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Project implemented by consortium partner

Services to assess the reasons for

non-compliance of the emission

ceilings set in the National Emission

Ceilings Directive

Final Report

Client: DG Environment

Rotterdam, December 2013



ceilings set in the National

Emission Ceilings Directive

Final Report





Final Report





Final Report





Final Report





Final Report





Final Report

Client: DG Environment

Authors: Douglas Clark, Julija Dubasinska, Vladislav Bizek, Valts Vilnitis

Rotterdam, December 2013

2

Services to assess the reasons for non-compliance of the emission ceilings set in the National

Emission Ceilings Directive – Final Report

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4



Acknowledgements

This report was prepared for the European Commission DG Environment. We are

grateful for the valuable feedback and comments from policy officers Ulf Björnholm

Ottosson and Andre Zuber and their collegues in the Commission. The team also thanks

an anonymous reviewer from the European Environment Agency for helpful comments on

the Executive Summary.

The project team thanks the Member State officials and technical experts who

participated in this study for their cordial discussions and contributions regarding the

national perspectives, and helpful insights and comments in the development of this

report.

5

Services to assess the reasons for non-compliance of the emission ceilings set in the National Emission Ceilings

Directive – Final Report

Acknowledgements 4

List of Figures 8

List of Tables 9

Abbreviations and Acronyms 13

Executive Summary 17

1 Introduction 33

1.1 Context of the project 33

1.2 Objectives and tasks 35

1.3 Methodology 36

1.4 Structure of this report 39

2 Analysis of Common Denominators for Non-compliance 41

2.1 Summary of reasons for non-compliance 41

2.2 Common issues for NOX non-compliance 43

2.3 Country-specific issues for NOX non-compliance 49

2.4 Common issues for NH3 non-compliance 51

2.5 Country-specific issues for NH3 52

2.6 Common issues on emission inventory methodology and reporting 53

2.7 Common issues on national programmes of reduction measures 54

2.8 Common issues on emission projections 54

2.9 Differences between the independent assessment and Member State

perceptions 55

3 Estimated Time for Compliance with 2010 and 2020 Commitments 57

3.1 Estimated time for compliance with the NECD 2010 ceilings 57

3.2 Estimated time for compliance with the 2020 reduction commitments in the

amended Gothenburg Protocol 60

4 General Observations and Recommendations 63

4.1 Removing disincentives to improved inventory methodology 63

4.2 Enhancing the transparency and comparability of emission inventories 64

4.3 Improved national programmes and projections 66

4.4 Improved policy coherence 67

4.5 Unified access to emission information 68

5 Austria 69

5.1 Introduction 69

5.2 Independent assessment 71

5.3 Main reasons for non-compliance as identified by Austria 75

6


Directive- Final Report

5.4 Expected time of compliance with the 2010 Ceilings 76

5.5 Impact on future reduction commitments 77

6 Belgium 79

6.1 Introduction 79


6.3 Reasons for non-compliance as identified by Belgium 85



6.6 Observations and recommendations for Belgium 87

7 France 89

7.1 Introduction 89


7.3 Reasons for non-compliance as identified by France 93



8 Germany 97

8.1 Introduction 97


8.3 Reasons for non-compliance as identified by Germany 101


8.5 Impact on Future Reduction Commitments 102

8.6 Observations and recommendations for Germany 103

9 Ireland 105

9.1 Introduction 105


9.3 Reasons for non-compliance as identified by Ireland 109



10 Luxembourg 113



10.3 Reasons for non-compliance as identified by Luxembourg 117



10.6 Observations and recommendations for Luxembourg 120

11 Croatia 121


7




11.3 Reasons for non-compliance as identified by Croatia 124



12 Finland 127



12.3 Reasons for non-compliance as identified by Finland 131



13 References 135

8



List of Figures

Figure 5-1 Major NOX contributing sectors (left scale, kt) and national total NOX

emissions in Austria (right scale, kt), based on fuel used, CLRTAP 2012 72

Figure 5-2 Number of diesel and petrol passenger cars registered annually in Austria

(left scale) and the total number of vehicles (right scale) (EUROSTAT data) 73

Figure 6-1 NOX contributing sectors in Belgium, fuel used, 2012 NECD submission (kt) 82

Figure 6-2 Final energy consumption in Belgium by sector and fuel type, 1000s TOE

(Eurostat) 83

Figure 6-3 Number of registered passenger cars in Belgium by engine type (Eurostat) 83

Figure 7-1 NOx emission trends in the national total and major contributing sources in

France (CEIP database, submitted before 2013) 91

Figure 7-2 Final energy consumption by sector and fuel type in France (Eurostat) 92

9



List of Tables

Table 1-1 National NOX emissions in 2010 in comparison to NECD 2010 ceilings, for

non-compliant Member States. Blank entries indicate the values that are not

reported. Sources: EEA CDR online – NECD.SUBM12. 33

Table 1-2 National 2010 NH3 emissions in comparison to NECD 2010 ceilings, for non-

compliant Member States. 34

Table 1-3 National 2010 NMVOC emissions in comparison to NECD 2010 ceilings, for

non-compliant Member States. 34

Table 1-4 Gothenburg 2012 amendment NOX emission reduction commitments for

2020 and beyond. Blanks indicate values not reported. Sources:

NECD.SUBM12 35

Table 1-5 Gothenburg 2012 amendment NH3 emission reduction commitments for

2020 and beyond, with comparison to 2010 ceiling, for Member States non-

compliant in 2010 by 10% or more. Source: NEC.SUBM12, CLRTAP.SUBM13 35

Table 1-6 Differences in methodology – nitrogen oxides. 37

Table 1-7 Availability of national projections – ammonia. 37

Table 2-1 Summary matrix of reasons for non-compliance with NOx ceilings for Austria

(AT), Belgium (BE), France (FR), Germany (DE), Ireland (IE) and Luxembourg

(LU). 41

Table 2-2 Summary matrix of reasons for non-compliance with NH3 ceilings in 2010, for

Croatia (HR) and Finland (FI). 43

Table 2-3 Change in 2010 NOx emissions (fuel sold) from 1999 RAINS projections to

actual 2010 road transport activity and revised exhaust emission factors

(COPERT 4 ver 8.0), in comparison to distance from ceiling in 2010. Adapted

from Ntziachristos and Papageorgiou, 2011. 45

Table 2-4 Comparison of 1990 to 2010 changes in road transport fuel consumption

(fuel sold) and diesel share as assumed in 1999 when NECD ceilings were

agreed, versus actual changes in 2010, for the EU-15 Member States. Source:

IIASA, 1999; and Eurostat, 2013. 46

Table 2-5 Comparison of fuel sold and fuel used NOX emissions*. 48

Table 3-1 Estimated time for compliance with NECD 2010 ceilings based on the GAINS

model CLE scenario and available national with-measures projections (Nat.)

for 2015 to 2030. The GAINS model projections are compared to reported

emissions (Rep.) for 2005 and 2010. Emissions given in kt/year. 58

Table 3-2 Estimated annual compliance costs – 2025, based on GAINS model current

legislation (CLE) and maximum technically feasible reduction (MTFR)

scenarios 60

Table 3-3 Estimated time for compliance with the 2020 reduction commitments in the

2012 Gothenburg Protocol amendments, based on the GAINS model current

legislation scenario and national with-measures projections (Nat.) for 2015 to

2030. Emissions given in kt/year. 61

Table 5-1 Overview of Austria's final 2010 and provisional 2011 NOx emission data

submitted under NECD and CLRTAP. 69

10



Table 5-2 Main reasons for Austria's non-compliance with the NECD 2010 NOx ceiling,

based on the independent assessment. Quantified contribution to

exceedance is given in kt and percent where possible. 74

Table 5-3 Reasons for Austria's non-compliance with the NECD 2010 NOX ceiling as

identified by Austria. Quantified contributions to NOX emission exceedance

are given in kt and percent, where provided by Austria. 75

Table 5-4 Summary of projection analysis on the year for Austria to attain the NECD

2010 NOX ceiling (103 kt, fuel used). Emissions in kt/year – fuel sold (fuel

used based emissions in brackets) 77

Table 5-5 Estimated compliance period – Gothenburg protocol (GP) – Austria.

Emissions in kt/year – fuel sold. 77

Table 6-1 Overview of Belgium's final 2010 and provisional 2011 NOx emission data


Table 6-2 Reasons for Belgium's non-compliance with the NECD 2010 NOx ceiling,

based on the independent assessment. Contribution to exceedance is given

in kt and percent where possible. 84

Table 6-3 Reasons for Belgium's non-compliance with the NECD 2010 NOx ceiling as

identified by Belgium. Contribution to NOx emission exceedance is given in kt

and percent where provided by Belgium. 85

Table 6-4 Summary of projection analysis for Belgium on the year to attain the 2010

ceiling (176 kt). Emissions in kt/year 85

Table 6-5 Estimated time for compliance – Gothenburg protocol (GP) – Belgium.

Emissions in kt/year. 86

Table 7-1 Overview of France's final 2010 and provisional 2011 NOx emission data


Table 7-2 Reasons for France's non-compliance with the NECD 2010 NOx ceiling, based

on the independent assessment. Contribution to exceedance is given in kt

and percent where possible. 93

Table 7-3 Total and road traffic NOx emission for France in 1990 and 2010. Source:

December 2012 submission. 94

Table 7-4 Comparison of French NOx emissions in 2010 for current methodology

compared to the methodology in place at the time the NEC Directive was

established, based on the French submission in December 2012. 95

Table 7-5 Reasons for France's non-compliance with the NECD 2010 NOx ceiling as

identified by France. Contribution to NOx emission exceedance is given in kt

and percent where provided by France. 95

Table 7-6 Summary of projection analysis for France on the year to attain the 2010

ceiling (810 kt). 96

Table 7-7 Estimated compliance period – Gothenburg protocol (GP) – France. Emissions

in kt/year. 96

Table 8-1 Overview of Germany's final 2010 and provisional 2011 NOx emission data


Table 8-2 Reasons for Germany's non-compliance with the NECD 2010 NOx ceiling,



Table 8-3 Reasons for Germany's non-compliance with the NECD 2010 NOx ceiling as

identified by Germany. Contribution to NOx emission exceedance is given in

kt and percent where provided by Germany. 101

11



Table 8-4 Summary of projection analysis for Germany on the year to attain the 2010

ceiling (1051 kt). Emissions in kt/year – fuel sold 102

Table 8-5 Estimated time for compliance – Gothenburg protocol (GP) – Germany.

Emissions in kt/year – fuel sold. 103

Table 9-1 Overview of Ireland's final 2010 and provisional 2011 NOx emission data


Table 9-2 Reasons for Ireland's non-compliance with the NECD 2010 NOx ceiling, based



Table 9-3 Reasons for Ireland's non-compliance with the NECD 2010 NOx ceiling as

identified by Ireland. Contribution to NOx emission exceedance is given in kt

and percent where provided by Ireland. 110

Table 9-4 Summary of projection analysis for Ireland on the year to attain the 2010

ceiling (65 kt). Emissions in kt/year 110

Table 9-5 Estimated time for compliance – Gothenburg protocol (GP) – Ireland.


Table 10-1 Overview of Luxembourg's final 2010 and provisional 2011 NOx emission

data submitted under NECD and CLRTAP. 113

Table 10-2 Reasons for Luxembourg's non-compliance with the NECD 2010 NOx ceiling,



Table 10-3 Reasons for Luxembourg's non-compliance with the NECD 2010 NOx ceiling

as identified by Luxembourg. Contribution to NOx emission exceedance is

given in kt and percent where provided by Luxembourg. 118

Table 10-4 Summary of projection analysis for Luxembourg on the year to attain the

2010 ceiling (11 kt). Emissions in kt/year – fuel sold (fuel used based

emissions in brackets) 119

Table 10-5 Estimated compliance period – Gothenburg protocol (GP) – Luxembourg.

Emissions in kt/year – fuel sold (fuel used based emissions in brackets) 120

Table 11-1 Overview of Croatia's final 2010 and provisional 2011 NOx emission data


Table 11-2 Reasons for Croatia's non-compliance with the NECD 2010 NOx ceiling, based


and percent of exceedance where possible. 124

Table 11-3 Reasons for Croatia's non-compliance with the NECD 2010 NH3 ceiling as

identified by Croatia. Contribution to NH3 emission exceedance is given in kt

and percent where provided by Croatia. 125

Table 11-4 Summary of projection analysis for Croatia on the year to attain the NECD

2010 ceiling (30 kt). Emissions in kt/year. 125

Table 11-5 Estimated compliance costs – 2025 - Croatia 126

Table 11-6 Estimated compliance period – Gothenburg protocol (GP) – Croatia.


Table 12-1 Overview of Finland's final 2010 and provisional 2011 NH3 emission data


Table 12-2 Reasons for Finland's non-compliance with the NECD 2010 NOx ceiling, based



12



Table 12-3 Reasons for Finland's non-compliance with the NECD 2010 NH3 ceiling as

identified by Finland. Contribution to NH3 emission exceedance is given in kt

and percent where provided by Finland. 132

Table 12-4 Summary of projection analysis for Finland on the year to attain the 2010

ceiling (31 kt). Emissions in kt/year. 132

Table 12-5 Estimated annual compliance costs – 2025 - Finland 133

Table 12-6 Estimated compliance period – Gothenburg protocol (GP) – Finland.


