Review comments by Experts on First Order Draft of Volume 2 of 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories
Comment ID Volume

Chapter From line To line

5644

2

4

247

4462

2

4

4464

2

4466

2

5646

247

Comment

ExpertResponse

Authors note

Javier Marcelo Hanna
Figueroa
KEWEI YU

Accepted255

It seems the bullet for this line is missing. Add the symbol of bullet before of: "Seamgas emissions…".
CH4 not methane, be consistent

4266

CH4 not methane, be consistent

KEWEI YU

Accepted

4287

CH4 not methane, be consistent

KEWEI YU

Accepted

2

4

300

300

Replace "these sources" by "coal gas drainage wells".

Javier Marcelo Hanna
Figueroa

Accepted

Accepted to avoid ambiguity. The sentence may be rewritten as under:
Fugitive emissions from coal seam gas drainage wells are already counted in
Underground and Surface Mining Activities.

5648

2

4

314

314

Table 4.1.1 would benefit of adding a column indicating the availability of default EF Javier Marcelo Hanna(and related gas) at the level of each category/subcategory, as well an indication of the Figueroa
methods available in the Refinement/Guidelines (tier 1, tier 2, tier 3).

Noted

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

5650

2

4

314

314

Instead of "Sector name", the heading of the second column should be"Category/subcategory".

Javier Marcelo Hanna
Figueroa

Accepted

The heading of the Table column has been changed into
"Category/Subcategory".

5652

2

4

327

327

After "other coal mining sources" it would be good to illustrate to what are thosesources referred, mention at least two examples.

Javier Marcelo Hanna
Figueroa

Accepted

5654

2

4

349

349

The part of the sentence "augmented during the period" is unclear. To what period are Javier Marcelo Hanna
you referring? What is the meaning of amount augmented? Please clarify with clearer Figueroa
langauge.

Accepted

Accepted to clarify. The sentence has been rewritten as Emission duringexploratory borehole drilling may be largely associated to the amount ofcoal or lignite added to the resources during the reporting period..

4468

2

4

352

lower "global warming", not "greenhouse"

KEWEI YU

Noted

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

5552

2

4

368

368

If parts shaded in grey means unchanged text, therefore, "included in the guidelines
for the first time" is no longer needed as it was included before.

Marie-Eve Bonneau

Noted

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

554

2

4

391

392

It is rather strange to read here implicitly that CO2 could be utilized for energy
production or flaring. CO2 does not burn and therefore can not be used as such.
I assume that the authors refer to the possibility that CO2 might be present in the
mixture of gases fed into a burner or a flare. These lines therefore might need a bit
rephrasing. At the same time it could be mentioned that this CO2 then should bereported as originating from energy or from flares.

Tinus Pulles

Accepted withmodification

Equation 4.1.2 says that "the amount of CO2 contained in the gas recovered
and utilized for energy production or flared" should be taken into accountby the subtraction item; it does not imply that CO2 could be utilized forenergy production or flaring. In the SOD, Further explanation has been
provided in the paragraph just below the Equation 4.1.2, to avoid that kindof misunderstanding.

5554

2

4

392

392

Marie-Eve Bonneau
Why "CO2 contained in the gas recovered and utilized for energy production orflared" is substracted from emisions from underground mining CO2? When recovered
and utilized, this CO2 will remain CO2 and will be released. Is it because it isincluded elsewhere?

Accepted

Further clarification has been provided in the SOD.

5656

2

4

396

399

The langauge here neeeds some elaboration to take into account that equation 4.1.2
also presents CO2. It should be showed the link between CH4
recovered/utilized/flared and CO2 "contained in the gas" recovered/utilized/flared.

Accepted

Further clarification has been provided in the SOD.

Javier Marcelo Hanna
Figueroa

Accepted

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

5556

2

4

425

428

Is the source insignificant when compared to not gassy undergroud cole mines? If the Marie-Eve Bonneau
source is significant, consider adding a methdology.

Accepted withmodification

Coal low temperature oxidation is one among other CO2 sources frommining activity and elaborated CO2 EF of includes emissions from coal lowtemperature oxidation.

5658

2

4

437

437

I am not sure if there is a tier 3 method for CO2 from underground mines. Is it related Javier Marcelo Hanna
to measurements? Not aware of this practice and if exist how wide it is spread across Figueroa
the world. Please confirm.

Accepted withmodification

Tier 3 method is the direct measurement of CO2 emissions from anunderground coal mine ventilation air, based on gas composition andvolume flow. Essentially it is the same as a CH4 Tier3 method except
utiliases the CO2 gas composition. This will be made clearer in the text.

5558

2

4

450

450

Change Ch4 for CH4

Marie-Eve Bonneau

Noted

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

53

2

4

473

477

China is mentioned in line 475 but there is no reference for it. The semicolon ";"maybe an spelling error.

Mingshan Su

Accepted

Reference added.

5660

2

4

474

477

Javier Marcelo Hanna
The meaning of "for the coal mining countries and regions" is unclear, it would be
Figueroa
better to indicate "of the following countries". Otherwise looks that EFs have been
derived only for those countries and the regions in which they are located. My guess isthat the default EFs presented are applicable for any country, without restriction, if nocountry-specific data available. The references in brackets should not be located after
the full stop. Czech Republic should be changed to Czechia as this is the new name of
the country (check).

Accepted withmodification

After consulting the UN reference for Czech Republic(https://unterm.un.org/UNTERM/Display/Record/UNHQ/NA/4275087d4018-4082-899d-95f37efeda65), the authors have decided to keep using thelong form name.

8998

2

4

485

488

CO2 emission factor (low, ave, high) are representative of whole globe or just few
countries in line 476,477

Tiwari Yogesh

Noted

The Tier 1 emission factors are global defaults for application by all
countries. A Tier 2 method is also available where countries can develop
country-specfic emission factors based on data collected from own theircoal mines.

9000

2

4

485

488

Unit of emission factor is "meter cube per ton CO2". As its indicator of emission,
should it be "ton CO2 per Megawatt"?

Tiwari Yogesh

Rejected

The emission factor unit is cubic metre per tonne of underground coalproduction.

4158

2

4

485

488

CO2 emissions emission factors are proposed in the new guidelines for underground Eleonora Di Cristofarocoal mining. CH4 emission factors of 2006 IPCC Guidelines (IPCC, 2006) are
confirmed in the new guidelines. The proposed CO2 emission factors are significantly
higher (from 2.6 to 9.1 times) those obtained considering the species profile in coalmine gas by literature data (EMEP/CORINAIR, 2007), 80% of CH4 and 6% of CO2
by volume (Williams, 1993).

Accepted withmodification

The lower and average CO2 emission factors have been modified andreduced remarkedly after representative data from more countries have beentaken into account.

5662

2

4

486

488

It would be good to provide some very short information on the conditions given for
application of the lower and higher end of the range of the default EF. This comment
would be applicable to all EFs provided with a range in the Guidelines (this chapter).

Javier Marcelo Hanna
Figueroa

Accepted withmodification

The text currently suggests factors that may influence the level of the CO2
emission factor. Guidance will be also be provided for the higher end of therange to indicate that where CO2 outbursts have been frequently observed
as a safety issue in mining, then a country should consider the use of thehigh end emission factor. It is difficult to add further specific guidance forthe lower end of the range to that already provided as the lower end can beinflenced by many local/coal basin factors. A better understanding of theCO2 levels in underground mines are best gained through sampling andanalysis of mine air ventilation flow. The addition of guidance for existing
emissions factors currently in the 2006 IPCC Guidleines is outside thescope of this refinement.

Comment ID Volume

Chapter From line To line

Comment

ExpertAuthors note

Noted

It is noted that Japan's CO2 emission factor is significantly lower than thatof other coal mining countries. There is significant inherent variablity
observed in the CO2 content of coals. In recognising this, the refinement of
the IPCC guidelines has also made available a Tier 2 method which
provides the flexability for countries such as Japan can make use ofcountry-specific emission factor, rather than using the Tier 1 default
emissions factors.

Is there in the data analysed any correlation between CO2 and CH4 emission rates, i.e. Ole-Kenneth Nielsen
could it be assumed that a mine with high CH4 emissions would also have high CO2emissions? Whether there is a correlation or not, it is relevant that this is mentioned.

Accepted

The text has been modified accordingly; The authors also decided to analyze
and address the issue of correlation between CO2 and CH4 emission rates
in the Second Order Draft.

In accordance with comment above for tier 3 for CO2. If really exist such practice, it Javier Marcelo Hanna
would be good to add some words on this and clarify the current technical knowledge. Figueroa

Accepted withmodification

Tier 3 based on directly measured data from coal mines and technicalpossibility of measurement was known from last century.

25-40%KEWEI YU

Rejected

The authors have decided to use "percent" in text and "%" in tables.

553

If parts shaded in grey means unchanged text, therefore, "This represents a departurefrom the previous guidelines" is no longer needed as it was included before.

Marie-Eve Bonneau

Noted

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

577

577

Change (a) to (b)Marie-Eve Bonneau

Accepted

Has Changed (a) to (b) as (a) corresponds to the first eaquation inside thebox corresponding to EQUATION 4.1.5

4

580

580

Change "oxidised" to "flared" to reflect the term used into the equation 4.1.5

Marie-Eve Bonneau

Noted

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

2

4

584

Gas? letter case

KEWEI YU

AcceptedHas changed "gas" to "Gas".

5566

2

4

631

Marie-Eve Bonneau
If parts shaded in grey means unchanged text, therefore, "This is a departure fromprevious guidelines which suggested that the methane emissions or reductions only be
accounted for during the year in which the coal was produced (e.g. the degasification
wells were “mined through.”)" is no longer needed as it was included before.

Noted

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

4474

2

4

658

better use 50%

KEWEI YU

Rejected

The authors have decided to use "percent" in text and "%" in tables.

4476

2

4

679

flow rates

KEWEI YU

Accepted

Has inserted a space between "flow" and "rates".

4478

2

4

739

CH4 Emission, a space

KEWEI YU

Accepted

Has inserted a space between "CH4" and "Emission".

5570

2

4

750

777

Same sentence 750-751 and 776-777. Suggest to remove one.

Marie-Eve Bonneau

AcceptedHas deleted lines 750-751…
The other place makes more sense.

5568

2

4

753

754

Some font size are smaller

Marie-Eve Bonneau

Accepted

Font size of "data reported to the Australian National Greenhouse andEnergy Reporting program for years 2009-17 and measurements of gas in
Kazakhstan surface mines." has been enlarged to size 10 instead of 9.

4230

2

4

486

488

Japan estimates the CO2 emission factor (EF) of underground mines by multiplying
the volume basis CH4 EF by 0.0088 (see National Greenhouse Gas Inventory Reportof Japan, 2017, page 3-72). The CO2 EF could be 0.088 - 0.22 m^3/t if the default
CH4 EF (10 - 25 m^3/t) and the Japan's factor would be applied. The proposed EF in
FOD is 3.5 - 12.3 m^3/t. The order of magnitude is inconsistent between them. I
would appreciate it if the authors would reconfirm the proposed EF. I also take notethat Japan's data may not be always representative of global average.

8762

2

4

492

494

5664

2

4

502

502

4470

2

4

521

5560

2

4

553

5564

2

4

5562

2

4472

633

Naofumi Kosaka

Response

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

5666

2

4

753

755

It seems that a mention to Japan's reporting/measurements is missing at the beginning Javier Marcelo Hanna
Figueroaof the sentence, because in the brackets there is a reference to the MoE of Japan.
Check.

AcceptedHas modified the text accordingly.

5668

2

4

753

755

It would be good to provide some very short information on the conditions given for
application of the higher end of the range of the default EF.

Javier Marcelo Hanna
Figueroa

Accepted

Guidance has been provided that it is good practice to use the high CO2emission factor for those mines with overburden depths over 50 meters.

4160

2

4

766

768

CO2 emissions emission factors are proposed in the new guidelines for surface coalmining. CH4 emission factors of 2006 IPCC Guidelines (IPCC, 2006) are confirmedin the new guidelines. The proposed CO2 emission factors are significantly higher(from 4.1 to 10.5 times) those obtained considering the species profile in coal minegas by literature data (EMEP/CORINAIR, 2007), 80% of CH4 and 6% of CO2 byvolume (Williams, 1993).

Eleonora Di Cristofaro

Accepted withmodification

The lower and average CO2 emission factors have been modified accordingly

4232

2

4

766

768

Naofumi Kosaka
Japan estimates the CO2 emission factor (EF) of surface mines by multiplying thevolume basis CH4 EF by 0.0088 (see National Greenhouse Gas Inventory Report ofJapan, 2017, page 3-75). The CO2 EF could be 0.003 - 0.018 m^3/t if the default CH4
EF (0.3 - 2.0 m^3/t) and the Japan's factor would be applied. The proposed EF in FOD
is 0.37 - 0.94 m^3/t. The order of magnitude is inconsistent between them. I would
appreciate it if the authors would reconfirm the proposed EF. I also take note thatJapan's data may not be always representative of global average.

Noted

It is noted that Japan's CO2 emission factor is significantly lower than thatof other coal mining countries. There is significant inherent variablity
observed in the CO2 content of coals. In recognising this, the refinement of
the IPCC guidelines has also made available a Tier 2 method which
provides the flexability for countries such as Japan can make use ofcountry-specific emission factor, rather than using the Tier 1 default
emissions factors.

1478

2

4

771

771

To maintain consistency between the methane and carbon dioxide volume to massconversion factors it is proposed to limit rounding to 2 decimal points, i.e. write 1.84
instead the 1.839 (10-6 Gg m-3)

Accepted

1.839 has been rounded to be 1.84.

8764

2

4

772

775

Is there in the data analysed any correlation between CO2 and CH4 emission rates, i.e. Ole-Kenneth Nielsen
could it be assumed that a mine with high CH4 emissions would also have high CO2emissions? Whether there is a correlation or not, it is relevant that this is mentioned.
Also, the basis for recommending the lower value for mines with an overburden depth
less than 25 meters should be provided including a proper reference.

Accepted withmodification

There is no useful correlation between methane and carbon dioxide
emission rates for the purposes of estimating tier 1 emissions from coalmining. This is a consequence of the two gases having different origins that
may take place at different time scales amd periods. Methane is derived
from coalification and/or microbial processes whereas carbon dioxide isoften derived from magmatic activity at more recent geological periods. The
final gas composition is the intergation of those past processes plus theopportunity to escape as a reult of surface weathering. A note of the lack ofusefule correleation between the gases will be inserted in the text. The
basis for reccomending the lower value for mines with overburden less than
25 metres is to align with the existing reccomendation structure for methane
in the 2006 Guidleines. Underpinning this assumption is the general
understanding that those coal deposits closer to the surface will tend to be oflower gas concentration as a result of interaction with surface weathering
processes which provide pathways for gas to escape to the atmosphere overgeological time scales.

Michael Gytarsky

Comment ID Volume

Chapter From line To line

Comment

ExpertMarion Pinterits

Response

Authors note

Accepted

5190

2

4

1148

1197

Please clarify the meaning of 'Augmentation of Resource'. Under subchapter 4.1.6.3
Choice of Activity Data (starting at line 1190) the provided description is not clear atall. It would be helpful to provide some examples of potential activities.

8766

2

4

1151

1151

The sentence "Since this information is not readily available in the exploration or any Ole-Kenneth Nielsen
other report." seems to be missing something.

Accepted

The sentence should be modified as "This information is not readily
available in the exploration or any other report."

5572

2

4

1151

1151

The folowing sentence is incomplete : Since this information is not readily available in Marie-Eve Bonneau
the exploration or any other report.

Accepted

The sentence should be modified as "This information is not readily
available in the exploration or any other report."

5670

2

4

1151

1153

The sentences starting from "Since this information…" and ending in line 1154, need Javier Marcelo Hanna
Figueroa
editorial checking and improvement. It is very unclear the link among the threesentences there. What is the relation among lack of highly technical information
around exploration boreholes and updating of an inventory? How updating of an
inventory could be part of coal exploration? what is the meaning of annual
augmentation of coal resources? There is a clear definition of this term? Pleaseconsider carefully these issues and improve the guidance provided, in particular define"annual augmentation of coal resources" and "coal resource" or "resource". Thisshould be made clearly in section 4.1.6.3.

Accepted

The paragraph may be rewritten as "However, annual updating of national
inventory of coal and lignite resources is an integral part of exploration forthese minerals. Therefore, augmentation of coal resources in a reporting
year over that of the preceding year can be easily estimated by subtracting
the resources of the current year and that of the preceding year, and may be
used as activity data for exploration boreholes. It may not be out of place tomention here that the augmentation of coal resources is the additional
resource of coal found during exploration in a reporting year which gives
current resource when added to the previous year’s resource. Further, theaugmentation of coal or lignite resource is linked to the drilling performed
in a year and hence to the number of exploration boreholes drilled."

5574

2

4

1152

1152

The folowing sentence is unclear. Specifying which National Inventory could help. Is Marie-Eve Bonneau
it the inventory of coal or lignite resources?

Accepted

The words "National Inventory" have been replaced with "the national
quantity of coal and lignite resources"

8768

2

4

1152

1154

The sentence "However, annual updating of National Inventory is an integral part ofcoal exploration. Therefore, augmentation of coal resources in a year over that of thepreceding year can be easily ascertained and may be used as activity data for
exploration boreholes." is very difficult to understand. The first part that annual
updating of the national inventory (emission inventory?) is an integral part of coal
exploration does not make sense. Also, it is not clear how "augmentation of coalresources" (increase in coal production?) could be used as activity data for coal
exploration. This part needs further elaboration.

Ole-Kenneth Nielsen

Accepted

Changes made above against comment number 5670 takes care of comment
number 8768 .

