 2019 Refinement. Therefore it is not relevant to theglossary any longer.

NorwayNorway3865 Overview_ChOverview_Ch

250

250 Please include an explanation of non‐biogenic in the Glossary

3873 Overview_ChOverview_Ch

352

352 Please include an explanations of abiogenic in the glossary

NorwayRejected
NorwayPage 236