13



Abbreviations and Acronyms

ARTEMIS Assessment and Reliability of Transport Emission Modeling and

Inventories (EU sponsored project)

AT Austria

BAU Business as usual (scenario)

BE Belgium

CDR Central Data Repository of Reportnet

CEIP Centre on Emission Inventories and Projections

CHP Combined heat and power (plant)

CLRTAP UNECE Convention on Long-range Transboundary Air Pollution

CLRTAP.SUBM13 National CLRTAP submission with deadline March 2013

CO Carbon monoxide

CO2 Carbon dioxide

COPERT Computer Programme to Calculate Emissions from Road

Transport

DE Germany

DPF Diesel particulate filter

EC European Commission

EEA European Environment Agency

EF Emission factor

EIONET European Environment Information and Observation Network

EMEP European Monitoring and Evaluation Programme (a scientifically

based and policy driven programme under the UNECE CLRTAP

for international co-operation to solve transboundary air pollution

problems)

ETC/ACC European Topic Centre on Air and Climate Change

ETC/ACM European Topic Centre on Air Pollution and Climate Change

Mitigation

ETS EU emissions trading system

EU European Union

Euro European emission standard for vehicles

Eurostat EU Statistical Office

FI Finland

FR France

GAINS Greenhouse Gas and Air Pollution Interactions and Synergies

Model

GEORG Austrian national model of emissions from non-road mobile

machinery

GHG Greenhouse gas

14



GLOBEMI Austrian national model of emissions from road transport

GP Gothenburg Protocol (UNECE CLRTAP Protocol to Abate

Acidification, Eutrophication and Ground-level Ozone)

HBEFA Handbook of Emission Factors

HDV Heavy duty vehicle

HR Croatia

IA independent assessment

IE Ireland

IIASA International Institute for Applied System Analysis

IIR Informative Inventory Report

IRCELIN Belgian Interregional Environmental Agency

kt Kiloton (1000 t)

LCP Large combustion plant

LDV Light duty vehicle

LEZ Low emission zone

LU Luxembourg

MMR Monitoring Mechanism Regulation (525/2013)

MS Member State

NEC National emission ceiling

NEC2010 National emission ceiling for 2010

NECD National emission ceiling directive - Directive 2001/81/EC of the

European Parliament and of the Council of 23 October 2001 on

national emission ceilings for certain atmospheric pollutants

NECD.SUBM12 National NECD submission with deadline 31 December 2012

NFR Nomenclature for Reporting

NH3 Ammonia

NMVOC Non-methane volatile organic compounds

NO2 Nitrogen dioxide

NOX Nitrogen oxides

NPK Combined mineral fertilizers (nitrogen, potassium, phosphorus)

PC Passenger car

PM2.5 Particulate matter which passes through a size-selective inlet with

a 50% efficiency cut-off at an aerodynamic diameter of 2.5 μm

RAINS Regional Air Pollution Information and Simulation model

Reportnet EIONET’s infrastructure for supporting and improving data and

information flows

SO2 Sulphur dioxide

Toe Ton of oil equivalent

TREMOD German national model for the calculation of emissions from road

transport where emission factors are taken from the “Handbook of

Emission Factors” (HBEFA)

15



TSAP Thematic Strategy on Air Pollution

UK United Kingdom

UNECE United Nations Economic Commission for Europe

UNFCCC United Nations Framework Convention on Climate Change

WAM With additional measures (scenario)

WM With measures (scenario)

μm Micrometer

17



Executive Summary

The European Commission (EC) is making a comprehensive review of EU air pollution

policy in 2013, including Directive 2001/81/EC on national emission ceilings (NECD). As

a part of this review, this report presents an in-depth assessment of the main reasons for

non-compliance with the 2010 national emission ceilings. This study covers eight Member

States whose reported emissions significantly exceeded (by 10% or more) the existing

2010 emission ceilings as set out in the NECD1: Austria, Belgium, France, Germany,

Ireland and Luxemburg for nitrogen oxides (NOX) and Croatia and Finland for ammonia

(NH3). This report also looks at the prospects for these Member States to meet the 2010

ceilings and the 2012 Gothenburg Protocol reduction commitments for 2020. The study

highlights lessons learned through these non-compliance cases and presents

recommendations to facilitate compliance with current and future emission reduction

commitments.

Two complementary approaches have been used to identify and compare the reasons for

non-compliance: 1) an independent assessment made by the authors of this report based

on submitted data and reports, and 2) Member States' own assessments based on official

reports and telephone interviews with Member State officials and experts.

The study identifies common denominators among the reasons for non-compliance and

identifies possible differences between the independent and Member State assessments.

Estimated compliance dates for these eight Member States to achieve the NECD 2010

emission ceilings and the Gothenburg Protocol commitments for 2020 have been

assessed based on available national emission projections and projections made from

the IIASA Greenhouse Gas and Air Pollution Interactions and Synergies (GAINS2) model.

Overview of emissions and non-compliance in 2010 and 2011

Table ES-1 shows the current status of emissions and non-compliance with the

respective NECD national ceilings in 2010 and 2011, for the eight Member States

studied. Exceedances are given in kilotons and percent of the ceiling. Reported data for

2011 are preliminary.

1 This selection of Member States was based on preliminary reporting for 2010 emissions made in December 2011. In

December 2012, Spain reported final 2010 NH3 emission and preliminary 2011 NOX emission that were 10% above the

respective ceilings, but the timing of this new information was too late for Spain to be included in this study, despite

fulfilling the 10% exceedance criteria. 2 The GAINS model is part of the standard modelling framework for cost-effective emission control strategies for transboundary

air pollutants and greenhouse gases. http://www.iiasa.ac.at/web/home/research/researchPrograms/GAINS.en.html

http://www.iiasa.ac.at/web/home/research/researchPrograms/GAINS.en.html

18



Table ES-1 Summary of emissions and compliance with the 2010 NECD ceilings in 2010 and 2011*.

Reported emission NECD Exceedance 2010 Exceedance 2011

Member

State

fuel

basis

2010

kt

2011

kt

Ceiling

kt

kt

%

kt

%

NOX

Austria used 147.5 144.2 103 44.5 43.2% 41.2 40.0%

Belgium used 220.7 210.1 176 44.7 25.4% 34.1 19.4%

France sold 1075.3 1005.0 810 265.3 32.7% 195.0 24.1%

Germany sold 1331.9 1292.9 1051 280.9 26.7% 241.9 23.0%

Ireland used 75.4 67.6 65 10.4 16.0% 2.6 4.1%

Luxembourg used 17.9 18.0 11 6.9 63.0% 7.0 64.0%

NH3

Croatia - 38.1 36.8 30** 8.1 27.1% 6.8 22.7%

Finland - 37.5 37.3 31 6.5 21.1% 6.3 20.4%

* Data based on national NECD 2012 submissions (31 December 2012) except Croatia data based on CLRTAP

2013 submission (15 March 2013). ** Croatia joined the EU 1 July 2013 and their ceilings in the NECD3 are

identical to those in the 1999 UNECE Gothenburg Protocol.

Main reasons for non-compliance with ceilings

This study finds that the current emission situation and main reasons for non-compliance

are:

For the NOX ceilings:

Vehicle NOX emissions (primarily diesel) under real-world driving conditions are

significantly higher than expected from the test cycle emissions specified by the Euro

exhaust emission standards. Vehicle NOX emission factors have been increased to

reflect the real-world driving NOX emission levels, resulting in higher reported NOX

emissions compared to estimations and projections used at the time the NECD

ceilings were set. Estimated additional NOX emissions in 2010 due to revised vehicle

emission factors since the 2010 ceilings were set range from 16% of the national total

for Germany to 26% for France and 27% for Ireland4. These correspond to 75% of

Germany's 2010 exceedance, 106% for France and 192% for Ireland.

Climate policy, tax incentives and policies and consumer choice have led to large

increases in the number of diesel passenger cars and light duty vehicles during the

last decade, called dieselification of the vehicle fleet. As a result, the diesel share of

vehicle fuel consumption in 2010 was much higher than assumed in 1999 – 80% for

France, 83% for Luxembourg and 85% for Belgium. Since Euro 2, NOX emission

limits for diesel cars have declined more slowly than for petrol-fuelled cars5. The Euro

3, 4 and 5 emission standards which went into effect in 2000, 2005 and 2009 allow

three times more NOX to be emitted from new diesel vehicles than corresponding

new petrol-fuelled vehicles. These differences are much larger under real-world

driving conditions. The combination of dieselification and higher specific NOX

3 Croatia’s NECD 2010 ceilings are established in Council Directive 2013/17/EU of 13 May 2013 adapting certain directives in

the field of environment, by reason of the accession of the Republic of Croatia. http://eur-

lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32013L0017:EN:NOT 4 Ntziachristos and Papageorgiou, 2011. Road transport emission projections in the context of the EU NEC Directive ceiling

commitments. Impacts of model versions. ETC/ACC Technical Paper 2010/20.

http://acm.eionet.europa.eu/reports/docs/ETCACC_TP_2010_20_Copert2vsCopert4.pdf 5 Euro 1 NOX standards (1992) were fuel neutral. Euro 2 (1996) allows 40% more NOX from new diesel cars than for petrol.

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32013L0017:EN:NOT


http://acm.eionet.europa.eu/reports/docs/ETCACC_TP_2010_20_Copert2vsCopert4.pdf

19



emissions for diesel vehicles resulted in significantly higher total NOx emissions than

expected (in the range of 22 to 32 percent of the national totals for France, Germany

and Ireland).

Although the COPERT 4 model introduced in 2007 gave significantly higher NOX

emissions for road traffic than expected at the time the ceilings were set, Member

States were slow to take compensating measures. On the other hand, NECD does

not require further revision of national programmes of measures after 2006.

Emission inventory improvements have added new NOX emission source sectors

after the ceilings were set, which have increased the distance to reach the fixed

ceilings. An example of a new, previously not accounted source, is NOx emissions

from agricultural soils reported by Germany, Austria and Luxembourg, adding 9% to

the national total for Germany6. Some non-road mobile machinery sources were also

omitted by some Member States at the time the ceilings were set.

Climate and renewable energy policies have led to increased consumption of

biomass, which typically has higher NOX emissions in small combustion installations

than natural gas or oil7.

Total road transport fuel consumption between 1990 and 2010 increased more than

projected in 1999 for Austria, Ireland and Luxembourg, but was lower than the 1999

projection for Belgium, France and Germany, making this a mixed issue for NOX

emissions.

Underestimated base year emissions at the time ceilings were set, due to poor

activity data quality and/or lack of reliable emission factors, have also contributed in

some Member States, in particular in Belgium and Germany. These require a greater

reduction to meet the fixed ceilings than originally foreseen.

For the NH3 ceilings

Poor quality of activity data for the agricultural sector, including limited information on

livestock populations, manure management systems, etc., largely underestimating

the total activity of the sector and thus underestimating the 1990 base year for

ammonia emissions in the 1999 Gothenburg Protocol.

Inadequate (too low) emission factors used at the time when the NECD ceilings were

set.

Late and inadequate national measures to reduce agricultural NH3 emissions.

In addition to the main reasons listed above the study identifies a number of country-

specific reasons, as listed below Member State by Member State.

Specific observations for Austria

Energy consumption from road transport increased 62% from 1990 to 2010, twice as

fast as assumed in 1999, and the second largest departure from assumed growth

among the EU-15.

The share of diesel cars in Austria increased from 14% in 1990 to 55% in 2010. The

diesel share of passenger car kilometres driven in the country (ie. fuel used basis)

increased from 18% in 1990 to 60% in 2010.

6 Germany reported agricultural soil NOX emissions (NFR sector 4.D) of 110 kt in 2011 (9% of national total NOX); Austria’s was

0.7% of the national total and Luxembourg’s was 1.7% of the national total. 7 Tier 1 default NOX emission factors for biomass combustion in small residential heating installations are 57% higher than for

natural gas or oil. EMEP/EEA Guidebook (2013), section 1.A.4 Small combustion.

http://www.eea.europa.eu/publications/emep-eea-guidebook-2013/part-b-sectoral-guidance-chapters/1-energy/1-a-

combustion/1-a-4-small-combustion

http://www.eea.europa.eu/publications/emep-eea-guidebook-2013/part-b-sectoral-guidance-chapters/1-energy/1-a-combustion/1-a-4-small-combustion


20



No additional measures beyond measures in existing legislation were proposed in the

National Programmes of 2002 and 2006 despite updated national emission

projections indicating that without additional measures, NOX ceilings would be widely

exceeded.

Specific observations for Belgium

Improved inventory methodology has increased the reported NOX emissions for

19908 by 18% compared to the level reported at the time the ceilings were set,

making the reduction required to meet the fixed ceiling for 2010 larger than was

originally foreseen.

The Walloon and Brussels regions continued using the COPERT III (2002) road

transport emission model until updating to COPERT 4 in 20119. This delayed

introduction of "real world" vehicle emission factors, and underestimated NOX

emissions when developing the National Programme.

Climate policy in the Flemish region promoted the development of decentralized

electricity generation using small cogeneration plants (Combined Heat and Power,

CHP) with a capacity of less than 50 MW that have high specific NOX emissions.

Specific observations for France

France calculates an increase of 152 kt in 2010 NOX emissions due to the 2007

methodology change from COPERT III to COPERT 4 for road transport emissions

(57% of 2010 exceedance). An ETC/ACC study10 estimates an overall increase of

282 kt NOX in 2010 due to revised exhaust emission factors from COPERT II in use

at the time the ceilings were set as compared to COPERT 4 v8.0 (106% of 2010

exceedance)11.

The diesel share of road transport increased more than was assumed in 1999, but

was offset by total road transport fuel consumption increasing less than expected.

Inventory improvements added emissions from non-road mobile machinery in

industry and agriculture not reported at the time the ceilings were set, and lead to a

reported increase of the 2010 NOX emissions by 39 kt (15% of the 2010

exceedance).

Specific observations for Germany

An increase of 210 kt NOX in 2010 road transport emissions due to revision of

emission factors from COPERT II to COPERT 4 v8.010 (75% of 2010 exceedance)11.

Fuel consumption by heavy duty diesel vehicles increased much more than assumed

in the 1999 RAINS model projections. In spite of an overall 8% decline in road

transport fuel consumption from 1990 to 2010, the increase of heavy duty vehicle

activity and change in fleet composition compared to the 1999 assumptions accounts

for 113 kt of additional NOX in 201010 (40% of the 2010 exceedance).

Increased biomass combustion in energy and manufacturing industries and small

combustion resulted in an additional 106 kt NOX emission in 2010 (38% of the 2010

exceedance).