1480

2

4

1152

1189

Michael Gytarsky
The use of augmentation of coal reserves as an activity data for estimation methane
emissions from exploration boreholes may result in overestimation of exploration
emissions. This is because not all methane releases from augementation coalbed
through the exploration boreholes. With this, additional justification for theaugmentation of coal reserves as the activity data for these particular estimates isrequired. Otherwise it is recommended to reconcile the activity data proposed for thiscategory source.

Accepted

Changes made above against comment number 5670 takes care of comment
number 1480 .

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

5672

2

4

1156

1157

This sentence seems to be incomplete. It looks that a conclusion is lacking after thestatement. Is the reason that an EF based on other parameter was not possible todevelop (number of [new] mines in a year, production, etc.)? Complete, clarify.

Javier Marcelo Hanna
Figueroa

Accepted

The paragraph to be rewrittem as "No results are available in the literature
on measurement of fugitive emission specifically from coal exploration
boreholes. However, emission factors provided below are as per expert
opinion. Since the exploration boreholes are filled with water or mud, thehydrostatic pressure on the coal seams encoutered will be significant.
Accordingly, emission factors for exploration boreholes are supposed to besmall compared to those of coal mining.

8774

2

4

1156

1189

It is stated that there are no data available in the literature on fugitive emissions from Ole-Kenneth Nielsencoal exploration, yet default emission factors are included. This begs the question of
how the default EFs have been determined and the validity of them. The assumptions
should be made clear to allow for a review of the suggested EFs and if no data are
available, it could be considered premature to include a methodology and default EFs
without any scientific basis.

Accepted

Changes made above against comment number 5672 takes care of comment
number 8774 .

5576

2

4

1160

1160

Lacking what this tier 1 method apply: Coal exploration boeholes fugitive methane
emissionsMarie-Eve Bonneau

Accepted

Changed "TIER 1: GLOBAL AVERAGE METHOD" to "TIER 1:
GLOBAL AVERAGE METHOD - FUGITIVE EMISSION FROM COAL
EXPLORATION BOREHOLES"

8770

2

4

1166

1166

What is meant by "Augmentation of Resource"?

Ole-Kenneth Nielsen

Accepted

Changes made above against comment number 5670 takes care of comment
number 8770 .

4234

2

4

1168

1186

I suggest that the authors specify which literatures are cited to determine the default
emission factors of coal exploration.

Naofumi Kosaka

Accepted

Text has been added under section 4.1.6.2 "emission factors provided below
are as per expert opinion.".

8772

2

4

1176

1176

Equation 4.1.15 for tier 2 should be amended to show that it should be summed overthe different depth ranges.

Ole-Kenneth Nielsen

Accepted

Equation 4.1.5 has been modified accordingly.

5578

2

4

1176

1176

Lacking what this tier 12method apply: Coal exploration boeholes fugitive methane
emissionsMarie-Eve Bonneau

AcceptedHas been addressed in the Second Order Draft.

4480

2

4

1191

activity? Letter case

KEWEI YU

Accepted

The word "Activity" in line 1191 has been changed into "activity".

5674

2

4

1191

1197

Include the definition of "resource", "category-wise net augmentation of quality-wise Javier Marcelo Hanna
resource" and "increase of depth-wise resource". How the two last may correspond to Figueroa
higher tiers? Complete.

AcceptedHas been addressed in the Second Order Draft .

8776

2

4

1191

1197

It is still not clear what is meant by "Augmentation of Resource". Should this beinterpreted as simply the difference in production between two years? If so, I thinkthat it is unlikely that changes in production would be an accurate proxy for coal
exploration. This should be further elaborated.

Ole-Kenneth Nielsen

Accepted

Elaboration made above against comment number 5672.

5580

2

4

1194

1194

Suggest the following equation instead: Augmentation or New Addition = (Resource Marie-Eve Bonneau
for a year-mine abandonned during that year) – (Resource for the previous year - mine
abandonned during that year)

Rejected

Emissions are being estimated from exploratory drilling of boreholes andsuch holes are never made in the command area of an abandoned mine. In
fact, drilling through disturbed zone is very difficult due to geotechnicalreasons. Secondly, there is no need of coal exploration in the leasehold areaof a mine which is going to be abandoned in near future.

Comment ID Volume

Chapter From line To line

5676

2

4

1198

4482

2

4

1265

6706

2

4

1280

8778

2

4

9912

2

5678

2

1203

Comment

ExpertResponse

Authors note

Commenting on these sections should be possible for experts before Governmental
review.

Javier Marcelo Hanna
Figueroa

Noted

Chapter 8? Letter case

KEWEI YU

AcceptedHas been addressed in the Second Order Draft.

1323

Clarify how reporters should determine if emissions from co-producing wells belong
in Natural Gas Systems or Petroleum Systems.

David Lyon

Accepted

Added footnote upfront and text in the tier 1 EF sections for explorationand production.

1280

1280

Considering the expansion to reflect town gas and biogas, the chapter should be
renamed in order not to just reference oil and natural gas.

Ole-Kenneth Nielsen

Noted

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

4

1280

1281

The new draft guidance on fugitive emissions from oil and gas systems, particularly Irving William
unconventional techniques, is critically important for keeping the IPCC Gl relevant tochanging conditions in this important industry.

Noted

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

4

1287

1287

1.B.2 Fugitive emissions from oil and natural gas systems is to be considered acategory and not a subcategory (of the fugitive emissions "category"). In that sense(and undersatnding that the scope of the Refinement is not to do this improvement),
the use of terms "category" and "subcategory" should be standardized across allvolumes and sectors of the 2006 IPCC Guidelines and the 2019 Refinement. For atime being there is inconsitency in the treatment of these terms across the guidelines.

Javier Marcelo Hanna
Figueroa

Accepted withmodification

Category, subcategory and segment have been polished throughout thechapter to imporve consistency.
Text was added to glossary.

1670

2

4

1294

1294

This document mentions NMVOCs, so wouldn't fugitives include these too?

Adam Eisele

Noted

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

5582

2

4

1295

1296

Why area fugitive emissions (from oil sands mining mine surface and tailing pond)
are not included?

Marie-Eve Bonneau

Accepted withmodification

Added a footnote under table 4.2.4, saying the fugitive emission fromtailings ponds and the exposed mine surface has included in the Efs of Oil
Sands Mining and Ore Processing.

1672

2

4

1297

1297

instead of "deliver", would it be more appropriate to use "transport" or "distribute"?

Adam Eisele

Rejected

Existing language is clear.

10006

2

4

1298

1298

Miriam Lev-On
Recommend striking out the phrase "including fugitive emissions from appliances".
End-Use emissions should not be aggregated with emissions from operations of
natural gas systems. End use emissions, including gas fired appliances, vary widely bycountry and region. These emissions should be reported separately in a mannerconsistent with the approach utilized for the use of natural gas for transportation andindustry, which are excluded from Distribution emissions.

Rejected

Emissions from internal piping and leakage of end-use appliances are partof the chain from production to final use. Hence, they have to be reported in
the chapter of fugitive emissions.

10008

2

4

1308

1309

Recommned amnding the sentence to read: "... occur at industrial facilities and due to Miriam Lev-On
use of gas appliances....". Fugitive Emissions from gas appliances should be includedin the Product Use Volume (Volume 3 Chapter 8). Chapter 8 addresses, “Other
Produce Manufacture and Use”. A NEW subchapter could be developed to include a
range of methane emissions from Natural Gas use (in a manner similar to section 8.4
on N2O from product use).

Rejected

Emissions from internal piping and leakage of end-use appliances are partof the chain from production to final use. Hence, they have to be reported in
the chapter of fugitive emissions.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

8780

2

4

1308

1309

This statement is very confusing as for example in the IPPU chapter on metal
production there is a reference to this chapter related to emissions from flaring. It
should be coordinated between the different sectors (Energy, IPPU and waste) where
methodological descriptions and EFs should be presented for flaring in other than oil
and natural gas installations, i.e. where is the guidance on estimating emissions fromflaring associated with industry (other than oil and natural gas) and waste handling?

Ole-Kenneth Nielsen

Rejected

The scope is clear: oil and gas system.

5680

2

4

1323

1323

Footnote 2: In second line, better use "town gas" instead of "coal gas". In the first line, Javier Marcelo Hanna
it should read "a manufactured gaseous fuel", instead of "fuels".
Figueroa

Accepted

Text was replaced.

1674

2

4

1327

1327

Should working losses be added here?

Adam Eisele

Accepted

Revised text to show that working losses are included.

1676

2

4

1328

1329

Suggest using "…, while leak emissions are unintentional (or uncontrolled)"

Adam Eisele

Accepted

10010

2

4

1352

1360

Recommend adding here that there is a distinction between hydraulic fracturing
practices - such as the use of reduced emissions completions - in different countries
that greatly impact the atmospheric emissions associated with unconventional
completions.

Miriam Lev-On

Accepted

10012

2

4

1360

Recommendations for revision or insertion of new terms will be provided below aspart of the comments to the Annex of Terms.

Miriam Lev-On

Noted

4236

2

4

1362

1369

Figure 4.2.1 is very user-friendly.

Naofumi Kosaka

Noted

5682

2

4

1363

1368

In both of these figures under Figure 4.2.1, it would be good to show for each of thesegment with small arrows the ocurrence of fugitive, flaring and venting emissions
with showing the gases involved. These is clear needed in accordance with thehaeding of the figure. Replace "petroleum" by "oil" in the titles.

Javier Marcelo Hanna
Figueroa

Accepted withmodification

The figure title change to match caption has been addressed in the Second
Order Draft, as it was difficult to illustrate "occurrence of emissions andgases involved" within the figure Accepted change of "petroleum" to "oil".

5684

2

4

1363

1364

Javier Marcelo Hanna
Under the distribution segment, you may delete "evaporative losses" as you areshowing more the activities in the chain and not this type of losses that may occur also Figueroa
in othe segments. Under the refining segment, change "lubes" by "lubricants",a sthis
the term used elsewhere in the guidelines.

Accepted withmodification

Evaporation is dominant in this part and should remain, as it is included inTable 4.2.15. Changed "lubes" to "lubricants".

10014

2

4

1366

1367

Figure 4.2.1 should be amended since sources in the natural gas systems should notinclude leakage from end users. As such, distribution emissions should only include
vents and leaks associated with distribution pipelines but not those that occur at thecustomer side when using gas appliances.

Rejected

Both should be included; by definition IPPU sector includes GHGs fromindustrial processes, use of GHGs in products (specifically, F-gases), andnon-energy use of fossil fuels. Therefore, natural gas appliances do not fit
in IPPU sector because it is an energy use of fossil fuels.

5686

2

4

1367

1368

Delete the green CCS arrow, it is not related to the natural gas chain.In the distribution Javier Marcelo Hanna
segment, delete the lower part of the picture (Not included) as it is irrelevant. You
Figueroa
may keep the power plant and the industry icons to be connected to the distribution
network of the upper figure. In the upper figure you better show a distribution gas
network (with houses and others), together with the appliances shown. No need to put
the word "Included" and instead of "fugitive emissions past city gate" simply indicate"distribution network past city gate".

Accepted withmodification

Kept the qualifying statement "not included" for clarity; deleting it may be
more confusing. Added a "distribution gas network" between
houses/factories/appliances. Adopted wording "distribution network pastcity gate".

Miriam Lev-On

Added text.

Comment ID Volume

Chapter From line To line

Comment

4484

2

4

1373

1374

formation of

2364

2

4

1381

1381

1682

2

4

1396

2362

2

4

6704

2

5688

Expert
KEWEI YU

Response

Authors note

Rejected

The correct terminology is "formation CO2".

FIJI GEORGE
Starter motors on compressors engines are not considered pneumatic devices in thesame sense as a pneumatic controller or chemical injection pump. Classifying starter
motors in the same group as pneumatic controllers could lead to inappropriate
application of pneumatic controller emission factors.

Noted

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

1397

Should this sentence include waste gas characterisitcs such as energy content (HHV)? Adam Eisele

Accepted withmodification

Revised as: The decision on whether to vent or flare depends largely on theamount and energy content of the gas to be disposed of and the specificcircumstances (e.g., public, environmental and safety issues as well as local
regulatory requirements) (line 1395-1397).

1399

1400

The statement "Waste gas volumes are usually vented on gas transmission systems and FIJI GEORGE
may be either vented or flared on gas distribution systems…" is incorrect.
Transmission pipeline systems may have flares at the compression stations. It is veryrare to have a flare on a gas distribution pipeline or station.

Accepted"flaring" is deleted.

4

1413

1420

Provide more information about O&G CH4 emission assessment issues. For example, David Lyon
component-level measurements tend to underestimate site-level emissions due toissues such as inaccessible or difficult to measure sources.

Noted

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

2

4

1430

1432

Javier Marcelo Hanna
Please check carefully the language in this sentence, as it could be interpreted as adeviation of the general principles establshed in the decision trees for methodological Figueroa
choice. Remember that the recommended disaggreagtion for the key category analysis
is oil, natural gas and venting/flaring, so no segments (subcategories) are mentioned.
Therefore, figures 4.2.2, 4.2.3 and 4.2.4 accordingly should be carefully revised or
made consistent, in particular the diamond where it is asked if the oil and gas
operations are key category. In addition is necessary to define the term "significant"contribution (first time appears in line 1443). The langauge identified here can beseem as contradicting other parts of the text of the guidance (e.g. line 1541).

Accepted withmodification

Clarified the language to be clear that compilers may apply different
methodological tiers to different subcategories and segments within
categories. (line 1429-1430, p.4.42). Throughout, clarified the language tobe consistent on the definitions of subcategories and categories. The
remainder of the comment is on text that was not changed from the 2006
GL and therefore is out of scope of the refinement.

5690

2

4

1435

1450

Same coment as above.

Rejected

The CRF tables clearly distinguish between the segments so it is appropriate
to note that here.

2366

2

4

1439

1440

FIJI GEORGE
Abandoned wells are called out in the same manner as crude oil production andnatural gas production. This seems inappropriate. Abandoned wells should be treatedas an emission source under crude oil production and natural gas production.

Rejected

Emissions from abanboned wells are not a part of producing activities. It
occurs when producing activities are completed.

5692

2

4

1464

1464

Replace "petroleum" by "oil".

Javier Marcelo Hanna
Figueroa

Accepted

5694

2

4

1468

1487

In figures 4.2.2, 4.2.3, 4.2.4 and 4.2.5 define in footnote "significant".

Javier Marcelo Hanna
Figueroa

Rejected

Javier Marcelo Hanna
Figueroa

Framing is consistent with 2006 GL.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

2368

2

4

1484

1486

FIJI GEORGE
Abandoned wells are called out in the same manner as crude oil production andnatural gas production. This seems inappropriate. Abandoned wells should be treatedas an emission source under crude oil production and natural gas production.

Rejected

Emissions from abanboned wells are not a part of producing activities. It
occurs when producing activities are completed.

1482

2

4

1485

1486

Correct the second step in decision tree to replace "Yes" with "No" in the vertical path Michael Gytarsky
line

Accepted

2290

2

4

1485

1486

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

8782

2

4

1485

1486

The first box of the decision tree only has 'yes' options to proceed.

Ole-Kenneth Nielsen

Accepted

8784

2

4

1485

1486

The sentence "If emissions from abandoned wells are a key category, are contributions Ole-Kenneth Nielsen
from abandoned wells significant?" does not make sense.

Rejected

5696

2

4

1486

1486

In the box, correct "Tier 2".

Javier Marcelo Hanna
Figueroa

Accepted

2370

2

4

1498

1507

The subscript "gas" needs to be defined as CO2, CH4, or N2O.

FIJI GEORGE

Rejected

This comment is on text that was not changed from the 2006 GL to the2019 refinement, and is therefore out of scope.

10016

2

4

1534

1535

In Table 4.2.1 Consumer appliances should not be part of Gas Distribution segment

Miriam Lev-On

Rejected

Emissions from internal piping and leakage of end-use appliances are partof the chain from production to final use. Hence, they have to be reported in
the chapter of fugitive emissions.

9614

2

4

1534

1535

I support the addition of "Liquefied Natural Gas" in Table 4.2.1. However, I think it is Naofumi Kosaka
better to rename "Liquefied Natural Gas Supply" (or "Liquefied Natural Gas System",etc.) in order to be consistent with the names of other industry segments. The rule ofnaming seems to be product + segment (e.g. gas exploration).

Accepted

Agree, changed to "system".

9914

2

4

1534

1534

Table 4.2.1 has useful updates to industry segments and sources. Consider a short text Irving William
box example on the Aliso Canyon leak to illustrate "Other: anomalous leak events"

Accepted

Added example to table 4.2.1

5698

2

4

1534

1535

Recognizing the value of the new figures (4.2.1) showing graphically the segments of Javier Marcelo Hanna
the industry, it seems that still is needed the definitions of categories and subcategories Figueroa
that are presented in Table 4.2.1 of the 2006 IPCC Guidelines (this is implemented but
in limited manner, e.g. for gas exploration). These definitions are really fundamental
and necessary to have in the 2019 Refinement in tabular format. In addition, therevised table 4.2.1 would benefit of adding a column indicating the availability ofdefault EF (and related gas) at the level of each category/subcategory, as well an
indication of the methods available in the Refinement/Guidelines (tier 1, tier 2, tier 3).

Accepted withmodification

See comment No.5678.

The sentence is consistent with 2006 IPCC GLs (e.g. decision trees in
Fig.4.2.2-4.2.4 use the same language).

The sentence is consistent with 2006 IPCC GLs (e.g. decision trees in
Fig.4.2.2-4.2.4 use the same language).

Comment ID Volume

Chapter From line To line

4486

2

4

1565

6708

2

4

1571

4488

2

4

1575

2372

2

4

1595

2374

2

4

6710

2

556

Comment

ExpertResponse

Authors notegood practice in italic

KEWEI YU

Accepted

Reporters should validate that GOR values are based on gross production (e.g.,pressurized liquid sample from separator). If GOR is based on marketed production,then it could underestimate emissions from associated gas venting.

