Report on the individual review of the annual submission of Luxembourg submitted in 2016*

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1 United Nations Distr.: General 30 August 2017 English only Report on the individual review of the annual submission of Luxembourg submitted in 2016* Note by the expert review team Summary Each Party included in Annex I to the Convention must submit an annual greenhouse gas (GHG) inventory covering emissions and removals of GHG emissions for all years from the base year (or period) to two years before the inventory due date (decision 24/CP.19). Parties included in Annex I to the Convention that are Parties to the Kyoto Protocol are also required to report supplementary information required under Article 7, paragraph 1, of the Kyoto Protocol, with the inventory submission due under the Convention. This report presents the results of the individual inventory review of the 2016 annual submission of Luxembourg, conducted by an expert review team in accordance with the Guidelines for review under Article 8 of the Kyoto Protocol. The review took place from 26 September to 1 October 2016 in Bonn, Germany. * In the symbol for this document, 2016 refers to the year in which the inventory was submitted, not to the year of publication. GE (E)

2 Contents Paragraphs I. Introduction II. Summary and general assessment of the 2016 annual submission III. Status of implementation of issues and/or problems raised in the previous review report 8 7 IV. Issues identified in three successive reviews and not addressed by the Party V. Additional findings made during the 2016 technical review VI. Application of adjustments VII. Annexes Accounting quantities for activities under Article 3, paragraph 3, and, if any, activities 1under Article 3, paragraph 4, of the Kyoto Protocol VIII. Questions of implementation I. Overview of greenhouse gas emissions and removals for Luxembourg for submission year 2016 and data and information on activities under Article 3, paragraphs 3 and 4, of the Kyoto Protocol II. Information to be included in the compilation and accounting database III. Additional information to support findings in table IV. Documents and information used during the review V. Acronyms and abbreviations Page 2

3 I. Introduction 1 1. This report covers the review of the 2016 annual submission of Luxembourg organized by the UNFCCC secretariat, in accordance with the Guidelines for review under Article 8 of the Kyoto Protocol (decision 22/CMP.1, as revised by decision 4/CMP.11) (hereinafter referred to as the Article 8 review guidelines). As indicated in the Article 8 review guidelines, this review process also encompasses the review under the Convention, as described in the Guidelines for the technical review of information reported under the Convention related to greenhouse gas inventories, biennial reports and national communications by Parties included in Annex I to the Convention (hereinafter referred to as the UNFCCC review guidelines) and particularly part III, UNFCCC guidelines for the technical review of greenhouse gas inventories from Parties included in Annex I to the Convention. The review took place from 26 September to 1 October 2016 in Bonn, Germany, and was coordinated by Mr. Simon Wear and Mr. Vitor Gois Ferreira (UNFCCC secretariat). Table 1 provides information on the composition of the expert review team (ERT) that conducted the review of Luxembourg. Table 1 Composition of the expert review team that conducted the review of Luxembourg Area of expertise Name Party Generalist Ms. Lea Kai Aboujaoude Lebanon Mr. Lindsay Pratt Canada Energy Mr. Sangay Dorji Bhutan Ms. Inga Konstantinaviciute Ms. Laetitia Nicco Ms. Awassada Phongphiphat Lithuania France Thailand IPPU Ms. Mausami Desai United States of America Mr. David Kuntze Ms. Emilija Poposka Germany Agriculture Ms. Agita Gancone Latvia Ms. Sumaya Ahmed Zakieldeen The former Yugoslav Republic of Macedonia Sudan LULUCF Ms. María Fernanda Alcobé Argentina Ms. Yasna Rojas Ponce Mr. Nijavalli Ravindranath Chile India Waste Ms. Kaat Jespers Belgium Ms. Hlobsile P. Sikhosana-Shongwe Swaziland 1 At the time of publication of this report, Luxembourg had not yet submitted its instrument of ratification of the Doha Amendment, and the amendment had not yet entered into force. The implementation of the provisions of the Doha Amendment is therefore considered in this report in the context of decision 1/CMP.8, paragraph 6, pending the entry into force of the amendment. 3

4 Area of expertise Name Party Lead reviewers Ms. Lea Kai Aboujaoude Mr. David Kuntze Abbreviations: IPPU = industrial processes and product use, LULUCF = land use, land-use change and forestry. 2. This report contains findings based on the assessment by the ERT of the 2016 annual submission against the Article 8 review guidelines. The ERT has made recommendations to resolve those findings related to issues, 2 including issues related to problems. 3 Other findings, and if applicable, the ERT s encouragements to resolve them, are also included. 3. A draft version of this report was communicated to the Government of Luxembourg, which provided comments that were considered and incorporated, as appropriate, into this final version of the report. 4. Annex I shows annual greenhouse gas emissions for Luxembourg, including totals excluding and including the land use, land-use change and forestry sector, indirect carbon dioxide emissions and emissions by gas and by sector. Annex I also contains background data related to emissions and removals from activities under Article 3, paragraph 3, forest management under Article 3, paragraph 4, and, additional activities under Article 3, paragraph 4, of the Kyoto Protocol, if elected, by gas, sector and activity for Luxembourg. 5. Information to be included in the compilation and accounting database can be found in annex II. 6. The ERT notes that Luxembourg s 2015 annual submission was delayed, consistent with decision 6/CMP.9, paragraph 4. As a result, the review of the 2016 annual submission is being held in conjunction with the review of the 2015 annual submission, in accordance with decision 10/CMP.11, paragraph 1. To the extent that identical information is presented in both annual submissions, the ERT has reviewed this information only once, and, as appropriate, has replicated the findings below in both the 2015 and the 2016 annual review reports. II. Summary and general assessment of the 2016 annual submission 7. Table 2 provides the ERT assessment of the annual submission with respect to the tasks undertaken during the review. Further information on the issues identified, as well as additional findings, may be found in tables 3 and 5 below. 2 Issues are defined in decision 13/CP.20, annex, paragraph Problems are defined in decision 22/CMP.1, annex, paragraphs 68 and 69, as revised by decision 4/CMP.11. 4

