Review Comments by Governments on Second Order Draft of Volume 5 of 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories
Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

5220

5

2

122

134

In the text (as in lines 146 to 147) you added information on VSS (and TSS), and typeof sludge (raw/stabilized). But in table 2.4 A there is no link with this information
although it is said that "it is good practice to differentiate […]". So I don't really
understand what for this information on TSS and VSS is provided. If it is for referencing
purpose of the DOC values, it could be more transparent just to add the information as anote in the table 2.4A.
Moreover, if it is good practice to differentiate between raw and stabilized sludge,
UNFCCC reviews will expect annex 1 countries to do it. Please could you provide
separate defaults values for carbon content, nitrogen content and DOC ?

FranceAccepted

See comment 4918

5218

5

2

128

128

It is indicated in the text that it is "good practice to split between "BIODEGRABLE"
and "FOSSIL" shares…". Do you mean between "biogenic" and " fossil" ? I guess yes(for CO2 emissions purpose), so it will be more transparent and consistent with the otherpart of the GL to use this wording “biogenic”.

FranceAccepted withmodification

See comment 4916

904

5

2

139

Data in Table 2.3 for some region are more than 100% when add composition together(off by 0.1-0.2%).

ThailandAccepted withmodification

Footnote number 2 below the table explains the reasons for such descrepancy.

6424

5

2

139

139

These data might also be reconsidered. Due to its previous carbon pricing policy,
Australia put a lot of work into composition estimates. Estimates used in Australia are:food 0.35; paper & cardboard 0.13; garden and park 0.165; wood 0.01; textiles 0.015;
sludge 0; nappies 0.04; rubber & leather 0.01. Inert waste fractions can be derived fromthe national waste report workbook ('other national data'): metals 0.03; plastics 0.12;
glass 0.04.

Australia

Rejected

The data used for Austalia in table 2.A.2 is from the 2018 NIR of Australia.
The proposed reference by the reviewer is from 2008 and therefore is not upto
date compared to the 2018 NIR.

6426

5

2

139

139

Inert waste fractions can be derived from the national waste report workbook ('othernational data'): metals 0.03; plastics 0.12; glass 0.04.

Australia

Rejected

The data used for Austalia in table 2.A.2 is from the 2018 NIR of Australia.
Although the proposed reference is a recent one, the 2018 NIR of Australia ismore recent and for consistency purposes, it is appropriate to use the samereference for all waste composition values.

6792

5

2

144

145

It may be useful to consider the carbon content in sludge in more details taking into
account new information from the Chapter 6 and Annex 6A.1 Volume 5 on fossil carbon
content in wastewater and sludge.

Russian Federation

Accepted withmodification

Annex 6.1 was reviewed and carbon content of sludge was confirmed ascorrect.

6794

5

2

146

147

TSS and VSS are characteristic of sludge from all wastewater treatment operations, notonly from wastewater plants. It is also may be important to note that VSS in general case
can also include soluble particles.

Russian Federation

Accepted withmodification

The section 2.3.2 was fully redrafted to clarifiy the TSS and VSS issues.

6796

5

2

148

153

It is proposed to rewrite this paragraph omitting the information included in the Table
2.4A

Russian Federation

Accepted

6798

5

2

154

157

The proposed method for calculating DOC content in sludge should be checked because
most of the carbon usually is contained in VSS (may be differ only for some types ofindustry sludge) so calculated results for DOC would be lowered.

Russian Federation

Accepted withmodification

The total carbon is used, icluding carbon in inorganic fraction of sludge. Mostof the degradable carbon is contained in VSS.

6800

5

2

156

157

According to the definition VSS is measured in mg/l so it would be better to reformulate
this paragraph by clarifying the use of percentages.

Russian Federation

Accepted withmodification

The VSS used is a percentace of TSS. This approach allows comparison ofsludges with various VSS in mg/l.

6802

5

2

156

157

It is proposed to clarify whether it is possible to use these values in the calculations bydefault and also whether the value of carbon content be different in raw and stabilized
sludge.

Russian Federation

Accepted withmodification

Session 2.3.2 was revised and provides clear guidance on the use of VSS. In
addition, Table 2.4A divides domestic sewage sludge into treated and untreatedsludge to avoid confusion

6804

5

2

161

162

It is proposed to check difference in data for sludge carbon content in the Table
2.4(New) Chapter 2 and Table 5.2 (UPDATED) Chapter 5 Volume 5 and explain orchange them.

Russian Federation

Accepted

Value in table 5.2 was updated.