David Lyon

Noted

m3/m3, superscript

KEWEI YU

Accepted

1597

Equation 4.2.5 should include a term for the flare efficiency. As written, it assumes
flaring is 100% efficient, which is not correct.

FIJI GEORGE

Noted

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

1595

1597

The units conversion factor for Equation 4.2.5 is incorrect. It should be 42.3x10^-6 as FIJI GEORGE
used in Equations 4.2.3 and 4.2.4

Accepted

This error has been delt with following the IPCC Error Protocol apart fromthe development of the 2019 Refinement. See 10th Corrigenda for the 2006
IPCC Guidelines. https://www.ipccnggip.iges.or.jp/public/2006gl/corrigenda10.html

4

1624

1626

0.98 is too high for a default production flaring destruction removal efficiency (DRE). David Lyon
For example, Gvakharia et al 2017 reports that Bakken flares had a median DRE of
0.97. They state that using 0.98 would overpredict methane destruction due to thepositively skewed distribution of individual flare DREs.

Noted

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

2

4

1672

1990

Without studying the proposed tier 1 Efs in detail, I noted that for very many of these Tinus Pulles
three significant digits are provided, where at the same time relatively large
uncertainty intervals are proposed and in many cases not provided (yet; TBD).
Providing three significant digits ofr such EFs might therefore be not very appropriate
and suggesing a higher precision (lower uncertainty) than is defendable.
I propose that the authors revisit these proposed EFs and limit the precision in theirvalues to a number of significant digits that reflects the uncertainty. In most cases I
feel that one significant digit would be enough.

Accepted withmodification

Changed the number to scientfic format in case the number having several"0" (for example, 0.00003 to 3*10^-5).

5700

2

4

1680

1698

Here it should be a clear reference and explanations leading to to Annex 4A.2, where Javier Marcelo Hanna
are presented the % emissions that are leaked, vented, and flared in the data sets used Figueroa
for the Tier 1 EFs. Because this change (aggregated EFs) represents a significant
structural change in the reporting, in particular under the UNFCCC for Annex I
Parties, the guidance should be very clearly included and at the beginning of thesection on default EFs. the reasons for this new approach should be provided, showing
a qualitative positrive change. Also, some words on the change from presenting two
sets of default EFs, one for developed countries and another for developing countries
and EITs in the 2006 IPCC Guidelines to the current presentation in the 2019
Refinement should be transparently discussed.

Accepted

We provided text on leak/vent/flare discussion, and point to the an example
for how to calculate leak/vent/flare disaggregation in annex 4A.2. We
provided discussion on how factors are technology or practice-specific.

9916

2

4

1682

1684

Qualify the statement about only certain basic types of statistics being consistently
available, by adding "…in some/many countries."

Irving William

Accepted withmodification

Added text "…in many countries".

8786

2

4

1692

1696

Why has the NMVOC EFs not been updated using the correlations provided?

Ole-Kenneth Nielsen

Accepted withmodification

Developed values for NMVOCs using ratios with Ch4 from 2006 GL.

1577

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

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

4238

2

4

1694

1694

I suggest that the authors replace "values for CH4" by "values for NMVOC". This line Naofumi Kosaka
is related to discussion on NMVOC.

Rejected

Text irrelevant in SOD; deleted.

4240

2

4

1694

1694

I suggest that the authors replace "buy" with "by".

Naofumi Kosaka

Rejected

Text irrelevant in SOD; deleted.

1690

2

4

1695

1695

"buy" should be "by"Adam Eisele

Rejected

Text irrelevant in SOD; deleted.

7152

2

4

1695

1695

replace 'buy' with 'by'

Amanda Penistone

Rejected

Text irrelevant in SOD; deleted.

Text should read "by assuming" and not "buy assuming"

Miriam Lev-On

10018

2

4

1695

Rejected

Text irrelevant in SOD; deleted.

1484

2

4

1723

1723

Michael Gytarsky
After the first sentence in line 1723 the following text is proposed for inclusion: "Insome countries, the associated petrol gas annual production data are also available. If
available, the annual associated gas production is an optimum activity data that can beused for estimation of emissions from oil exploration and the elaboration of relevant
emission factors."

RejectedEfs related to associated petrolg gas are only avaiable in few countries.
Therefore, we try to link the EF with AD that more broadly available inmost countries.

54

2

4

1732

1733

The subscript of the variables in Equation is too long. It is better to have same format Mingshan Su
as Equation 4.2.7.

Rejected

The full subscripts help to clarify what is included in each segment
calculation.

2376

2

4

1733

1734

The reference "EPA analysis (2015)" is not included in the reference list.

FIJI GEORGE

Accepted

Added.

8790

2

4

1733

1734

Footnote d refers to gas exploration while Table 4.2.3 only covers oil production.

Ole-Kenneth Nielsen

Accepted

Fixed.

55

2

4

1733

1734

The format of Table 4.2.3 is not good. The Part of table in Page 4.55 just have first 2
rows.

Mingshan Su

Accepted

8788

2

4

1733

1734

Is there a difference between onshore and offshore emissions that should be reflected? Ole-Kenneth Nielsen
E.g. are the EFs for conventional oil production equally applicable to both onshore andoffshore production? This should be clarified. The third set of EFs for conventional
production mentions onshore, but the first two sets do not. If no emissions are
expected from offshore production this should be mentioned in the text.

8792

2

4

1733

1734

N2O emissions are in many cases listed as NA (Not applicable). However, it seems
illogical that N2O is applicable when using one type of AD (oil production) but notwhen using wells drilled or well population. This should be clarified.

1488

2

4

1734

1734

6712

2

4

1734

1734

Rejected

1) The comment is unclear on which table is referred to.
2) The Efs listed in table 4.2.4 (assuming the reviewer commening on thistable) provides Efs by on shore and off-shore. Due to the data availablity,
the Efs for off-shore is less detailed than on-shore.

Accepted withmodification

Data revised.

Table 4.2.3, footnotes a to c: The rationale for the use of implied emission factors as a Michael Gytarsky
proxy for default emission factors in Table 4.2.3 has not been sufficiently justified.
The authors should justify the proposal to use the implied emission factors as thedefault emission factors for oil exploration in Table 4.2.3.

Rejected

The source of many EF in IPCC GL are implied EF, no need for additional
justfication.

Will oil well completion EFs be updated in the near future with USEPA GHGRP data? David Lyon

Rejected

Only one year of data are available and these have not yet been assessed foruse in national inventories.

Ole-Kenneth NielsenComment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

1486

2

4

1734

1734

Michael Gytarsky
Table 4.2.3: It is not clear from Table 4.2.3 and corresponding text what emission
sources are accounted for and how these sources correpond to the emission sources in
the 2006 IPCC Guidelines. Further, it should be clarified, for what time period theemission factors have been provided in Table 4.2.3 (year, month, etc.). Furthermore,
the authors should clarify, if the same emission factor referred to in table 4.2.3 is to be
applied for each emission category (and the emission estimates derived should be
subsequently summarised). Otherwise the emission factors in table 4.2.3 represent theaggregation of few emission categories (operations) referred to in 2006 IPCC
Guidelines (for example, drilling, testing and servicing operations for oil wells,
because in practice emissions from particular operation cannot be separated).
However, in case of aggregation of few operations, the authors should indicate theoperations aggregated to ensure the completeness and avoid underestimations. It is
recommended that the authors provide the links to tables 4A.2 and 4A.3 and themethod for estimation the emission factors using the tables 4.2.3, 4A.2 and 4A.3.

Accepted withmodification

Changed the headlines of table 4.2.3 and other tables. Category into subcategory, sub-category into segments/operations;
The 2019 refinements will replace the fugitive emission context in 2006
GLs. In segment of oil exploration, guidance will not go in-depth to drilling,
testing and servicing operation which are hard to be seperated as thereviewer commented as well, EFs would be applied to the whole segment.
The operations included are now clarified in the notes under table 4.2.3.
EFs are for the period of year for all sources. This was clarified in the text.
Cross-reference to table 4.2.3 and 4A.2 is provided in the text. Table 4A.3
is for refineries and is not relevant for exploration.

1490

2

4

1744

1744

After the end of the sentence in line 1746 (before the sentence starting from "Where Michael Gytarsky
this information..."), the following text is proposed for inclusion: "If the associatedpetrol gas annual production data are available, it can be used for estimation emissions
from oil production and upgrading and the elaboration of relevant emission factors tothese category sources."

Rejected

See comment No.1484.

56

2

4

1774

1774

The subscript of the variables in Equation is too long. It is better to have same format Mingshan Su
as Equation 4.2.7.

Rejected

The full subscripts help to clarify what is included in each segment
calculation.

57

2

4

1776

1777

The format of Table 4.2.4 is not good. The Part of table in Page 4.59 just have first 2
rows.

Accepted

1492

2

4

1776

1777

Table 4.2.4: It is not clear from Table 4.2.4 how the proposed emission factors should Michael Gytarsky
be used. Do the authors propose to use both emission factors? Furthermore, theguidance should be provided on the choice of emission factor, if both activity data setsexist and are availabe. For example, the guiding principle for such choice could be thedifference in the uncertainty. It is recommended that along with provision of links toTable 4A.2 the calculation method is provided that would describe the use of thevalues in tables 4.2.4 and 4A.2.

8796

2

4

1776

1777

Considering that there is a requirement to report emissions from flaring separately, it
should be considered to present EFs as fugitive EFs and flaring EFs in the main
chapter rather than in the annex.

1494

2

4

1776

1777

8794

2

4

1776

1777

Mingshan Su

Accepted withmodification

The SOD discusses the options available, but choice is up to compiler's
judgement.

Rejected

The tables are unreasonably long if we include all of this information in themain body.

Table 4.2.4, footnotes a to d: So far as the IPCC 2019 Refinement is aiming at
Michael Gytarsky
verification and, if necessary, correction of the default emission factors in the 2006
IPCC Guidelines, the rationale for keeping the same values of default emission factors
for N2O and NMVOCs should be sufficiently justified in the footnotes a to d, Table
4.2.4

Accepted withmodification

We have updated the NMVOC values to be consistent.

In some cases Table 4.2.4 presents ranges, e.g. 0.54-0.74 for N2O. A single value
should be provided or further guidance to users on how to choose an EF.

Accepted withmodification

Added a footnote for clarification (see comment No.8792).

Ole-Kenneth Nielsen

Ole-Kenneth NielsenComment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

1496

2

4

1785

1786

Michael Gytarsky
Table 4.2.5, footnotes a, b and d: So far as the IPCC 2019 Refinement is aiming atverification and, if necessary, correction of default emission factors in the 2006 IPCC
Guidelines, the rationale for keeping the same values of default emission factors for
N2O and NMVOCs should be sufficiently justified in the footnotes a, b and d, Table
4.2.5.

Accepted withmodification

We have updated the NMVOC values to be consistent.

2292

2

4

1785

1786

Table 4.2.5: Emission factors for offshore oil loading are given with reference to the Vigdis Vestreng
Norwegian GHG Inventory. The periods chosen for the estimated factors are notuniform with respect to VRU use, and we do not recommend this use of the inventory.
Please do also check the conversion from the original inventoy data.

Accepted withmodification

Changed to: without VRU: 1990-2002; with VRU: 2003-2015; adding theword of "average"(In NIR 2017 of Norway, it says: Since year 2000 an increasing share of the
shuttle tankers have had installed vapor recovery units (VRU), from 2003,
Emissions, activity and emissions factors with and without VRU arereported)

5098

2

4

1787

1794

Kristina JuhrichThis chapter includes all refining emissions (leaks, venting and flaring). Emissions
from combustion processes are reported in the stationary combustion sector (1.A.1.b).
However, some important emission sources are still missing: hydrogen production(process related emissions), calcination and catalyst regeneration. They are mentioned
in line 1790 regarding methane but not in terms of CO2. There is a reference fromvolume 3 chapter 3 to 1.B.2.aiii 4 in cases were hydrogen is produced as a by-productin refineries. But there is no methodical description available in the 1.B sector.
Calcination is also a production process and insofar no venting, no flaring and noleakage in the proper sense (since the flue gas usually takes the correct way throughthe chimney). The exhaust heat from Catalyst regeneration is normally used forrefinery processes. In some countries the catalyst material is reported as own
consumption of pet coke in the energy statistic. However, often data is not complete
and there is no methodical description for stationary plants in 1.A. I would suggest to
open source category 1.B for other processes than leaks, venting and flaring in order toaddress these missing emission sources. It wouldn’t be recommendable to add a new
subcategory in the IPPU sector for the Refinery process emissions. Currently it’s
possible to aggregate emissions from source category 1.A.1.b and 1.B.2.aiii 4 in orderto get the sum of all refinery emissions. An additional subcategory under IPPU would
complicate the work of inventory compiler and review experts. Therefore I would
suggest to add some methodical descriptions for hydrogen production, calcination andcatalyst regeneration in the Guideline Chapter 2, volume 4 (1.B.2.aiii 4). Data isavailable from EU ETS. Otherwise these emissions are missing. (These sources are
more relevant than all flares, venting and leakage activities together.) In the broadest
sense all emissions from the mentioned production processes can be considered asleaks, if a renaming of this source category is impossible.

Accepted withmodification

Regarding emissions from H2 production, a documentation box where toreport was included. Methodical description are provided under the newhydrogen chapter under IPPU.
Calcination has to be reported under 1.B.2.iv - the EF includes emissions
from that process.
Emissions from catalyst regeneration are mainly triggered by combustionand should be reported under 1.A.1.b.
Renaming the category is out of scope.

10038

2

4

1788

1792

Recommend including here a citation to the 2009 API Compendium for a description Miriam Lev-Onof the refining sector (Section 2.2.8) and elaboration of GHG estimation for GHG
emissions from refinery sources including process vents (section 5.0) and fugitive
emissions (section 6.0).

Rejected

The existing definition on refining segment is not different from what saysin 2009 API. However, the definition in 2019 Refinements on fugitive
emission is different with that in API. In 2019 Refinements, fugitive
emission includes leaks, processing venting and flaring, however, in API it
only means leaks.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

8798

2

4

1793

1794

Does the EFs presented include emissions from flaring? If so, it would be useful tohave the EFs separately since flaring emissions are reported separately. If flaring
emissions are not included, there should be presented default EFs for flaring in
refineries.

Ole-Kenneth Nielsen

Rejected

It will be possible for compilers to calculate this information using annex
4.A. The text was edited to make clearer the link to annex 4.a here.

5702

2

4

1811

1811

Replace "petroleum" by "oil".

Javier Marcelo Hanna
Figueroa

Accepted

558

2

4

1839

1840

Table 4.2.8 provides ranges for the tier 1 Efs for CH4 and un uncertainty range
expressed i8n as many as 4 significant digits. These values are in my view not very
helpful for users that are obliged to use a tier 1 method. Such users do not haveadditional information, so they cannot decide which value to use.
A solution might be to provide the arithmetic mean (SQRT((lower value)*(higher
value)) as the most probable default value and determine the uncertainty range fromthe range provided. I feel that it would be quite defendable to interpret the lower andhigher values of this range as (close to) the boundaries of the uncertainty range.

Tinus Pulles

Accepted withmodification

9622

2

4

1839

1840

I suggest that the authors replace "unplugged" with "plugged" in units of measure forplugged onshore subcategory. I suggest that the authors replace "plugged" with
"unplugged" in units of measure for unplugged onshore subcategory.

Naofumi Kosaka

Accepted

9624

2

4

1839

1840

I suggest that an emission factor (EF) is determined as a single value and range isincorporated into uncertainty. Currently, the EF for plugged onshore is 0.02-3.13
kg/well with 62.22% uncertainty. For example, it could be 1.58 (median of the upperand lower range) with uncertainty of 100%(=100*(3.13/1.58-1)) or more (62.22%).

Naofumi Kosaka

Accepted withmodification

The SOD includes single EFs provided from Townsend-Small et al. study.

9626

2

4

1839

1840

Naofumi Kosaka
The CH4 emission factor (EF) for oil exploration is 1.47 kg/well and the EF foronshore production is 2-3 t/well according to Table 4.2.3 and 4.2.4. The order ofmagnitude is the same between the EF for plugged onshore abandoned wells in Table
4.2.8 and the EF for oil exploration. The EF for unplugged onshore abandoned wells is
between the EF for oil exploration and the EF for onshore production. If the authors
consider the magnitude is reasonable, it is no problem.

Rejected

The values and its units are not correctly reflected in the comment.

6714

2

4

1840

1840

Providing two emission factor options for abandonded wells is confusing. Have you David Lyon
considered combinining the Kang et al and Townsend-Small et al datasets to calculate
a single emission factor? If both factors are provided, then provide more guidance
about how to chose which is most appropriate for specific regions or well types.

Accepted withmodification

The SOD includes single Efs provided from Townsend-Small et al. study.

Uncertainty values and EFs were updated to use information from
Townsend-Small et al.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

35

2

4

1841

1859

David Reay
A good, clear explanation of approaches with hydraulic fracturing well covered.
However, the scope of unconventional gas exploitation is chnaging rapidly.
Commercial exploitation of methane clathrates is now a real possibility, with succesfultrials having been conducted. I realise that there is very large uncertainty as to what
the figiutive emissions from such methane clathrate exploitation would be, but wonder
if it could at least be note as an activity to note in national reporting (i.e. level ofactivity) so that future accounting where we have a useable emissions factor can thenalso estimate historical emission from this source. More generally, it would be usefulfor the IPCC EF panel to examine this emerging area and begun to assemble emission
estimates.

Rejected

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

58

2

4

1860

1861

The subscript of the variables in Equation is too long. It is better to have same format Mingshan Su
as Equation 4.2.7.

Rejected

The full subscripts help to clarify what is included in each segment
calculation.