5 Table 2 Summary of review results and general assessment of the inventory of Luxembourg Assessment Dates of submission Review format Original submission: 15 April 2016 (NIR), 15 June 2016, Version 4 (CRF tables), 31 May 2016 (SEF tables) Revised submissions: 15 June 2016 (NIR), 16 November 2016, Version 5 (CRF tables), 22 January 2017, Version 6 (CRF tables) The values from the latest submission are used in this report Centralized Issue or problem ID #(s) in tables 3 and/or 5 a Application of the requirements of the UNFCCC Annex I inventory reporting guidelines and Wetlands Supplement (if applicable) Have any issues been identified in the following areas: (a) Identification of key categories Yes G.8 (b) (c) Selection and use of methodologies and assumptions Development and selection of emission factors Yes W.3, W.4 Yes W.7 (d) Collection and selection of activity data Yes E.10, E.12, E.18, I.9, L.4, W.13 (e) Reporting of recalculations No (f) Reporting of a consistent time series Yes I.2, L.4 (g) Reporting of uncertainties, including methodologies Yes G.3, I.8, L.3, L.13 Significance threshold Description of trends Supplementary information under the Kyoto Protocol (h) QA/QC QA/QC procedures were assessed in the context of the national system (see below) (i) Missing categories/completeness b Yes W.6, W.9 (j) Application of corrections to the inventory No For categories reported as insignificant, has the Party provided sufficient information showing that the likely level of emissions meets the criteria in paragraph 37(b) of the UNFCCC Annex I inventory reporting guidelines? Did the ERT conclude that the description in the NIR of the trends for the different gases and sectors is reasonable? Have any issues been identified in the following areas: 1. National system: (a) The overall organization of the national system, including the effectiveness and reliability of the institutional, procedural and legal arrangements NA Yes No 5

6 Assessment (b) Performance of the national system functions 2. National registry: (a) Overall functioning of the national registry (b) Performance of the functions of the national registry and the technical standards for data exchange 3. ERUs, CERs, AAUs and RMUs and on information on discrepancies reported in accordance with decision 15/CMP.1, annex, chapter I.E, taking into consideration any findings or recommendations contained in the SIAR 4. Matters related to Article 3, paragraph 14, of the Kyoto Protocol, specifically problems related to the transparency, completeness or timeliness of reporting on the Party s activities related to the priority actions listed in decision 15/CMP.1, annex, paragraph 24, including any changes since the previous annual submission 5. LULUCF activities under Article 3, paragraphs 3 and 4, of the Kyoto Protocol: (a) Reporting in accordance with the requirements of decision 2/CMP.8, annex II, paragraphs 1 5 (b) The Party has demonstrated methodological consistency between the reference level and reporting on forest management in accordance with decision 2/CMP.7, annex, paragraph 14 (c) The Party has reported information in accordance with decision 6/CMP.9 (d) Country-specific information has been reported to support provisions for natural disturbances, in accordance with decision 2/CMP.7, annex, paragraphs 33 and 34 No No No No No No No No No Issue or problem ID #(s) in tables 3 and/or 5 a CPR (e) Other issues Was the CPR reported in accordance with the annex to decision 18/CP.7, the annex to decision 11/CMP.1 and decision 1/CMP.8, paragraph 18? Adjustments Has the ERT applied an adjustment under Article 5, paragraph 2, of the Kyoto Protocol? Response from the Party during The ERT accepts that the revised estimate submitted by Luxembourg in its 2016 submission can replace a previously applied adjustment in the compilation and accounting database Has the Party provided the ERT with responses to the questions raised, including the data and information No No G.10 No NA Yes 6