6806

5

2

161

162

There is a difference in the unit for DOC between the title of the Table 2.4A and thecorresponding table column (percent of dry matter and fraction) that should becorrected. Also using different units for DOC and other sludge components can be areason for mistakes.

Russian Federation

Accepted

Text in the table was updated.

7644

5

2

161

162

DOC fraction default value has changed significantly (too much) for domestic sewage
sludge in Table 2.4A (now 0.16, earlier 0.4-0.5 in 2006 IPCC Guidelines). In addition,
the difference between carbon content and DOC fraction is too large for domestic
sewage sludge and for WWT sludge in paper industry. Please check/revise

FinlandAccepted withmodification

The section 2.3.2 was fully redrafted.

DOC in domestic sewage sludge was verified. The value of DOC in paperindustry was revised according to literature. Carbon content of domestic sludge
was separated into treated and untreated process for clearer guidance.

Comment ID Volume

Country

Response

6808

5

Chapter From line
2

177

To line181

In the current version of Chapter 4 (Volume 5) the appropriate process for anaerobic
sludge stabilization is called "Anaerobic digestion" (and in the Chapter 6 also) so it
would be better to indicate it in this text more clearly.

Comment

Russian Federation

Accepted

The terminology was cleared the term anaerobic digestion is used in theguidelines.

Authors note

6810

5

2

177

181

In the Chapter 4 (Volume 5) is stated that "when sludge from wastewater treatment istransferred to an anaerobic facility which is co-digesting sludge with solid municipal orother waste, any related CH4 and N2O emissions should be reported under this category,biological treatment of solid waste. Where these gases are used for energy, thenassociated emissions should be reported in the Energy Sector" so the existing text should
be supplemented by this information.

Russian Federation

Noted

Box 2.1 A was reviewed and not appear in the final draft.

1824

5

2

188

In the 10th and 11th rows of the table, ‘Hong Kong’ and ‘Macao’ are inaccurately
worded. It is suggested to rephrase the former as “Hong Kong, China”, and the latter as“Macao, China”.

China

Accepted

In accordance with UN classification for geographic regions,' Hong Kong' wil
be changed to 'Hong Kong Special Administrative Region, China' and 'Macao'
will be changed to 'Macao Special Administrative Region, China'.

5222

5

2

189

189

In order to increase the transparency of annex 2A2, please add a table including the titleof column at the beginning of each column.

FranceAccepted

Corrected as suggested.

5224

5

2

189

189

Table 2A2 : Please consider that, for many countries, the default value for the category"other" is very high.
Considering the list of of waste (ligne 122), this category is supposed to include "(2)garden waste", "(6) nappies" and "(11) other (e.g. ash, dirt, dust, soil, electronic waste).
So, this category covers type of wastes very different in terms of DOC, carbon content(FC) and fossil carbon content (FCF) (see 2006 GL, vol 5, Chap 2, table 2.4) andtherefore in terms of CH4 emission .
There is a riskq that countries make a link between the "other" category in thecomposition table (2A2) and the "other, inert waste" category in table of default values
proposed in the the2006 GL . This would result in an underestimation of emissions.

FranceAccepted

Please see comment 4922.

5226

5

2

189

189

Waste composition provided for France is supposed to come from Dong Qing Zhang etal. (2010) "Municipal solid waste management in China: Status, problems andchallenges". This document does not include any waste composition for France. Pleasecheck the references.

FranceAccepted

Please see comment 4924.

6428

5

2

289

289

Change: 'Approved CDM methodology' to: 'The approved CDM methodology'.

Australia

Accepted

SOD Volume 5 Chapter 2 from lime 191-395 are references section. This
comment is belong to Chapter 3 which is revised as suggested in the final draft.

6430

5

2

293

293

Change: 'Aerobic pathway' to: 'The aerobic pathway'.

Australia

Accepted

SOD Volume 5 Chapter 2 from lime 191-395 are references section. This
comment is belong to Chapter 3 which is revised as suggested in the final
draft.

6432

5

2

300

300

Change 'woking' to 'working'Australia

Accepted

SOD Volume 5 Chapter 2 from lime 191-395 are references section. This
comment is belong to Chapter 3 which is revised as suggested in the final
draft.

6434

5

2

301

301

Change 'duffusively' to 'diffusively'

Australia

Accepted

SOD Volume 5 Chapter 2 from lime 191-395 are references section. This
comment is belong to Chapter 3 which is revised as suggested in the final
draft.