1498

2

4

1862

1863

Michael Gytarsky
Table 4.2.9: It is not clear from Table 4.2.9 and corresponding text, what emission
sources are accounted for and how these sources correpond to the emission sources in
the 2006 IPCC Guidelines. Further, it should be clarified, for what time period theemission factors have been provided in Table 4.2.9 (year, month, etc.). Furthermore,
the authors should clarify, if the same emission factor referred to in table 4.2.9 is to be
applied for each emission category (and the emission estimates derived should be
subsequently summarised). Otherwise the emission factors in table 4.2.9 represent theaggregation of few emission categories (operations) referred to in 2006 IPCC
Guidelines (for example, drilling, testing and servicing operations for gas wells,
because in practice emissions from particular operation cannot be saparated).
However, in case of aggregation of few operations, the authors should indicate theoperations aggregated to ensure the completeness and avoid underestimations. It is
recommended that along with provision of the links to Table 4.A.4 and 4A.5, thecalculation method is provided that would describe the use of the values in tables
4.2.9, 4A.4 and 4A.5.

Rejected

Calculation methods are provided and the Efs are annual as are all in the
IPCC GL.

8800

2

4

1862

1863

Is there a difference between onshore and offshore emissions that should be reflected? Ole-Kenneth Nielsen
E.g. are the EFs for conventional gas production equally applicable to both onshore
and offshore production? This should be clarified. The second set of EFs forconventional production mentions onshore, but the other sets do not. If no emissions
are expected from offshore production this should be mentioned in the text.

Accepted withmodification

No data are available on emissions from offshore exploration, therefore thiscategory cannot be added.. It is unlikely that there are significant emissions
from exploration for offshore. We overlooked adding text on offshore
exploration and can do so for the final draft.

8802

2

4

1862

1863

N2O emissions are in many cases listed as NA (Not applicable). However, it seems
illogical that N2O is applicable when using one type of AD (gas production) but notwhen using wells drilled or well population. This should be clarified.

Ole-Kenneth Nielsen

Accepted

Added N2O values.

8804

2

4

1862

1863

In some cases Table 4.2.9 presents ranges, e.g. 0.07-1.10 for N2O. A single value
should be provided or further guidance to users on how to choose an EF.

Ole-Kenneth Nielsen

Accepted

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

10020

2

4

1862

1863

In Table 4.2.9 Footnote (a) - EFs for gas well completions from the average of 20062010 data are outdated, though they could be used for uncontrolled gas wellcompletions outside of the U.S. Newer data (2013-2016) from the U.S. GHG
reporting program is available for both controlled and uncontrolled unconvetional
completions.

Miriam Lev-On

Rejected

The years 2006-2010 represent a better average value for uncontrolled
completions. In year 2011 and after, most well completions in the data set
were required to use controls, which would make the uncontrolled
population not representive of avreage uncontrolled popultions but of thesmall unregulated population.

10022

2

4

1865

1866

Recommend separating the Production segment from Gathering and Boosting one due Miriam Lev-On
to the potential difference in ownership profile and data sources.

Rejected

Not possible to separate them due to the category numbering, but the 2019refinement does include a separate input value for gathering for the first
time.

10024

2

4

1868

1868

It is especially important to estimate emissions from gas compressing (boosting)operations, which are essential to gathering operations, and should be included in thelist of sources from such operations.

Accepted withmodification

Added text to note that compressors are included in gathering and boosting.

4086

4

2

1869

1870

Recommend that the order of the sentence be flipped to conform with the order of the Mark de Figueiredo
natural gas systems value chain. In other words, sentence should read: "The gatheringand boosting stations receive natural gas from production sites and transfer it, via
gathering pipelines, to processing facilities or transmission pipelines..."Accepted

Edited.

4088

4

2

1870

1870

Recommend deleting the parenthetical because the wording is awkward. Custodytransfer meters are not used to segregate gas; rather, they track the flow of gas fromone owner to another. Also, some vertically integrated companies may conduct bothproduction and processing, in which case there would not necessarily be a transfer ofcustody of the gas.

Mark de Figueiredo

Accepted

Deleted.

59

2

4

1891

1892

The format of Table 4.2.10 is not good. The Part of table in Page 4.70 just have first 2 Mingshan Su
rows.

Accepted

6716

2

4

1891

1892

Based on my calculations, the Tier 1 onshore production EFs are equivalent to: low David Lyon
emissions technology = 0.48 kg/h/well = 0.45% production-normalized loss rate, highemission technology = 0.78 kg/h/well = 0.73% production-normalized loss rate. Thereis growing evidence from empirical site-level and basin-level data that the underlying
data from the EPA GHG Inventory underestimates production sector emissions.
Several published papers report average U.S. well pad emission rates that exceed the
low and high emission technology EFs, including Omara et al 2016, Robertson et al
2017, and Zavala-Araiza et al 2017. The EFs should be updated to incorporate recent
site-level measurement studies, or at least mention that the studies indicate the EFs areconservatively low.

Rejected

Chapter 4.2 provides information on difficulties and considerations(including measurement issues) for quantifying emissions from oil andnatural gas systems (see Methodological Issues).

8806

2

4

1891

1892

Considering that there is a requirement to report emissions from flaring separately, it
should be considered to present EFs as fugitive EFs and flaring EFs in the main
chapter and not only in the annex.

Rejected

The tables are unreasonably long if we include all of this information in themain body.

Miriam Lev-On

Ole-Kenneth NielsenComment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

10026

2

4

1891

1892

Miriam Lev-On
In Tabel 4.2.10 footone (d): the use of data from Marchese et. al. 2015 is notapplicable for global Tier 1 EFs for gathering. Marchese data is hardly representativeof U.S. gathering operations and should not be extrapolated globally.

Rejected

Other data are unavailable.

1692

2

4

1896

1896

In this line, should "uncombusted methane" also include uncombusted NMVOCs? If Adam Eisele
there is uncombusted methane present through slip, there is likely other uncombusted
NMVOCs which also may be products of incomplete combustion. NMVOCs are alsomentioned in other parts of this chapter

Accepted withmodification

Edited to "uncombusted gas".

2378

2

4

1916

1917

The CO2 emission factors in Table 4.2.11 appear to be very low when compared toemissions from EPA's 2017 national inventory report

FIJI GEORGE

Rejected

This is because they do not include acid gas removal. For countries withacid gas removal, they must add the sour gas/acid gas removal estimate.
Clarifying text added

10028

2

4

1924

1925

Recommend citing the API LNG document as a resources for description of LNG
sector and calculation methodology, "Liquefied Natural Gas (LNG) Operations:
Consistent Methodology for Estimating Greenhouse Gas Emissions", Version 1.0,
API, Washington DC, May 2015

Miriam Lev-On

Accepted

Sentence now reads "This source also includes LNG stations and import andexport terminals; further details on the LNG sector can be found in
Liquified Natural Gas (LNG) Operations: Consistent Methoodlogy for
estimating Greenhouse Gas Emissions (API, 2015). " Also added reference
to EndNote.

1500

2

4

1925

1925

After the end of the sentence in line 1925 (before the sentence starting from "Where Michael Gytarsky
this information..."), the following text is proposed for inclusion: "For some countries,
length of transmission pipelines and annual gas transmission totals may be available.
Each of these data can be used for estimation the emissions from natural gas
transmission within the country and the elaboration of relevant emission factors."

Rejected

These information are already provided in the GL.

8808

2

4

1925

1930

Two sets of EFs are presented for natural gas transmission. The text states that when Ole-Kenneth Nielsen
there are limited or no leak detection and little use of centrifugal compressors then the
EF using gas throughput should be used, while for systems with leak detection andcentrifugal compressors with dry seals, the EF using length of pipeline should be used.
It would be very helpful to include the reasoning behind this assertion. Also, the CH4
EF seems to be considerably higher than the value in the 2006 IPCC GL (1.3 tonnes
per 10^6 m3 vs. 0.8 tonnes per 10^6 m3 (highest value from 20016 IPCC GL
including both venting and fugitives). Any substantial changes should be addressed.

Rejected

The tables would be very large if we included this in the main body.

10030

2

4

1933

1934

Recommend citing Section 4.0 of the API 2015 LNG GHG Emissions document for
further elaboration of emission estimation methods

Accepted withmodification

Added a citation in a slightly different place (lines 1933-1934). Now reads:
Where LNG imports and exports or storage occur, the number of stations
should be determined, and the emission factors for LNG should be used .
See API (2015) for further elaboration of emission estimation methods for
the LNG sector. "Miriam Lev-On

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

2382

2

4

1938

1939

The units of measure "gas consumption" is unclear and is inconsistent with the activity FIJI GEORGE
data values shown for transmission and storage in Table 4.2.15

Accepted

Changed text in 4.2.15 for consistency. Table 4.2.15 was unchanged from2006 guidelines, and listed activity as "10^6 m^3 of marketable gas"
whereas in new Table 4.2.12 we use "Tonnes per million cubic meter gas
consumption" - Table 4.2.15 has been changed to use this activity basis andwe changed the description to reflect gas consumption rather thanmarketable gas definition.

1502

2

4

1938

1939

Michael Gytarsky
Table 4.2.12: It is not clear from Table 4.2.12 and corresponding text what source
categories have been accounted for and how they correspond to the emission sourcesin the 2006 IPCC Guidelines. Further, it should be clarified, for what time period theemission factors have been provided in Table 4.2.12 (year, month, etc.). Furthermore,
the authors should clarify, if the same emission factor referred to in table 4.2.12 is tobe applied for each emission category (and the emission estimates derived should be
subsequently summarised). However, in case of aggregation of few operations, theauthors should indicate the operations aggregated to ensure completeness and avoid
underestimations. It is recommended that the authors provide the links to tables 4.A.4
and 4A.5 and the method for estimation the emission factors using the tables 4.2.12,
4A.4 and 4A.5.

Accepted withmodification

The categories are consistent witih categories from the 2006 GL. Clarified
text, noting that all EF are for the time period of 1 year. Added text on
rationale and note that the transmission EF is within the range of reported
value. Added an equation to show how emissions are to be summed.

2380

2

4

1938

1939

The CO2 emission factor for LNG import/export is 3 orders of magnitude higher than FIJI GEORGE
emissions reported for the U.S. in EPA's 2017 national inventory report

Accepted

Corrected error.

8810

2

4

1938

1939

For LNG, the EFs for both handling and storage are provided per terminal. Is this the Ole-Kenneth Nielsen
best activity data? LNG terminals can vary from small terminals, e.g. 500 m3 and up
several 100000 m3. Is the expectation that these would have similar emissions. At
least it should be mentioned what types of terminals have been used in establishing theEFs.

Accepted withmodification

A better activity data option is unavailable, but additional information on EF
data set was provided in the text.

10032

2

4

1950

1955

Recommend moving the discussion and Efs for applicance to the Product Use Volume Miriam Lev-On(Volume 3), where Chapter 8 addresses, “Other Produce Manufacture and Use”. A
NEW subchapter could be developed to include a range of methane emissions fromNatural Gas use in power transport and appliances (in a manner similar to section 8.4
on N2O from product use).

Rejected

Emissions from internal piping and leakage of end-use appliances are partof the chain from production to final use. Hence, they have to be reported in
the chapter of fugitive emissions.

4036

2

4

1953

1953

Insert between sentences: "An exception to this generalization is biogas produced
from wastewater treatment, which may have a significant fossil component (seeVol5_Chp6_Annex6A.2). In such cases compilers are encouraged to determine theextent to which this may influence emissions."

Gregory Peters

Rejected

Methane losses have to be reported, no matter from what fuel they comefrom. There will be no exception.

8814

2

4

1962

1963

An EF for appliances is reintroduced based on the classification for gas losses reported Ole-Kenneth Nielsenin the 2006 IPCC GL. The value of 5 m3 per appliance has been converted to 5 kg per
appliance, which seems to fail to consider the density of the natural gas. Also, it is notclear what assumptions have been made as to the CO2 content of the natural gas toderive a CO2 EF. This should be specified.

Accepted

A specification on CO2 content was be provided.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

8816

2

4

1962

1963

The use of the classification of gas losses as low, medium or high at selected types of Ole-Kenneth Nielsen
natural gas facilities as a source for a default EF for appliance losses seems
questionable. The source of the data is reported in the 2006 IPCC GL as "Adapted by
the authors from currently unpublished work by the International Gas Union, andbased on data for a dozen countries including Russia and Algeria.". This is hardly asolid reference as it is unpublished, not peer-reviewed and impossible for users toanalyse and hence assess the applicability at a wider scale. Residential natural gas
boilers are usually placed indoors and with odorant being added to the natural gas any
leakages would be detected and repaired, which makes it unlikely that leaks of themagnitude suggested would occur. If including a default EF the scientific basis should
be better than what is currently the case. The appropriateness of the EFs should bereassessed and if proper data are not available no default emission factor should be
provided. The same concern applies to the EF suggested for large-scale users. The useof the value for 'rest of the world' from an obsolete version of the IPCC GL should not
be considered sufficiently scientifically robust to form the basis of a default EF. In
addition, it is unclear what calorific value has been used to convert the EF from kg/PJ
to t/10^6 m3.

Accepted withmodification

A conversion factor was provided.
The reference to the 1996 GL is agreed by the IPCC. In addition to this, thestudy is already published and can be downloaded from IGU.

8818

2

4

1962

1963

It is not clear whether the EF for natural gas vehicles covers emissions from the whole Ole-Kenneth Nielsen
chain, i.e. storage at filling stations, the refuelling of vehicles and emissions fromvehicle tanks. This should be specified.

Accepted

The comment is right, but during the drafting of SOD, the point is still
under discussion and it will be clarified in the final draft.

10034

2

4

1962

1963

The EF in Table 4.2.13 regarding Natural Gas Vehicles, Appliance, Industrial Plants
and Power Plants should be included in a NEW segment in Volume 3 Chapter 8 on
'Methane Emissions from Product Use'

Miriam Lev-On

Rejected

Emissions from internal piping and leakage of end-use appliances are partof the chain from production to final use. Hence, they have to be reported in
the chapter of fugitive emissions.

2384

2

4

1962

1963

The units of measure "gas consumption" is unclear and is inconsistent with the activity FIJI GEORGE
data value shown for gas distribution in Table 4.2.15

Accepted

Changed text in 4.2.15 for consistency. Table 4.2.15 was unchanged from2006 guidelines, and listed activity as "10^6 m^3 of marketable gas"
whereas in new Table 4.2.12 we use "Tonnes per million cubic meter gas
consumption" - Table 4.2.15 was updated to use this activity basis and wechanged the description to reflect gas consumption rather than marketablegas definition.

6718

2

4

1962

1963

For the processing plant EF, the underlying EPA GHG Inventory data underestimates David Lyon
emissions. Marchese et al 2016 reports that processing plant emissions were higher
than estimated by the EPA GHG Reporting Program, which is used in the EPA GHG
Inventory. It would be more approrpriate to develop the EF from the empiricallybased Marchese et al 2016; for example, they report an average throughput loss rate of
0.18%.

Rejected

Disagree-the Marchese study measured 16 plants; the data set used todevelop the EF included hundreds of plants.

6720

2

4

1962

1963

For the transmission EF, the EPA GHG Inventory data underestimates emissions by
excluding the super-emitter/uncategorized emissions from Zimmerle et al, the sourceof the underlying data. The EF should be adjusted upward by approximately 27% toaccount for this important source, which represents real emissions from abnormal
conditions such as malfunctions that are not easily cartegorized into EPA's existingsource categories.

David Lyon

Rejected

The EF is a combination of Zimmerle and other data sources and covers all
emission sources in the transmission segment.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

6722

2

4

1962

1963

Provide pipeline type specific EFs (CH4 / km pipeline) based on Lamb et al 2015 and David Lyon
EPA GHGI. They could be useful to countries with detailed pipeline activity data but
no emissions data.

Rejected

These are in the annex.

8812

2

4

1962

1963

Ole-Kenneth Nielsen
Based on the text preceding Table 4.2.13, it would seem that for pipelines 'Greaterthan 50% plastic pipelines, and leak detection and repair programs are in use' the EF
to use would be based on the pipeline length. However, both set of EFs are presented
for both subcategories. It should be further clarified which of the four different sets of
EFs should be used under which conditions.

Accepted

Clarified text.

10036

2

4

1972

1974

Miriam Lev-On
Recommend emphasizing that the guidance provided both for oil an gas wells may
result in highly uncertain reporting. Existing data on abandoned oil and gas wells aswell as practices for plugging such wells in a well regulated fashion is scarce and data
about plugging practices is and the number of plugged wells is hard difficult to collect.

Accepted

Although it is not particularly mentioned in the text, the table (4.2.8) has
proivded default emission factors with a large uncertianty in SOD which isdifferent from FOD.

5704

2

4

1975

1990

Move the text here to the beginning of the section 4.2.2.3 on choice of emission
factors. This information should be given before the tables with default EFs.

Javier Marcelo Hanna
Figueroa

Accepted

Moved above table.

4490

2

4

1988

better use 100%, check other places

KEWEI YU

Rejected

100 per cent = 100%

4492

2

4

2016

formation of

KEWEI YU

Rejected

Disaggree, "formation CO2" is correct.

2386

2

4

2044

2045

FIJI GEORGE
Table 4.2.14 is indicated to provide Tier 1 emission factors for data presented inTables 4.2.3 through 4.2.13. This description is incconsistent with the data presented
in Table 4.2.14, which provides Tier 3 activity data. For the same reason that Tier 3
emission factors are not provided in Chapter 4, Tier 3 activity data should also not beprovided since the level of detail can vary widely. Suggest removing Table 4.2.14

Noted

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

2388

2

4

2052

2053

For the same reason that Tier 3 emission factors are not provided in Chapter 4, Tier 3 FIJI GEORGE
activity data should also not be provided since the level of detail can vary widely.
Suggest removing Table 4.2.14

Accepted withmodification

The table is from the 2006 GL and it is out of the scope of the refinement.
However, we did add text above the table to clarify why there is a table on
Tier 3 AD information presented.

