Topic III: Assessment and Treatment of Underestimations

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1 Topic III: Assessment and Treatment of Underestimations Presented at the: REFRESHING SEMINAR ON GOOD PRACTICE APPROACHES TO INVENTORY ISSUES IDENTIFIED DURING THE REVIEW PROCESS Jongikhaya Witi, Sandro Federici, Kiyoto Tanabe, Simon Eggleston

2 Presentation Outline Objectives of the presentation Problem analysis Examples and case studies a) Dealing with NE s (Not Estimated) b) Dealing with NO s (Not Occurring) and NA (Not Applicable) c) Dealing with EF/AD trends and lack of Transparency d) Dealing with IE s (Included Elsewhere) e) Dealing with Underestimations Lessons and conclusions from the case studies Proposed procedures for dealing with cases of underestimations General Conclusions and recommendations

3 Presentation Objectives a) To highlight broad cases of underestimations and provide a problem analysis associated with how they are treated, b) To demonstrate case studies based on real cases from last two review cycles cycle on how these broad cases are identified and treated and c) Based on the case studies presented, propose procedures on how experts can deal with these cases in future reviews d) To refresh common approaches and enhance their consistency

4 Problem Analysis a) A brief assessment of the last two review cycles show that experts are struggling to identify underestimates across sectors b) As a consequence, there are findings that could have been identified as potential problems but only reflected in the Annual Review Reports (ARRs) c) In some cases, findings are neither included in the Saturday paper nor in the ARRs d) It emerges that experts do not have a procedure of dealing with underestimation once identified and often resorting to treating the problem as lack of transparency and in some cases no procedure to identify these cases

5 Problem Analysis (Cont.) A brief analysis of the last two review cycles show that missed opportunities to identify underestimation cases largely fell in these categories: Energy Fugitive emissions from Oil and Natural gas operations IPPU Underestimation of emission associated with F- gases CO2 emissions from Iron and Steel plants Agriculture - Application of fertilizer in agricultural soils LULUCF N2O emissions, Emissions from deforestation Waste N2O emissions from wastewater treatment systems AD associated with CH4 emissions from solid waste disposal

6 Problem Analysis (Cont.) Broadly, cases of underestimations fall into four categories: a) NE (Not Estimated) Clear case of a source not estimated b) NO (Not Occurring) and NA (Not Applicable) A possible case of underestimation (could be an NE) c) Deviation from IPCC GPG/lack of transparency A possible case of inappropriate EF/AD and often related to lack of transparency d) IE (Included Elsewhere) and underestimations Possible cases of NE and often related to lack of transparency

7 UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE Case Studies

8 About Case Studies Covers NEs, NOs, Deviation from GPG/transparency and IEs and underestimations Case Study review approach How the problem was identified (CRF, NIR etc) How the problem was treated by the ERT How the Party responded to the ERT Follow-up by ERT and confirmation of PP Reflects those PPs that were solved and some cases that were supposed to be reflected in PPs but only reflected in ARRs

9 UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE Case Studies : Category 1 - Not Estimated (NE)

10 Not Estimated (NE) Case Study 1: CO2, CH4 Fugitive emissions from venting in oil production [1] How the problem was identified (CRF, NIR etc) [2] How the problem was treated by the ERT In CRF table 1B2c, CO2, CH4 emissions from venting in oil production reported as NE Methodology exist? - ERT noted that methodologies and EFs do exist in the IPCC GPG ERT Recommended the following in the Saturday paper: Party to estimate emissions using available methodologies and EFs provided in the IPCC GPG [3] How the Party responded to the ERT 1 st Response to the Saturday Paper by the Party: Revised CH4 emissions calculated and provided Party argued that CO2 EFs presented in the IPCC GPG are based on North America and not represented of their region [4] Follow-up by the ERT Follow up to the 1 st Response: ERT accepted CH4 emissions The IPCC GPG stipulates that: Where actual vented volumes are known from oil production facilities, these should be used rather than the presented emission factors applied to production rates