8 In the 1999 Gothenburg Protocol, the year 1990 is used as the reference year (or "base year") for defining interim

environmental objectives relative to the situation in that year (Article 5), but NECD does not use a base year. 9 Belgium, Informative Inventory Reports under CLRTAP, 2009, 2010, 2011. 10 Ntziachristos and Papageorgiou, 2011. Table 8, difference between "COPERT 4+New Activity" (v8.0) and "COPERT II+New

Activity" columns. 11 Note: the estimated additional emissions in 2010 can sum to more than 100% relative to the 2010 exceedance, indicating that

the 2010 NOX emissions could have been below the ceiling if all these issues had not arisen.

21



Changes in inventory methodology lead to the inclusion of NOX emissions from

agriculture (not included at the time the ceilings were set), increasing 2010 emissions

by 99 kt (35% of the 2010 exceedance).

National projections consistently overestimated the expected NOX reductions from

planned and additional measures, masking the need to put additional measures in

place.

Specific observations for Ireland

Reported road transport NOX emissions for 2010 increased by 20 kt due to revision of

vehicle emission factors from COPERT II to COPERT 4 v8.010 (192% of 2010

exceedance).

Ireland had the second highest growth (138%) in overall road transport fuel

consumption among the EU-15, which was not foreseen at the time when the ceilings

were set.

Economic growth has been much higher than assumed in 1999, particularly in the

construction industry.

Inventory improvements added emission sources that were not included at the time

the ceilings were set, such as from agriculture and national fishing, adding nearly 2 kt

to the 2010 NOX emission (18% of the 2010 exceedance).

Ireland has reported that implementation of emission reduction technologies has

been more successful than projected in 1999, but that this effect has been insufficient

to compensate for the factors leading to higher emissions.

Specific observations for Luxembourg

The population growth rate and economic growth rate have been much higher than

assumed when the ceilings were set.

Commuters living in the border regions around Luxembourg correspond to an

additional 30% of the population. Non-resident commuter traffic was not fully

considered at the time the ceilings were set.

Primary energy consumption in 2010 was 51% greater than assumed when the

ceilings were set.

Luxembourg had the greatest increase in road transport fuel consumption, 373% on

fuel used (146% on fuel sold), from 1990 to 2010 among the EU-15.

Diesel fuel consumption for road transport increased 305% (fuel sold12) from 1990 to

2010 - the largest percentage increase among the EU-15 - while petrol consumption

only declined by 15%. The diesel share of road transport fuel consumption was 83%

in 2010, twice the share estimated when the ceilings were set.

A new gas-fired 350 MWel co-generation plant began operation in 2002, replacing

electricity previously imported, with NOX emissions corresponding to about 8% of the

2010 exceedance.

Luxembourg has not submitted any national informative inventory reports or national

emission projections for years after 2010, making it more challenging to identify and

adopt compensatory additional measures.

12 Eurostat statistics and reporting under the EU GHG Monitoring Mechanism include road transport fuel consumption (TJ) by

fuel type, based on fuel sold, but data is not generally available by fuel type for fuel consumption based on fuel used.

22



Specific observations for Croatia

National NH3 emission factors in use at the time the GP ceilings were set

underestimated NH3 emissions significantly. The fixed 30 kt ceiling requires a 7 kt

(19%) emission reduction from the reported 1990 emission at the time the ceilings

were set, but the improved methodology applied meant that the reduction effort

suddenly tripled to a much more challenging reduction of 21 kt. Although Croatia has

reduced annual NH3 emissions by 13 kt, which is nearly twice the reduction foreseen

when the ceiling was set, it is still 7 kt above the ceiling.

National legislation implementing emission ceilings and a National Programme of

emission reductions were adopted as late as 2008. However, the national legislation

established a national NH3 ceiling of 45 kt rather than the GP 30 kt ceiling, and

proposed reduction measures were insufficient to meet the 30 kt ceiling13 set out in

the GP and the NECD.

Specific observations for Finland

Improved inventory methodology for the agricultural sector (emission factors, activity

data) and addition of transport, energy, solvent use and waste management source

sectors, increased the reported 2010 NH3 emissions by 6 kt (89% of the 2010

exceedance) compared to the methodology at the time the ceiling was set.

No targeted national measures were adopted and planned for reduction of ammonia

emissions. The National Programmes only referred to other EU policies, such as the

Nitrate Directive14, and overestimated the effectiveness of those policies.

Finland continued through 2008 to report national current legislation projections for

2010 equal to the RAINS model projections made at the time the ceilings were set,

showing compliance with the ceiling value in 2010. Improved inventory methodology

was introduced in 2009, but recalculations showing the full impact of the changes

were not completed until 2011 when it was acknowledged that the ceiling would be

exceeded in 2010 and beyond. Updated projections showing non-compliance were

reported in 2012. These signals came very late that the measures in existing

legislation were inadequate and this could have contributed to delays in adopting

compensating measures.

Estimated time for compliance with NECD 2010 ceilings

National and GAINS projections have been analysed to estimate when the eight Member

States are likely to reach their NECD 2010 ceilings. The analysis is based on the most

recent national with-measures (WM) projections submitted under NECD or CLRTAP15,

and on the GAINS model current legislation scenario TSAP_Mar13_CLE16. A summary of

the analysis is shown in Table ES-2. The projections assume implementation of existing

EU and national legislation, including the Euro 6/VI vehicle emission standards, leading to

13 In August 2013, Croatia adopted a new regulation (OG 108/13) establishing the GP/NECD 30 kt NH3 ceiling and repealing the

national 45 NH3 kt ceiling. The National Programme is to be revised as necessary. 14 Council Directive 91/676/EEC of 12 December 1991 concerning the protection of waters against pollution caused by nitrates

from agricultural sources, http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31991L0676:EN:NOT 15 National projection submissions used: Austria – NECD.SUBM11; Belgium – NECD.SUBM12; France – NECD.SUBM12;

Germany – CLRTAP.SUBM12; Ireland – CLRTAP.SUBM13; Croatia – CLRTAP.SUBM13; Finland – CLRTAP August

2013. Luxembourg has not submitted any projections for years after 2010. 16 Amann et al. (2013). Policy Scenarios for the Revision of the Thematic Strategy on Air Pollution. TSAP Report #10, Version

1.2, March 2013, IIASA.

http://www.iiasa.ac.at/web/home/research/researchPrograms/MitigationofAirPollutionandGreenhousegases/TSAP_10-v1-

2.pdf


http://www.iiasa.ac.at/web/home/research/researchPrograms/MitigationofAirPollutionandGreenhousegases/TSAP_10-v1-2.pdf


23



relatively steep emission reductions of NOx emissions by 2020-2025. The first projections

indicating compliance for each Member State are highlighted in green in the table.

The GAINS model calculates national NOX projections based on fuel sold. For Member

States with NOX compliance checking based on fuels used, GAINS model values

corresponding to fuel used emissions have been estimated using the fuel used to fuel

sold ratio from concurrent national projections (Austria, Ireland), or from reported 2011

road transport emissions (Luxembourg)17. Belgium indicates that the GAINS model has

been adjusted for Belgium to represent as closely as possible fuel used emissions, so no

conversion is made.

The GAINS model does not include agricultural NOX emissions except field burning18, but

three Member States (Austria, Germany, Luxembourg) report agricultural NOX emissions

from manure management (NFR 4.B) and agricultural soils (NFR 4.D)19. To make

national NOX emissions and projections more comparable with the GAINS model,

agricultural soil NOX emissions are deducted from Austria's, Germany's and

Luxembourg's emission and national projection values in Table ES-2.

Table ES-2 shows the GAINS model projection values for 2005 and 2010 in comparison

to the reported NECD emissions for these years, indicating differences in the GAINS

modelling approach compared to reported emissions. The GAINS model underestimates

the 2005 and 2010 emissions – by 1 to 3 percent for France and Germany to as much as

24 to 25 percent for Croatia and Luxembourg, which suggests that the GAINS model may

underestimate emissions in the projection years for these Member States. The GAINS

model, on the other hand, overestimates Ireland emissions for 2005 and 2010 by 11 and

20 percent respectively, suggesting the GAINS model projection may also be

overestimated. For Belgium, the GAINS model overestimates the 2005 and 2010 fuel

used emissions by 3% and 6%. Not surprisingly, the GAINS model projects earlier

compliance than national projections for Austria, Germany and Finland, and later

compliance for Ireland. For France and Belgium, the GAINS model projections are very

close to the national projections.

17 The difference between fuels sold and fuels used is very large for Luxemburg, so this methodology may be subject to high

uncertainties. 18 The GAINS model includes NOX emissions from field burning of agricultural wastes (NFR sector 4.F), which are negligible for

the Member States in this study. 19 EEA (2013) NEC Directive status report 2012. Appendix 4: Member State reporting of NOX and NMVOC emissions from the

agriculture sector.

24



Table ES-2 Estimated time for compliance with NECD 2010 ceilings based on the GAINS CLE scenario

and available national with-measures projections (Nat.) for 2015 to 2030. The GAINS model

projections are compared to reported emissions (Rep.) for 2005 and 2010. Emissions given

in kt/year.

Reported emissions for previous years,

used for reference, kt Projections, kt

2010 fuel 2005 2010 2011 2015 2020 2025 2030

ceiling basis GAINS Rep. GAINS Rep. Rep. GAINS Nat. GAINS Nat. GAINS Nat. GAINS Nat.

NOX

AT 103 sold 229 237 174 192 182 140 159 99 129 76 65 121

used 163 168 133 147 143 108 124 82 108 64 56 105

BE 176 sold 300 234 215 174 147 135

used 292 221 210 200 170

FR 810 sold 1374 1410 1053 1075 1005 847 848 619 620 496 438

DE 1051 sold 1413 1462 1219 1228 1182 991 1076 751 902 615 549

IE 65 sold 142 127 95 79 71 95 67 86 56 65 47 49

used 135 121 91 75 68 91 64 82 54 62 45 47

LU 11 sold 48 64 40 46 48 25 19 12 10

used 14 21 11 18 18 7 6 4 4

NH3

HR 30 - 29 40 29 38 37 31 39 32 42 32 33

FI 31 - 34 38 33 38 38 31 35 31 36 31 31 36

Data sources: GAINS online - scenario: TSAP_Mar13_CLE (current legislation); National emissions and WM

(with measures) projections from NECD and CLRTAP submissions through August 2013.

Notes:

a. For AT, BE, IE and LU, values based on fuel used are the basis for compliance assessment. Calculations of

NOX emissions in the GAINS model are based on fuel sold. The GAINS values based on fuel used are

estimated here based on the fuel used/fuel sold ratio from national emissions or projections in the same

year (AT, IE).

b. For LU, the fuel used/fuel sold ratio for 2011 reported road transport emissions is used to adjust GAINS

model road transport emission values to fuel used basis for all projection years.

c. Belgium informs that the GAINS model has been adjusted in such a way that it would represent as much as

possible the emissions as estimated in the Belgian inventory based on fuel used, and the actual difference

between fuel used and fuel sold is expected to be larger. The GAINS model values for BE are assumed to

represent fuel used emissions.

d. For AT, DE and LU, NFR categories 4D1 (emissions from soils) and 4D2 (handling of agricultural products)

are deducted from national values for comparability between Member States and with the GAINS model

projections.

e. For LU, fuel sold emissions are about 2½ times larger than fuel used emissions in 2010, making fuel export

emissions (28 kt) larger than the national total emission based on fuel used (18 kt). Without a projection for

fuel export, any conclusion for LU based on fuel sold projections from the GAINS model will be uncertain.

Conclusions for NECD 2010 ceilings

One Member State (Ireland) may achieve compliance before 2015 with current

legislation.

Ireland is projected to comply with the NOX ceiling shortly after 2015 by national

projections. The level projected for 2015 has already been reached in 2011, but

Ireland indicates that national NOX emissions in 2012 are likely to increase. The

GAINS model, which overestimates emissions in 2005 (11%) and 2010 (20%),

projects compliance shortly after 2020 with current legislation.

25



Five Member States (Austria, Belgium, France, Germany and Luxembourg) are likely to

achieve compliance with their NOX ceilings between 2015 and 2020 with current

legislation.

Germany is likely to achieve compliance about 2015.

Belgium and France are likely to achieve compliance between 2015 and 2020.

Austria is likely to achieve compliance before 2020 according to the GAINS model,

but national projections submitted in 2011 do not show compliance through 2030.

Luxembourg has not submitted national projections for years after 2010. Fuel export

NOX emissions are significantly larger than national fuel used emissions and vary

over time. For this analysis, the GAINS model projections (based on fuels sold) are

adapted to the fuel used basis using the fuel used/fuels sold ratio for road transport

emissions in 2011. This approach shows compliance in 2010 – an underestimation

which indicates that this approach for Luxembourg is more uncertain than the others.

Two Member States (Croatia, Finland) are not likely to reach compliance with their NECD

2010 NH3 ceilings without significant additional measures beyond current legislation.

Croatia shows continued exceedance through 2030 according to both national and

GAINS model current legislation projections.

Finland shows continued exceedance through 2030 according to national current

legislation projections but just equalling the ceiling in 2015 and thereafter, according

to the GAINS model. However, the GAINS model underestimates Finland's NH3

emissions in 2005 (10%) and 2010 (13%), which may indicate that this projection is

unrealistic.

Additional measures

To assess the technical emission reduction potential for the Croatia and Finland, the

GAINS model current legislation projections (the CLE scenario20) were compared with

maximum technically feasible reduction (MTFR21) projections for 2025 in Table ES-3.

Cost figures are not available for 2020 but 2025 values are here used as a proxy for

emission reduction potential and costs for 2020.

Table ES-3 Estimated annual compliance costs, 2025, based on GAINS model current legislation (CLE) and

maximum technically feasible reduction (MTFR) scenarios.

Emission projections (kt) Cost 2025 (MEUR/year)

NEC2010

ceiling

CLE

2020

CLE

2025

MTFR

2025

Difference 2025

CLE – MTFR

CLE

2025

MTFR

2025

Difference 2025

MTFR - CLE

HR NH3 30 32 32 19 13 n.a. 46.9 46.9

FI NH3 31 31 31 24 7 15.8 64.6 48.8

Source: GAINS online.