9630

2

4

2053

2054

Table 4.2.7 of the 2006 IPCC Guidelines corresponds to Table 4.2.4 (or 4.2.5) one-by- Naofumi Kosaka
one. I suggest that the authors also keep this correspondence among Table 4.2.15 and4.2.3 through 4.2.13. For example, Sweet Gas Plants and Default Weighted Total SubCategories in Gas Processing Category no longer exist in Table 4.2.11 and these SubCategories can be removed from Table 4.2.15. On the other hand, it is needed to add
with/without LDAR Sub-Categories in Table 4.2.15.

Accepted

Edited table--removed guidance column adding discussion above the table,
noting that they should reference national statistics and that additional
discussion in tier 1 ef section.

9632

2

4

2053

2054

I suggest that a horizontal line is missing between Unconventional and Conventional
Sub-Categories in Gas Exploration Category.

Naofumi Kosaka

Accepted

9612

2

4

2054

2055

I suggest that the authors replace "bitumen" with "crude bitumen" for Oil Upgradingin Table 4.2.15 in order to avoid confusion with bitumen as final products of oil
refineries.

Naofumi Kosaka

Noted

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

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

The 2nd option provided under guidance for abandoned wells suggests using the count FIJI GEORGE
of wells drilled less the number of actively producing wells. This is not a valid
approximation for the number of abandoned wells. This can result in a negative wellcount for some producting areas. Suggest removing this option.

Accepted

2061

bureaux? Spelling

KEWEI YU

Rejected

British spelling is used for IPCC guidelines.

4

2105

GCV, NCV, definitions?

KEWEI YU

Accepted

Added definitions to glossary from IEA
https://www.iea.org/media/training/alumni/CheatSheet.pdf

2

4

2127

2127

The following new paragraph is proposed for inclusion at the beginning of line 2127: Michael Gytarsky"Different activity data sets may be available for some countries. In particular, theannual associated gas production may be available for oil operations segment, whilelength of transmission pipelines and annual gas transmission totals may be available
for operations with natural gas. When these data are available, they can be used for
estimation of fugitive emissions from oil exploration and production as well as fromnatural gas transmission. Furthermore, these data can be applicable for the elaborationof relevant emission factors."

Rejected

All of these points are covered elsewhere in the text and are unrelated tocompleteness.

5706

2

4

2127

2129

The language here should be carefully redrafted, it is unclear how the comparisson
between tier 1 EFs and tier 2/tier 3 EFs will help in the assessment of completeness.
Why here reasonableness of EFs is playing a role in completeness?. Also, howemissions from specific segment will be assessed against uncertainty range? which
would be here the central estimate? Clarify, redarft, as the idea is very unclear as it isnow.

Javier Marcelo Hanna
Figueroa

Rejected

It is always good practice to compare country-specific or technologyspecific Efs with defuat Efs with range to faciliate the understanding on thereasonaiblity of bottom-up data.

5708

2

4

2130

2132

It seems that still the language here refers to the table 4.2.8 in the 2006 IPCC
Guidelines and is not fully applicable for the change introduced. Revise.

Javier Marcelo Hanna
Figueroa

Accepted

Deleted these lines.

good practice in italic

KEWEI YU2149

To reinforce the guidance provided, recommend adding that measured data should be Miriam Lev-On
carefully analyzed and screened to ascertain its validity. It is important to identify
obvious data errors and/or outlying observations. It is also essential to ensure theapplicability of short duration measurement studies to depict average annual emissions
for inclusion in national inventories.

Notedshould be

KEWEI YU

Accepted

2390

2

4

2054

4494

2

4

4496

2

1504

2055

4498

2

4

2142

10042

2

4

2142

Accepted

4500

2

4

2159

9918

2

4

2160

2165

Where EF's change over time to reflect technological changes, particularly if newer
technology is lower emitting, add some guidance on how to make mitigation or
reductions as transparent as possible in the inventory report.

Irving William

Noted

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

10040

2

4

2174

2175

Recommend including a citation to the 2015 API/IPIECA document, "Addressing
uncertainty in oil and natural gas industry greenhouse gas inventories: Technicalconsiderations and calculation methods"

Miriam Lev-On

Noted

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

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

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

1696

2

4

2204

2213

There appears to be a formatting issue in this paragraph, perhaps with the use of
special characters not showing up. Specifically, the character before the numeral
percent is incorrectly formatted.

Adam Eisele

Accepted

2392

2

4

2205

2206

Symbols for "+/-" are not displayed correctly.

FIJI GEORGE

Accepted

4502

2

4

2205

2221

%, and some errors, err?

KEWEI YU

Accepted

4504

2

4

2224

good practice in italic

KEWEI YU

Accepted

2394

2

4

2256

2261

The text under "External Review" is duplicative of the text under Industry
Involvement (lines 2232-2236). Suggest combining these into one section.

FIJI GEORGE

Accepted

4506

2

4

2265

good practice in italic

KEWEI YU

Accepted

9920

2

4

2277

2281

See earlier comment on line 2160 regarding changing EF's over time and howreporting and documentation of mitigation in this sector should be transparently
demonstrated.

Irving William

Noted

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

9634

2

4

2808

2808

I suggest that the authors replace "recalculation" with "adjustment" (or "correction").
The word recalculation is used to a limited extent in the IPCC Guidelines whenoverwriting the past emission estimates due to methodological changes, error
corrections, etc. (cf. 2006 IPCC Guidelines, Volume 1, Section 5.2.1 and 5.4)

Naofumi Kosaka

Accepted

Replaced with "correction".

5182

2

Annexes

2844

2844

What is APG? Should be defined/explained.

Kari Grönfors

Accepted

Done

9636

2

4

2856

2857

Naofumi Kosaka
I suggest that the "To 0 °С" and "To 20 °С" columns in Table 4A.1 are unnecessary
because line 2802-2804 state that "If activity data are derived at reference conditions,which are different from those used by IPCC default EFs, inventory compiler should
harmonize activity data with 15°С and 101.325 kPa." On the other hand, it isnecessary to include a table for the parameters used in Equation 4A.1 through 4A.4.

Accepted withmodification

1 - The columns were deleted. 2 - There are around 30 pages of values ofparameters used in Equations 4A.1-4A.4. Including these pages in the GLs
is not reasonable. The reference on documents, from which the parameters
may be taken, was provided.

9922

2

4

2861

2862

Section 4.2.2.3 could use some text describing the importance of this Annex and how Irving William
it fits into the choice & use of emission factors.

Rejected

1) The annex (4A.2)has been mentioned in the main context on p.4.54 andother pages for reference;2) The annex is not as important as main context, otherwise it will be
included in.

5978

2

Annexes

2863

2864

It is not exactly clear how the disaggregated factors in Annex 4A.2 would be used

Accepted

Added text to clarify link with 4A.2

Vincent Camobreco

Combined these.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

8820

2

4

2871

2872

Table 4A.2 is very important based on the preliminary decision not to report emissions Ole-Kenneth Nielsen
from venting, flaring and fugitive losses separately in the main part of the chapter.
This makes it very important that this information is accurate. Therefore, it isworrying that e.g. flaring is only assumed to be 1 % of the CO2 emission from
offshore oil production. This seems like an obvious error. For onshore oil production
flaring is apparently 0 % (!) of the CO2 emission. Also, the table does not mirror the
information presented in Table 4.2.3 and 4.2.4, e.g. the N2O EFs presented in thesetables are not reflected in Table 4A.2, which would make it impossible for users tocomply with the requirement to report flaring emissions separately from the fugitive
emissions. The same goes for the other tables in this annex.

Accepted

This is fixed with the latest US GHGI which reallocates oil flaring to oil,which is used in the SOD. Previously was all reported under natural gas.

1514

2

4

2877

2972

It is proposed to include additional information on country-specific emission factors
from the attached file in the Annex 4A.3

Michael Gytarsky

RejectedAnnex has been deleted.

5980

2

Annexes

2877

2877

Suggest Annex 4A.3 instead reference the IPCC EFDB

Vincent Camobreco

RejectedAnnex has been deleted.

8822

2

4

2877

2972

This is a great annex with a lot of useful information. Some tables are without units
but they are generally available in the accompanying text. One exception is Table
4A.10, where the unit should be added.

Ole-Kenneth Nielsen

RejectedAnnex has been deleted.

10044

2

Annexes

2888

2889

The CH4 emission factors for HF gas with and without controls seem to have beenswitched. All the US numbers should be updated to match current GHGI values.

Miriam Lev-On

RejectedAnnex has been deleted.

564

2

4

2888

2972

Would it be possible to add uncertainty information on these Efs as reported by thesecountries? I would assume that their NIRs will have this information available or atleast provides references to the measuring reports that underpin these values.

Tinus Pulles

RejectedAnnex has been deleted.

2294

2

4

2900

2901

We do not recommend this use of IEFs from our GHG inventory

Vigdis Vestreng

RejectedAnnex has been deleted.

2296

2

4

2903

2904

Table 4A.10: Units for the data are missing.

Vigdis Vestreng

RejectedAnnex has been deleted.

2298

2

4

2903

2904

Table 4A.10: Emission factors for offshore oil loading are given with reference to the Vigdis Vestreng
Norwegian GHG Inventory. The periods chosen for the estimated factors are notuniform with respect to VRU use, and we do not recommend this use of the inventory.
Please do also check the conversion from the original inventoy data.

RejectedAnnex has been deleted.

10046

2

Annexes

3014

3015

This definition of Casing is different than tha one provided in Line 3026

Miriam Lev-On

Accepted

Deleted duplicate definition in line 3014; retained this: "casing: cement pipe
lowered down a well borehole meant to prevent fluids from escaping and/or
the borehole from collapsing. "

10048

2

Annexes

3026

3026

A second definition of Casing that does is different than the one provide in Line 3014 Miriam Lev-On

Accepted

Deleted duplicate definition in line 3014; retained this: "casing: cement pipe
lowered down a well borehole meant to prevent fluids from escaping and/or
the borehole from collapsing. "Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

9638

2

4

3029

3029

Naofumi Kosaka
I suggest that it is necessary to add the words "VRU" and "centrifugal compressors
with dry seals" in Annex 4A.4 because it seems that the words are used in Table 4.2.5
and 4.2.11 without definition.

Accepted withmodification

Added definitions to glossary. For centrifugal compressors defined both
wet and dry seals as follows - "centrifugal compressor: centrifugal
compressors are widely used in production and transmission of natural gas.
Seals on the rotating shafts prevent the high-pressure natural gas fromescaping the compressor casing. Traditionally, these seals, termed “wet”
seals, used high pressure oil as a barrier against escaping gas. An alternative
to the traditional wet (oil) seal system is the mechanical dry seal system.
This seal system does not use any circulating seal oil. Dry seals operatemechanically under the opposing force created by hydrodynamic grooves
and static pressure. Replacing “wet” (oil) seals with dry seals significantly
reduces operating costs and methane emissions." Defined VRUs as "Vapor
recovery unit (VRU): a system used to recover vapours formed insidesealed crude oil or condensate tanks; consists of a switch that detects
pressure variations within a tank and turns a compressor on and off. The
compressor sucks vapours through a scrubber that catches liquids andvapours for return to tanks or pipelines."

10050

2

Annexes

3032

3032

The definition of Coal Bed Methane could be accompanied by a definiton of Coal Bed Miriam Lev-On
Methane Production "Coalbed methane (CBM) was first extracted from coal mines asa safety measure to reduce the explosion hazard posed by methane gas in the mines.
Today the methane is captured and used as a source of energy. Deeper coal formations
might require hydraulic fracturing to release the natural gas"

Accepted withmodification

Reworded as follows: coal bed methane (CBM): natural gas (methane/CH4,
mainly) generated during coal formation and absorbed in coal. Originally
extracted as a safety measure to reduce explosion hazards in mines, today
CBM is captured and used as a source of energy. For deeper coalformations, hydraulic fracturing may be needed to release the natural gas.

10052

2

Annexes

3036

3036

Miriam Lev-On
Recommend providing a separate definition of Conventional and Uncoventional
completions: (a) "Well Completion, Conventional refers to the process that initiates theflow of petroleum or natural gas from a newly drilled well prior to production. This
stream of fluids during well completions is referred to as “flowback”. During
completion the reservoir is connected to the wellbore allowing the flowback of drilling
and reservoir fluids (gas, oil, water, mud, etc.) to the surface. In a conventional wellcompletion, the flowback period (also known as well cleanup) may involve flaring or
venting of produced gas to the atmosphere via an open pit or tank collecting thefluids"; (b) "Well Completion, unconventional involve hydraulic fracturing and resultin a higher rate of flowback than most conventional well completions, due to the large
quantities of water and proppant (mainly sand) used to fracture lower permeability
reservoirs. This high-rate flowback is generally composed of a mixture of fracking
fluids with reservoir gas and liquids and may generate significant amount of methaneand hydrocarbon emissions to the atmosphere. Similarly, flaring generates asignificant amount of combustion emissions, incurs product losses and is not always aviable option depending on the well location, the concentration of flammable gases in
the flowback gas as well as other considerations."

Accepted withmodification

Adopted some of wording but not all: completion, as follows: completion:
process of initiating flow of petroleum or natural gas from a newly drilled
well prior to production (a) For conventional well completion a reservoir isconnected to the wellbore during this process, allowing the flowback ofdrilling and reservoir fluids (gas, oil, water, mud, etc) to the surface. While
there is flowback, a period known also as well cleanup, there may be flaring
or venting of produced gas from the reservoir. (b) For unconventional wellcompletion, if hydraulic fracturing is employed, there may be a higher rateof flowback of water, fracking fluids, reservoir gas and fracturing proppant(e.g. sand) that can release greater amounts of methane and hydrocarbons to
the atmosphere when compared to a conventional well completions.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

10054

2

Annexes

3038

3038

Recommend inserting a definition of Green Completion. "Green Completions is atechnology known as Reduced Emissions Completions (RECs) or “green
completions” that may be implemented to offset potential loss of methane and otherhydrocarbons during flowback associated with unconventional well completions.
‘Green Completions’ is an alternate practice that captures the produced gas during
well completions and well workovers following hydraulic fracturing.

Miriam Lev-On

Accepted withmodification

Added definition as subpoint of "completion". Completion: process of
initiating flow of petroleum or natural gas from a newly drilled well prior to
production (a) For conventional well completion a reservoir is connected to
the wellbore during this process, allowing the flowback of drilling andreservoir fluids (gas, oil, water, mud, etc) to the surface. While there is
flowback, a period known also as well cleanup, there may be flaring or
venting of produced gas from the reservoir. (b) For unconventional wellcompletion, if hydraulic fracturing is employed, there may be a higher rateof flowback of water, fracking fluids, reservoir gas and fracturing proppant(e.g. sand) that can release greater amounts of methane and hydrocarbons to
the atmosphere when compared to a conventional well completions. (c) in agreen completion or reduced emissions completion (REC) produced gas
following hydraulic fracturing is captured, offsetting the loss of methaneand other hydrocarbons during flowback from the well completion.

10056

2

Annexes

3151

3151

Recommend inlcuding a range in the definition of heavy crude (API < 20 degrees)

Miriam Lev-On

Accepted

Added to definition. heavy crude: a low API (< 20 degrees)/high density
hydrocarbon .

10058

2

Annexes

3156

3157

Recommend broadening the definition by including the EPA explanation: "Hydraulic Miriam Lev-On
fracturing produces fractures in the rock formation that stimulate the flow of natural
gas or oil, increasing the volumes that can be recovered. Wells may be drilled
vertically hundreds to thousands of feet below the land surface and may include
horizontal or directional sections extending thousands of feet.

Accepted withmodification

Updated language to: hydraulic fracturing: a method of enhanced oil or gas
recovery in which fluids are pumped into a rock formation a geologic
formation is broken down by pumping down fluids at very high pressures inorder to fracture the rock and stimulate the flow of natural gas or oil,increasing the volumes that can be recovered. ; the purpose is to increase
production rates from a reservoir. Wells may be drilled vertically hundreds
to thousands of feet below the surface and may include horizontal or
directional sections extending thousands of feet away from the well.

10060

2

Annexes

3177

3177

The dfinition of LPG provided here is not adequate. It should be replaced with thedefinition provided in Line 3184 to 3186

Miriam Lev-On

Accepted

Deleted duplicate definition in 3177. Retained definition 3184-3186. liquid
petroleum gas (LPG): a light hydrocarbon that is gaseous at atmospherictemperature and pressure and which is held in a liquid state (by pressure) inorder to ease transport and handling; consists of either propane, butane, or
mixtures of the two.

10062

2

Annexes

3184

3186

Retain this definition for LPG and remove the one in Line 3177.

Miriam Lev-On

Accepted

Deleted duplicate definition in 3177. Retained definition 3184-3186. liquid
petroleum gas (LPG): a light hydrocarbon that is gaseous at atmospherictemperature and pressure and which is held in a liquid state (by pressure) inorder to ease transport and handling; consists of either propane, butane, or
mixtures of the two.

10064

2

Annexes

3192

3192

Recommending adding a statement that MBOE is a unit of energy equal to 0.1555
billion m3 of natural gas, or equivalent to 1.7 TWh

Miriam Lev-On

Accepted withmodification

Changed definition to reflect that is a unit of energy; however, did notprovide conversion factors since this depends on the energy content of theoil or gas which can vary significanty. million barrels of oil equivalent(MBOE): a unit of energy based on the energy release by burning one
million barrels (one barrel is 42 US gallons or 158.9873 L) of crude oil.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

4820

2

4

3223

3224

The definision of oil shale in the ducument is given wrong (the definition of both oil Anna Paturska
shale and shail oil (lines 3292-3293) are given the same. We recommend the diffinionof oil shale as it is given in International Recommendations forEnergy Statistics (IRES) - Oil shale / oil sands - A sedimentary rock which contains
organic matter in the form of kerogen. Kerogen is a waxy hydrocarbon-rich material
regarded as a precursor of petroleum.