11 Not Estimated (NE) Case Study 2: CO2, CH4 Fugitive emissions from oil transport [1] How the problem was identified (CRF, NIR etc) [2] How the problem was treated by the ERT In CRF table 1B2a, CO2, CH4 emissions from oil transport reported as NE Methodology exist? - ERT notes that a methodology and default emission factors exist in the IPCC good practice guidance (p. 2.81, Figure 2.13; and p. 2.87, Table 2.16, respectively) ERT Recommended the following in the Saturday Paper: Collect activity data and estimate fugitive CO 2 and CH 4 emissions from oil transport using the available methodology, for example, by applying the default EFs for CO 2 and CH 4 (IPCC good practice guidance, p. 2.87, Table 2.16) to the volume of oil transported by pipeline in the country [3] How the Party responded to the ERT Response by the Party to the Saturday Paper : Party followed guidance by the ERT and estimated emissions [4] Follow-up by the ERT Follow up to the Response: ERT accepted revised estimates as they were in line with IPCC GPG

12 Not Estimated (NE) Case Study 3 (many similar cases): Stock changes from carbon pools under KP reporting [1] How the problem was identified (CRF, NIR etc) [2] How the problem was treated by the ERT Supplementary information under KP reporting to demonstrate that a not accounted pool was not a net source was not provided in the NIR (in order of relevance: Soil Organic matter, Dead Wood, Litter) ERT Recommended the following in the Saturday Paper: Party to Provide missing information [3] How the Party responded to the ERT Response to the Saturday Paper by the Party: a. No information available b. Generic knowledge, no scientific evidences, that the pool is not a net source [4] Follow-up by the ERT Follow up to the Responses: a & b - Recommendation (for countries with CP accounting) or adjustment (for countries with annual accounting)

13 NB The not a source rule aims to make KP accounting requirements less demanding; ERTs consideration of the possible steps of Parties when reporting on C pools as not net sources: 1. Are available data/estimates (from sampling and/or models) robust enough to be used in accounting? - Is the sampling/modeling representative of country? - Are the methods used well documented and transparent? - Are relationships used meaningful and statistically significant? - Have the results been somehow verified? - Uncertainty analysis available? NO (to any of the questions) YES (to all questions) Data may be used for KP accounting Provide additional information: 2. Reasoning based on sound knowledge of likely system responses 3. Survey of relevant peer-reviewed literature A special case is when the demonstration of not a source is done for two merged carbon pools (e.g. litter and dead wood); as long as the demonstration is robust, this approach should be accepted because the overall outcome is conservative. Does available information under 1 to 3 above clearly supports the not a source notion? NO The Party should report NE (not estimated) [during accounting years, this would end up in an adjustment] YES Use NR (not reported) in table KP-NIR-1 and provide adequate supporting documentation in the NIR text. In tables 5(KP-I) NE may be used, but information in the documentation box and in the relevant NIR section must be reported to demonstrate that the pool is not a source. 1 In some case (e.g., mineral soil in FM) tier 1 assumes no C stock change. However, as general rule, Tier 1 can be used ONLY for non key categories.

14 Lessons from the NE case studies Where clear guidance has been provided by the ERT (referencing the IPCC GPG or Revised 1996 GLs) in drafting the Potential Problem the possibility of confusion is reduced ERT has to communicate to the Party that emissions needs to be estimated regardless of how small the category if IPCC GPG or Revised 1996 GLs provide guidance Also, prior knowledge on the size of categories is not possible for the ERT Investigation to check if activity occurs is also important ( NE can lead to NO ) ERT to provide guidance where there are gaps in time series AD

15 Proposed procedure for dealing with NEs ERT identifies all NE cases No ERT relegates issue into ARR and encourages Party to estimate emissions GPG + Guidelines provide guidance? Yes ERT provides Party with exact reference and page No. in the GPG and/or guidelines Party to estimate emissions using time series complete AD No Are there gaps in the AD time series to be used in estimating emissions? Yes Party fill-in gaps in time series AD using methods in line with IPCC GPG Chapter 7