6436

5

2

307

307

Change: 'Anaerobic pathway' to: 'The anaerobic pathway'. (In general, the new text
would benefit from a spellcheck and edit by a native English speaker.)

Australia

Accepted

SOD Volume 5 Chapter 2 from lime 191-395 are references section. This
comment is belong to Chapter 3 which is revised as suggested in the final
draft.

Comment ID Volume

To lineComment

Country

Response

5214

5

Chapter From line
2

62

62

FranceNoted

See comment 4912 above.

5216

5

2

62

62

Table 2,1 - note 2 : "the per capita values should be multiplied with the population
WHOSE WASTE IS COLLECTED […] this encompasses ONLY urban population."In the view of an inventory compiler for waste, capacity building to non annex 1
countries, this is not complete: rural population is also generating waste (maybe withanother generation rate than urban one). These waste, even when not collected, are insome cases discharges in collective dumps out of the villages where anaerobic
decomposition definitely occurs. These emissions must be considered in the inventory toensure completeness. Otherwise there is an underestimation.
Therefore, in this view, the production ratio has to be multiplied with the TOTAL
national population AND, the fact that a part of rural waste may not be disposed in
dump/landfills could be considered using the parameter " fraction of MSW disposed to
SWDS" (and therefore has to reflect that a part of national waste is not collected) OR
could be considered using an additional national parameter "fraction of waste
collected").
Do the proposed default generation rates correspond to waste generated by the national
population only ? What about very touristic areas/countries (islands especially) where afraction of waste is generated by tourists ? Not considering tourists in the estimation of
the amount of waste disposed in landfills may lead to an underestimation.

Authors note

FranceNoted

See comment 4914 above.

6582

5

2

64

64

Unnecessary 1 or l after "material recovery"

United Kingdom (of GreatBritain and Northern
Ireland)Accepted

The "1" has been deleted.

6790

5

2

79

80

Information on the carbon content in sludge is also used in the Chapter 5 Volume 5.

6422

5

2

99

99

The data presented for waste generation in Australia and New Zealand are not accurate.
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.

6584

5

2

99

99

The text mentioned italics in table 2.1, but the table doesn't have any

7646

5

3

152

153

It would be much better if the types of waste in Table 3.0 were according to Table 3.3 in2006 IPCC Guidelines (grasses should be moderately decomposable and textiles andpaper are missing now).

6812

5

3

165

166

4796

5

3

175

Russian Federation

Accepted

Australia

Accepted withmodification

The data in table 2.1 are provided for the year 2010 for all countries forconsistency purposes in the table. In case the country has more updated data aswith the case of the quoted reference which provides data for the year 2016,
countries may use such update data for years beyond 2010 while compilingtheir inventories to enhance the estimate of their time series.

United Kingdom (of GreatBritain and Northern
Ireland)Accepted

Finland

Noted

The text has been modified to clarify that for developing countries using
regional waste generation rates provided in the updated Table 2.1 and fordeveloping countries in italics in the Table 2 A.1, the generation rates should be
multiplied by the urban population only to obtain the total waste generated in
the country since these rates assume that the waste is generated by urban
population only and not rural population.
The waste types in Table 3.0 are classified based on the degradability of waste
whereas those in Table 3.3 of 2006 IPCC Guidelines were classified based on
their degradation rate (k value). Those two classification may not necessary
match each other. For example, grass is reported to be highly decomposable but
its degradation rate is only moderate. Paper and textile are included in the table
under moderately decomposable waste category.

The description of Facultative lagoons (first note 1, now at the bottom of the page)would be better to move inside of the Table 6.1.

Russian Federation

Accepted

The text has been updated.

A guidance to adopt new MCFs by management status is necessary for the actual
estimation of emissions from this category.

Japan

Accepted

Agree that the proving the "appropriateness" should be only achieved bymonitoing or other relevant management data. We have added corresponding
sentence in this part.

1) To adopt MCFs of well-managed site, periodical monitoring of management status foreach disposal site is thought to be necessary. When there is not any information for
management status of disposal sites, MCFs should be treated conservatively as "poorly
managed". Clearly describing is better.

Text has been modifed to refer to chapter 5, volume 5Comment ID Volume

To lineComment

Country

Response5234

5

Chapter From line
3

191

191

3 categories of SWDS have been added in the table. The "poorly managed semiaerobically SWDS" is defined with very detailled managing conditions. These conditions
may be known at the level of one site but could not be estimated at the national level.
Even if a questionnaire is sent to the SWDS (for those which are not closed yet) the
fraction ofd waste disposed in such condition may evolved from one year to another.
Do you have examples of countries, having such a precise and exhaustive historical
dataset of managing parameters of its landfills ?
...so, the criteria defining if a site is "poorly managed" is too "micro" (level of a site) andshould be more "macro" to become really applicable by inventory compilers.