Accepted withmodification

Deleted shale oil definition. Changed oil shale to new definition - oil shale:
a sedimentary rock containing organic matter in the form of kerogen, awaxy hydrocarbon-rich material regarded as a precursor to petroleum. Oilshale may be burned directly or processed by, for example, heating to
extract shale oil.

10066

2

Annexes

3292

3292

Definition is redundant with definiton provided in Line 3223

Miriam Lev-On

Accepted withmodification

Deleted definition for "shale oil" and used "oil shale" definition according toComment #4820.

1686

2

4

Table
4.2.1

For the Gas Production industry segment, should "wet gas" be included?

Adam Eisele

Accepted withmodification

Table 4.2.1 was revised to delete activity data requirement for tier 3. For
example, for gas production, the AD would be gas production volume, no
mentioning dry gas or wet gas.

1680

2

4

Fig 4.2.1 Fig 4.2.1 In the Production step, shouldn't storage be included? It's common for natural gas(1(1
production well pads to include storage tanks

Adam Eisele

Accepted

Added image.

1678

2

4

Fig 4.2.1 Fig 4.2.1 For (b) Production and Upgrading, does upgrading include onshore oil polishing(1(1
facilities?

Adam Eisele

Rejected

No EF is available.

1684

2

4

Fig 4.2.5 Fig 4.2.5 The "Yes" in between the diamonds "Are actural measurements or…" and "Arenational Tier 2…" should say "No".

Adam Eisele

Accepted

4072

4

2

Table
4.2.1

Table
4.2.1

Gathering and boosting appears to be missing from the list.

Mark de Figueiredo

Accepted

Added it.

4076

4

2

Table
4.2.1

Table
4.2.1

It is not clear why anomalous events are categorized under "other" as industry segment Mark de Figueiredo
instead of the industry segment itself. For example, shouldn't anomolous storage wellleaks be classified under the gas storage industry segment?

Rejected

Reporters could report information on the segment of origin in the
documentation box if interested.

4074

4

2

Table
4.2.1

Table
4.2.1

The example activities in the second column of Table 4.2.1 differ from exapmle
activities noted in Figure 4.2.1

Mark de Figueiredo

Rejected

Figure 4.2.1 gives in brief introcution on the segments of oil system (subcategory), and table 4.2.1 refer to the AD and/or emission sources in eachsegments. They are not necessarily the same.

4092

4

2

Table
4.2.10Table
4.2.10

There is a typo in footnote 3. The phrase "factor s" should be changed to "factors".

Mark de Figueiredo

Accepted

4090

4

2

Table
4.2.10Table
4.2.10For second row on page 4.71, the indentation of the second column should be
conformed to match the indentation of the other columns

Mark de Figueiredo

Accepted

4094

4

2

Table
4.2.11

Table
4.2.11On Page 4.74, recommend conforming terminology between the first and second rows Mark de Figueiredo
for describing centrifugal compressors with dry seals. The first row calls them "dryseal compressors", while the second row describes them as "centfigual compressors[that] are dry seal".

Accepted

4096

4

2

Table
4.2.11

Table
4.2.11

Mark de Figueiredo
It was not clear whether the first and second rows were intended to be a continuum.
For example, does "limited use of dry seal compressors" (first row) mean that less than
50% of centrifugal compressors are dry seal (second row)? Recommend changing the
sub-category in the first row if they are intended to be a continuum.

Accepted

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

4098

4

2

Table
4.2.12Table
4.2.12In the first column, the term "Gas Transmission" is cut off due to the column width.

Mark de Figueiredo

Accepted

4100

4

2

Table
4.2.12Table
4.2.12In the last column, the term "Tonnes per km pipeline" has a larger font size than theother units of measure.

Mark de Figueiredo

Accepted

4102

4

2

Table
4.2.12Table
4.2.12

It is not clear why the term "Extensive use of LDAR" is used rather than "Mostactivities occuring with lower-emitting technologies and practices"Mark de Figueiredo

Accepted

4104

4

2

Table
4.2.12Table
4.2.12

Footnote a has a smaller font size than the other footnotes of the table.

Mark de Figueiredo

Accepted

4106

4

2

Table
4.2.13Table
4.2.13For the first row on page 4.79, the indentation of the first column should be
conformed to match the indentation of the other columns

Mark de Figueiredo

Accepted

1694

2

4

Table
4.2.15Table
4.2.15In the "Gas Processing" category (and throughout the rest of the document), is it
accurate to refer to Gas Processing plants as either "Sweet Gas Plants or "Sour Gas
Plants"? It seems like amine treating is only one step of many at Gas Processing
Plants.

Adam Eisele

Rejected

2019 refinment tries to provide more accurate and diversified Efs used byTier 1 approach, based on the national statistic system and EF avaialibity.
In may cases, gas production is not able to be disaggregated to sweet andsour gas, and a general EF has to be provided. And EFs for other steps thanamine treating is not available.

1688

2

4

Table
4.2.2

Table
4.2.2

For this table, does the US have any data available for conventional oil for areas such Adam Eisele
as the Bakken or the Eagle Ford basins? The geographical coverage seems limited.

Noted

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

4078

4

2

Table
4.2.3

Table
4.2.3

Mark de Figueiredo
There appears to be a typo in the first row shown on Page 4.56. "Unconventional
without flaring" should be written as "Unconventional without flaring or recovery" oralternatively "Unconventional without flaring or gas capture".

Accepted

4082

4

2

Table
4.2.5

Table
4.2.5

For footnotes b and c, the "4" in CH4 and "2" in N2O should be subscripts.

Mark de Figueiredo

Accepted

4080

4

2

Table
4.2.5

Table
4.2.5

The font size for footnotes b and c is smaller than the font size for the other footnotes Mark de Figueiredoof the table

Accepted

4084

4

2

Table
4.2.9

Table
4.2.9

For footnote c, the "2" in N2O should be a subscript.

Mark de Figueiredo

Accepted

5626

2

4

In Table 4.2.4, the uncertainty levels for fugitive emissions in gas transmission,storage and distribution are -20-500% which is too coarse. It is recommended that
IPCC provided leakage rates per country and considers types of pipelines, age, etc.

MINGMING WANG

Accepted withmodification

Uncertainty is now better explained. Leakage rates by country areunavailable but some examples are in the annex.

5958

2

4

2308

2308

Change Fusitive to Fugitive

Vincent Camobreco

AcceptedSpelling corrected.

9628

2

4

2308

2308

"FUSITIVE" may be "FUGITIVE".

Naofumi Kosaka

AcceptedSpelling corrected.

4038

2

4

2308

2308

Two typos: change "Fusitive emissions from fuel transforamation" to "Fugitive
emissions from fuel transformation"

Gregory Peters

AcceptedSpellings corrected.

5710

2

4

2308

2309

Correct "Fugitive"and "Transformation"

Javier Marcelo Hanna
Figueroa

AcceptedSpellings corrected.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

5108

2

4

2308

2309

2 misprints in title, should read: Fugitive emissions from fuel transformation

Kari Grönfors

AcceptedSpellings corrected.

5712

2

4

2310

2311

These sentences are irrelevant. Delete.

Javier Marcelo Hanna
Figueroa

Rejected

It is important that there is a clear and simple definition that defines thescope of the section. The text has been reviewed to ensure clarity.

8824

2

4

2310

2311

This seems to be copy/paste and should either be modified to fit this section ordeleted.

Ole-Kenneth Nielsen

Rejected

It is important that there is a clear and simple definition that defines thescope of the section. The text has been reviewed to ensure clarity.

5110

2

4

2311

2319

First paragragh 4.3 speaks about fossil fuels, but paragaraph 4.3.1 takes in to account Kari Grönfors
also biomass. Fossil fuel transformation and biomass transformation should be dealt inseparate chapters. Fugitive biogenig CO2 emissions should not be estimated orreported.

Accepted

The comment is right, but the during the drafting of SOD, the cross-cutting
discussion with other volumes is still going on, and it will be clarified in the
final draft.

5714

2

4

2313

2313

Change the beginning to: "This section clarifies how fugitive emissions…."

Javier Marcelo Hanna
Figueroa

Rejected

It is not just this section of the document that clarifies the treatment offugitive emissions. All sections are about fugitvie meission.

5716

2

4

2318

2319

To make consistent this text with table 4.3.1, include "gasification transformation" and Javier Marcelo Hanna
Figueroain brackets: coal to liquid, gas to liquid, biomass to liquid, biomass to gas. Delete"refineries".

Accepted

Scope of the paragraph and Table 4.3.1 has been harmonised.

3318

2

4

2322

2323

Table 4.3.1. Category number in 1A subsector where "Emissions from the use of this Veronika Ginzburg
fuel for energy purposes should be reported" should be indicated not generally 1A, butmore specifically in the last column of the table. I suppose that for charcoal production
this should be 1A1cii, for coal production 1A1ci, etc.

Accepted withmodification

The comment is right, but the during the drafting of SOD, the relevant
discussion is still going on, and it will be revised in the final draft.

5112

2

4

2322

2323

Kari Grönfors
In table 4.3.1 wood pellet production is mentioned as part of Solid to solid fueltransformation. This does not follow the fuel definitions mentioned in 2006GL ch.
1.4.1.1; there Solid fuels include coal and coal products, wood (in general) is includedin Biomass. Production of charcoal, wood pellets and briquettes as well as biomass toliquids and biomass to gas transformation processes should be separated undertitle"Biomass transformation".

Accepted withmodification

The header in table 4.3.1 has been changed to "Wood pellet production".

9640

2

4

2324

2781

Naofumi Kosaka
The International Energy Agency (IEA)'s energy balance tables have the rows of"Patent fuel plants", "BKB/peat briquette plants", "Coal liquefaction plants" and"Charcoal production plants" under "Transformation processes". These row shows thequantity of feedstock input and product output. The CO2 emissions can be estimatedfrom the carbon balance ("Total" column) of this row. If national energy balance tables
have rows such as IEA, inventory compilers can estimate the emissions. The
methodology of IPPU sector in the 2019 Refinement may be good reference. Section
4.2.2.1 of Volume 3 provides production-based method as Tier 1a and simplified
carbon balance method as Tier 1b.

Rejected

Out of scope. The refinement for fuel transformation covers only fugitive
emissions.

5114

2

4

2331

2332

Lifecycle emissions should no be mentioned here, because inventory calculations have Kari Grönfors
nothing to do with lifecycle calculations. These are two totally different frameworks. It
is very confusing to mention lifecycle emissions here. At least there should be awarning not to include lifecycle emissions in sectoral GHG inventory calculations.

Accepted

References to lifecycle emissions have been removed.

Comment ID Volume

Chapter From line To line

Comment

5116

2

4

2340

2341

Add : Biogenig fugitive CO2 emissions from charcoal production should not be
included in 1A or 1B emission estimates.

4242

2

4

2341

2341

3320

2

4

2347

5718

2

4

4250

2

8826

ExpertKari Grönfors

Response

Authors note

Accepted

Comment added that emissions of biogenic CO2 from charcoal production
are considered under AFOLU.

Naofumi Kosaka
I suggest that the authors replace "Land Use, Land Use Change and Forestry(LULUCF)" with "Agriculture, Forestry and Other Land Use (AFOLU)". LULUCF is
not used in the 2006 IPCC Guidelines.

Accepted

We have replaced "LULUCF" with "AFOLU".

2347

Guidelines for estimation of CS EF is provided in the Vol.1 ch.2 of the 2019
Refinement. Cross reference to this chapter would be useful

Rejected

In the FOD of volume 1, chapter 2, no charcoal production is mentioned. In
chatper 5, a case study is there to highlight the possible overlap in CH4
estimation in charcoal prodciton, which is not relevant to the developmentof CS EF.

2352

2353

Javier Marcelo Hanna
In figure 4.3.1 the answer NO to "national charcoal production available" should
conduct to "collect AD", otherwise it will be impossible to use even tier 1 as indicated Figueroa
in equation 4.3.1. For tier 1 is irrelevant the judgement of key category. Correct this.

Accepted

We have reviewed the logic of the decision tree.

4

2366

2366

I suggest that the authors move this sentence to line 2373 or 2374, because thissentence is related to the emission factors.

Rejected

The sentence has not been moved since it follows the logic to describe theequation 4.3.1.

2

4

2372

2376

In general, there should be one generic EF for charcoal production, i.e. in addition to Ole-Kenneth Nielsen
the technology specific EFs, there should be one EF for unspecified charcoal
production. Currently, there are three CH4 EFs for unspecified charcoal production,
22-89 kg/t, 32 kg/ton and 27-45 kg/ton. Based on these data sources one EF should be
calculated, so that inventory compilers are not left to guess which one to choose.
Another issue with Table 4.3.2 is that the CH4 EF for a high-efficiency kiln is higher
than for a low-efficiency kiln, which is illogical. Also, the two EFs presented for ahigh-efficiency kiln differ by more than a factor 1000! This should be checked further.
The unit of the EFs could also be streamlined, i.e. pick either g/kg or kg/ton.

Accepted

We have selected one generic EF for charcoal production and provided
lower and upper bound limits.

3322

2

4

2372

2376

The range of emission factors according to kiln technology type provided in the table Veronika Ginzburg
4.3.2. is huge (from 0 to 89 kg CH4/t charcoal). More detail guidelines should be
provided in this section how to use the sppropriate EF.

Accepted

We have provided additional guidance.

4248

2

4

2373

2374

Naofumi Kosaka
I suggest that the authors provide a guidance how to choose the default emission
factors if the charcoal production by kiln efficiency is not available. The suggested text
might be "If the charcoal production by kiln efficiency and country-specific emission
factors are not available, it is good practice to apply the largest emission factors listed
in table 4.3.2."

Accepted

We have provided additional guidance.

5960

2

4

2375

2376

Table 4.3.2 22-89 kg CH4/t charcoal is this charcoal produced?

Accepted

We have confirmed that the reference is to charcoal being produced.

5720

2

4

2375

2376

Correct 32 +/- 5 g CH4/kg charcoal produced for the EF developed by Chidumayu and Javier Marcelo Hanna
Figueroa
Gumbo (2013). Also for consistency you can show as 27-37 g CH4/kg charcoal
produced.

Accepted

We have improved the consistency of the presentation of the emission
factors.

Veronika Ginzburg

Naofumi Kosaka

Vincent Camobreco

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

4226

2

4

2375

2376

I propose another potential reference for emission factors of charcoal production(http://dx.doi.org/10.1029/2000GB001382). This paper uses the emission factors ofcharcoal making as 10.7 g-CH4/kg(dry) and 0.03 g-N2O/kg(dry) (see Table 1). The
2006 IPCC Guidelines refer this paper in another context (Volume 4, Chapter 2).

Naofumi Kosaka

Rejected

The reference is about emission from biomass burning, not fugitive
emission from charcoal production.

4228

2

4

2375

2376

Naofumi Kosaka
I propose another potential reference for emission factors of charcoal production.
United States Environmental Protection Agency (1995). AP 42, Fifth Edition, Volume
I, Section 10.7: Charcoal (https://www3.epa.gov/ttn/chief/ap42/ch10/index.html)

Rejected

This EF cited in the EPA report has a quality rating of "E", and is based on
2 EFs. One EF is from 1967 and the other from 1971.

2438

2

4

2375

2376

Table 4.3.2 provides six ranges of emission factors for CH4, for example, 0~0.036 kg Dong Koo Kim

Accepted

We have selected one default EF for charcoal production, and provided a
range.

CH4/kg charcoal, 22~89kg CH4/t charcoal, etc. according to various sources. The
emission factors for N2O also have three ranges. The guideline will be more helpful toinventory compilers if it provides a kind of default emission factor for charcoal
production or low, average, and high emission factors similar to those of undergroundmining.
4244

2

4

2375

2376

I suggest that the authors aggregate as one default emission factor per each kiln
efficiency (high or low), for simplification.

Naofumi Kosaka

Accepted

We have selected one default EF for charcoal production, and provided a
range.

4246

2

4

2375

2376

Naofumi Kosaka
I wonder that the CH4 emission factors (EF) depend on kiln efficiency. The EF forhigh efficiency kiln reported by Pennise et al (2001) and UNDP (2013) is close to the
EF for low efficiency kiln reported by Smith et al (1999).

Accepted

We have selected one default EF for charcoal production, and provided a
range.

4252

2

4

2375

2376

The CH4 emission factor (EF) reported by Bailis (2009) Taccini (2010) is about 1000 Naofumi Kosaka
times higher than other EF. I suggest that the authors investigate the reason of thisdifference.

Accepted

We have investigated this.

4798

2

4

2375

2376

In Table 4.3.2, EFs for charcoal production according to kiln technology are provided. Takashi Morimoto
Though various kinds of CH4 EFs are provided in the table, it is difficult to choose
which EF is appropriate in accordance with each country's national circumstances
because enough supporting information for each EF is not provided. It would be betterto provide additional information for each EF so that the inventory compiler canchoose which EF should be used. (For example, three default CH4 EF for unspecified
kiln are provided (22-89 kg CH4/t charcoal, 32+-5g CH4/kg charcoal produced, 27–
45 gCH4/kg charcoal produced). This is confusing on which EF should be used whenkiln technology used in the country cannot be specified)Accepted

We have selected one default EF for charcoal production, and provided a
range.

5722

2

4

2385

2385

Javier Marcelo Hanna
Reference needed for bag weight of 40 kg. However, this figure is highly uncertain
because weight may vary considerably from country to country and region by region. Figueroa
Try to avoid this reference and provide other type of guidance.