20 GAINS current legislation scenario: TSAP_Mar13_CLE 21 GAINS TSAP_Mar13_MTFR_2025 scenario; cost level 2005, 4 % interest rate

26



Estimated time for compliance with the 2020 reduction commitments in the

amended Gothenburg Protocol

Table ES-4 gives an overview of when the GP 2020 reduction commitments are likely to

be reached, based on the same national with-measures projections and the GAINS

current legislation scenario22 projections presented in Table ES-2 and subject to the

same uncertainty. The GP 2020 reduction commitments are expressed as percent

reductions relative to the reported emission for reference year 2005. Equivalent target

values in kilotons are shown in the table.

Emission values in the Table ES-4 exclude certain agricultural emissions for consistency

with the GAINS model (see Table ES-2 notes). GAINS fuel used values are estimated

from the GAINS fuel sold values using the fuel used/fuel sold ratio of the reported

national emission inventories. GAINS model values for Belgium are assumed to

represent fuel used emissions.

National projections are compared to the target values based on reported emissions in

2005 (the GP base year). To partially compensate for under- or overestimation by the

GAINS model seen in Table ES-2, the GAINS projections are compared to target

emissions based on the GAINS values for 2005. The earliest projections showing

compliance with their respective targets are highlighted in green in Table ES-4.

Table ES-4 Estimated time for compliance with the 2020 reduction commitments in the 2012

Gothenburg Protocol amendments, based on the GAINS current legislation scenario and

national with-measures projections (Nat.) for 2015 to 2030. Emissions given in kt/year.

GP 2020 targets, kt Projections, kt

GP 2020 reduction

commitment Based on

GAINS projection for 2005

Based on reported emission for 2005

2015 2020 2025 2030

% fuel

basis GAINS Nat. GAINS Nat. GAINS Nat. GAINS Nat.

NOX

AT 37 sold 144 149 140 159 99 129 76 65 121

used 102 106 108 124 82 108 64 56 105

BE 41 sold 177 215 174 147 135

used 172 200 170

FR 50 sold 687 705 847 848 619 620 496 438

DE 39 sold 862 893 991 1076 751 902 615 549

IE 49 sold 72 65 95 67 86 56 65 47 49

used 69 62 91 64 82 54 62 45 47

LU 43 sold 27 36 25 19 12 10

used 9 11 7 6 4 4

NH3

HR 1 - 29 40 31 39 32 42 32 33

FI 20 - 27 30 31 35 31 36 31 31 36

Data sources and notes: See Table ES-2.

22 The Commission's draft GHG Projection Guidelines (TNO et al, 2012) uses the clearer expression "with existing measures"

(WEM) rather than "with measures" (WM) to refer to an existing legislation scenario, which has also been adopted in the

new EMEP/EEA guidelines for reporting 2013.

27



Conclusions for GP 2020 reduction commitments

Except for Austria, the available projections show little difference between fuel sold and

fuel used estimates of time for compliance with the 2020 NOX reduction commitments.

Five Member States (Austria, Belgium, France, Ireland, Luxembourg) are likely to meet

their GP 2020 commitments based on current legislation.

Ireland is projected to comply shortly after 2015 by national projections. Reported

emissions in 2011 have already reached the level projected for 2015 by the national

projection, but Ireland indicates that national NOX emissions in 2012 are likely to

increase. The GAINS model projects compliance between 2020 and 2025, with

current legislation.

Luxembourg is projected to comply with its GP 2020 commitment before 2015

according to the GAINS model. Having no national projections to compare with

leaves some uncertainty around the conclusion.

Austria, Belgium and France are likely to comply with their respective GP 2020

reduction commitments by 2020 with measures in accordance with current legislation.

The GAINS current legislation projection based on fuel sold suggests compliance

closer to 2015 for Austria.

Germany would reach its reductions commitments between 2015 and 2020

according to the GAINS current legislation projections. However, national projections

do not indicate compliance by 2020, suggesting additional measures may be needed.

Two Member States (Croatia, Finland) are not likely to meet their GP 2020 commitments

for NH3 without additional measures.

Croatia's NH3 emission is below the GP 2020 target through 2015, but rises above

the target after 2015 according to the national projection (with measures scenario).

The GAINS model indicates non-compliance through 2030 based on current

legislation. Based on this analysis, Croatia is not likely to achieve the GP 2020

commitment without additional measures beyond current legislation.

Finland does not appear to reach the target level through 2030 according to both the

national and the GAINS model current legislation projections.

Table ES-3 also indicates the range of additional feasible reductions and mitigation costs

for Croatia and Finland to meet their GP 2020 commitments.

General observations and recommendations

This study of eight cases of non-compliance with the NECD ceilings in 2010 has identified

common denominators as well as country-specific reasons for the exceedances. These

include issues at EU, national and regional levels. This section summarizes key

observations and sets out a number of corresponding recommendations in the context of

a revised NECD.

Removing disincentives to improved inventory methodology

Changed methodology contributes to the non-compliance of several of the Member

States in this study. The NECD provides no mechanism to compensate for this, which

may constitute a disincentive for improving inventories, and could inhibit ambitions for

setting future reduction commitments. The 2012 Gothenburg Protocol amendments

introduce two provisions that can compensate for increasing emissions due to

28



improvements in methodology – relative reduction targets and an "adjustment

mechanism":

Relative reduction targets maintain a proportional reduction requirement regardless of

whether reported base year emissions increase (or decrease) due to methodology

improvements. Relative targets also cancel out most differences with regard to

emissions based on fuel sold or fuel used.

The GP adjustment mechanism allows parties to propose adjustments in exceptional

circumstances to their emission reduction commitments or to their inventories used

for compliance checking, for non-compliance caused by three types of exceptional

circumstances: 1) inclusion of new emission categories, 2) revised emission factors

due to improved knowledge, and 3) significant changes in methodology since the

commitments were set.

These two provisions will remove earlier barriers to inventory improvements and reporting

of the most scientifically correct emissions, while at the same time alleviating some of the

risks related to uncertainties for emission inventories and projections.

Recommendation 1: Future national commitments for emission reductions under a

revised NECD should be expressed as percentage reductions relative to emissions

in a reference year (as reported at the time of compliance checking). The criteria,

procedures and timetable for checking compliance with the percentage reductions

should be clearly defined.

Recommendation 2: A mechanism should be provided in a revised NECD to enable

Member States to apply for adjustments in exceptional circumstances only to their

emission inventories used for checking compliance, when non-compliance is the

result of certain types of methodology improvements. Guidance should be provided

and the process should be transparent. Alignment with the GP adjustment

mechanism should be considered.

Enhancing the transparency and comparability of emission inventories

This study has encountered issues with some emission inventories which hindered the

assessment of reasons for non-compliance. A number of "new" source categories have

been recognized. However, many Member States do not estimate the new categories23

and some Member States also do not estimate a significant number of the "old"

categories. This motivates strengthening the requirements for completeness of inventory

reporting, and to limit reporting of "not estimated" categories.

The NECD, via the UNECE reporting guidelines, requires Member States to report NOx

emissions based on fuel sold, but allows some Parties to use emission inventories based

on fuels used when comparing with the ceilings24. The possibility to report emissions on

the basis of fuel used is inconsistent with the reporting obligations for climate and energy,

which are compiled on the basis of fuel sold only. With a change to relative emission

reduction targets, the significance of fuel sold versus fuel used for emission reduction

measures is lessened, enabling reconsideration of permitting compliance checking based

on fuel used.

23 NECD (via the UNECE reporting guidelines) allows MS to report emissions as "NE" for those sectors where emissions are

known to occur but have not been estimated or reported. 24 The fuel sold or fuel used basis refers to transport emissions.

29



Basing compliance only on fuel sold emissions remains a problem for smaller Member

States where the transport sector is dominating. An adjustment mechanism for

inventories taking tank tourism into account could be considered for exceptional cases as

long as the environmental targets are not compromised.

An Informative Inventory Report (IIR) is essential to document the methodology and

changes in national emission inventories. Most Member States submit an IIR under

CLRTAP, but the NECD does not require an IIR.

Member States report emissions of the four NECD pollutants under the NECD, the

UNECE CLRTAP, and (except for NH3) the UNFCCC and Kyoto protocol, and the

Monitoring Mechanism Regulation25 (MMR) (525/2013) for greenhouse gasses. There are

differences in reporting requirements, submission deadlines, and methodologies. This

motivates further harmonization of reporting requirements among emission instruments

and protocols.

Recommendation 3: A revised NECD should better clarify the methodology and reporting

requirements for emissions, including:

that all source categories have to be reported in accordance with the EMEP

guidelines, reporting templates and EMEP/EEA Guidebook,

that it is made mandatory for all Member States to report road transport emissions

based on fuel sold for all years,

that future reduction commitments and thus reporting of road transport emissions

data be based on fuels sold only, and

that it is made mandatory for all Member States to submit an IIR under the NECD.

Harmonization of methodologies should enable a single IIR document to serve both

the CLRTAP and NECD requirements.

NECD, CLRTAP, UNFCCC and MMR reporting templates include reporting of activity

levels (primarily fuel consumption) associated with emission amounts and projections, for

each source sector, but not all Member States report these. Projected activity data are

valuable for monitoring changes in assumptions for projections. Activity data by fuel type

would be very useful for road transport sub-sectors, for monitoring of changing vehicle

fleet composition. Aggregate vehicle mileage is also a useful activity indicator.

The COPERT 4 software implements the Guidebook's Tier 3 mileage-based emission

methodology for road transport. Two thirds of Member States use various versions of

COPERT 4 to estimate emissions from road transport, and the remaining third use a

variety of other approaches26. There are few comparisons of the national approaches to

the Guidebook approach implemented in COPERT, so the magnitude of differences is not

known.

For Member States where tank tourism is significant (AT, BE, IE, LU), there is an

inconsistency between the requirement to report road transport emissions based on fuel

sold and the Guidebook Tier 3 methodology for road transport (and COPERT software)

based on in-country mileage corresponding to fuel used. Little guidance is given on

25 The Monitoring Mechanism Regulation (525/2013) Art. 7.1.b requires Member States to annually report CO, SO2, NOX and

VOC emissions that are consistent with data already reported under NECD and CLRTAP. 26 EEA (2013). NEC Directive status report 2012, Table 2.6

30



reconciling fuel sold versus fuel used fuel consumption. This is a concern for some

Member States, indicating a need for improved guidance on this topic.

Recommendation 4: NECD guidance should be strengthened to:

encourage Member States using the COPERT software to use the latest available

version in a given reporting year.

promote comparison and harmonisation of national methodologies for road transport

emission estimation.

improve guidance on best practice for calculating road transport emissions due to fuel

export (tank tourism), for Member States where this is significant.

require complete reporting of annual activity data for all inventory years and

projection activity data for all projection years.

include annual reporting of road transport activity data by fuel type (petrol, diesel,

etc.) and also aggregate vehicle mileage.

Improved national programmes and projections

National programmes of measures for emissions reduction have varied considerably in

content and level of detail among the Member States in this study. The NECD does not

specify what types of information about policies and measures should be reported in

national programmes, other than quantified estimates of the effects on emissions.

Recommendation 5: More detailed requirements on format and content of national

programmes should be considered for the updated NECD. National programmes

under NECD should be consistent with policies and measures on greenhouse gases,

as reported under the Monitoring Mechanism Regulation (525/2013). Hence updates

and reporting of NECD national programmes every two years should be considered.

Detailed implementation guidelines for the preparation of national programmes

should be prepared to assure that all Member States include the same level of

information, including estimates of the expected emission reduction for all measures.

Revisions to programmes should indicate the progress of existing measures in

comparison to the planned reduction.

This study has encountered national emission inventories and national projections with

differences in emission categories and methodology, and widely varying levels of

documentation. There are also several cases where national emission projections have

not been updated for several years after major methodology changes.

Among the Member States in this study, there are varying interpretations of the meaning

of "with measures" (WM) and "with additional measures" (WAM) projection scenarios,

and the years for which projections are calculated varies. The EMEP/EEA Guidebook

(2013)27 and proposed revision of the EMEP reporting guidelines28 align the definitions for

reporting with those under MMR, and this harmonisation should be reflected in a revised

NECD.

27 EMEP/EEA air pollutant emission inventory guidebook 2013, http://www.eea.europa.eu//publications/emep-eea-guidebook-

2013 28 TFEIP (2013) Guidelines for Reporting Emission Data Under the Convention on Long-Range Transboundary Air Pollution

(draft v2). http://tfeip-secretariat.org/assets/Meetings/Documents/2013-TFEIP-Istanbul/UNECE-2014-RepGuidelines-draft-

v2-clean-commented.doc

http://www.eea.europa.eu/publications/emep-eea-guidebook-2013


http://tfeip-secretariat.org/assets/Meetings/Documents/2013-TFEIP-Istanbul/UNECE-2014-RepGuidelines-draft-v2-clean-commented.doc


31



Recommendation 6: NECD guidance on projections should be strengthened regarding

the definitions and numbers of scenarios, the frequency and years for projections,

fuel basis, assessment of uncertainty, and updating of projections when

methodologies change. A two-year frequency for reporting projections as specified in

the MMR29 should be considered. Projections prepared for NECD should be

consistent with projections prepared for CLRTAP and MMR.

Improved policy coherence

Several Member States have mentioned during this study that implementation of other

EU environmental policies has led to increases in NOX emissions, which have contributed

to Member State non-compliance with the NOX ceilings, demonstrating shortcomings as

regards internal policy coordination in the Member States. Many Member States have

created incentives for diesel vehicles as part of their climate policies, which has led to

dieselification of vehicle fleets. The real-world emissions of NOx from diesel vehicles are

substantially above the limits set in the Euro exhaust emissions legislation, and this in

turn has led to increases in NOX emissions from transport.

Associated with climate policy, EU renewable energy policy promotes biomass. Several

Member States have reported increases in NOX emissions due to the shift to biomass,

especially from smaller combustion units with less strict emission limits.