France

Noted

Authors note

6438

5

3

286

289

Australia

Accepted withmodification

Where there are sufficient data to do so, we have provided emission factors
and/or methane correction factors (MCFs) in Chapter 6, Table 6.3 foradditional types of treatment systems, as well as a range associated with
updated MCFs. We have now added ranges to the emission factors presented in
the table as well.

6442

5

3

286

289

Wastewater treatment and processing plant design has produced many different styles
and layouts of wastewater treatment systems.
The use of a single emission factor does not reflect the reality of each treatment plants
operational dynamic.
Perhaps a range of Emission Factors and Methane Correction Factors should be
provided to allow a tailored calculation that is more appropriate to each style and type oftreatment plant?
Currently the methods to calculate methane production rely on measures of COD/BOD
multiplied by emission/correction factors. Is it clear that the tier 3 method allows for
direct measurement of methane from a facility or sub facilities? Technology allows the
mapping of gas flux in 3D providing a more accurate measure of the true fugitive
emissions and sources.

Australia

Accepted

Updated Figure 6.2 identifies Tier 3 where facility-specific data and a countryspecific method are available.

6440

5

3

290

293

Nitrogen removal by means other than sludge is not considered in the calculation of
N2O emissions from a wastewater treatment plant.
For example in Europe algal ponds are removing nitrogen from wastewater. If algae(Nitrogen) is removed from a treatment plant how can this reduction in nitrogen load befactored into the calculation for N2O production in the wastewater treatment plant unlessthe nitrogen rich algae are considered sludge?

Australia

Rejected

N2O emission factors have been provided based on the monitoring data of fullscale wastewater treatment plans. Unfortunately, we could not find literaturereporting N2O emissions from algal pond systems. However, the amount of
nitrogen removed as a solid like algae could be taken into account in thecalculation of N2O emission from wastewater effluent discharged to aquatic
environments (updated equation 6.8).

6444

5

3

290

293

Technological improvement in instrumentation and measurement has greatly increased
the accuracy of measurement in the wastewater industry. As well as reducing the cost of
installing automated flow/gas concentration/realtime chemical analysis metering.
Currently the methods to calculate N2O production rely on measures of Nitrogenentering and leaving the treatment plant/receiving environment multiplied by emission
factors. Is it clear that the tier 3 method allows for direct measurement of N2O from afacility or sub facitly. Direct measurement methods would provide a more accurate
measurement of N2O production from each treatment plant and hence inter-plant
performance comparisons could lead to optimisation of underperforming wastewater
treatment plants.

Australia

Accepted

Direct N2O measurement in each facility is good practice. We have modified
the decision tree to more specifically note the use of direct measurement data.

4798

5

3

334

336

The title of Appendix should be changed from "Information on Estimation of CH4" to"Basis for future methodological development on Estimation of CH4"in order to clearly
indicate the position of Appendix as technical information for future methodologicaldevelopment.

Japan

Accepted withmodification

6586

5

3

51

51

Define the acronym SWDS

United Kingdom (of GreatBritain and Northern
Ireland)

Rejected

This appendix handles the information for future development of methdology
rather than the basis. Since FOD parameters suported by direct measured data
are encouraged to use in 2006 IPCC Guidelines in order to develop the
methodology. Therefore we have added the link to it in the sentences to make itclear
It is given in Chapter 1.1, Volume 5.

5228

5

5

111

111

"estimated" should be completed by "and reported"?

France

5232

5

5

183

183

Could you precise if the default CH4 EF proposed in the table 5.3A (new) correspond to
EF for the destruction step (gasifier, pyrolysis reactor) or to the complete plants
including the energy recovery system ?
It is not clear for me as in the pyrolysis scheme you are presenting an "EXTERNAL"
energy use of the pyro-gas and in the gasification scheme you are presenting thatemissions are from the "energy recovery system". However, you are proposing an EF for
both system. In order to increase transparency, you may add the "CO2, N2O, CH4"
flow.

FranceAccepted withmodification
Accepted

5230

5

5

96

96

"commingled" could be replaced by "mixed" ?