Accepted withmodification

We have replace the single weight with "of each bag is known".

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

4254

2

4

2396

2481

The 2006 IPCC Guidelines (Volume 3, Section 4.2) provide the methodology ofmetallurgical coke production. I wonder how the new guidance is different from theexisting guidance.

Naofumi Kosaka

Noted

It will be important to ensure harmonisation of the terminology andinformation in this section with the text in Volume 3, Section 4.2. But the
information in this section is more detailed than that in Volume 3, Section
4.2.2.1.

7154

2

4

2397

2397

replace 'processes' with 'process'Amanda Penistone

Accepted

Text replaced.

5962

2

4

2398

2401

Move the sentence "In the coke production process …" to after the sentence "Theprocesses produces coke …" on line 2398

Vincent Camobreco

Accepted

Text moved.

5724

2

4

2404

2404

Include "coke oven gas" before COG and put this in brackets.

Javier Marcelo Hanna
Figueroa

Accepted

Proposition Accepteded.

3324

2

4

2404

2405

Is it significant? Data for 2014 will not be already relevant after 2019 when 2019
Refinement is approved.

Veronika Ginzburg

Accepted withmodification

The authors suggest putting the scale of coke production in context is
important and we have retained the sentence. We have added the latest coalproduction from the IEA statistics when the SOD was revised.

5118

2

4

2408

2409

It is not clear, whether petroleum coke and crashed rubber tyres can be used as input
material for coke production or blast furnaces? Please clarify.

Kari Grönfors

Accepted

This has been clarified.

4256

2

4

2414

2415

I suggest that the authors delete or rewrite 'non-recovery'. It seems that 'non-recovery' Naofumi Kosaka
contradicts 'heat recovery'.

Accepted

This has been modified.

4800

2

4

2419

2420

Figure 4.3.2 shows the typical flow diagram of a coke oven plant showing emissions Takashi Morimoto
sources. This figure is a little bit difficult to understand which GHG emission sources
should be considered because not only GHG but other emissions such as dust andwater are shown together without distinction. This figure could be revised by
distinguishing between GHG emissions and other substance emissions.

Accepted

We have marked the likely major points of fugitive GHG emissions on the
diagram.

1506

2

4

2419

2420

Figure 4.3.2: The flow diagram is very helpful. However, it is not clear what stages of Michael Gytarskycoke production are the sources of CO2, CH4 and N2O emissions. It would help, if
the authors could indicate the particular emission sources at the diagram. The authors
could also accommodate particular production stages on Figure 4.3.2 and in Table
4.3.4.

Accepted

We have marked the likely major points of fugitive GHG emissions on the
diagram.

3326

2

4

2419

2420

Diagram is ery detailed. It would be great if it is possible to indicate on the diagram
which emission sources considered as fugitive, as energy combustion and as IPPU
sourcesVeronika Ginzburg

Accepted

We have marked the likely major points of fugitive GHG emissions on the
diagram.

5120

2

4

2434

2435

The explanations of likelihood "N", "Y", "P", "U" are missing (are they somewhere
else, too far from this table?)

Kari Grönfors

Accepted

A technical error in the PDF conversion meant the table footnote explaining
these terms was omitted. This has been added back.

8828

2

4

2434

2435

While it is possible to guess the meaning of Y, N, P and U, it probably should bespecified somewhere.

Ole-Kenneth Nielsen

Accepted

A technical error in the PDF conversion meant the table footnote explaining
these terms was omitted. This will be added back.

1508

2

4

2434

2435

Table 4.3.4: It is proposed that the description of notation keys for fugitive emission
likelihood ("N", "Y", "P" and "U") is provided below the Table 4.3.4.

Michael Gytarsky

Accepted

A technical error in the PDF conversion meant the table footnote explaining
these terms was omitted. This will be added back.

4258

2

4

2435

2435

I suggest that the authors add a footnote for the definition of 'N', 'Y', 'P' and 'U' in table Naofumi Kosaka
4.3.4.

Accepted

A technical error in the PDF conversion meant the table footnote explaining
these terms was omitted. This will be added back.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

3328

2

4

2436

2437

Figure 4.3.3 If onle national coke production data available it is not possible to use tier Veronika Ginzburg
3 AD. The box "Estimate emissions using tier 3 AD and default EF (tier 2)" should be
revised. Tier 2 ususally means use of CS EFs.

Accepted

Figure 4.3.3 has been revised.

5122

2

4

2436

2437

The second box in the right: should probably include "..using tier 2 AD.." instead oftier 3 AD.

Kari Grönfors

Accepted

Figure 4.3.3 has been revised.

5124

2

4

2436

2437

Using the desicion tree: how can be emissions estimated, if no coke production data is Kari Grönfors
available, in non-key-category case? What does Tier 1 mean here?

Accepted

Figure 4.3.3 has been revised.

5726

2

4

2436

2437

The answer NO to "Are process stage level emission factors available?"should conduct Javier Marcelo Hanna
directly to "Estimate emissions using tier 3 AD and default EF (tier 2)".
Figueroa

Accepted

Figure 4.3.3 has been revised.

5728

2

4

2436

2437

In figure 4.3.3 the answer NO to "national coke production available" should conduct Javier Marcelo Hanna
Figueroato "collect AD", otherwise it will be impossible to use even tier 1 as indicated inequation 4.3.2. For tier 1 is irrelevant the judgement of key category. Correct this. It is
unclear what means tier 2 AD and tier 3 AD. Clarify.

Accepted

Figure 4.3.3 has been revised.

5128

2

4

2448

2452

Equation 4.3.2: this cannot be Tier 1 method, because this requires the most detaileddata.

Kari Grönfors

Accepted

Equation 4.3.2 has been revised and simplified the equation further, so that
it is more applicable to Tier 1.

5130

2

4

2450

2452

Equation 4.3.2: check, whether the equation is possible for tier 1 or tier 2 or tier 3 or
any tier; crosscheck against desicion tree.

Kari Grönfors

Accepted

Equation 4.3.2 has been revised and simplified the equation further, so that
it is more applicable to Tier 1.

8830

2

4

2450

2452

Equation 4.3.2 refers to charcoal production rather than coke production.

Ole-Kenneth Nielsen

Accepted

The text has been corrected.

5126

2

4

2452

2452

Equation 4.3.2: replace "charcoal" with "coke"

Kari Grönfors

Accepted

The text has been corrected.

3330

2

4

2467

2472

It is not clear which default EFs CH4 and N2O should be used for tier 1 approach. If
there is no sufficient default fugitive emission factors for coke production then tier 1
methodology could not be applied. However, Tier 1 approaches are simple methods
that can be applied by all countries in all circumstances. Default values for theemission factors and any other parameters needed must be supplied

Veronika Ginzburg

AcceptedA default factor has been included.

2440

2

4

2468

2469

The FOD does not present emission factors from coke production, however, it might
be very difficult for inventory compilers to estimate the amount of GHG emissions
from coke production without reliable remission factors.

Dong Koo Kim

AcceptedA default factor is provided in table 4.3.5 on p.4.119.

5730

2

4

2468

2472

If there are no default EFs this section should be dropped from the 2019 Refinement.
Or put in an annex as a basis for further development. Strong objection to include
some guidance that cannot be used or supported with default EFs.

Javier Marcelo Hanna
Figueroa

AcceptedA default factor is provided in table 4.3.5 on p.4.119.

5132

2

4

2482

2482

Rephrase the title to follow 2006GL fuel definition principles, for example: Solidbiomass transformation and write another chapter concerning fossil fuels and peattransformation processes.

Kari Grönfors

Accepted

The title of the section has been revised.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

5136

2

4

2482

2509

The whole chapter is confusing, starting with biomass, but later mixing biomass andfossil fuels. Biogenig fugitive CO2 emissions should not be estimated or reported,
whereas fugitive fossil CO2 emission should be estimated.

Kari Grönfors

Accepted

The order of the sections has been changed to group fossil and non-fossil
sources.

5134

2

4

2487

2488

Patent fuel, brown coal briquettes and peat briquettes and pellets should be discussed
under separate chapter (fossil fuels and peat separated from biomass).

Kari Grönfors

Accepted withmodification

The order of the sections has been changed to group fossil and non-fossil
sources. Material on wood pellets has been put in an Appendix.

5138

2

4

2500

2503

The whole chapter should be restructured, separating fossil fuels and biomass; if thiswill not be done, please add : Fugitive CO2 emissions should be estimated only fromfossil fuel transformation.

Kari Grönfors

Accepted

The order of the sections has been changed to group fossil and non-fossil
sources.

5964

2

4

2506

2507

Make figure formatting consistent throughout section

Vincent Camobreco

Accepted

The figure formatting has been harmonised.

5966

2

4

2512

2512

Put in standard note about inclusion of biogenic CO2 emissions in LULUCF sector

Vincent Camobreco

Accepted

A note about the inclusion of biogenic CO2 in the AFOLU section has been
added (note the IPCC guidelines refer to AFOLU).

5732

2

4

2512

2514

Brackets remain in the text. Carefully check. Also in line 2559, in 2581-2593, 26262627, 2676.

Javier Marcelo Hanna
Figueroa

Accepted

Brackets have been removed in the final text.

5734

2

4

2521

2522

Decision tree needs editorial work. Replace key source by key category.

Javier Marcelo Hanna
Figueroa

Accepted

The comment is right. The change on decission tree will be done in the final
stage.

5140

2

4

2524

2563

It seems, that this chapter takes into account so called lifecycle-emissions. This should Kari Grönfors
not be the case: inventory estimates should not include lifecycle emissions. Pleasecheck and correct the text and tables 4.3.5 - 4.3.11 correspondingly. Leave out all theissues concerning life-cycle approach.

Accepted

References to lifecycle emissions have been removed.

4818

2

4

2528

2532

Anna Paturska
Central Statistical Bureau of Latvia is collecting data of amount of produced woodpellets, but is not collecting information about sources of pellet production (as it isgiven in Volume 2 Chapter 4:Pellets from forest logging residues; Pellets from woodindustry residues; Pellets from stem wood; and, Pellets from agricultural residues). It
is difficult to obtain such data and this would be an overload for respondents.

Noted

No action can be taken because comment does not require any substantial
reaction.

5142

2

4

2538

2539

Add a remark to the Figure 4.3.6 showing, which parts of the pathway include direct
fugitive emissions, and also a comment on estimation only fossil fugitive CO2
emissions. Show clearly which boxes include possibility of direct CH4 ort N2Oemissions (exclude lifecycle emissions caused by the non-road machinery, transport,
electricity use, heat use etc.)

Kari Grönfors

Accepted

The figure has been revised.

5144

2

4

2544

2545

Table 4.3.5 seems to give energy consumption figures (factors) for pellet production.
Emissions from these energy uses should not be accounted here, but in Fuelcombustion subsectors. If the emission factors in this table include emissions fromenergy use, remove or correct the figures.

Kari Grönfors

Accepted

The section on wood pellet production has been revised, and moved to an
Appendix.

4260

2

4

2544

2546

Tables 4.3.5 and 4.3.6 refer to "EMEP/EEA Guidebook 2013 Chapter 1.A.4.c.ii", but Naofumi Kosaka
I do not find such a chapter. If the exact chapter name is "1.A.4 Non-road mobile
sources and machinery", I suggest that the authors rewrite the reference as such.

Accepted

The table has been removed in SOD.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

5736

2

4

2544

2552

In all tables instead of "amount" use "value" and place the unit in a column at the right Javier Marcelo Hanna
Figueroaside of the value. In tables 4.3.8 and 4.3.9 there are blank cells, please fill in. It is
unclear for what purpose data in table 4.3.9 is used or how it should be used. Clarify,
provide clear guidance.

Accepted

The table has been removed in SOD.

1510

2

4

2544

2552

Tables 4.3.5 to 4.3.10: It is not clear why the Tables 4.3.5 to 4.3.10 have been
Michael Gytarsky
included, so far as they do not provide the values of greenhouse gas emission factors.

Accepted

The table has been removed in SOD.

4262

2

4

2544

2553

Naofumi Kosaka
I assume that Tables 4.3.5 through 4.3.11 refer to "EMEP/EEA Guidebook 2013,
1.A.4 Non-road mobile sources and machinery, table 3-1, Forestry". Table 3-1
specifies fuels as diesel, LPG, four-stroke gasoline and two-stroke gasoline. I thinkthat the emission factors in table 3-1 can not be applied to biomass fuels. As explainedin Appendix C of the same chapter, table 3-1 is based on engine. I think that it isinappropriate to construct default emission factors of solid to solid transformation
based on the emission factors in table 3-1 of EMEP/EEA Guidebook 2013.

Accepted

The table has been removed in SOD.

5146

2

4

2545

2546

Table 4.3.6 seems to give energy consumption figures (factors) for pellet production.
Emissions from these energy uses should not be accounted here, but in Fuelcombustion subsectors. If the emission factors in this table include emissions fromenergy use, remove or correct the figures.

Kari Grönfors

Accepted

The table has been removed in SOD.

5148

2

4

2547

2548

Kari Grönfors
Table 4.3.7 seems to give energy consumption figures (factors) for forest residues
collection. Emissions from these energy uses should not be accounted here, but in Fuelcombustion subsectors. If the emission factors in this table include emissions fromenergy use, remove or correct the figures.

Accepted

The table has been removed in SOD.

5150

2

4

2548

2549

Table 4.3.8 seems to give energy consumption figures (factors) for woodchipping.
Emissions from these energy uses should not be accounted here, but in Fuelcombustion subsectors. If the emission factors in this table include emissions fromenergy use, remove or correct the figures.

Kari Grönfors

Accepted

The table has been removed in SOD.

5152

2

4

2549

2550

Table 4.3.9 seems to give some transportation information for typcial pellet pathways. Kari Grönfors
Emissions from transportation should not be accounted here, but in Fuel combustion
subsectors. Remove table, or add emission factors, if there are direct fugitive
emissions of CH4 or N2O during transportation.

Accepted

The table has been removed in SOD.

5154

2

4

2551

2552

Kari Grönfors
Table 4.3.10 seems to give energy consumption figures (factors) for agri-residues
preprocessing. Emissions from these energy uses should not be accounted here, but in
Fuel combustion subsectors. If the emission factors in this table include emissions
from energy use, remove or correct the figures.

Accepted

The table has been removed in SOD.

5156

2

4

2552

2553

Kari Grönfors
Table 4.3.11 seems to give emission factors for pellet production. Emissions fromenergy uses should not be accounted here, but in Fuel combustion subsectors. If theemission factors in this table include emissions from energy use, remove or correct thefigures.

Accepted

The table has been removed in SOD.

Comment ID Volume

Chapter From line To line

Comment

ExpertAuthors note

Accepted

The table has been removed in SOD.

The derivation of the values contained in Table 4.3.11 is very unclear. The preceding Ole-Kenneth Nielsen
tables show e.g. emissions associated with transport and the energy consumption used
for e.g. woodchipping. The EFs should represent fugitive emissions and only fugitive
emissions and not energy related emissions from the manufacturing or transport. This
needs a lot of further clarification.

Accepted

Tables 4.3.5 through 4.3.11 have been removed in SOD.

2559

Wood pellets are usually commercially traded, thus the amounts should be available in Kari Grönfors
energy statistics.

Accepted withmodification

The introduction on wood pellets has been revised without mentioning theavailablity on statiscial data.

2574

2612

All three sections (BTL, CTL, and GTL) have a slightly different discussion of FT
process. Suggest creating a generic discussion of FT and move it to the up front
section after line 2573

Accepted withmodification

These sections have been rewritten focusing on Gasification process
technology and highlighting that biomass, coal and gas are the inputs thatcan be used in the process. However, all information related to biomass
input has been provided as an appendix because the technology isdeveloping.

4

2575

2588

This segment on biomass to gaseous fuels seems to only consider thermal processes, Gregory Peters
whereas biogas is commonly produced by microbial fermentation of wastewater. Line
2575 should be refined to recognise this other source. Additionally the start of thesentence "The biomass used in these processes does not have any carbon of fossil
origin …" should be changed to "With the exception of many wastewater treatment
processes, the inputs to these processes do not have any carbon of fossil origin …"

Rejected

Section 4.3, this section, does not cover fugitive emissions from non-energy
related sectors. BtG is related to a specific process of gasification where
biomass is gasified with oxygen and steam resulting in a synthetic gas, thesyngas. Biogas produced by microbial fermentation is another process not
related to BtG technology.

2

4

2580

2717

This part uses several different expressions for a chemical process. Those are "Fisher Dong Koo Kim
Tropsch (FT)"(line 2580), "Fischer-Tropsch"(lines 2600, 2601, and 2717),"FischerTropsch(FT)"(line 2609), and "Fishcer and Tropsch"(line 2649). Maintaining
consistency in expression will make the guideline more readable.

Accepted

We have used one expression for the Fischer–Tropsch process.

5160

2

4

2589

2590

This seems to be a new requirement. According to present guidelines, only biogenig
CO2 emissions from combustion should be reported as an information item. Fugitive
biogenig CO2 emissions have not been included under this information item. This isquite a radical change, it should be checked.

Kari Grönfors

Accepted

This comment is very important, however, the cross discussion with
AFOLU is still going on during the drafting of SOD and no action is
implemeted right now.

5970

2

4

2590

2593

Consistent language on biogenic CO2 emissions inclusion in LULUCF

Vincent Camobreco

Accepted

This comment is very important, however, the cross discussion with
AFOLU is still going on during the drafting of SOD and no action is
implemeted right now.

2442

2

4

2596

2599

This part uses chemical terms such as "carbon monoxide, hydrogen"(line 2596),"hydrogen sulphide"(line 2597), and "hydrogen to carbon monoxide"(line 2599), notchemical symbols such as CO, H2, CO2 which are used in other parts of the FOD.
Unless there is a special reason, maintaining consistency in expression will make theguideline more readable.