7 Assessment the review Recommendation for an exceptional in-country review Question of implementation necessary for the assessment of conformity with the UNFCCC Annex I inventory reporting guidelines and any further guidance adopted by the Conference of the Parties? On the basis of the issues identified, does the ERT recommend that the next review be conducted as an incountry review? Did the ERT list a question of implementation? No No Issue or problem ID #(s) in tables 3 and/or 5 a Abbreviations: AAU = assigned amount unit, CER = certified emission reduction unit, CPR = commitment period reserve, CRF = common reporting format, ERT = expert review team, ERU = emission reduction unit, LULUCF = land use, land-use change and forestry, NA = not applicable, NIR = national inventory report, QA/QC = quality assurance/quality control, RMU = removal unit, SEF = standard electronic format, SIAR = standard independent assessment report, UNFCCC Annex I inventory reporting guidelines = Guidelines for the preparation of national communications by Parties included in Annex I to the Convention, Part I: UNFCCC reporting guidelines on annual greenhouse gas inventories, Wetlands Supplement = 2013 Supplement to the 2006 Intergovernmental Panel on Climate Change Guidelines for National Greenhouse Gas Inventories: Wetlands. a The ERT identified additional issues in all sectors that are not specifically listed in table 2 but are included in table 3 and/or 5. b Missing categories, for which methods are provided in the 2006 Intergovernmental Panel on Climate Change Guidelines for National Greenhouse Gas Inventories, may affect completeness and are listed in annex III to this document. III. Status of implementation of issues and/or problems raised in the previous review report 8. Table 3 compiles all the recommendations made in the previous review report. Owing to the unique circumstances of the 2015 annual submission described in paragraph 6 above, the latest available review report was for the review of the 2014 annual submission, published on 12 May For each issue and/or problem, the ERT specified whether it believes the issue and/or problem has been resolved by the conclusion of the review of the 2016 annual submission and provided the rationale for its determination, taking into consideration the publication date of the previous review report and national circumstances. Table 3 Status of implementation of issues and/or problems raised in the previous review report of Luxembourg ID# Issue and/or problem classification a, b Recommendation made in previous review report c ERT assessment and rationale General G.1 QA/QC and verification (14, 2014) Adherence to UNFCCC Annex I inventory reporting guidelines G.2 Uncertainty analysis (16, 2014) (16, 2013) Adherence to UNFCCC Annex I Address inconsistencies between the CRF tables and the NIR and improve the effectiveness of the QA/QC procedures Include all categories in its uncertainty analysis Resolved. Known inconsistencies were addressed, however, the CRF tables still contain errors Resolved. This has been implemented in the 2016 submission (cf. NIR, p. 88, section ) 7

8 ID# Issue and/or problem classification a, b Recommendation made in previous review report c ERT assessment and rationale inventory reporting guidelines G.3 Key category analysis (20, 2014) (18, 2013) Energy E.1 1. General (energy sector) (25, 2014) (34, 2012) E.2 1. General (energy sector) (28, 2014) (23, 2013) (39, 2012) (47, 2011) E.3 1. General (energy sector) liquid (29, 2014) (22/30, 2013) Include more detailed information on its uncertainty analysis and key category analysis in the NIR Expand the recalculation sections within each category and subcategory to include recalculated values and the impact of the change, or include a cross reference to the section in the NIR where recalculations are explained Report and explain the differences between the reference and sectoral approaches, including the net calorific value used in the inventory and in the energy balance Continue the efforts to fix the problem related to the reporting of AD for emissions from lubricants as fuels in the reference approach Addressing. This will be implemented in the next submission. The Party is currently doing a reassessment of the input uncertainties from all sectors Addressing. Recalculation sections are included in the NIR but should be more detailed in terms of values and impact of change Not resolved. See E.16 in table 5 Resolved. AD and emissions from lubricants in the reference approach are corrected E.4 1. General (energy sector) (30, 2014) (22, 2013) Adherence to UNFCCC Annex I inventory reporting guidelines E.5 1. General (energy sector) (33, 2014) Implement a planned improvement that fuels used in marine activities will be subtracted from the reference approach, where they are still included, enter all fuels used in the country in the reference approach estimates, and improve its QC procedures Implement the planned improvement on the transparency of section of the NIR by adding a table listing AD, carbon stored and emissions, as well as listing in which CRF category they are reported Addressing. The Party has planned two improvements: (1) to move the fuel consumption of international marine activities from imports to international bunkers for gas/diesel oil in the reference approach (table 1.A(b)); and (2) to add other fuels consumed and CO 2 emissions in the reference approach that are not included in the national energy balance Resolved. Information available in the NIR (sections and 4.5.1) E.6 International Report fuel consumption in marine bunkers and Addressing. Fuel 8

9 ID# Issue and/or problem classification a, b Recommendation made in previous review report c ERT assessment and rationale navigation liquid (32, 2014) associated emissions in the CRF tables consumption in marine bunkers has been reported in table 1.D but not in table 1.A(b). This is already a planned improvement (see E.4 above) E.7 International aviation liquid (31, 2014) (25, 2013) Describe transparently the methodology used to split national and international (bunker) fuel consumption to ensure that civil aviation emissions are accurately estimated Resolved. The methodology is described in sections and of the 2016 NIR E.8 1.A.2 Manufacturing industries and construction liquid (35, 2014) (47, 2013) (54, 2012) Implement the planned effort to improve the transparency (through the reallocation of emissions) and accuracy of these emissions and report emissions from off-road vehicles under the category mobile under other (fuel combustion) and clearly explain any reallocation and recalculation in its NIR Resolved. Emissions from off-road machinery are now reported under 1.A.2.g.vii E.9 1.A.3.b Road transportation liquid N 2O (34, 2014) (32, 2013) (47, 2012) (56, 2011) E.10 1.A.3.d Domestic navigation liquid CO 2, CH 4, N 2O (26, 2014) (37, 2012) (59, 2011) Accuracy* E.11 1.B.2 Oil and natural gas and other liquid, gas CO 2 (26, 2014) (37, 2012) (60, 2011) Adherence to UNFCCC Annex I inventory reporting guidelines IPPU I.1 2. General (IPPU) (38, 2014) Incorporate findings to explain large differences in the N 2O IEF for gasoline for different years (ranging from 2.25 to 6.85 kg/tj) from the study on N 2O emissions for gasoline from road transportation Review the possible double counting of emissions from leisure boats reported under navigation Collect country-specific data for estimating CH 4 emissions from natural gas distribution Explain every recalculation such as the emissions from the solvent and other product use sector update of AD and EFs, and state correctly that recalculations have not been implemented in the solvent and other product use sector Resolved. New methodology taking into account the study described in the NIR (section ) Addressing. The subject is under discussion with the National Statistics Office of Luxembourg and will be addressed in the 2017 submission No longer relevant. This category is not a key category: tier 1 EF can be used Not resolved. The Party has made efforts to provide more information on the types of updates, but has not provided sufficient detail to explain its recalculations. For all 9