FranceRejected

In the countries that dispose the waste into SWDS with different type ofmanagement, such as Japan, survey on the ratio of each category ofmanagement is conducted and the results are reflected to their inventory.

We have changed in line with comment 1704.
Same as comment number 4930.

See response to Comment 4928

Comment ID Volume

Chapter From line

To lineCountry

Response

Table 6A.2 do not have proper heading.

Comment

ThailandAccepted

Table headings have been adjusted.

Authors note

Methane emission from wastewater discharge (domestic and industrial) to waterways(lakes, reservoirs and others) should be mentioned as a new emission source.

FinlandAccepted

Changes compared to the 2006 Guidelines have been updated and are now
located in Section 6.1.5.

914

5

6

7648

5

6

127

910

5

6

162

Solid line in Figure 6.1 may not clearly distinct.

ThailandAccepted

Figure has been updated.

912

5

6

162

Figure 6.1 has some unusual connecting lines for sludge flow.

ThailandAccepted

Figure has been updated.

6814

5

6

165

166

Detailed description of emission potential for Septic tanks in the Table 6.1 is lacking.

Russian Federation

Accepted withmodification

Table 6.1 has been revised to include an entry for septic tanks (without
dispersion fields) and septic systems (including a septic tank and a soil
disperson system). The description of emissions potential for each of thesepathways has been improved and further discussion is included in the chapter
text.

6816

5

6

165

166

It is proposed checking the use of terms "recovered" and "flared" in the Table 6.1 asaccording to IPCC guidelines CH4 can be at first recovered and then flared or
combusted (for heat/electricity).

Russian Federation

Accepted

Only the amount of CH4 recovered or flared is important for the calculation.
How to use the CH4 is just additional information. So the sentence has beenrevised to avoid confusion.

6818

5

6

165

166

It is proposed to add more clear explanations how to divide sludge treatment between
onsite and located elsewhere and add this information to the other relevant Chapters of
the Volume 5 also.

Russian Federation

Rejected

The division of emission reporting between on-site sludge treatment and sludge
treated elsewhere is not a new issue introduced in the refinement and istherefore out of scope of the refinement. It is impossible to give general advice
on whether sludge is treated on site or elsewhere since this depends on local
practice and circumstances.

6820

5

6

185

186

The description of Facultative lagoons (first note 1, now at the bottom of the page)would be better to move inside of the Table 6.1.

Russian Federation

Accepted

The text has been updated.

6822

5

6

191

192

It is not clear to which category should be classified unmanaged SWDS with depths 5 m
or greater but with low water table in the Table 3.1.

Russian Federation

Noted

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

7660

5

6

213

219

The matter that sludge removal is needed in the calculation method to describe thesituation when organic matter that would normally be removed by the system instead
pass through and are discharged to the aquatic environment is false. Instead, this matteris described accurately when measured BOD load values into waterways are used
(instead of Table 6.13 and Equation 6.3D). Particularly, these measured values aremonitored in many countries since the permission procedures obligate that.

FinlandAccepted withmodification

Countries possessing data on the BOD of treated wastewater from plants arewelcome to use this in a tier 3 method of their choosing. The guidelines cannot
describe every potential tier 3 method nor point out every place they can beused. This text relates to the Tier 1 method. Equation 6.1A has been revised toinclude TOW_EFFtreat to provide an explicit way to estimate the discharge oforganic matter to waterways in the absence of plant data. For overloaded plants,
additional methane emissions are expected from both the plant and thereceiving environment. Updated equation 6.1 and new equation 6.1A willreflect this situation. Countries with the ability to do so can replace theestimated TOW_EFFtreat with monitoring data for more accurate results.

6824

5

6

259

268

There is no explanation how to consider emissions from wastewater discharges that are
not enter aquatic environment (for example, some industrial wastewater, effluents fromseptic tanks and latrines).

Russian Federation

Accepted

Emission factors for CH4 and N20 emissions from discharges that do not enter
aquatic environments have been added to Tables 6.3 and 6.15 for domestic
WW and to Table 6.8 for industrial WW. In addition, discharge to non-aquatic
environments has been added to Table 6.1.

6826

5

6

289

292

It is proposed to check using of terms "recovered" and "flared" because according to
guidelines CH4 can be first recovered and then flared or combusted (for heat/electricity).

Russian Federation

Accepted withmodification

Only the amount of CH4 recovered or flared is important for the calculation.
How to use the CH4 is just additional information. So the sentence has beenrevised to avoid confusion.