One Member State noted that the EU Emission Trading System (ETS) places a financial

value on CO2 emissions, and a financial penalty for non-compliance. There is to date no

similar valuation or financial penalty for NECD non-compliance. This can cause Member

States to disproportionately prioritize GHG reduction measures, to the detriment of their

other pollutant reduction commitments.

Recommendation 7: Member States should improve policy coherence in the

implementation of interlinked environmental and climate and energy policies, e.g. by

comparing emissions and reduction measures for greenhouse gasses to emissions

and reduction measures of air pollutants. Further development of approaches to

establish equivalence factors or valuations for CO2 and non-GHG pollutants could be

helpful for policy comparisons and coherence. The EU should promote such efforts.

Unified access to emission information

A wealth of emission data is presently available online under various legal instruments,

and has been compiled into various datasets30 that are accessible or downloadable

online. The value of these resources would be enhanced for environmental monitoring,

education and research if the various NECD, CLRTAP and MMR national emission

databases were further harmonised to facilitate access and merging of these data

sources.

Recommendation 8: Publically-accessible databases of reported national emission and

activity data under the various emission instruments and protocols should be further

harmonised (common data definitions and encoding) to facilitate access and

merging of these data sources.

29 MMR Article 14, Reporting on projections. 30 For example NECD, CLRTAP and MMR emission datasets at EEA http://www.eea.europa.eu/data-and-maps/data and the

CLRTAP online emission database at EMEP CEIP http://www.ceip.at/webdab-emission-database, which also includes

activity and gridded data.

http://www.eea.europa.eu/data-and-maps/data

http://www.ceip.at/webdab-emission-database

33



1 Introduction

1.1 Context of the project

The Commission is undertaking a comprehensive review of EU air pollution policy in

2013. The review encompasses relevant EU regulatory instruments, including Directive

2001/81/EC on national emission ceilings (NECD), the focus of this project.

The National Emission Ceilings Directive (NECD) is a key element of EU air quality

policy. The aim of this Directive is to limit emissions of acidifying and eutrophying

pollutants and ozone precursors31. NECD covers emissions of sulphur dioxide (SO2),

nitrogen oxides (NOX), non-methane volatile organic compounds (NMVOC) and ammonia

(NH3). The Directive defines interim environmental objectives, introduces legally-binding

national emission ceilings to be met by 2010, and requires development and reporting of

national programmes for reduction of emissions, annual emission inventories and

projections.

Status of emissions under the NECD

Eleven Member States did not comply with their NOX emission ceilings in 2010, as shown

in Table 1-1.

Table 1-1 National NOX emissions in 2010 in comparison to NECD 2010 ceilings, for non-compliant

Member States. Blank entries indicate the values that are not reported. Sources: EEA CDR

online – NECD.SUBM12.

NOX

Country

2010 NOX emission

(fuel sold) kt

2010 NOX emission

(fuel used) kt

NECD 2010 emission ceiling, kt

Distance to NOX ceiling in

2010, kt

Distance to NOX ceiling in

2010, %

Luxembourg* 17.9 11* 6.9 63.0%

Austria* 193.2 147.5 103* 44.5 43.2%

France 1075.3 810 265.3 32.7%

Germany 1331.9 1051 280.9 26.7%

Belgium* 220.7 176* 44.7 25.4%

Ireland* 78.9 75.4 65* 10.4 16.0%

Spain 901.1 847 54.1 6.4%

Netherlands 274.1 291.9 260 14.1 5.4%

Denmark 133.5 127 6.5 5.1%

Sweden 153.4 148 5.4 3.6%

Malta 8.1 8 0.1 1.3%

* Compliance based on fuel-used emissions.

As shown in Table 1-2, Croatia, Finland and Spain did not comply with their 2010 NECD

ceilings for NH3. Croatia, Finland and Spain exceeded their NH3 ceilings by 10% or more.

31 In addition, pollutants covered by NECD are precursors of secondary particles, which represent considerable part of total PM

concentrations in the ambient air.

34



Spain's NH3 non-compliance has not been included in this study because at the time this

study started, Spain's preliminary 2010 emission was less than 10% above the ceiling.

Table 1-2 National 2010 NH3 emissions in comparison to NECD 2010 ceilings, for non-compliant

Member States.

NH3

Country

2010 NH3 emission, kt

2010 emission ceiling, kt

Exceedance of 2010 NH3 ceiling, kt

Percent exceedance of

NH3 ceiling

Croatia 37.6 30 6.6 25.0%

Finland 37.5 31 6.5 21.1%

Spain 388.8 353 35.8 10.1%

Denmark 69.3 69 0.3 0.5%

Table 1-3 shows that only Germany was non-compliant for the 2010 NMVOC emission

ceiling level in 2010. The NMVOC ceiling level was not exceeded by 10% or more.

Table 1-3 National 2010 NMVOC emissions in comparison to NECD 2010 ceilings, for non-compliant

Member States.

NMVOC

Country

2010 NMVOC emission, kt

2010 emission ceiling, kt

Exceedance of 2010 NMVOC

ceiling, kt

Percent exceedance of NMVOC ceiling

Germany 1056.6 995 61.6 6.2%

Denmark 86.1 85 1.1 1.3%

There were no exceedances of the 2010 ceiling levels for SO2.

Causes of non-compliance

As part of the revision of the EU air quality policy it is essential to identify and clarify the

main reasons for the selected Member States’ inability to meet the defined emission limits

in order to consider appropriate solutions of the issues. In this context, it is also

necessary to consider the role of methodology for the development of emission

inventories and emission projections.

Gothenburg Protocol 2012 Amendments

The 2012 amendments to the UNECE CLRTAP Protocol to Abate Acidification,

Eutrophication and Ground-level Ozone32 (Gothenburg Protocol, GP) provide for new

2020 emission reduction commitments for the four NECD pollutants, among other

changes (addition of emission reduction commitments for PM2.5). These new CLRTAP

commitments will be considered in the revision of the NECD. The new Gothenburg NOX

commitments for the six Member States to be assessed for NOX non-compliance are

shown in Table 1-4 and for NH3 in Table 1-5. The GP base year for reductions is 2005.

Reduction commitments for 2020 and beyond are given as a percentage of the 2005

emission level. The tables show the equivalent ceiling level in 2020 and the change from

the 2010 ceiling for each country.

32 CLRTAP (2012). Report of the Executive Body on its thirtieth session, Addendum, Decisions adopted

35



Table 1-4 Gothenburg 2012 amendment NOX emission reduction commitments for 2020 and beyond.

Blanks indicate values not reported. Sources: NECD.SUBM12 33, CLRTAP.SUBM13

NOX Reported 2005 NOX emission, kt

NOX reduction commitment

for 2020

Equivalent 2020 NOX target, kt

Country fuel sold fuel used fuel sold fuel used

Austria* 237.5 169.0 37% 149.6 106.5

Belgium* 291.8 41% 183.8 172.2

France 1409.5 50% 704.8

Germany 1575.4 39% 961.0

Ireland* 127.4 120.9 49% 65.0 61.7

Luxembourg* 61.8 18.9** 43% 35.2 10.8

* based on fuel-used emissions.

** CLRTAP.SUBM13.

Regarding NH3, Croatia’s 1% reduction commitment in 2020 from the 2005 reference

year is equivalent to a 2020 target level which is 10 kt (33%) higher than its 2010 ceiling

(30 kt). Finland’s 20% reduction commitment for 2020 is equivalent to a 0.8 kt (2.5%)

reduction compared to the 2010 ceiling level (31 kt).

Table 1-5 Gothenburg 2012 amendment NH3 emission reduction commitments for 2020 and beyond,

with comparison to 2010 ceiling, for Member States non-compliant in 2010 by 10% or more.

Source: NEC.SUBM12, CLRTAP.SUBM13

NH3

Country

Reported 2005 NH3 emission,

kt

Reduction commitment

from 2005

Equivalent 2020 NH3 target, kt

Croatia 40.4 1% 40.0

Finland 37.8 20% 30.2

1.2 Objectives and tasks

The role of this study is to improve the understanding of the main reasons that some EU

Member States did not meet their national air pollution reduction targets (ceilings) defined

in NECD as well as provide new information for the upcoming EU air quality review,

which is not included in existing reports34.

The specific tasks of the project include:

Independent assessment of the key reasons for non-compliance with the NECD 2010

emission ceilings for the Member States that have exceeded the defined ceilings in

year 2010 and/or 2011 (Task 1)

Assessment of the key reasons for non-compliance with the NECD 2010 emission

ceilings identified by the Member States themselves for the Member States that have

exceeded the defined ceilings in year 2010 and/or 2011 (Task 2)

Assessment of when the 2010 ceilings are expected to be met (Task 3)

33 EEA On-line CDR 34 such as EEA, 2012. Evaluation of progress under the EU National Emission Ceiling Directive. Technical report No 14/2012;

and EEA, 2013. NEC Directive status report 2012. Technical report No 6/2013.

36



Assessment of the possible need for additional measures at the national level beyond

existing national or EU legislation for Member States to achieve the new Gothenburg

commitments for 2020. (Task 4)

Development of policy recommendations for the review and revision of NECD (Task

5)

The assignment focuses on those EU Member States (including Croatia as of July 2013),

which have exceeded the existing 2010 NECD ceilings for one or more pollutants by 10%

or more, as of October 2012. This study focuses on the six Member States (Austria,

Belgium, France, Germany, Ireland and Luxembourg) which exceeded their 2010 NOX

emission ceilings by 10% or more, and Finland and Croatia for exceeding their 2010 NH3

emission ceilings by 10% or more. None of the Member States exceeded their SO2 or

NMVOC emissions ceilings by 10% or more. The project thus focuses only on NOX and

NH3.

1.3 Methodology

1.3.1 Task 1 – Independent assessment of reason for non-compliance

An independent analysis of reasons for non-compliance with the NECD 2010 emission

ceilings was carried for each of the eight Member States through the following main

activities:

Review of the national legal framework related to the implementation of the NECD;

Assessment of the policies and measures implemented by the Member States to

reduce emissions of a pollutant. This was done by reviewing the National

Programmes developed in the context of NECD, and communication of the Member

States with the EU and Secretariat of CLRTAP;

Analysis of the emission inventories, main emission sources and statistical and

activity data;

Review of the emission projections reported by the Member States in different years,

as well as the assumptions and methodologies used in the development of the

projections.

The individual assessments are synthesized to identify common denominators shared by

several Member States pertaining to their non-compliance with NOX or NH3.

1.3.2 Task 2 – Member States' perception of the reasons for non-compliance

The Member States' perspective on the reasons for non-compliance with the 2010 NECD

ceilings was based on telephone interviews with Member State official representatives

and experts, and documents provided by or referred to by them. Questions specific to

each Member State were prepared and sent to the representatives in advance of the

telephone interviews. Some Member States also provided written replies to the questions.

The results of the interviews and analysis of documents has been summarised and

compared with the assessment of Task 1. Particular attention has been paid to the issues

of road transport emissions based on fuel sold versus fuel used, the associated tank-

tourism issue, and the impact of non-delivery of Euro standards in real world driving

conditions.

37



1.3.3 Task 3 – Expected compliance with the NECD 2010 ceilings

During preparation of this report (November 2012 – June 2013), IIASA has developed

several new GAINS model scenarios for the review of the EC Thematic Strategy on Air

Pollution (TSAP). The assessment was therefore based on the comparison of available

national emission projection(s) with the results of the most recent GAINS model current

legislation (CLE) scenario TSAP_Mar13_CLE.

As a first step in the assessment of expected time of compliance, the results of GAINS

model calculations for 2000, 2005 and 2010 were compared to actual reported emission

data for these years, to check the differences and to develop corrective measures

enabling comparison.

The comparison of GAINS model and national projections was complicated both by

differences in methodology and by incomplete or missing national projections, as

presented in Table 1-6 and Table 1-7 below.

Table 1-6 Differences in methodology – nitrogen oxides.

Country Fuel

sold

Fuel

used

Road

transport

emission

model

Emissions from

agriculture

included

National projections

available

2015 2020 2025 2030

Austria X X National35 X X X - X

Belgium - X COPERT - X X - -

France X - COPERT - X X - -

Germany X - National36 X X X - -

Ireland X X COPERT - X X - X

Luxembourg X X COPERT X - - - -

GAINS X - COPERT - X X X X

Table 1-7 Availability of national projections – ammonia.

Country National projection available

2015 2020 2025 2030

Croatia X X - -

Finland X X - X

It can be seen that major differences lie in:

Different assumptions for the assessment of emissions of nitrogen oxides from road

transport (fuel used/fuel sold); the GAINS model uses fuel sold approach only,

Different methodology for the assessment of emissions of nitrogen oxides from road

transport (different models, different sets of emission factors); the GAINS model uses

emissions factors based on the COPERT 4 model,

Different scope of emission inventories/projections (inclusion or non-inclusion of

emissions of nitrogen oxides from NFR sub-sectors 4D1 and 4D2 – emissions from 35 GLOBEMI model for road transport, GEORG model for non-road machinery 36 TREMOD model with emission factors taken from /HBEFA/ARTEMIS

38



fertilizers and handling of agricultural products); emissions of these sub-sectors are

not included in the GAINS model,

Different projection years provided, and no national projections beyond 2010 in the

case of Luxembourg,

Different break-down of emissions among NFR sectors in national projections and

GAINS model projections,

Different assumptions for activity projections between national projections and GAINS

model projections.

The scope of national emission inventories/projections varies. The inclusion or non-

inclusion of emissions of nitrogen oxides from agriculture (NFR sub-sectors 4D1 and

4D2) represents a major issue. In the case of Germany, this item represents around 8 %

of the national total and representing more than a third of the exceedance for the 2010

ceiling, while in the case of France it is not included in national totals but rather reported

as a memo item (7B).

1.3.4 Task 4 – Impact on future reduction commitments for 2020

The aim of the Task 4 is to investigate if the compliance with the new Gothenburg

Protocol reduction commitment for year 2020 will require any additional national or EU

policy measures, in particular for three non-compliant countries: Austria, Luxembourg and

Finland. The analysis is based on available national and GAINS scenarios and

projections for years 2015, 2020, 2025 and 2030. Where compliance with the GP 2020

reduction targets is in doubt from projections based on existing legislation ("with existing

measures" or "with current legislation" scenarios), the potential of "additional measures"

or "maximum technically feasible measures" scenarios is investigated.