10 ID# Issue and/or problem classification a, b Recommendation made in previous review report c ERT assessment and rationale I.2 2. General (IPPU) HFCs, SF 6 (40, 2014) Consistency* Revise the estimates of HFC emissions from foam blowing and SF 6 emissions from electrical equipment for to ensure time-series consistency of these categories in accordance with the IPCC good practice guidance recalculations, the Party needs to transparently explain updates to EFs, AD and the impact of recalculations in the NIR. See table 5 below for additional examples Addressing. Emissions have been revised for both categories, but the Party has not reported these recalculations in the NIR or CRF tables, or explained the approach applied to ensure time-series consistency I.3 2.F. Product uses as substitutes for ozone depleting substances HFCs (42, 2014) (40, 2013) (54, 2012) (76, 77, 2011) I.4 2.F.5 Solvents N 2O (46, 2014) (44, 2013) (63, 2012) (81, 2011) Consistency* I.5 2.F.6 Other applications (product uses as substitutes for ozone depleting substances) SF 6 (43, 2014) (41, 2013) I.6 2.F.6 Other applications (product uses as substitutes for ozone depleting substances) PFCs (44, 2014) (42, 2013) Not an issue Report AD, IEF and emissions from refrigeration and air-conditioning equipment and noise reduction windows in CRF table 2(II).F to improve the consistency of the reporting Demonstrate the consistency of the time series or collect country-specific data for the entire time series for N 2O emissions Provide a more detailed explanation in the NIR of the country-specific methodologies and AD used to estimate SF 6 emissions from electrical equipment in order to increase the transparency of the reporting For potential PFC emissions, replace the notation key NO (not occurring) with either a value or the notation key NE (not estimated) Resolved. Submitted 2016 CRF tables include the completed CRF table 2(II).F reporting information consistent with categories relevant to the Party Resolved. The Party has provided information on pages 357 and 358 of the NIR to demonstrate time-series consistency Not resolved. More description is provided on the EFs during operation, but not on EFs during manufacture. Further, the NIR provides no direct reference to which IPCC methodology is applied and does not provide the AD to estimate emissions from manufacturing, operation and then disposal No longer relevant. Reporting of potential emissions is no longer required under the 2006 IPCC Guidelines 10

11 ID# Issue and/or problem classification a, b Recommendation made in previous review report c ERT assessment and rationale Agriculture A.1 3.B Manure management CH 4, N 2O (49, 2014) A.2 3.B.3 Swine3.B.3 swine CH 4, N 2O (50, 2014) (50, 2013) (75, 2012) (92, 2011) Adherence to UNFCCC Annex I inventory reporting guidelines A.3 3.D Direct and indirect N 2O emissions from agricultural soils N 2O (52, 2014) A.4 3.D Direct and indirect N 2O emissions from agricultural soils N 2O (54, 2014) LULUCF L.1 4. General (LULUCF) (58, 2014) (53, 2013) (83, 2012) (99, 2011) (64, 2010) Describe the changes in the estimation of CH 4 emissions from manure management in the NIR Implement a higher-tier method for manure management from swine Describe the methodology for the revision of the estimation of nitrogen excretion (Nex) used for mature dairy cattle in the NIR Describe the methodology for nitrogen emissions from agricultural soils in the NIR, and the amount of AD for synthetic fertilizer applied, revisions to AD for peas, carrots and leeks and the amount of sewage sludge applied to soils for 2012 Improve the transparency of the reporting by providing references for LULUCF and KP- LULUCF in a systematic manner with references for EFs and AD that were provided in earlier reports (e.g. the meaning of IFL1 in the NIR (2014, p.367); the soil carbon content of various land uses; the country-specific value for carbon stock of forest land biomass before conversion; the annual volume increment of species other than spruce, Douglas fir, beech and oak) Addressing. A rationale table was provided with estimates; in addition, information that explains the changes was provided by Luxembourg during the review Resolved. A tier 2 method for manure management for swine was implemented Not resolved. The ERT noted the lack of information and references that assist in understanding all the changes related to the selection of values of Nex from dairy cows Resolved. The description of the methodology to estimate N 2O emissions from agricultural soils has been included in the NIR (pp ) Addressing. The NIR now provides references and elaborates the QC procedures that are in place for land area estimates and emission or removal factors that come from NFI for forest land. There is scope for further improvement in providing references, especially for AD and EFs for land categories other than forest land. References could be provided for the soil carbon content of various land uses; the country-specific value for 11