16 UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE Case Studies : Category 2 - Not Occurring (NO)

17 Not Occurring (NO) Case Study 1: CNG use in Road Transportation [1] How the problem was identified (CRF, NIR etc) In CRF table 1A3b, CO2, CH4 and N2O emissions from use of CNG for road transportation reported as NO ERT investigated the availability of CNG filling stations [more than 50 stations reported] Introduction of CNG use in transport started in 2006 Confirmation with Party experts that this activity occurs in the country [3] How the Party responded to the ERT 1 st Response to the Saturday Paper by the Party: Party energy experts confirmed with Stats office that CNG use in road transportation is accounted for under 1A4 Commercial Institutional. Party will use IE 2 nd Response by the Party Further data analysis by the Party confirmed that 80% CNG consumption is indeed accounted under stationary combustion but 20% is not [2] How the problem was treated by the ERT ERT Recommended the following in the Saturday Paper: Party to estimate emissions using default EFs from the Revised 1996 IPCC GL, or; Provide documentary evidence that this fuel use is included elsewhere in stationery consumption, giving details on where it is accounted for If accounted for under stationary combustion, Party to make efforts to separate this CNG consumption from Stationary combustion as non-co2 gases depend on technologies [4] Follow-up by the ERT Follow up to the 1 st Response: ERT would like to know how stats-office modified their total natural gas balance for the years 2005 and 2006 to take into account the introduction of CNG for road transportation Follow up to the 2 nd response: The ERT accepted revised estimates based on the data analysis presented by the Party NO in reality represented both NE and IE

18 Not Occurring (NO) Case Study 2: Fugitive CO2 emissions from natural gas transmission [1] How the problem was identified (CRF, NIR etc) [2] How the problem was treated by the ERT In CRF table 1B2b, fugitive CO2 emissions from natural gas transmission reported as NO ERT enquired whether the Party does have gas transmission pipeline or not Party energy experts confirmed that it has xxxx km of gas transmission pipeline network based on 2009 data ERT Recommended the following in the Saturday Paper: Party to estimate emissions using default EFs provided in the IPCC GPG [ERT maintained that this was a clear case of NE ] [4] Follow-up by the ERT [3] How the Party responded to the ERT 1 st Response by the Party to the Saturday Paper: Fugitive CO2 emissions are accounted for under 1A1c manufacture of solid fuels and other energy industries as per Safety Health and Environmental reports provided by the gas production Industry. Party will use IE 2 nd Response by the Party Further data analysis by the Party showed that it was not possible to confirm with certainty that fugitive CO2 emissions are accounted for in the data presented by the gas production industry and therefore Party estimated emissions based on the size of transmissions pipeline network Follow up to the 1 st Response: ERT requested the Party to separate between combustion and fugitive related emissions. Combustion emissions for NG transport should be reported under 1A3e other transportation Wherever transport of NG exists, fugitive emissions and combustion emissions exists, so the NO and NE in other transportation category is often not correct Follow up to the 2 nd response: The ERT accepted revised estimates based on the data analysis presented by the Party NO reality translated into NE

19 Not Occurring (NO) Case Study 3: N2O emissions from wastewater handling, other: septic tanks [1] How the problem was identified (CRF, NIR etc) [2] How the problem was treated by the ERT In CRF table 6B, N2O emission from wastewater handling, other: septic tanks is reported as NO The ERT noted that the Revised 1996 guidelines provide a method and EFs to estimate emissions During the review, Party experts confirmed that the process leading to N2O emissions in septic tanks occurs in the country. [3] How the Party responded to the ERT Response by the Party: Party applied methodology and EF provided in the Revised 1996 IPCC GLs and developed time-series data for AD, applied EFs presented in the Revised 1996 guidelines to estimate emissions ERT Recommended the following in the Saturday Paper: Party to estimate emissions in line with methodology and EF provided in the Revised 1996 IPCC GLs; Use documented data on protein intake, and; Apply interpolation, extrapolation methods to derive missing data in the time series. [4] Follow-up by the ERT Follow up to the 1 st Response: ERT agreed with the emission estimates presented by the Party as they were in line with the 1996 IPCC GLs. NO in reality translated into NE