6828

5

6

293

294

If data in the Table 6.13 include loss of organic matter to sludge and they are defaul thendefault data for sludge removal as 0 is mostly incorrect or need additional explanation.

Russian Federation

Accepted

The new approach presented in this refinement is not based on default S=0 andthe text has been updated to reflect this.

6830

5

6

310

324

It is proposed to consider adding additional steps for calculating emissions according to
the methodology given in the Chapters 3, 4, and 5 (Volume 5) but included in this
sector.

Russian Federation

Accepted withmodification

The text gives clear references which methodology to use based on thetreatment systems used on site. In addition, Step 4 has been added to the text
instructing how to estimate emissions from anaerobic digestion.

4802

5

6

329, 564, 62

In the termination of the decision trees, there are a description of “Are activity data
available to categorize discharge by type of waterbody?” or “Are activity data available
to categorize discharges to hypoxic environments?” when we use Tier 1a emission
factors.

Japan

Accepted

1541) It is necessary to provide a guidance to categorize and collect activity data for eachwaterbody to which wastewater is discharged.

We have revised our previous approach and have now provided additional
guidance on the types of activity data which allow for receiving environments to
be categorised as "nutrient-impacted" or otherwise. We have also provided
guidance on the types of activity data and where to find existing data (including
examples of existing databases online for some global regions) to help classify
wastewater discharge receiving environments by type ("nutrient-impacted" or"non-impacted"). The methodology has also been revised to a Tier 3 method
and provided with new guidance as above.

Comment ID Volume

To lineComment

Country

Response

Authors note

6832

5

Chapter From line
6

387

406

There is no explanation how to consider emissions from wastewater discharges that are
not enter aquatic environment (for example, some industrial wastewater, effluents fromseptic tanks and latrines).

Russian Federation

Accepted

Emission factors for CH4 and N20 emissions from discharges that do not enter
aquatic environments have been added to Tables 6.3 and 6.15 for domestic
WW and to Table 6.8 for industrial WW. In addition, discharge to non-aquatic
environments has been added to Table 6.1.

6834

5

6

438

439

It is proposed to consider the possibility of adding specific emission factor for sludge
digestion in Chapter 4, because value for DOC and N content in sludge is significantly
differ from the one adopted in the existing evaluation used in the Table 4.1.

Russian Federation

Rejected

The DOC of sludge was updated and considering the range of emission factor
we do not consider to introduce a specific parameter for sludge.

6836

5

6

438

439

It is proposed to check difference in data for sludge carbon content in the Table
2.4(New) Chapter 2 and Table 5.2 (UPDATED) Chapter 5 Volume 5 and explain orchange them.

Russian Federation

Accepted

Value in table 5.2 has been changed in relation to table 2.4A (New)

7656

5

6

453

501

The method for calculating activity data is incorrect. Sludges removed mainly at the endof the process cannot have considerable effects on emissions occuring mainly at the
beginning of the process. The incoming load to wastewater plants without any sludge
removals describes the activity needed for wastewater plants much better and at least, it
does not lead to underestimated emissions. In addition, it is hard to think that sludge
removal activity data in different stages (Tabel 6.12) could be obtained in any country.

Finland

Noted

The Eq. 6.1 applied on aerobic WWTP assumes that organics removed as
sludge were converted to sludge through aerobic process, thus only remaining
organics may be a source for emissions.
We are not requesting countries to obtain the data suggested, but to provide
characterisation of data on sludge they use for emission estimation.

6838

5

6

469

470

It would be better to add information is these data in the Table 6.12 for dry or wet
sludge.

Russian Federation

Accepted

All data are based on dry mass of sludge and the table has been revised to makethis clear.

7654

5

6

502

513

Please reconsider Equation 6.3C. As there are no definition or guidance what the sludge
removal instructions should be like, the parameter F i.e. the fraction of the population
managing their septic system in compliance with these (undefined, national?)
instructions remains undefined and fuzzy.

Finland

Rejected

Equation 6.3C proposed a default tier 1 methodology to estimate the amount of
TOW removed as sludge in septic tanks. Septic tanks/systems typically include
instructions on the frequency of sludge removal depending on the size of thetank and the number of poeple connected to the tank. In the absence of countryspecific information, it is considered in the methodology that 50% of the
population manage their septic tanks in compliance with the sludge removal
instructions (F=0.5). This explaination was provided from line 471 to 478 of
the SOD but some modification were made in the final version.

7658

5

6

515

529

It should be mentioned that instead of Equation 6.3D and Table 6.13 directly measured
BOD values into waterways should/could be used in countries having comprehensive
statistics.