12 ID# Issue and/or problem classification a, b Recommendation made in previous review report c ERT assessment and rationale L.2 4. General (LULUCF) (59, 2014) (55, 2013) (86, 2012) (102, 2011) (66, 2010) L.3 4. General (LULUCF) (60, 2014) L.4 4.A.1 Forest land remaining forest land CO 2 (61, 2014) Accuracy* Improve the QC procedures, in particular regarding references for EFs and AD, and regarding consistency between the NIR and the CRF tables Report the uncertainty analysis for LULUCF in accordance with the IPCC good practice guidance for LULUCF and transparently describe the method used to estimate the uncertainty Reproduce the entire time series of harvest statistics, provide an explanation for the inconsistency between harvesting trends and carbon stock changes in living biomass and investigate the discrepancy between STATEC and FAOSTAT data on harvest carbon stock of forest land biomass before conversion; and the annual volume increment of species other than spruce, Douglas fir, beech and oak Not resolved. The Party has described elaborate QC procedures for land area AD, however, the QC procedures for other land category emission and removal factors need to be described Not resolved. Uncertainty is provided for the whole sector. The Party intends to submit full details for different land categories in the 2017 submission Addressing. The Party has provided all the data available from FAO and national sources. Luxembourg intends to adopt an improved method for estimating and reporting AD for harvested wood products in the coming years L.5 4.A.1 Forest land remaining forest land CO 2 (62, 2014) (60, 2013) (89, 2012) (103, 2011) (67, 2010) Use the results from the second NFI to recalculate the emission/removal estimates from forest land remaining forest land and all categories involving forest land Resolved. The Party has used emission/removal factors from the NFI L.6 4.A.1 Forest land remaining forest land CO 2 (63, 2014) Describe transparently the planned improvements to estimate the increment and harvest for species other than beech, oak, spruce and Douglas fir Resolved. Data on gains and losses and information is to be provided from the NFI for the forest land category L.7 4.A.2 Land converted to forest land CO 2 (64, 2014) Include clarification on the method for calculating carbon stock changes for conversions to forest land from wetlands, settlements and other land in the NIR Resolved. The Party has largely used emission/removal factors from IPCC defaults and from the NFI 12

13 ID# Issue and/or problem classification a, b Recommendation made in previous review report c ERT assessment and rationale L.8 A.2 Land converted to forest land CO 2 (65, 2014) Accuracy* Report on the results of the investigation into the accuracy of the values of the areas in view of the new AD for , paying particular attention to areas that may have undergone a back-and-forth classification from and to forest land Resolved. Luxembourg is using multi-temporal RapidEye data (satellite images) L.9 4.B.1 Cropland remaining cropland N 2O (68, 2014) L.10 4.C.2 Land converted to grassland CO 2 (66, 2014) L.11 4.C.2 Land converted to grassland CO 2 (67, 2014) Adherence to UNFCCC Annex I inventory reporting guidelines Waste W.1 5.A Solid waste disposal on land CH 4 (75, 2014) (70, 2013) (104, 2012) W.2 5.D Wastewater treatment and discharge N 2O (77, 2014) Accuracy* Explain explicitly in the NIR that forest fertilization does not occur and correct the inconsistency between the NIR and CRF table for cropland remaining cropland Review the drivers of the decrease in forest land to grassland converted annually; report all areas of cropland converted to grassland in the category land converted to grassland Correct the NIR to ensure consistency between the NIR and the CRF tables Assess whether the assumption of the 90% reduction for the methane correction factor is valid for the Party's national circumstances and provide the results of this assessment Review the N 2O EF for plants with significant denitrification and use a consistent methodology to estimate these emissions Resolved. The NIR provides information on the ban on fertilization of forest land Resolved. CO 2 emissions/removals for cropland converted to grassland is reported correctly Addressing. Significant improvement has been made. There are still a few inconsistencies, especially in the NIR Addressing. The Party explained that a study was conducted, taking into account the previous recommendations. The methodology is currently under validation and will be implemented in the 2017 submission. The ERT believes that this issue should be considered further in future reviews to confirm that emissions are not underestimated Addressing. The Party explained that a study was conducted to completely revise the calculation of emissions from wastewater treatment in Luxembourg, taking into account any 13

14 ID# Issue and/or problem classification a, b Recommendation made in previous review report c ERT assessment and rationale changes coming from the 2006 IPCC Guidelines and the recommendations in previous ARRs. Validation is still to be completed. The results of the study will be included in the 2017 submission, subject to available resources W.3 5.D Wastewater treatment and discharge N 2O (79, 2014) Accuracy* W.4 5.D.3 Other (wastewater treatment and discharge) N 2O (78, 2014) Accuracy* KP-LULUCF Take into account the nitrogen removed in the sludge spread on agricultural fields when estimating the N 2O emissions from wastewater in order to avoid double counting; revise the method to estimate N 2O emissions from wastewater handling Review the estimates from all discharges of wastewater, including those from wastewater plants, to confirm there are no underestimates, and that all N 2O emissions are estimated and nitrogen removal at these plants should be considered in the estimates Addressing. The Party explained that a study was conducted to completely revise the calculation of emissions from wastewater treatment in Luxembourg, taking into account any changes coming from the 2006 IPCC Guidelines and the recommendations in previous ARRs. Validation is pending. Hence, the results of the study will be included in the 2017 submission, subject to available resources Addressing. The Party explained that a study was conducted to completely revise the calculation of emissions from wastewater treatment in Luxembourg, taking into account any changes coming from the 2006 IPCC Guidelines and the recommendations in previous ARRs. Validation is pending. Hence, the results of the study will be included in the 2017 submission, subject to available resources KL.1 General (KP- LULUCF) (83, 2014) Improve the transparency of the reporting by including the explanation on species mix estimation in the NIR Resolved. Species mix and areas are described in the land use change matrix and the NIR KL.2 General (KP- LULUCF) (84, 2014) Classify afforestation and reforestation, and deforestation as key categories according to the IPCC good practice guidance for LULUCF Resolved. According to NIR 2016, only forest land remaining forest land is 14