20 Not Occurring (NO) Case Study 4: CO2, CH4 and N2O emissions from biomass burning in ARD activities [1] How the problem was identified (CRF, NIR etc) [2] How the problem was treated by the ERT In CRF table 5(KP-II)5, CO2, CH4 and N2O emissions from biomass burning in ARD activities were reported as NO. However, in the NIR was reported that fires in forest land are considered insignificant (data available but fires usually smaller than 10 hectares) ERT Recommended the following in the Saturday Paper: Since activity data are available to provide estimates [3] How the Party responded to the ERT Response by the Party to the Saturday Paper: Activity data on forest fires available only at the aggregate level of forest land no proxies to be used for disaggregation. The only remaining option is to assign a portion of forest fires to ARD lands on the basis of their contribution to the total area of forest land; considering the insignificance of the source this option will add more uncertainties than information to the GHGI. [4] Follow-up by the ERT Follow up to the 1 st Response: Since activity data is available, even if with high uncertainty, the ERT recommended the Party to provide the estimate otherwise when accounting an adjustment will be applied. There is not any provision to allow excluding sources of emissions from the accounting

21 Lessons from the case studies Case studies shows that some NO cases are likely to be NE cases. This is similarly the case with some NA cases. Investigation by ERT on the existence of activity is very critical in NO and NA cases Critical for ERT to request Party to demonstrate that activity does not occur and not because its negligible Case studies shows that some NO cases are likely to be IE cases and evidence to demonstrate this is also important Again, where NO or NA has been confirmed to be a NE case, clear guidance by the ERT to the Party to highlight this is key

22 Proposed procedure for dealing with NOs If ERT is not able to determine whether activity occurs or not during the review week because of lack of transparency, it should follow the NE procedure No Perceived problem solved. NO or NA is maintained in the CRF tables ERT identifies all NO and NA cases Activity occurs/applica ble in the country? Yes ERT to do its own investigation (e.g. using publicly available information + Confirm with Party experts ERT relegates issue into ARR and encourages Party to estimate emissions No GPG + Guidelines provide guidance? Yes Follow NE procedure No Emissions included elsewhere? Yes ERT asks Party to provide evidence showing that emissions are included elsewhere

23 UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE Case Studies : Category 3 Deviation from IPCC GPG)

24 IEF (tons N2O /Tons of Nitric Acid Produced) Deviation from IPCC GPG/ Transparency Case Study 1: N2O from Nitric acid production 10 Austria Belgium Croatia 1 Denmark Finland France (KP) 0.1 Greece Ireland Japan Norway Romania Slovakia Sweden Turkey US Plant X Plant Y Series31 Plant Z Netherlands Plant

25 Deviation from IPCC GPG/ Transparency Case Study 1: N2O from Nitric acid production (Cont.) [1] How the problem was identified (CRF, NIR etc) In the NIR Party explained that technological changes resulted in N2O emissions reduction equivalent to 23% between 2007 and 2008 ERT performed an analysis of N2O Implied Emission Factors (IEFs) Analysis showed that IEFs for three plants are outliers (Plants X,Y and Z) ERT did a literature review on the abatement technologies mentioned by the Party [3] How the Party responded to the ERT 1 st Response by the Party to the Saturday Paper: Party provided a guideline document explaining how the measurement are made 2 nd response by the Party in Saturday Paper: Party provided reports documenting evidence of the technological change and 23% reduction of N2O emissions [2] How the problem was treated by the ERT ERT Recommended the following in the Saturday Paper: Party to provide evidence that proves that the implemented technological changes in all plants resulted in the combined 23% N2O emissions reduction, [4] Follow-up by the ERT Follow up to the 1 st Response: To improve clarity, ERT requested the Party to provide the following: measurement reports (facility level); and validation reports (local authorities); or verification reports (e.g. trading schemes such as the ETS) Follow up to the 2nd response: The ERT accepted evidence presented by the Party In the end this was not a case of underestimation