1.3.5 Task 5 – Make policy recommendations in the context of the revision of the

NECD

Task 5 is to synthesise and present observations from the results of the prior tasks, and

to make policy recommendations to be taken into consideration in the process of the

review of NECD. The observations and recommendations are to focus on

emission inventory methodology, including frequency of reporting

emission projection methodology

national programmes for emission reduction

interaction (antagonism/synergy) with other Directives:

o Ambient air quality

o Climate change policy instruments (e.g. ETS)

o Energy policy instruments

o Agricultural policy instruments

1.3.6 Special issues

The following special concerns and risks have been identified by the EC and the project

team.

39



Difficulty of comparison

There are some complications in making comparisons among national emission

inventories due to the different scope of emission sectors included and different

methodologies applied, mainly for calculation of emissions from mobile sources. The

same problems have been found in the case of comparisons between national

projections and GAINS model projections (due to different source categories used,

changing methodologies and data completeness over time). Careful attention is given to

these types of issues when making comparisons or evaluating trends.

Fuel sold versus fuel used

The NEC Directive and the CLRTAP Gothenburg Protocol allow parties to choose to base

emissions (for mobile sources) on either fuel sold or fuel used, for the purpose of

checking compliance with ceilings. Four of the Member States in the study (AT, BE, IE

and LU) have chosen to base compliance checking on fuels used. This is related

primarily to tank tourism – the purchase of fuel by transit vehicles, which is then used in

neighbouring countries. Tank tourism is caused by fuel price differences, primarily due to

tax differences.

The project team has been careful to distinguish emissions based on fuel used or fuel

sold when making analyses and assessments. National and international analyses of

tank tourism, and relevant fuel price and tax information, have been reviewed to assess

the significance of tank tourism and the extent to which it may be a reason for non-

compliance.

Euro standards

The Euro 3, 4 and 5 standards have not delivered the expected NOX reductions, because

real world driving NOX emissions are much higher than the test-cycle emission limits in

the Euro Directives. Member States point to the failure of the Euro standards as a main

reason for difficulty in reducing national NOX emissions.

Euro 6/IV will be a necessary element for future NOX reductions, since the timing and

success of Euro 6/VI standards to deliver expected NOX reductions is critical for

achievement of 2020 commitments and beyond. The Euro VI emission standards for

heavy duty vehicles came into force in January 2013. The Euro 6 emission standards for

passenger cars and light duty vehicles comes into force in September 2014. Additional

requirements will be phased in from 2016 to 2017 and requirements for on-road

emissions verification are planned to come into force in 2017, so it may take several

years to achieve the full effect of Euro 6. The experience with the failure of the previous

Euro generations has created uncertainty among some Member States regarding

willingness to commit to reductions dependent on the outcome of Euro 6 emissions under

real world driving conditions.

Evolving inventory methodology

Inventory completeness, the addition of new source categories, changes in emission

factors and inventory methodologies, and possibly mistakes in inventories, may be part of

the reasons for non-compliance.

1.4 Structure of this report

This report is organised in two groups of chapters: First, chapters 1 to 4 present the

overall assessment and second, chapters 5 to 12 present more detailed individual

assessments for each of the eight Member States in the study.

40



Chapter 2 presents a synthesis of the reasons for non-compliance compiled from the

independent and Member State assessments. Common issues contributing to non-

compliance are identified and discussed.

Chapter 3 present the analysis of estimated times that the non-compliant Member States

in this study will achieve compliance with the NECD 2010 ceilings, and also with the 2020

emission reduction commitments in the 2012 amendments to the Gothenburg Protocol.

Chapter 4 contains observations drawn from the study and policy recommendations for

consideration in the review and revision of the NECD.

Chapters 5 to 12 present the study's analyses of the eight individual Member States in

the study. Each chapter contains a summary of independent assessment of reasons for

non-compliance, a summary of the Member State's assessment of reasons, and

estimates of the time that the Member State will comply with the NECD 2010 ceilings and

the 2020 emission reduction commitments in the 2012 amendments to the Gothenburg

Protocol.

References are listed in Chapter 13, and also in footnotes throughout the text.

41



2 Analysis of Common Denominators for Non-compliance

2.1 Summary of reasons for non-compliance

Reasons for non-compliance with the NECD ceilings in 2010 have been identified in two

ways: 1) an independent assessment and 2) by asking the Member States. For the six

Member States where NOX emissions in 2010 were more than 10% above the NECD

ceilings, Table 2-1 provides a long-list of the main reasons for non-compliance compiled

from the two approaches. Similarly, Table 2-2 summarizes the main reasons for non-

compliance with the NH3 ceilings, for the two countries where NH3 emission in 2010 were

more than 10% above the NECD ceilings. Discussion of the common reasons is given in

following sections and the specific Member State situations are presented in the country

chapters 5 to 12.

These tables indicate with letter "I" if a reason was identified in the independent

assessment, and by letter "M" if the reason was identified by the Member State. "I+M" is

shown where the reason was identified by both. These three combinations are also

highlighted by colour shading.

The lists of reasons in Table 2-1 and Table 2-2 are presented in groups according to:

reasons related to the available knowledge, data and methodology at the time the

ceilings were set;

reasons associated with the national programmes of emission reduction measures or

national projection required by the NECD;

national or international developments from 2001 to 2010;

mobile source emissions;

issues related to emission inventory and projection methodologies; and

policy interactions identified in the study.

Table 2-1 Summary matrix of reasons for non-compliance with NOx ceilings for Austria (AT),

Belgium (BE), France (FR), Germany (DE), Ireland (IE) and Luxembourg (LU).

Reason for non-compliance with 2010 NOx ceiling AT BE FR DE IE LU

Emission inventories and projections at the time of NECD

negotiation 1998-2000

1) 1990 activity levels were underestimated M I I+M I

2) NOx inventory omitted significant source categories M I

3) Population growth rate underestimated I+M

4) Economic growth rate underestimated I M

5) Primary energy growth rate underestimated I+M I+M

6) Road transport mileage growth underestimated I+M M I+M I+M

7) Projections showed compliance by 2010 with existing

legislation and measures

I+M

42



Reason for non-compliance with 2010 NOx ceiling AT BE FR DE IE LU

National programmes of emission reduction measures

8) National programme of measures inadequate or delayed I I

9) National programme lacked reduction estimates for

measures

I

10) National measures cannot compensate for projection

errors or failure of Euro vehicle emission standards

M M


11) National projections overestimated emissions I

12) National projections underestimated emissions I I I I I

13) National projections showed compliance until too late M

Activity developments

14) Activity and energy consumption growth very high I I I I+M

15) Major new stationary source was not in original

projections

I+M

16) Increase in biofuel combustion with higher NOX emission M M M

Mobile source emissions

17) Vehicle NOX emissions did not decline as expected due

to real-world driving emissions higher than Euro limit

values

I+M I+M I+M I+M I+M I+M

18) Dieselification of PC and LDV fleet due to fuel price

and/or vehicle tax favouring diesel vehicles, with higher

NOx emission

I I I+M I I I+M

19) Higher than expected growth of passenger car fleet I I M I I

20) High growth in road freight transport activity and/or share I I I I I

21) High transit road transport, which is outside national

control

M

22) High growth of non-resident commuter traffic M

23) Delayed and weak EU emission standards for non-road

mobile machinery

M

24) Relatively low tax on diesel fuel encourages “tank

tourism”

I+M I+M I

Emission inventory methodology

25) Improved inventory methodology has resulted in an

increase in total assessed emissions

I M M

26) Non-road mobile source categories added to inventory I+M M I

27) Agricultural emissions (4.D) added to inventory M I

28) Default small combustion emission factors don't reflect

new technology

M

Policy interactions

1) Reducing CO2 via combustion units < 50 MW increases

NOX

M M

2) Decentralization of electricity generation increases NOX M

3) Reducing CO2 through incentives for diesel vehicles

and/or diesel fuel increases NOX

I M I I I

4) Renewable energy policy favours biofuels, but NOx

emission is higher

M I+M M

Table key: Letters and colour shading indicate reasons identified by: I - Independent

assessment, M – Member State, or I+M for both.

43



Table 2-2 Summary matrix of reasons for non-compliance with NH3 ceilings in 2010, for Croatia (HR)

and Finland (FI).

Reason for non-compliance with 2010 NH3 ceiling HR FI

Emission inventory at the time of NECD negotiation 1998-2000

1) Incorrect or poor quality of agricultural statistics for year 1990 I+M I+M

2) National emission factors significantly underestimate NH3 emissions

for 1990 I+M

3) Minor NH3 source categories were not estimated (transport, energy,

waste, solvent use) I+M

Projections at the time of NECD negotiation 1998-2000

4) 2010 activity levels underestimated (N-excretion rate, passenger

transport volume growth) I+M

5) 2010 emission reductions overestimated for existing measures (incl.

Nitrate Directive) I+M

National programmes of reduction measures

6) Absent, delayed or inadequate measures I I

7) Overestimation of emission reduction from measures I+M


8) Reported projections not updated when new methodology adopted I

Emission inventory methodology

9) Revised emission factors I+M I+M

10) Minor new source categories added – transport, waste, energy, solvent

use I+M

11) Improved agricultural activity data I+M I+M

EU policy conflicts

12) Vehicle emission control (catalysts) leads to increased NH3 emissions M

Table key: Letters and colour shading indicate reasons identification by: I - Independent

assessment, M – Member State, or I+M for both.

The common issues regarding NOX revealed by Table 2-1 are discussed in section 2.2

below. The remaining reasons given in Table 2-1 and Table 2-2 are mostly specific to the

individual Member States. The country-specific issues are briefly summarised in section

2.3 for NOX and in section 2.5 for NH3. The overall situation in each Member State is

summarized the eight country chapters 5 to 12. The sections on reasons for non-

compliance are followed by general issues related to emission inventory methodology

and reporting, national programmes of measures, and emission projections. Differences

between the independent assessment and reasons identified by the Member States are

also discussed.

2.2 Common issues for NOX non-compliance

Vehicle NOX emissions (primarily diesel) under real-world driving conditions are

significantly higher than expected from the test cycle emissions specified by the Euro

exhaust emission standards. Vehicle NOX emission factors have been increased to

reflect the real-world driving NOX emission levels, resulting in higher reported NOX

emissions compared to estimations and projections used at the time the NECD

ceilings were set. Estimated additional NOX emissions in 2010 due to revised vehicle

44



emission factors since the 2010 ceilings were set range from 16% of the national total

for Germany to 26% for France and 27% for Ireland37. These correspond to 75% of

Germany's 2010 exceedance, 106% for France and 192% for Ireland.

Climate policy, tax incentives and policies and consumer choice have led to large

increases in the number of diesel passenger cars and light duty vehicles during the

last decade, called dieselification of the vehicle fleet. As a result, the diesel share of

vehicle fuel consumption in 2010 was much higher than assumed in 1999 – 80% for

France, 83% for Luxembourg and 85% for Belgium. Since Euro 2, NOX emission

limits for diesel cars have declined more slowly than for petrol-fuelled cars38. The

Euro 3, 4 and 5 emission standards which went into effect in 2000, 2005 and 2009

allow three times more NOX to be emitted from new diesel vehicles than

corresponding new petrol-fuelled vehicles. These differences are much larger under

real-world driving conditions. The combination of dieselification and higher specific

NOX emissions for diesel vehicles resulted in significantly higher total NOx emissions

than expected (in the range of 22 to 32 percent of the national totals for France,

Germany and Ireland).

Although the COPERT 4 model introduced in 2007 gave significantly higher NOX

emissions for road traffic than expected at the time the ceilings were set, Member

States were slow to take compensating measures. On the other hand, NECD does

not require further revision of national programmes of measures after 2006.

Emission inventory improvements have added new NOX emission source sectors

after the ceilings were set, which have increased the distance to reach the fixed

ceilings. An example of a new, previously not accounted source, is NOx emissions

from agricultural soils reported by Germany, Austria and Luxembourg, adding 9% to

the national total for Germany39. Some non-road mobile machinery sources were also

omitted by some Member States at the time the ceilings were set.

Climate and renewable energy policies have led to increased consumption of

biomass, which typically has higher NOX emissions in small combustion installations

than natural gas or oil40.

Total road transport fuel consumption between 1990 and 2010 increased more than

projected in 1999 for Austria, Ireland and Luxembourg, but was lower than the 1999

projection for Belgium, France and Germany, making this a mixed issue for NOX

emissions.

Underestimated base year emissions at the time ceilings were set, due to poor

activity data quality and/or lack of reliable emission factors, have also contributed in

some Member States, in particular in Belgium and Germany. These require a greater

reduction to meet the fixed ceilings than originally foreseen.

Additional discussion of some of these common reasons is provided below.

37 Ntziachristos and Papageorgiou, 2011. Road transport emission projections in the context of the EU NEC Directive ceiling

commitments. Impacts of model versions. ETC/ACC Technical Paper 2010/20.

http://acm.eionet.europa.eu/reports/docs/ETCACC_TP_2010_20_Copert2vsCopert4.pdf 38 Euro 1 NOX standards (1992) were fuel neutral. Euro 2 (1996) allows 40% more NOX from new diesel cars than for petrol. 39 Germany reported agricultural soil NOX emissions (NFR sector 4.D) of 110 kt in 2011 (9% of national total NOX); Austria’s was

0.7% of the national total and Luxembourg’s was 1.7% of the national total. 40 Tier 1 default NOX emission factors for biomass combustion in small residential heating installations are 57% higher than for

natural gas or oil. EMEP/EEA Guidebook (2013), section 1.A.4 Small combustion.

http://www.eea.europa.eu/publications/emep-eea-guidebook-2013/part-b-sectoral-guidance-chapters/1-energy/1-a-

combustion/1-a-4-small-combustion

http://acm.eionet.europa.eu/reports/docs/ETCACC_TP_2010_20_Copert2vsCopert4.pdf



45



2.2.1 Real-world vehicle emissions exceed Euro emission limit values

The failure of the Euro vehicle emission standards for NOx to deliver the expected

emission reductions is a reason cited by all six Member States, and also by the

independent assessment for the six countries. The failure is most prominent for light duty

diesel vehicle (PC & LDV). Petrol vehicles are closer to the standards.