15 ID# Issue and/or problem classification a, b Recommendation made in previous review report c ERT assessment and rationale estimated as a key category. Thus afforestation/deforestation categories are not key categories KL.3 General (KP- LULUCF) (85, 2014) (76, 2013) (112, 2012) (133, 2011) Comparability* Report carbon stock changes in below-ground biomass and litter for the KP-LULUCF categories separately Resolved. The CRF tables show they are reported separately KL.4 Afforestation and reforestation (86, 2014) (76, 2013) CO 2 Improve the transparency of the reporting under the Kyoto Protocol and separately report the carbon stock changes for the living biomass pools (aboveground and below-ground) using the information already available within the national inventory system Resolved. The NIR provides all the details of carbon stock change estimation KL.5 Deforestation (91, 2014) CO 2 Explain the revisions in the estimation of changes in mineral soil organic carbon stock in deforestation resulting from the conversion of forest to grassland Resolved. NIR 2016 provides sufficient explanation on AD and EF used Abbreviations: AD = activity data, ARR = annual review report, CRF = common reporting format, EF = emission factor, ERT = expert review team, FAO = Food and Agriculture Organization of the United Nations, IEF = implied emission factor, IPCC = Intergovernmental Panel for Climate Change, IPCC good practice guidance for LULUCF = Good Practice Guidance for Land Use, Land-Use Change and Forestry, IPPU = industrial processes and product use, KP-LULUCF = LULUCF emissions and removals from activities under Article 3, paragraphs 3 and 4, of the Kyoto Protocol, LULUCF = land use, land-use change and forestry, NFI = national forest inventory, NIR = national inventory report, QA/QC = quality assurance/quality control, UNFCCC Annex I inventory reporting guidelines = Guidelines for the preparation of national communications by Parties included in Annex I to the Convention, Part I: UNFCCC reporting guidelines on annual greenhouse gas inventories, 2006 IPCC Guidelines = 2006 IPCC Guidelines for National Greenhouse Gas Inventories. a References in parentheses are to the paragraph(s) and the year(s) of the previous review report(s) where the issue was raised. Issues are further classified as defined in decision 13/CP.20, annex, paragraph 81. In the review of the supplementary information reported in accordance with Article 7, paragraph 1, of the Kyoto Protocol, the ERT has applied the classification in decision 22/CMP.1, annex, paragraph 69, in conjunction with decision 4/CMP.11. b An asterisk is included next to each issue type for all issues that are also problems, as defined in decision 22/CMP.1, annex, paragraphs 68 and 69, including those that lead to an adjustment or a question of implementation. c The review of the 2016 annual submission is being held in conjunction with the review of the 2015 annual submission, and as such, the 2015 annual review report was not available at the time of this review. Therefore, the recommendations reflected in table 3 are from the 2014 annual review report. For the same reason, the year 2015 is excluded from the list of years in which the issue has been identified. IV. Issues identified in three successive reviews and not addressed by the Party 9. In accordance with paragraph 83 of the UNFCCC review guidelines, the ERT noted that the issues included in table 4 have been identified in three successive reviews, including the review of the 2016 annual submission of Luxembourg, and have not been addressed by the Party. 15

16 Table 4 Issues identified in three successive reviews and not addressed by Luxembourg ID# a Previous recommendation for the issue identified Number of successive reviews issue not addressed b General G.3 Include more detailed information on its uncertainty analysis and key category analysis in the NIR 3 (2013, 2014, 2015/2016) Energy E.1 Expand the recalculation sections within each category and subcategory to include recalculated values and the impact of the change, or include a cross reference to the section in the NIR where recalculations are explained E.2 Report and explain the differences between the reference and sectoral approaches, including the net calorific value used in the inventory and in the energy balance E.4 Implement a planned improvement that fuels used in marine activities will be subtracted from the reference approach, where they are still included, enter all fuels used in the country in the reference approach estimates, and improve its QC procedures 3 (2013, 2014, 2015/2016) 5 (2011, 2012, 2013, 2014, 2015/2016) 3 (2013, 2014, 2015/2016) E.10* IPPU Enter all fuels used in the country in the reference approach estimates and improve the QC procedures 4 (2012, 2013, 2014, 2015/2016) I.5 Provide a more detailed explanation in the NIR of the country-specific methodologies and AD used to estimate SF 6 emissions from electrical equipment in order to increase the transparency of the reporting 3 (2013, 2014, 2015/2016) Agriculture No such issues for the agriculture sector were identified LULUCF L.1 Improve the transparency of the reporting by providing references for LULUCF and KP-LULUCF in a systematic manner with references for EFs and AD that were provided in earlier reports (e.g. the meaning of IFL1 in the NIR (2014, p.367); the soil carbon content of various land uses; the country-specific value for carbon stock of forest land biomass before conversion; the annual volume increment of species other than spruce, Douglas fir, beech and oak) 6 (2010, 2011, 2012, 2013, 2014, 2015/2016) L.2 Improve the QC procedures, in particular regarding references for EFs and AD, and regarding consistency between the NIR and the CRF tables 6 (2010, 2011, 2012, 2013, 2014, 2015/2016) 16