FinlandAccepted withmodification

If users have facility-specific data and/or a country-specific method, then you
should be using higher tier methods (Tier 2 or 3). This is now clarified in thedecision tree Figure 6.2

6840

5

6

528

529

It is not clear how data from the Table 6.13 take into account the removal of organic
matter with sludge as in the lines 293-294 it is considered that default for sludge removal
is 0 (except for septic tanks). So using them with the real data for sludge removal needadditional explanation.

Russian Federation

Rejected

Default S=0 is no longer applicable and the text has been revised (seeintroduction to chapter 6). The text after the table states that the data "include
loss to sludge and biological decomposition."

6842

5

6

561

562

It would be better if industry type classification in the Table 6.14 coincide to industry
type classification in the Table 6.9 or additional explanation should be added.

Russian Federation

Rejected

Regarding the values on table 6.14, and upon further review of the data source,
we have determined these values represent emission factors for specific industry
wastewater treated in an anaerobic digester, and have removed them from thechapter.

6844

5

6

568

568

There is no explanation how to consider emissions from wastewater discharges that are
not enter aquatic environment.

Russian Federation

Accepted

Emission factors for CH4 and N20 emissions from discharges that do not enter
aquatic environments have been added to Tables 6.3 and 6.15 for domestic
WW and to Table 6.8 for industrial WW. In addition, discharge to non-aquatic
environments has been added to Table 6.1.

6846

5

6

583

591

There is no explanations how to consider emissions from wastewater discharges that are
not enter aquatic environment (for example, effluents from septic tanks and latrines),
especially taking into account information in the lines 238-239 and 243-244 Chapter 6
Volume 5.

Russian Federation

Accepted

Emission factors for CH4 and N20 emissions from discharges that do not enter
aquatic environments have been added to Tables 6.3 and 6.15 for domestic
WW and to Table 6.8 for industrial WW. In addition, discharge to non-aquatic
environments has been added to Table 6.1.

6848

5

6

618

620

It is proposed to clarify the need for summarizing results for wastewater treatments andfrom effluent because according to the IPCC Guidelines N2O emissions fromwastewater treatment effluent are indirect and emissions from wastewater treatment
plants is direct.

Russian Federation

Accepted withmodification

Emissions from effluent are no longer referred to as indirect emissions as in the2006 Guidelines to avoid confusion with indirect emissions of N2O from
deposition of nitrogen compounds. Emission from effluent is considered as
direct emission.

Comment ID Volume

Country

Response

Authors note

4800

5

Chapter From line
6677

To line678

In the new table 6.15, definition of "Hypoxic" is unclear and arise confusion when a
Party selects appropriate methodology. Therefore, quantitative criteria of "Hypoxic"
should be provided in the table 6.15.

Comment

Japan

Accepted withmodification

We have revised our previous approach and have now provided additional
guidance on the types of activity data which allow for receiving environments to
be categorised as "nutrient-impacted" or otherwise. We have also provided
guidance on the types of activity data and where to find existing data (including
examples of existing databases online for some global regions) to help classify
wastewater discharge receiving environments by type ("nutrient-impacted" or"non-impacted"). The methodology has also been revised to a Tier 3 method
and provided with new guidance as above. We have also added the terms"hypoxia" and "nutrient-impacted" to the glossary.

6850

5

6

713

717

It would be useful to add explanation that data from Household Surveys can contain
information not about all consumed protein in a country but consumed only inhouseholds.

Russian Federation

Accepted withmodification

The Household Surveys in FAO database do not present sufficient information
on protein consumed and reference to them was deleted from the text.

6852

5

6

723

724

It is not clear what set of data from the Table 6.16 inventory compliers will need to use if
activity data based on protein available is multiplied by default data for fraction ofprotein consumed (from the lines 716-717).

Russian Federation

Accepted

The section was reformulated, parameters were simplified, and method ofemission estimation was adjusted.

6854

5

6

723

724

In-sink disposal and waste bin disposal in the Table 6.16 need more clear indication in
the text (especially terminology "waste bin"). Also it is not clear how to use two Fnoncon factors in the Equation 6.10

Russian Federation

Accepted

The section was reformulated, parameters were simplified, and method ofemission estimation was adjusted.

7650

5

6

729

753

It should be mentioned that instead of Equation 6.8 and Table 6.17 directly measured N
values into waterways should/could be used in countries having comprehensive statistics.