New vehicle models must meet the Euro emission standards to obtain EU type approval.

Emission testing is carried out on a dynamometer that runs a vehicle through a standard

test cycle while exhaust emissions are measured. On-road emission measurements of in-

service diesel vehicles have shown that "real-world" NOx emissions can be considerably

higher than the Euro standards. Exhaust emission factors used for inventory calculations

that were originally based on the Euro emission limit values have had to be revised to

reflect the higher real-world emissions. As a consequence, national NOx emissions from

road transport have increased each time the vehicle emission factors are revised. The

higher real-world emission rates were not foreseen at the time the Gothenburg Protocol

and NECD 2010 ceilings were set (1998-2000) and compound the effect of higher than

expected overall growth in road transport and shift from petrol to diesel vehicles.

The impact of these changes since the ceilings were set has been investigated by the

EEA ETC/ACC topic centre (Ntziachristos and Papageorgiou, 2011). This study

compared national NOx emissions for 2010 calculated by the 1999 RAINS model using

the original exhaust emission factors and projected 2010 transport activity levels with

NOx emissions based on revised emission factors and actual 2010 transport activity and

vehicle fleet composition. Four countries were studied: Germany, France, Netherlands

and Ireland. Table 2-3 shows the estimated NOx emissions attributable to the differences

in road transport activity and exhaust emission factors, from the 1999 RAINS projections

to actual 2010 activity and emission factors (represented by COPERT 4 ver 8.0). The

emission differences are also shown relative to the distance to ceiling in 2010.

Table 2-3 Change in 2010 NOx emissions (fuel sold) from 1999 RAINS projections to actual 2010 road

transport activity and revised exhaust emission factors (COPERT 4 ver 8.0), in comparison

to distance from ceiling in 2010. Adapted from Ntziachristos and Papageorgiou, 2011.

2010 NOx

exceedance

(fuel sold)

NOx difference due actual

2010 vehicle activity level

and fleet composition

NOx difference due to

revised exhaust emission

factors (COPERT 4 v8.0)

Country kt kt % of 2010

exceedance

kt % of 2010

exceedance

France 265.3 -44 -17% +282 +106%

Germany 280.9 +113 +40% +210 +75%

Ireland 13.9 +5 +36% +20 +144%

Netherlands 14.1 0 0% +56 +396%

The impact of activity and fleet differences and emission factor differences varied widely

among the four countries, but the impact of revised emission factors was substantial in all

four cases. For France, Ireland and The Netherlands, the emission factor changes were

larger than the distance to the NOx ceiling in 2010 based on fuel sold, but 75% of the

distance for Germany.

A study of the impact of real-driving Euro 2-5 emission factors for light duty diesel

vehicles was done by Borken-Kleefeld and Ntziachristos, 2012. The issue is also

discussed in EEA, 2012. However, it is not clear from the available studies if the impact of

46



revision of vehicle emission factors was significantly worse for the six Member States

studied in this report compared to other Member States or the EU-27 average.

2.2.2 Road transport growth and dieselification

Unforeseen growth in road transport is indicated as a reason for non-compliance for

Austria, Germany, Ireland and Luxembourg, and unforeseen dieselification of the road

transport fleet is indicated for all six Member States. Both of these factors would

contribute to higher than expected NOx emissions. It is useful to compare the assumed

and actual changes in fuel consumption, with respect to changes experienced by other

Member States and the EU as a whole.

Table 2-4 compares the assumed 1990 to 2010 changes in road transport fuel

consumption (fuel sold) used in 1999 RAINS projections, to the actual changes according

to Eurostat in 2013, for the EU-15 Member States.

Table 2-4 Comparison of 1990 to 2010 changes in road transport fuel consumption (fuel sold) and

diesel share as assumed in 1999 when NECD ceilings were agreed, versus actual changes

in 2010, for the EU-15 Member States. Source: IIASA, 1999; and Eurostat, 2013.

Change in road transport fuel sold, 1990 to 2010 Diesel share in 2010

Assumed change, 1999, % Actual change, Eurostat, % Assumed Actual

Country Petrol Diesel Total Petrol Diesel Total share, % share, %

Austria 14% 54% 32% -31% 200% 62% 52% 74%

Belgium -2% 68% 37% -54% 97% 32% 68% 85%

Denmark -1% -1% -1% -4% 66% 31% 59% 63%

Finland 17% 14% 16% -23% 44% 7% 52% 60%

France 15% 40% 27% -58% 79% 8% 54% 80%

Germany -7% 72% 23% -40% 45% -8% 53% 59%

Greece 116% 102% 109% 55% 53% 54% 45% 42%

Ireland 123% 141% 131% 64% 241% 138% 47% 60%

Italy 38% 12% 23% -25% 42% 11% 52% 69%

Luxembourg 25% 17% 21% -15% 305% 146% 41% 83%

Netherlands 19% 46% 33% 17% 65% 42% 57% 61%

Portugal 125% 63% 88% 1% 160% 87% 52% 75%

Spain 76% 48% 60% -33% 127% 56% 52% 81%

Sweden 35% 2% 21% -23% 96% 13% 34% 52%

UK -7% 79% 24% -39% 79% 0% 52% 59%

EU-15 16% 48% 31% -34% 76% 14% 52% 68%

At the time the ceilings were set, road transport energy growth for the EU-15 was

projected to increase by 31% from 1990 to 2010. The actual growth was only 14% - less

than half the expected growth. There was quite a difference in the growth rates for petrol

and diesel. Gasoline consumption declined by more than one third while diesel fuel

consumption increased 76%. In comparison, EU-15 petrol consumption had been

expected to increase by 16% and Diesel by 48% at the time ceilings were set. The diesel

share of EU-15 road transport fuel consumption in 2010 had been expected to be 52%

47



but was actually 68%. The fuel consumption and diesel share situation in the individual

Member States varied widely from these average levels, as is discussed below.

Austria: Road transport fuel consumption (fuel sold) increased nearly twice as fast

from 1990 to 2010 as foreseen in 1999. Petrol declined 31% instead of

increasing, but diesel increased 200%, nearly four times more than

assumed. The resulting 74% diesel share in 2010 was sixth highest in the

EU-15. The departure of the diesel share in 2010 from the 1999

assumption was the second largest in the EU-15 (74% versus 52%).

Belgium: Road transport fuel consumption (fuel sold) increased slightly less from

1990 to 2010 than assumed in 1999. Diesel consumption increased more

than assumed (97% versus 68%), but not significantly more than other

Member States. The diesel share of 85% in 2010 was the highest among

the EU-15.

France: The diesel share of road transport fuel consumption (fuel sold) increased to

80% in 2010, compared to 54% assumed in 1999 RAINS projections – the

third largest dieselification among the EU-15. The 58% decline in petrol

consumption from 1990 to 2010 was the largest decline among the EU-15.

As a result, total road transport fuel consumption increased less than

assumed in 1999 (8% versus 27%), which more than offset the NOx

increase due to dieselification (see Table 2-3).

Germany: Germany was the only EU-15 State to have an overall decline (-8%) in

road transport fuel consumption (fuel sold) from 1990 to 2010. A 23%

increase had been assumed in 1999. The diesel share in 2010 was 59%,

which is less than the EU-15 average of 68%, but higher than the 53%

share foreseen in 1999. However, diesel consumption by heavy duty

vehicles increased much more than expected (Ntziachristos and

Papageorgiou, 2011). As shown in Table 2-3, the combined increase of

heavy duty vehicle activity and change in fleet composition compared to

the 1999 assumptions accounts for 113 kt of additional NOx in 2010 (40%

of the 2010 exceedance).

Ireland: Ireland had the second highest growth in overall road transport fuel

consumption (fuel sold) among the EU-15. Ireland's 60% diesel share in

2010 was not unusual among the EU-15, but it was much higher than

assumed in 1999. The ETC/ACC study estimated the increase in vehicle

activity and change in fleet composition compared to the 1999 RAINS

assumptions added 5 kt to the 2010 NOx emission (36% of the 2010

exceedance based on fuel sold)

Luxembourg: Growth of road transport fuel consumption (fuel sold) from 1990 to 2010

was 146% compared to the assumed 21%. Diesel fuel consumption

increased three-fold while petrol consumption fell. The diesel share in 2010

was more than twice the share assumed in 1999, with a diesel share

second only to Belgium.

2.2.3 Fuel sold versus fuel used



48



on fuels used when comparing with the ceilings41. Seven Member States (AT, BE, IE, LT,

LU, NL, UK)42 may thus use emissions based on fuel used as the basis for compliance

checking. Four of the six NOX countries in this study (Austria, Belgium, Ireland,

Luxemburg) base compliance with the NECD ceilings on fuel used emissions (for road

transport), while France and Germany are based on fuel sold. Austria, Ireland and

Luxembourg report both fuel sold and fuel used emissions, but Belgium only reports fuel

used emissions. Germany and France report only fuel sold emissions. The fuel basis is

not significant for NH3 emissions.

The difference between fuel sold and fuel used emission varies over time, and can be

quite significant especially for the smaller Member States. Since Belgium only reports

emissions based on fuel used43, the difference between fuel sold and fuel used is not

known.

Table 2-5 compares the fuel sold and fuel used NOX emissions for the three countries

reporting both. The difference between fuel sold and fuel used NOX emissions, labelled

export, represents the emissions estimated to occur outside the Member State from

consumption of fuel bought in the Member State. The difference between fuel sold and

fuel used – known as tank tourism – arises when fuel prices are significantly lower than in

neighbouring countries, and especially in countries with high transit traffic.

Table 2-5 Comparison of fuel sold and fuel used NOX emissions*.

Reported NOX Emission

Member State basis 1990

kt

2005

kt

2010

kt

2011

kt

Austria fuel sold 195.5 237.5 193.2 182.7

fuel used 181.6 169.0 147.5 144.2

export 13.9 68.5 45.6 38.5

% of fuel sold 7% 29% 24% 21%

Ireland fuel sold 122.6 127.4 78.9 70.5

fuel used 128.2 120.9 75.4 67.6

export -5.6 6.5 3.5 2.9

% of fuel sold -5% 5% 4% 4%

Luxembourg fuel sold 41.5** 64.2** 46.1 48.2

fuel used 23.8* 21.4* 17.9 18.0

export 17.7** 42.8** 28.2 30.2

% of fuel sold 43% 67% 61% 63%

* Data from NECD.SUBM12 except NECD.SUBM11 for Luxembourg fuel used 1990 and 2005. ** LU Fuel sold and export

emissions for 1990 and 2005 estimated based on the difference between fuel sold and fuel used emissions reported in

CLRTAP.SUBM13.

The export amounts have varied over time, primarily in response to changing national fuel

tax levels. Since 2005 is the base year for the new Gothenburg Protocol emission

reduction commitments, the fuel sold/fuel used difference in 2005 will be significant for

the future choice of basis for compliance checking in these three countries.

EEA calculates the sum of EU-27 (EU-28) NOX emissions based on the national totals

used for compliance checking, which is a mix of emissions reported by Member States

41 The fuel sold or fuel used basis refers to transport emissions. 42 EEA, 2013. NEC Directive status report 2012. 43 EEA, 2013. NEC Directive status report 2012, Table 2.6.

49



based on fuel used (6 Member States) and fuel sold (21 Member States)44. The export

emissions between Member States reporting on the basis of fuel used and neighbouring

Member States reporting on the basis of fuel sold may therefore not be accounted for in

the EU totals. The export NOX amounts in Table 2-5 total 77 kt in 2010, nearly 1% of the

EU-27 NOX total. This illustrates the potential size of unaccounted NOX emissions at the

EU level due to mixed fuel sold/fuel used reporting.

The fuel sold/fuel used issue must be taken into account when working with energy

statistics, which are normally compiled on the basis of fuel sold within a Member State.

The fuel basis must also be considered when evaluating GAINS model emission

projections, because the GAINS model is based on fuel sold. Since fuel export can vary

significantly over time due to changing fuel price differences, there can be considerable

uncertainty in calculating future fuel used emissions based on GAINS model fuel sold

projections.

2.3 Country-specific issues for NOX non-compliance

In addition to the main reasons listed above the study identifies a number of country-

specific reasons, as listed below Member State by Member State.

Specific observations for Austria



among the EU-15.

The share of diesel cars in Austria increased from 14% in 1990 to 55% in 2010. The


increased from 18% in 1990 to 60% in 2010.




exceeded.

Specific observations for Belgium

Improved inventory methodology has increased the reported NOX emissions for

199045 by 18% compared to the level reported at the time the ceilings were set,

making the reduction required to meet the fixed ceiling for 2010 larger than was

originally foreseen.

The Walloon and Brussels regions continued using the COPERT III (2002) road

transport emission model until updating to COPERT 4 in 201146. This delayed

introduction of "real world" vehicle emission factors, and underestimated NOX

emissions when developing the National Programme.

Climate policy in the Flemish region promoted the development of decentralized

electricity generation using small cogeneration plants (Combined Heat and Power,

CHP) with a capacity of less than 50 MW that have high specific NOX emissions.

44 EEA, 2013. NEC Directive status report 2012. Technical report No 6/2013, page 23.

http://www.eea.europa.eu/publications/nec-directive-status-report-2012/at_download/file 45 In the 1999 Gothenburg Protocol, the year 1990 is used as the reference year (or "base year") for defining interim

environmental objectives relative to the situation in that year (Article 5), but NECD does not use a base year. 46 Belgium, Informative Inventory Reports under CLRTAP, 2009, 2010, 2011.

http://www.eea.europa.eu/publications/nec-directive-status-report-2012/at_download/file

50



Specific observations for France

France calculates an increase of 152 kt in 2010 NOX emissions due to the 2007

methodology change from COPERT III to COPERT 4 for road transport emissions

(57% of 2010 exceedance). An ETC/ACC study47 estimates an overall increase of

282 kt NOX in 2010 due to revised exhaust emission factors from COPERT II in use

at the time the ceilings were set as compared to COPERT 4 v8.0 (106% of 2010

exceedance)48.