26 Deviation from IPCC GPG/ Transparency Case Study 2: Iron + Steel [Energy + IP] [1] How the problem was identified (CRF, NIR etc) In CRF table 1A2a, 1A1c and 2C1 Allocation of CO2 emission between Energy and IP for integrated Iron and Steel production not transparent During the review week, ERT requested the Party to prepare a spreadsheet showing how CO2 emissions from integrated iron and steel are accounted for in energy and IP sectors. Observations: Carbon flows did not balance CO2 emissions from arch furnaces not accounted for [3] How the Party responded to the ERT 1 st Response to the Saturday Paper by the Party: The Party provided to the ERT a process flow diagram showing quantified carbon inputs and outputs and provided the missing CO2 estimates associated electric arch furnaces 2 nd Response to the Saturday Paper by the Party The Party revised the carbon flows by comparing them to data reported in the CRF tables, Analysis showed that some carbon flows where underestimated and the Party prepared revised estimates [2] How the problem was treated by the ERT ERT Recommended the following in the Saturday Paper: a detailed justification of all the data reported in the CRF tables including a detailed carbon mass-balance (process flow diagram) showing all the inputs and outputs in the iron and steel processes and how these carbon flows are accounted in the Energy and IP sectors, or Revised and documented emission estimates for all iron and steel categories in the Energy and Industrial processes sectors indicated above [4] Follow-up by the ERT Follow up to the 1 st Response: ERT accepted emissions estimates associated with electric arch furnaces but requested the Party to compare the carbon flows with the information presented in the CRF tables for both IP and Energy and resubmit underestimated emissions if differences are observed Follow up to the 2 nd response: The ERT accepted revised estimates based on the data analysis presented by the Party This was indeed a case of underestimation

27 Deviation from IPCC GPG/ Transparency Case Study 3: CO2 emissions from deforestation (KP Article 3.3 activity) [1] How the problem was identified (CRF, NIR etc) The Party reports as NE carbon stock changes from soils in category forest land converted to settlement and consequently under deforestation did not account for emissions from soils in forest land converted to settlement The Party did not report supplementary information for accounting to demonstrate that the pool is not a net source [2] How the problem was treated by the ERT ERT Recommended the following in the Saturday Paper: to provide estimate of emissions due to carbon stock losses from soils as a consequence of land use conversion from forest land to settlement [3] How the Party responded to the ERT 1 st Response by the to Party to the Saturday Paper: There are not IPCC methods and default factors for estimating carbon stock losses from dead organic matter and from soils in lands converted to settlements; therefore to estimate carbon stock changes in these pools is not mandatory and the lack of country method/data justifies the use of NE [4] Follow-up by the ERT The ERT should reply: a. Decisions 15 and 16/CMP.1 specify that all carbon stock changes and other emissions on units of land subject to deforestation must be accounted b. IPCC GPG LULUCF Chapter 4, page 60 states that carbon stock changes on lands subject to deforestation can be estimated by determining the carbon stocks in all pools prior to and after the deforestation event (i.e. method provided) c. A recommendation (CP accounting) to provide the estimate or an adjustment (annual accounting) should be applied d. Lack of data for a mandatory estimate may be considered an issue for the national system

28 Other prevalent cases of deviation with IPCC GPG/Transparency Use of other country EFs without clear and detailed reasoning for their use Use of EFs and methodologies sourced from 2006 IPCC guidelines without clear and detailed reasoning for their use Use of EU ETS AD without clear and detailed reasoning for its use Sudden decrease of emissions level (EFs, AD) in early years and then a more or less stable or steady trend until last year reported without any information providing reasons of this change (see next slide).