17 ID# a Waste Previous recommendation for the issue identified Number of successive reviews issue not addressed b W.1 Assess whether the assumption of the 90% reduction for the methane correction factor is valid for the Party's national circumstances and provide the results of this assessment 3 (2013, 2014, 2015/2016) KP-LULUCF No such issues for KP-LULUCF activities were identified Abbreviations: AD = activity data, CRF = common reporting format, EF = emission factor, IPPU = industrial processes and product use, KP-LULUCF = LULUCF emissions and removals from activities under Article 3, paragraphs 3 and 4, of the Kyoto Protocol, LULUCF = land use, land-use change and forestry, NIR = national inventory report, QC = quality control. a An asterisk is included after any issue ID# where the underlying issue is related to accuracy or completeness of a key category, a missing category or a potential key category, as indicated in decision 13/CP.20, annex, paragraph 83. b The review of the 2016 annual submission is being held in conjunction with the review of the 2015 annual submission. As the reviews of the 2015 and 2016 annual submissions are not successive reviews, but are rather being held in conjunction, for the purpose of counting successive years in table 4, 2015/2016 is considered as one year. The ERT noted that this table 4 is the same as that in the 2015 annual review report for Luxembourg, modified to reflect the combined 2015/2016 review. V. Additional findings made during the 2016 technical review 10. Table 5 contains findings made by the ERT during the technical review of the 2016 annual submission of Luxembourg that are additional to those identified in table 3 above. 17

18 18 Table 5 Additional findings made during the 2016 technical review of the annual submission of Luxembourg ID# Finding classification Description of the finding with recommendation or encouragement General G.4 NIR Luxembourg submitted an NIR, including information on key categories, methods, data sources, uncertainty estimates, QA/QC, verification activities, etc. The NIR provides a description of the QA/QC and verification procedures used in the preparation of the GHG inventory. However, Luxembourg did not include in its NIR annexes on key categories, uncertainty assessment, methodological description and energy balance, as per decision 24/CP.19 The ERT encourages Luxembourg to follow the outline and general structure contained in annex I to decision 24/CP.19 in its NIR Is finding an issue a and/or a problem b? If yes, classify by type Not an issue G.5 Time series consistency Luxembourg has performed a trend analysis for the period and has clearly explained the drivers behind the changes in CO 2, CH 4 and N 2O emissions. However, no explanation was provided of the reasons for the increase in F-gases (23,903%) during this period. In response to a question raised by the ERT, the Party provided a clear explanation of the rationale behind the increase in F- gases In order to increase transparency, the ERT recommends that Luxembourg provide a detailed explanation of the main drivers of the increase in F-gases in its NIR Yes. G.6 CRF Luxembourg provided adequate information in CRF table 9 on the use of notation keys NE (not estimated) and IE (included elsewhere). However, no explanation was included in the NIR The ERT encourages Luxembourg to provide a summary of the use of the notation keys in its NIR and a detailed explanation of the reasons for the use of IE and NE in each sector to increase transparency G.7 CRF The ERT notes that there is no consistency between the use of the notation keys IE (included elsewhere) and NE (not estimated) in the CRF tables (tables 9 and 10) and the NIR sectoral tables on completeness (tables 3.4, 4.3, 4.4, 4.23, 5.3 and 7.2) The ERT encourages Luxembourg to improve the consistency of the reporting of notation keys between the CRF tables and the NIR Not an issue Not an issue G.8 Key category analysis Key category analysis was performed using the IPCC tier 1 and level and trend assessment. Luxembourg has included the LULUCF sector in its assessment of the key categories. However, the ERT identified differences in the key categories reported in the NIR and in CRF tables that may lead Yes. Adherence to UNFCCC Annex I inventory reporting

19 19 ID# Finding classification Description of the finding with recommendation or encouragement to inconsistencies The ERT recommends that Luxembourg improve its QA/QC in the key category analysis to ensure consistency in reporting G.9 Uncertainty analysis Uncertainty analysis was performed using the tier 1 approach. Following the recommendations of previous ERT reports, all IPCC categories have been included in the uncertainty analysis. Uncertainties are presented in a summary section and are disaggregated into a detailed sectoral level. The NIR also states that an IPCC tier 2 uncertainty analysis will be performed for the Party s next submission The ERT commends Luxembourg for the improvement of its uncertainty analysis and encourages the use of the tier 2 approach G.10 National registry The ERT noted that the NIR (chapter 12.5) indicates that the CPR will be calculated once Luxembourg submits its report to facilitate the calculation of the assigned amount. During the review, the Party indicated that its CPR is 65,209,026 t CO 2 eq and that it is based on the assigned amount for the second commitment period of the Kyoto Protocol. The ERT agrees with this value The ERT recommends that the Party report the calculation of its CPR in its NIR Is finding an issue a and/or a problem b? If yes, classify by type guidelines Not an issue Yes. Energy E.12 Fuel combustionreference approach All fuels E.13 Fuel combustionreference approach All fuels The comparison of the apparent energy consumption for the reference approach and the sectoral approach shows noticeable discrepancies for the other fuels ( 48.20%), gaseous fuels ( 5.21%), liquid fuels ( 3.13%) and solid fuels ( 1.56%). In the NIR, the discrepancies for gaseous fuels and other fuels are explained and improvements are planned but not for the solid fuels and liquids. During the review week, the Party explained that the difference for solid fuels mainly derives from a calculation error (double exclusion of the carbon derived from other bituminous coal in iron and steel production) The ERT recommends that Luxembourg correct the calculation error detected in the reference approach for solid fuels concerning the double exclusion of carbon from other bituminous coal in iron and steel production The ERT identified several discrepancies between data submitted in CRF tables and international data (IEA and Eurostat) related to quantities of waste fuels, NCV used for motor gasoline, quantities of imports for solid fuels, quantities of lubricants, imports of bitumen and stock changes for gas/diesel oil in 2005 Yes. Accuracy* Not an issue