FinlandAccepted withmodification

If users have facility-specific data and/or a country-specific method, then you
should be using higher tier methods (Tier 2 or 3). This is now clarified in thedecision tree Figure 6.2

6856

5

6

766

768

There is no explanation how to consider emissions from wastewater discharges that are
not enter aquatic environment.

Russian Federation

Accepted

Emission factors for CH4 and N20 emissions from discharges that do not enter
aquatic environments have been added to Tables 6.3 and 6.15 for domestic
WW and to Table 6.8 for industrial WW. In addition, discharge to non-aquatic
environments has been added to Table 6.1.

6858

5

6

777

779

It is proposed to clarify the need for summarizing results for wastewater treatments andfrom effluent because according to the IPCC 2006 guidelines N2O emissions fromwastewater treatment effluent are indirect and emissions from wastewater treatment
plants is direct.

Russian Federation

Accepted withmodification

Emissions from effluent are no longer referred to as indirect emissions as in the2006 Guidelines to avoid confusion with indirect emissions of N2O from
deposition of nitrogen compounds. Emission from effluent is considered as
direct emission.

6860

5

6

804

807

There is no explanation how to consider emissions from wastewater discharges that are
not enter aquatic environment.

Russian Federation

Accepted

Emission factors for CH4 and N20 emissions from discharges that do not enter
aquatic environments have been added to Tables 6.3 and 6.15 for domestic
WW and to Table 6.8 for industrial WW. In addition, discharge to non-aquatic
environments has been added to Table 6.1.

7652

5

6

850

863

It should be mentioned that instead of Equation 6.14 and Table 6.17 directly measured N
values into waterways should/could be used in countries having comprehensive statistics.

FinlandAccepted withmodification

If users have facility-specific data and/or a country-specific method, then you
should be using higher tier methods (Tier 2 or 3). This is now clarified in thedecision tree Figure 6.2

6862

5

6

947

950

The purpose of this statement is unclear, it is necessary to clarify the need for calculation
or remove it.

Russian Federation

Accepted withmodification

This text was incorrectly labelled as an Annex in the second order draft and thishas now been corrected to an Appendix in the final draft, therefore thestatement remains relevant for future Guideline development906

5

Annexes

Annex 2A.2 should have table heading similar to Table 2A.1.

ThailandCorrection has been made.

908

5

AnnexesThailand data in Annex 2A.2 are not officially updated and not originally fromcorresponding agency in Thailand.

ThailandAccepted withmodification
Accepted

Updated with data from Pollution control department from Thailand.

Comment ID Volume
1784

General

Chapter From line

To lineComment

Country

Response

Authors note

The Chinese government appreciates and thanks the Bureau members, Lead Authors andthe TSU of the Intergovernmental Panel on Climate Change (IPCC) for the
Methodology Report of 2019 Refinement to the 2006 IPCC Guidelines for National
Greenhouse Gas Inventories for their hard efforts to prepare this report. In order to makethe IPCC assessment report more scientific, comprehensive and balanced, and taking
into full account the rationality and operability of the reported findings when they areapplied, the national government has put forward the following comments in the hopethat they can be adopted in the revision process.
1. Erroneous statements of China's sovereignty. There are common sense errors
concerning Hong Kong and Macao, China, in the report (Vol. 5, Chapter 2, page 188).
Correction must be made to all these errors, including but not limited to those mentioned
in proposed amendments in the review comments, and it is hoped that such errors will nolonger occur in future reports.
2. Some of the formulas in the report are not rigorous or normative. As it is a widelyused methodology report, accurate formulas are especially important. Considering the
problems of ambiguity, inconsistent citation and dimensional errors in some of theformulas in the report, it is suggested to correct them altogether.
3. The readability of the report to be increased. There are many problems in the report interms of linguistic logic, consistency and text editing, especially errors in serial number
when mutual or cross quotations occur between unrevised and revised parts. At the sametime, for the newly added chapters such as texts on GHG concentration measurement
and inversion models, it is suggested to give them the science-based definitions, andindicate the formulas involved and their sources, as well as their application range anduncertainty. For example, 419-420, 540-546 and 607 in Ch-6, Vol1. It is suggest that theoverall revision be made to increase the readability of the report.
4. With regard to newly added or revised texts, it is suggested to cite more literaturefrom developing countries to improve the integrity and practicality of the guidelines.

China

Accepted withmodification

Copied from "General" comments.
1) These have been corrected in table 2A.1 2) Noted
3) Noted 4) In
chapters 2 and 5 references from developing countries have been introduced.