29 Other prevalent cases of deviation with IPCC GPG/Transparency (Cont.) Norway Latvia

30 Lessons from the case studies Probably the most difficult of cases by ERT to identify Relies heavily on critical assessment of AD, EFs and transparency of methodology used Comparison with GPG and/or Revised guidelines is the first step in data analysis If abatement technology is used, literature review needs to be done to verify efficiencies or savings that technologies bring about Possible to have deviation from IPCC GPG or lack of transparency where direct measurements or models are used. In these cases, evidence pointing to measurement reports, validation and verification reports are important

31 Proposed procedure deviation with IPCC GPG and/or guidelines/lack of transparency Identification of an outlier value (EF + AD) and/or lack of information provided in the NIR ERT to do its own data analysis (e.g. comparison with IPCC GPG +/- Guidelines, comparison with other countries/facilities) (Locator Tool Important to use) If abatement technology is used, literature review is important Perceived problem solved No Possible Deviation from IPCC GPG and/or Guidelines identified? Yes ERT asks Party to provide evidence (e.g. measurement reports, verification reports, model validation reports, etc) Problem solved: However, transparency issues needs to be reflected in the ARR No Does evidence presented by the Party show an element of underestimation or lack of transparency? Yes Follow NE procedure and/or detailed/transparent information

32 UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE Case Studies : Category 4 Included Elsewhere (IE) and Underestimations

33 Included Elsewhere (IE) Case Study 1: CO2, CH4, N2O from Other Transportation [1] How the problem was identified (CRF, NIR etc) [2] How the problem was treated by the ERT In CRF table 1A3e Other Transportation, CO2,CH4 N2O from Other Transportation is reported as IE for the entire time series Comment on the CRF and in the NIR states that these emissions are included under 1A4c Agriculture and 1A2 Manufacturing Industries and Construction Party further explained in the NIR that separation of emissions is not possible as the AD is based on energy balance data [3] Recommendation to the Party Observation by the ERT: Lack of transparency : It is not clear whether these emissions include combustion emissions from remaining transport activities such as pipeline transport, ground activities in airports and harbours given that this activities exists in the country These equipment have different emission factors compared to those used in the sectors they have been reported under Potential Questions to the Party: Party should demonstrate how it has accounted for emissions associated with pipeline transport and ground activities in airports and harbours Party should demonstrate how it has dealt with the fact that emission factors for off-road vehicles may be different from those of off-road vehicles used in 1A4c and 1A2

34 Included Elsewhere (IE) Case Study 2: CO2, CH4 and N2O emissions from biomass burning [1] How the problem was identified (CRF, NIR etc) In the CRF table 5(KP-II)5 emissions due to biomass burning under afforestation and reforestation have been reported as IE with the information that have been included under forest management [2] How the problem was treated by the ERT ERT Recommended the following: Party to provide disaggregate estimate since accounting rules for emissions under forest management differ from those applied under afforestation and reforestation [3] How the Party responded to the ERT Response by the Party: Party indicated that no data were available for disaggregating estimates [4] Follow-up by the ERT Follow up to the 1 st Response: ERT recommended to collect needed data to allow to report separate estimates for biomass burning under afforestation and reforestation and under forest management ERT also recommend to disaggregate current reported emissions on the basis of proportion of the total forest area that is reported under afforestation and reforestation In case of annual accounting an adjustment would have been applied

35 Underestimations Case Study 1: CO2 from Lime Production [1] How the problem was identified (CRF, NIR etc) [2] How the problem was treated by the ERT In CRF table 2(1)A-G, CO2 from lime production is reported as IE for the entire time series Comment on the CRF states that lime production occurs only in the sugar industry and accounted for under 2D2 ERT noted that the Party had a paper industry which could regenerate lime from waste materials ERT Recommended the following in the Saturday Paper: Party to collect relevant information to demonstrate whether or not lime production occurs in the paper sector If it does occur, collect AD and estimate emissions for the complete time series in accordance with GPG [3] How the Party responded to the ERT Response by the Party to the Saturday Paper: Party indicated that most paper is produced from recycled fibers New pulp is mainly sourced from abroad Kraft (Sulphate) pulping process which results in CO2 is not used in the country Supporting documentation included: Sector report for lime industry and pulp and paper industry analysis report [4] Follow-up by the ERT Follow up to the 1 st Response: ERT considered the response and supporting material presented by the Party and decided that this IE does not lead to a possible NE.