20 20 ID# Finding classification Description of the finding with recommendation or encouragement The ERT encourages Luxembourg to provide in its NIR all information at its disposal that explains the discrepancies between international data (IEA and Eurostat) and data used in the inventory (difference in NCV, definition of fuel categories, etc.) Is finding an issue a and/or a problem b? If yes, classify by type E.14 Fuel combustionreference approach petroleum coke, other kerosene, other oil (white spirit) International data (IEA) reports imports of petroleum coke, other kerosene and other oil (white spirit) which are not reported in the CRF tables. During the review week, Luxembourg stated that emissions for these fuels are reported under 2.D.3 other (non-energy products from fuels and solvent use), and hence excluded from the reference approach The ERT recommends that the Party include data on petroleum coke, other kerosene and other oil (white spirit) in the reference approach as it is possible to enter fuels in CRF table 1.A(b) that are used for non-energy purposes in CRF table 1.A(d) Yes. Adherence to UNFCCC Annex I inventory reporting guidelines E.15 Feedstocks, reductants and other NEU of fuels All fuels The ERT notes that Luxembourg uses the notation key NE (not estimated) instead of IE (included elsewhere) for use of fuels/solid fuels/anthracite and other bituminous coal in CRF table 1.A(d) and explains that emissions are reported under 2.C.1. In response to a question raised by the ERT, Luxembourg indicated that the notation key would be changed in its next submission The ERT recommends that Luxembourg replace the notation key NE with the notation key IE in reporting emissions for use of fuels/solid fuels/anthracite and other bituminous coal in CRF table 1.A(d) Yes. E.16 1.A. Fuel Combustion- Sectoral Approach gaseous fuels CO 2, CH 4, N 2O Differences between the sectoral and the reference approaches for the apparent consumption of natural gas have been identified in previous ARRs and are still visible in the submission. For the period , the total natural gas energy consumption in the sectoral approach is lower than that in the reference approach (3.79 to 6.92%) whereas for the period , the total natural gas consumption in the sectoral approach is greater than in the reference approach (1.67 to 8.45%) During the review, the Party explained that discussions with experts from the National Statistics Institute of Luxembourg have identified that the difference lies in the balancing between the topdown sectoral fuel consumption from the energy balance as provided by the institute, and the bottom-up approach for the inventory calculation in which specific consumption as reported by the main companies for a given category are summed. The problem originates from the national energy balance, and this was confirmed in a meeting with the institute. During this meeting, a possible solution was discussed on how to better equilibrate the energy amounts (especially natural gas) consumed by the industry, by taking into account emission trading scheme declarations. This work is currently under way, and will be implemented for the 2017 submission. This will lead to a revision of the natural gas consumption data mainly for categories 1.A.2 and 1.A.4, with the national total for the energy balance remaining unchanged. Moreover, the difference between reference approach and Yes.

21 21 ID# Finding classification Description of the finding with recommendation or encouragement sectoral approach will tend towards zero Thus the Party confirmed that the methodology applied in the sectoral approach in the last submission resulted in an overestimation of the natural gas consumption in different subcategories of 1.A.2 The ERT recommends that the Party correct the natural gas consumption data in the sectoral approach using the newly revised energy balance in order to avoid underestimates for the period and overestimates for the period The ERT also recommends that Luxembourg strengthen its QC procedures by ensuring that total natural gas consumption in the sectoral approach is equal to total natural gas consumption from the energy balance. If this is not the case, the ERT recommends that the Party provide the rationale for the differences in its NIR Is finding an issue a and/or a problem b? If yes, classify by type E.17 1.A.2.e Food processing, beverages and tobacco liquid fuels E.18 1.A.2.g Other (manufacturing industries and construction) liquid fuels CO 2 Inter-annual changes were identified as exceptional and occur in the AD for subcategory 1.A.2.e (liquid fuels) for the years 1993/1994 (83.2%), 1998/1999 (93.8%) and 2008/2009 (158.3%). During the review week, the Party explained the drivers of these inter-annual changes: increase in gas oil as reported by the national energy balance (1993/1994), a switch from residual fuel oil to gas oil (1998/1999) and the emptying of gas oil stocks at one facility prior to shutting down (2008/2009) The ERT recommends that the Party include the explanations for the inter-annual changes in AD of 1.A.2.e (liquid fuels) in the NIR AD and emissions from off-road machinery in the industry sector are accounted for in 1.A.2.g.vii. In the NIR and the CRF tables, the Party states that this off-road machinery consumes gasoline and diesel oil. In the road transportation sector, biofuels have been used since 2004 During the review week, the ERT asked the Party if off-road machinery was consuming biofuels. The Party answered that biofuels have been consumed in this sector since 2004 but Luxembourg considers these biofuels as fossil fuels in this submission (i.e. the NCVs and EFs of gasoline and diesel are applied). This results in an overestimation of CO 2 emissions for the years 2004 to 2014 The ERT recommends that Luxembourg take into account the biofuel consumptions for off-road machinery, to allocate them to biomass fuels and to correct the CO 2 overestimation for the years 2004 to 2014 Yes. Yes. Accuracy* E.19 1.A.3.b Road transportation gasoline CO 2 Luxembourg uses a country-specific CO 2 EF for motor gasoline of 72.0 t CO 2 /TJ. As explained in the NIR (p.191 and following), motor gasoline is exclusively imported from neighbouring countries (Belgium, Germany and Netherlands) and as Luxembourg has no access to the carbon content of this Yes.