Dong Koo Kim

Accepted

We have harmonised the reference to chemical terms with their usages inother parts of the 2019 Refinement.

560

2

4

2552

2553

A similar remark on the default Efs as presented in table 4.3.11.
I cannot believe that the uncertainties in these Efs are consistent with theirpresentation with three significant digits. Furthermore, no uncertainty ranges areprovided here.

8832

2

4

2552

2553

5158

2

4

2559

5968

2

4

4040

2

2444

Tinus Pulles

Response

Vincent Camobreco

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

5162

2

4

2602

2602

…fraction of CTL plant CO2…

Kari Grönfors

Accepted

We have corrected this typographical error.

5164

2

4

2602

2602

…needs to be separated…

Kari Grönfors

Accepted

We have corrected this typographical error.

5972

2

4

2602

2602

Change sentence … CTL plan CO2 … to … CTL plant CO2 …

Vincent Camobreco

Accepted

We have corrected this typographical error.

5974

2

4

2624

2624

Table 4.3.12 add BTL CH4?

Vincent Camobreco

Rejected

No action since the context is about CTL and GTL process.

5166

2

4

2662

2663

Decision tree in Figure 4.3.7 has an endless loop.

Kari Grönfors

Accepted withmodification

The decision tree is still under consideration in SOD, and will be revised in
the FD.

5738

2

4

2662

2663

The title and the contents in boxes of decision tree should reffer to "gasificationtransformation processes" and not to "fuel transformation…"

Javier Marcelo Hanna
Figueroa

Accepted

The title has been updated. The decision tree is still under consideration in
SOD, and will be revised in the FD.

2446

2

4

2662

2663

Figure 4.3.7 only provides tier 1 and 3. Tier 2 needs to be added in the figure.

Dong Koo Kim

Accepted

The decision tree is still under consideration in SOD, and will be revised in
the FD.

1512

2

4

2672

2674

Michael Gytarsky
The authors should explain the reasons for the use of default data on characteristic
parameters from Chapter 2 of Waste Volume of the 2006 IPCC Guidelines within thedescription of mehodology for estimation of greenhouse gas emissions fromgasification transformation processes.

Accepted

5168

2

4

2677

2677

Equation 4.3.3 leaves out some CH4 and N2O due to FCFi. This is not correct. The
equation should be split to 2 equations, one for CO2 and the other for CH4 and N2O.

Kari Grönfors

Accepted

The equation has been modified into 2 equations in SOD.

5740

2

4

2687

2687

Include "municipal solid waste" before MSW and put this in brackets.

Javier Marcelo Hanna
Figueroa

Accepted

The use of acronyms and definitions has been reviewed.

5170

2

4

2692

2692

Equation 4.3.4 leaves out some CH4 and N2O due to FCFi. This is not correct. The
equation should be split to 2 equations, one for CO2 and the other for CH4 and N2O.

Kari Grönfors

Accepted

The equation has been modified into 2 equations in SOD.

5742

2

4

2707

2707

The first sentence needs some editorial work. It seems incomplete or to be linked with Javier Marcelo Hanna
the second sentence.
Figueroa

Accepted

The sentence has been rephrased.

5172

2

4

2728

2729

Table 4.3.13 gives CO2EF of BtG and BtL processes. If CO2 is biogenig, it should not Kari Grönfors
be estimated or reported.

Accepted

562

2

4

2728

2749

Default uncertainty data should be added to the tier 1 default EF tables 4.3.13, 4.3.14
and 4.3.15

Tinus Pulles

Accepted

The table will be modified and default uncertainty estimates will be addedin the FD.

5976

2

4

2729

2729

Would the CO2 emission in Table 4.3.13 be listed as memo item?

Vincent Camobreco

Noted

Yes, just as a memo item.

5744

2

4

2729

2729

Move this sentnce to the end of previous paragraph (line 2728).

Javier Marcelo Hanna
Figueroa

Accepted

Sentence order has been adjusted.

2448

2

4

2734

2734

The description "Table 4.3.10 presents" needs to be corrected as "Table 4.3.14
presents".

Dong Koo Kim

Accepted

Text has been modified.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

8834

2

4

2741

2749

Ole-Kenneth Nielsen
Table 4.3.15 is under the heading of gas to liquids, but the table heading mentions
biomass to gas and biomass to liquid. Finally, the unit of the EF is presented as kg per
TJ natural gas input.

Accepted withmodification

Modified the first part but the second part was not modified because it iscorrect.

4270

2

4

2742

2748

Line 2742 refers to Jaramillo et al. (2008), but such paper is not included in reference Naofumi Kosaka
list (line 3645 through 3664). The reference list includes Jaramillo et al. (2007), but
this paper is not related to 'gas to liquids'. I think the correct reference is as follows.
http://pubs.acs.org/doi/full/10.1021/es8002074

Accepted

References have been updated.

5174

2

4

2748

2749

Title of Table 4.3.15 is erraneous, it should read GTL instead of BtG and BtL.

Kari Grönfors

Accepted

The table heading has been changed.

4268

2

4

2749

2749

I suggest that the authors replace "BTG AND BTL" by "GTL" for the title of table
4.3.15.

Naofumi Kosaka

Accepted

The table heading has been changed.

5176

2

4

2756

2756

The activity data…

Kari Grönfors

Accepted

The typographical error has been corrected.

5178

2

4

2764

2764

The activity data…

Kari Grönfors

Accepted

The typographical error has been corrected.

4272

2

4

2764

2770

I introduce that the International Energy Agency (IEA)'s energy balance tables have Naofumi Kosaka
the row of "Gas-to-liquids (GTL) plants" under "Transformation processes". This row
shows the fuel quantity of gas input and liquid output. The CO2 emissions from GTL
can be estimated from the carbon balance of this row. If national energy balance tables
have GTL plants row like IEA, inventory compilers can estimate the emissions. I
suggest that inventory compilers investigate whether national energy balance tables
take into consideration GTL plants first. If it is already considered, inventory
compilers need to confirm whether the emissions are already included in fuelcombustion category. If it is confirmed, there is no need to estimate the emissions
separtely. If it is not confirmed, the emissions should be estimated by the default
emission factor and gas input.

Rejected

If you use energy balance we might overestimate the fugitive emissions. It
would be possible only if the amount of gas reported in energy balance
report is split between natural gas use for heating and electricity generationand for processing for liquid fuel production.

5746

2

4

2772

2780

For uncertainties please provide at least the expected order of magnitude for AD and
EFs.

Javier Marcelo Hanna
Figueroa

Accepted

The table will be modified and default uncertainty estimates will be addedin the FD.

5180

2

4

2783

2783

First sentence is strange (delete "That" from the beginning?)

Kari Grönfors

Accepted

Sentence has been modified.

4266

2

4

3550

3550

I suggest that the authors add "IPCC" before publication year (2012).

Naofumi Kosaka

Accepted withmodification

Reference has been deleted.

4264

2

4

3641

3644

I suggest that the authors add a reference of Asadullah (2014) mentioned in line 2727 Naofumi Kosaka
and table 4.3.13.

Accepted

Reference has been modified.

9036

2

4

2373
2394

2376
2395

Vishwa Bandhu Pant
Table 4.3.2 provides a range of emission factors according to kiln technology type low efficiency kiln, high efficiency kiln and Mound kiln.
Comment: It would be helpful for GHG inventory complier if some standard
specification / criterion / classification method may be provided to demarcate between
low efficiency kiln and high efficiency kiln to enable complier to select the emission
factors from Table 4.3.2 on this basis.

Accepted withmodification

The presentation of the EFs has been revised.

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

Vishwa Bandhu Pant
In 2014, 711 173 ktoe of coking coal were produced.
CHOICE OF EMISSION FACTOR - Currently there are no fugitive emission factors[of CH4 and N2O] from coke production which are sufficiently reliable to present as
Tier 1 factors. If inventory compilers have measurements of emissions from either
parts orall of the coke production processing stages, then these could be used as the basis ofreported fugitive emissions. It is good practice to try and verify these emissions toensure that they are realistic in magnitude in comparison with emissions from othercategories in the iron steel sector, and the energy sector.
Comment - Coking coal production is signifant amount. Absense of the reliable
fugitive emission factor(s) would lead to high uncertainties in emission estimate from
Coking coal production.

Accepted withmodification

CH4 emission from coke produciton is provided in SOD (table 4.3.5) based
ont the literature available in the drafting of SOD.

No refinment was made to Tables 2.2, 2.3 and 2.4. However, default emission factors MINGMING WANG
for stationary industrial combustion are considered too general, and it is recommended
that IPCC expands the disaggregation by types of equipment (boilers, furnaces, etc.),
technology and capacity, to reflect difference in emissions from different types ofequipment.

Noted

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

It is helpful to refine this section by adding a sentence to describe the reporting
boundary of Energy sector and IPPU sector, especitally for iron and steel subsector.

Mingshan Su

Noted

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

emission? Letter case

KEWEI YU

Accepted46

Define AFOLU, IEA

KEWEI YU

Rejected

These acronyms are available elsewhere in the guidance.

49

the use of international statistics (FAO or IEA) for AD would underestimate thecaused emissions. In most countries there arein addition large private collection procedures in place (this could add up to 100%
range of the data in official statitstics.
Should be mentioned in the data sources as well - a good tool to estimate these fuelquantities could be questionaires.

Michael Strogies

Noted

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

54

transformation, spelling

KEWEI YU

Accepted

4

58

production? letter case

KEWEI YU

Accepted

2

4

76

letter case

KEWEI YU

Accepted

4456

2

4

80

CO2, CH4, upper case letters

KEWEI YU

Accepted

4458

2

4

135

default, emission

KEWEI YU

Accepted

4460

2

4

188

Background

KEWEI YU

Rejected

9038

2

4

2404
2467

9592

2

2

23

52

2

2

32

4448

2

4

33

4446

2

2

37

9702

2

2

46

4450

2

4

4452

2

4454

2405
2472

32

90

136

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

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

9718

2

3

MINGMING WANG
The FOD does not contain any update to section 3.6 Civil aviation. However, as
mentioned in previous comments, cities as the largest GHG emissions contributors
often do not have access to airport and flight data, whereas national government or
agencies mostly do. Therefore it is strongly recommended that IPCC requires national
inventories to report aviation emissions per airport and even per flight where possible.

Noted

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

9720

2

3

MINGMING WANG
To improve modelling of LTO emissions, it is strongly recommended that IPCC
expands the EEA methods to provide average taxi-time data for airports outside EU
and USA, and to update the current ICAO default values of taxi-time as they are quite
rough and likely too high for small and medium sized airports and too low for poorly
managed large airports.

Noted

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

552

2

4

I congratulate the authors of this FOD for the good work they have performed.
As I hoped and expected, the refinements inb the energy volume are not very many.
Neither are my comments!

Noted

No action can be taken because comment does not require any substantial
reaction.

5262

2

4

Default emission factors for fugitive emissions are generally too coarse. For example, MINGMING WANG
the value for N2O from oil exploration in Table 4.2.3 range anywhere between 0.07
and 1.10. More refined data at more granular geographic level would be more helpful.

Accepted withmodification

Values were updated to use 1 value and no ranges in the SOD. We disagree
that more refined data at more granular geographic levels are appropriate forTier 1 factors.

2512

2

4

Chapter needs proof-reading, particularly from 4.2.2.4

Accepted

5638

2

2

34

35

Tinus Pulles

Anna Mikis

It is absolutely unclear what would be the issue on the link of biomass combustion and Javier Marcelo Hanna
Figueroa
methodologies for Harvested Wood Products. However, this elaboration should be
open for expert review also and not only for Governamental review.

Accepted withmodification

Appears that the commenter misinterpreted the text to mean that additional
information will be provided in this section later. We changed the wording
to not say "link" but instead say "note the location".

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

7840

2

2

37

41

Jason Funk
The text does not give compilers sufficient guidance about the implications of theirchoice of approach in accounting for harvested wood products that may be used as
biomass fuels, and these implications include over- or under-reporting emissions,which affect the accuracy of the reporting. Thus, countries need additional guidance
about how to fulfill the TACCC principles with respect to their choice of approach.
One way the risk of over- or under-reporting emissions arises is due to differences inaccounting approaches between importing and exporting countries. Depending on theapproaches used by each country, the carbon in traded HWPs could be reported once,
twice, or not at all. In particular, the use of the 'production approach' or 'stock-changesof domestic origin approach' by an importing country could lead to under-reporting ofemissions, because imported wood used for biomass fuel may not be included in theinventory. The volume of trade in HWPs is significant for many countries, andtherefore the guidance should explicitly indicate how their choice of approach vis-avis their trading partner(s) will affect the estimated emissions from HWPs in eachcountry. One suggestion is that the implications could be made clear by including asimple table in the guidance near this point in the text. The table should show the
choice of approach by exporting country in the columns and the choice of approach byimporting country in the rows. The cells of this matrix should indicate the number oftimes HWP emissions will be counted (zero, one, or two times) for each combinationof approaches by importing and exporting countries.

Noted

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

5640

2

2

37

45

The language should be rearranged and make clearer here. This chapter is for energy Javier Marcelo Hanna
experts, and they need first to know that: CO2 emissions from combustion of biomass Figueroa
fuels are estimated in the Energy sector, but reported as information item only, and notincluded in the sectoral and national totals. After that it should be indicated that CO2
emissions from combustion of biomass fuels are estimated and reported in the
AFOLU sector. Then it should be indicated that CH4 and N2O emissions fromcombustion of biomass fuels are estimated and reported in the Energy sector, andincluded in the sectoral and national totals.

Noted

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

7434

2

2

37

47

Onema Adojoh
Although emissions of CO2 from biomass fuels are estimated and reported in the
AFOLU sector as part of the 38 AFOLU methodology. However, there is still need toelaborate more on treatment of biomass.

Noted

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

7842

2

2

39

41

The emission factor tables referenced in these lines do not include emission factors for Jason Funk
all classes of wood products associated with the activity data defined in Volume 4
Section 12.5.1.1. As a result, inventory compilers may not have sufficient guidance toaccurately and completely report emissions from important classes of wood products.
In particular, certain classes of wood products, such as wood chips and particles, havebecome increasingly important as exports and as sources of biomass used for energy.
To provide sufficient guidance to inventory compilers for the Energy sector, Volume 4
Table 12.3 should be expanded to include all HWP categories listed in Volume 4
Table 12.2, along with default half-lives for each category.

Noted

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

Comment ID Volume

Chapter From line To line

Comment

ExpertResponse

Authors note

9174

2

2

39

41

In reference to item 2.3.3.4, where countries are to report the split the fossil- and non- peter riggs
fossiil fractions between 'biofuels combusted jointly with fossil fuels…' This is apractical impossibility. Each firing may involve a different split between fractions,and the non-fossil component of that firing could vary from whole trees to rice straw.
The better solution would be to report co-fired biomass in the energy sector, subtractig
out the net carbon from pellets or torrefied materials that would still be reported under
AFOLU. The emission factor tables referenced here simply do not include emission
factors for the necessary range of wood products associated with the activity data
defined in Volume 4 Section 12.5.1.1. To provide better guidance, Table 12.3 inVolume 4 should be expanded to include all HWP categories listed in Volume 4 Table
12.2, along with the defaul half-lives for each category.

Noted

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

9410

2

2

42

43

AYNUR TOKEL
It is stated that CO2 from biomass combusted for energy purposes should be
estimated and included as an information item in the Energy sector but not includedin national total. From this explanation it is understood that all kind of biomass shouldbe treated in the same manner.
However for sludge gas produced from sewage sludge digestion, biogas from
biological treatment of waste (e.g manure), and landfill gas combusted for energy
purpose, it will be better to add further explanation to clarify why those areconsidered carbon neutral and how they are treated under AFOLU sector (or in whichpart of AFOLU guidelines they are considered).

Noted

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

5642

2

2

52

54

Here some words should be added on the typical case of use of biomass fuels blended Javier Marcelo Hanna
with fossil fuels that occurs in transport and that this issue is treated in sections 3.2.1.2 Figueroa
and 3.2.1.3 of chapter 3.

Noted

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

4034

2

2

52

54

Gregory Peters
Recent research has shown that some "biofuels" are in fact a blend of biogenic andfossil carbon (see Vol5_Chp6_L773-811). We should insert a statement after the first
sentence like "It is also the case that gaseous, liquid and solid biofuels are produced ina single process unit using both biogenic and fossil carbon (seeVol5_Chp6_Annex6A.2)."

Noted

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

9172

1

4

216

220

peter riggs
The Inventory of Quality is incomplete. If the authors acknowledge that 'use of
harvested woody biomass for energy purposes does not belong to a defined andreported carbon pool,' then what are the 'relevant categories' for biomass energy? How
can biomass for energy be made into a more relevant category given its increased
prominence in renewable energy strategies and international trade?

Noted

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

9404

2

2

273

274

Iciar Alberdi
I found this sentence confusing in the paragraph: "With regard to allometry, newmodels with parameter estimates differing from the ones in use do
not necessarily require recalculations, because allometry can change over time
(Lopez-Serrano et al. 2005)." It should be noted that many European forests are young
and not in equilibrium and thus, the relation between tree compartments can change. It
is therefore interesting to highlight the interest of this analysis.

Transferred

Transferred to Volume 4 AFOLU.

Comment ID Volume5628

2

Chapter From line To line
3

Comment
Section 3.3.1.4 (Completeness) states that carbon from biomass should be estimatedseparately and reported as an information item to avoid double accounting, as theseemissions are already treated in the AFOLU sector. Will the IPCC provide further
guidance on emissions from combustion of renewable diesel (RD)? How can nations(and cities) share the accountability of emissions generated by the RD combustion, if
RD is produced in a different country?

ExpertMINGMING WANG

Response
Noted

Authors noteNo action can be taken because comment is out of scope of 2019
Refinement.