36 Underestimations Case Study 2: CO2, CH4 and N2O emissions from road transportation [1] How the problem was identified (CRF, NIR etc) In the NIR, a methodological note states that fuel consumption in foreign cars for road transportation - foreign cars as reflected in the energy balances, are accounted for under export category The ERT noted this implies that this fuel consumption is not accounted for in domestic fuel consumption Party experts confirmed this assessment by the ERT [2] How the problem was treated by the ERT ERT Recommended the following in the Saturday Paper: Party to estimate fuel consumption sold to foreign vehicles and include this consumption and associated emissions under 1A3b [3] How the Party responded to the ERT Response by the Party to the Saturday Paper: Party indicated that it has no AD for fuel sales to foreign vehicles [4] Follow-up by the ERT Follow up to the 1 st Response: ERT considered that the energy balance is part of sources of data for the inventory and the Party should use it to estimate missing emissions. In this case underestimations could lead to NE

37 Lessons from the case studies IE cases links very strongly with estimate provided but lack of transparency PPs Therefore IE cases can often lead to identification of missing estimates that needs to be verified (e.g. lime production case) Underestimation cases can also lead to identification of missing AD or AD definition problems IE cases also require experts to do their own investigation on whether emissions are really allocated elsewhere Evidence to support IE cases should clearly show the principles used to allocate emissions where they are allocated

38 Proposed procedure for dealing with IEs and Underestimations No Perceived problem solved ERT identifies all IE cases IE leads to a possible underestimate? Yes ERT investigates whether IE case does not lead to underestimate (e.g. resulting in missing category, incomplete AD on in problems with definition of AD ERT asks Party to demonstrate principles and scope used to allocate emissions where they are allocated Problem solved: However, transparency issues needs to be reflected in the ARR No principles and scope of allocation result in underestimation? Yes Follow NE procedure

39 General conclusions and recommendations How problem is indentified by the ERT [Box 1] a) Deviation from IPCC GPG and/or Revised guidelines require some level of analysis and comparison before establishing a case of underestimation b) Investigation into existence of activity is important (e.g. use of public data, Statistics from Regional and International bodies, internet and so on) c) Case studies demonstrates that some NO, NA and IE cases are likely to be NE. In such cases the ERT needs to request and examine evidence for the notation key used d) Lack of transparency can also lead to NE

40 General conclusions and recommendations (Cont.) How ERT treats the problem [Box 2] a) Critical for ERT to explicitly specify guidance (Methodologies and EFs) and reference IPCC GPG and/or Revised guidelines methodologies or EFs b) This also requires evidence such as verification and validation reports c) In formulating a recommendation in a Saturday Paper, the ERT needs to consider all possibilities (e.g. provision of estimates and/or justification for use of notation keys) d) In providing guidance, the ERT also needs to highlight relational issues between categories and sectors (e.g. Wherever transport of NG exists, fugitive emissions and combustion emissions exists, so the NO and NE in other transportation category is often not correct)

41 General conclusions and recommendations (Cont.) How Party responds to the Saturday Paper recommendation [Box 3] a) ERT needs to ensure that data gaps are filled using guidance provided in the IPCC GPG, Chapter 7 b) In most cases measurements, or model results are not sufficient unless they have been subjected to a validation process c) There is always a potential for a misunderstanding between the ERT and the Party in some cases, therefore it is important that the recommendation reflected in [Box 2] are raised well in advance to allow the Party to respond in a manner that is satisfactory to the ERT

42 General conclusions and recommendations (Cont.) Follow-up by the ERT [Box 4] a) ERT needs to impress upon the fact that no matter how small a category, if guidance exists, it needs to be estimated b) If ERT feels that the response by the Party still presents lack of transparency, it should not be comfortable with an explanation if a possibility of more information or clarity still exists

43 Thank You

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