The diesel share of road transport increased more than was assumed in 1999, but

was offset by total road transport fuel consumption increasing less than expected.

Inventory improvements added emissions from non-road mobile machinery in

industry and agriculture not reported at the time the ceilings were set, and lead to a

reported increase of the 2010 NOX emissions by 39 kt (15% of the 2010

exceedance).

Specific observations for Germany

An increase of 210 kt NOX in 2010 road transport emissions due to revision of

emission factors from COPERT II to COPERT 4 v8.047 (75% of 2010 exceedance)48.


in the 1999 RAINS model projections. In spite of an overall 8% decline in road

transport fuel consumption from 1990 to 2010, the increase of heavy duty vehicle

activity and change in fleet composition compared to the 1999 assumptions accounts

for 113 kt of additional NOX in 201047 (40% of the 2010 exceedance).

Increased biomass combustion in energy and manufacturing industries and small

combustion resulted in an additional 106 kt NOX emission in 2010 (38% of the 2010

exceedance).

Changes in inventory methodology lead to the inclusion of NOX emissions from

agriculture (not included at the time the ceilings were set), increasing 2010 emissions


National projections consistently overestimated the expected NOX reductions from

planned and additional measures, masking the need to put additional measures in

place.

Germany notes that during 2010, the inclusion of revised vehicle emission factors in

HBEFA 3.149 and other inventory changes increased reported emission projections for

2010 by about 200 kt/year (71% of 2010 exceedance). Germany also notes that the EU-

level emission standards for non-road mobile machinery were delayed and inadequate,

which delayed and weakened potential NOX reductions in this sector.

Specific observations for Ireland

Reported road transport NOX emissions for 2010 increased by20 kt due to revision of

vehicle emission factors from COPERT II to COPERT 4 v8.047 (192% of 2010

exceedance).

47 Ntziachristos and Papageorgiou, 2011. Table 8, difference between "COPERT 4+New Activity" (v8.0) and "COPERT II+New

Activity" columns. 48 Note: the estimated additional emissions in 2010 can sum to more than 100% relative to the 2010 exceedance, indicating that

the 2010 NOX emissions could have been below the ceiling if all these issues had not arisen. 49 Vehicle emission model HBEFA (www.hebfa.net) was updated to version 3.1 in January 2010, in particular with emission

factors for Euro II-V heavy duty vehicles to reflect real-world driving emissions. COPERT 4 was updated to v8.0 in October

2010 to match the changes in HBEFA 3.1 (Gkatzoflias and Ntziachistos, 2010).

http://www.hebfa.net/

51



Ireland had the second highest growth (138%) in overall road transport fuel

consumption among the EU-15, which was not foreseen at the time when the ceilings

were set.

Economic growth has been much higher than assumed in 1999, particularly in the

construction industry.

Inventory improvements added emission sources that were not included at the time

the ceilings were set, such as from agriculture and national fishing, adding nearly 2 kt

to the 2010 NOX emission (18% of the 2010 exceedance).

Ireland has reported that implementation of emission reduction technologies has

been more successful than projected in 1999, but that this effect has been insufficient

to compensate for the factors leading to higher emissions.

Specific observations for Luxembourg


assumed when the ceilings were set.


additional 30% of the population. Non-resident commuter traffic was not fully

considered at the time the ceilings were set.

Primary energy consumption in 2010 was 51% greater than assumed when the

ceilings were set.

Luxembourg had the greatest increase in road transport fuel consumption, 373% on

fuel used (146% on fuel sold), from 1990 to 2010 among the EU-15.

Diesel fuel consumption increased 287% (fuel sold50) from 1990 to 2010 - the largest

percentage increase among the EU-15 - while petrol consumption only declined by

15%. The diesel share of the vehicle fleet was as high as 83% in 2010, twice the

share estimated when the ceilings were set.


electricity previously imported, with NOX emissions corresponding to about 8% of the

2010 exceedance.




Luxembourg adds that biofuel combustion has doubled during the last decade, with

higher NOX emissions, although not a big impact on overall emissions. Luxembourg

further considers that the default emission factors for small combustion units may

overestimate the real NOX emissions, because they may not reflect the relatively large

proportion of high-efficiency, low-emission units used in Luxembourg due to extensive

new residential and commercial construction.

2.4 Common issues for NH3 non-compliance

Although only two Member States are reviewed regarding NH3, the following three

common issues for NH3 non-compliance have been identified and are discussed below:



52



Poor quality of activity data for the agricultural sector, including limited information on

livestock populations, manure management systems, etc., largely underestimating

the total activity of the sector and thus underestimating the 1990 NH3 emissions.

Inadequate (too low) emission factors used at the time when the NECD ceilings were

set.

Late and inadequate national measures to reduce agricultural NH3 emissions.

2.4.1 Poor quality of activity data for the agricultural sector

Ammonia emissions estimations for both Finland and Croatia have experienced

significant changes due to the changes (improvements) in quality of the activity data used

for calculation of emissions from agricultural sector. Complex and precise calculations of

emission from agricultural sector (Tier 2 and 3) require detailed information of such

parameters like population of livestock in various age and/or weight groups, manure

management practices, etc.

In the case of Croatia, statistical data was updated to include livestock number split by

categories, which resulted in changes in the total NH3 emissions in agricultural sector.

Finland recognised the need for improvement of agricultural statistics in 2006 and since

then has introduces a model which aims to improve the unsatisfactory activity data quality

and reduce the uncertainty in emission estimations.

2.4.2 Outdated emission factors used at the time of the ceiling negotiations

At the time of emission ceilings negotiation for the Gothenburg Protocol, Croatia relied on

emission factors based on national expert judgement for estimating ammonia emissions

from animal husbandry. These emission factors were several times smaller than the

emission factors recommended by the EMEP/EEA Guidebook. Croatia changed to the

EMEP/EEA Guidebook methodology for NH3 in 2003.

The latest ammonia emission estimations in Finland are performed based on the

specially developed model which takes into consideration most current knowledge on

manure management and ammonia volatilization in Finland. The emissions factors

estimation based on this new approach differ both from the emission factors integrated

into RAINS model and emission factors previously used by Finland, resulting in significant

changes in the recalculated time-series.

2.4.3 Absence or lack of measures other than those implemented at EU level

In relation to measures aimed at reduction of ammonia emissions both Finland and

Croatia have largely relied on existing legislation and EU regulations and policies (mainly

the Nitrate Directive and the Industrial Emissions Directive), with little or no specific

measures developed to address agricultural NH3 emissions.

2.5 Country-specific issues for NH3

Specific observations for Croatia

National NH3 emission factors in use at the time the GP ceilings were set

underestimated NH3 emissions significantly. The fixed 30 kt ceiling requires a 7 kt

(19%) emission reduction from the reported 1990 emission at the time the ceilings

were set, but the improved methodology applied meant that the reduction effort

suddenly tripled to a much more challenging reduction of 21 kt. Although Croatia has

53



reduced annual NH3 emissions by 13 kt, which is nearly twice the reduction foreseen

when the ceiling was set, it is still 7 kt above the ceiling.


emission reductions were adopted as late as 2008. However, the national legislation

established a national NH3 ceiling of 45 kt rather than the GP 30 kt ceiling, and

proposed reduction measures were insufficient to meet the 30 kt ceiling51 set out in

the GP and the NECD.

Croatia also underlines that the political importance given to the agricultural sector means

that only "win-win", cost-effective policy options targeting the period until 2020 for farmers

are politically acceptable.

Specific observations for Finland


data and additional source sectors) increased the 2010 NH3 emissions by 6 kt (89%

of the 2010 exceedance) compared to the methodology at the time the ceiling was

set.

No targeted national measures were adopted and planned for reduction of ammonia

emissions. The National Programmes only referred to other EU policies, such as the

Nitrate Directive52, and overestimated the effectiveness of those policies.










2.6 Common issues on emission inventory methodology and reporting

A number of inventory methodology issues were identified during the study. These do not

necessarily contribute to non-compliance with the NECD ceilings, but can be significant

for the efficient management and monitoring of emission inventories the timely and

reliable provision of information to decision makers responsible for planning and

implementation of policies and measures.

Changes in the emission estimation methodologies, emission factors used and the

number of sectors included in the inventory appears as a critical issue for non-compliance

in most of the countries.

As discussed in section 2.2.1, changes in emission factors for road transport –

corresponding to the increase in NOx emissions for real-world driving conditions

compared to the type-approval emission limit values - was explicitly stated as one of the

51 In August 2013, Croatia adopted a new regulation (OG 108/13) establishing the GP/NECD 30 kt NH3 ceiling and repealing the

national 45 NH3 kt ceiling. The National Programme is to be revised as necessary. 52 Council Directive 91/676/EEC of 12 December 1991 concerning the protection of waters against pollution caused by nitrates

from agricultural sources, http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31991L0676:EN:NOT


54



main reasons for non-compliance with the 2010 NECD emission ceilings by the six

countries concerned. Quantitative estimates of the impact of revised vehicle emission

factors due to Euro failure are available for Austria, Belgium, France, Germany and

Ireland, but the scope of the estimates varies. The available analyses suggest that for

Belgium, France and Ireland, the impact of Euro failure alone could account for all or

most of the NOX exceedance in 2010. No estimates of the impact in Luxembourg are

available.

The situation is similar for the two countries exceeding their ammonia ceilings.

Development of improved methodologies for emission inventories based on the emission

factors presented in the EMEP/EEA Guidebook instead of national emission factors in

Croatia resulted in an increase of emission estimates of up to 40%. This makes the

attainment of the Gothenburg Protocol 2010 emission ceilings very challenging. In

addition, improvements of the quality of the activity data and overall methodology applied

in the estimation of the emissions from the agricultural sector, resulted in the significant

increase of the ammonia emission for the whole time-series. The level of knowledge and

data for calculating NH3 emissions has increased significantly since the time the ceilings

were set, but these improvements have resulted in reporting of significantly higher

emissions.

For all of the countries, it appears that there have been major shortcomings in the

emission projections used for negotiation of the 2010 emission ceilings. This suggests

that inadequate or incorrect activity data and/or inventory methodologies were used at

that time. Only several years after the conclusion of negotiations, when developing the

first National Programmes, some Member States found that even implementation of

additional measures would not be enough to bring the NOx emission level below the

ceilings. Some of the Member States found it very challenging to introduce necessary

additional emission reduction measures, which would be both socially and economically

proportionate.

The issue of emission estimation and assessment based on “fuel used” and “fuel sold”

discussed in 2.2.3 is also a complicating factor for emission inventories and projections

which makes comparisons between the Member States more difficult.

2.7 Common issues on national programmes of reduction measures

The issue of quality and consistency of the National Programmes is an equally important

factor when looking at the reasons for non-compliance. Despite the Commission

guidelines for the development of National Programmes, very few of the eight countries

analysed in this study have followed these guidelines completely. For instance, the lack

of estimates of the emission reductions expected for specific measures hinders analysis

of the impact that individual measures have had in the past. Additionally, the terms

“implemented measures”, “planned measures” and “additional measures” seem to be

interpreted differently by some Member States.

This suggests that the guidance is followed rather loosely by some Member States. The

guidance would be strengthened if key elements of the information to be included when

reporting on national programmes were identified as requirements in a revised NECD.

2.8 Common issues on emission projections

Different interpretations of the guidance on emissions projections were apparent in some

Member States. The interpretation of "business as usual", "with measures" and "with

55



additional measures" varied considerably and the scenarios included in projections also

varied. Although most of the Member States in this study submit IIRs to document their

emission inventories and projections, the documentation of projection methodologies

varies from detailed to almost none. In the context of a revised NECD, additional

requirements and guidance on best practices for preparation, reporting and

documentation of emission projections would be beneficial.

2.9 Differences between the independent assessment and Member State

perceptions

A visual comparison of Table 2-1 and Table 2-2 clearly shows more "green" I+M entries

in the NH3 table than in the NOX table, indicating greater coherence between independent

assessment and the Member State's perceptions for ammonia than for NOX. For NOX

there seems to be somewhat more reasons identified only by the independent

assessment or by the Member State interviews.

An explanation for the additional discrepancies between the independent assessment

and the Member States assessments for NOX can be that the "blame" for some of the

reasons for NOX exceedance is placed on the EU rather than being the Member States'

own responsibility. NH3 emissions do not have that aspect of "external responsibility".

Member States in several instances presented arguments for exceedances that might not

be apparent from the routinely reported inventories and projections alone, such as:

National measures cannot compensate for projection errors or failure of Euro vehicle

standards.

High transit road transport, which is outside national control, and

Few Member States have the capacity to identify the range of national cost-effective

measures to address the gap left by the underperformance of the Euro standards.

There were differences between the independent assessment and Member States' views

regarding the responsiveness of national programmes to compensate for the "failure" of

the Euro emission standards. In a number of cases the independent assessment did not

identify justification for the amount of time elapsed between reporting or projections of

much higher emissions than originally expected and the responses to the developing

patterns evidenced by revisions of policies and measures. The NECD (Article 6) requires

preparation and reporting of a national programme of emission reduction measures in

2002 with updating and revision in 2006. Technically, there was not a requirement for

further revision of the national programmes after 2006, although the binding commitment

to meet the ceilings remains.

Several Member States argue that the full effect of Euro failure was not known until 2010

(COPERT 4 v8.0), too late to respond to it. However, substantial increases in road

transport NOX emissions were seen with the introduction of COPERT III in 2002, the

transition from COPERT III to COPERT 4 (v3.0) in November 2006, and to COPERT 4

v4.0 in October 2007 (revised emission factors for Euro 4 diesel PC). While additional

increases came as late as 2010 (COPERT 4 v8.0), there were earlier warnings of the

increasing departure of road transport NOX emissions from the levels projected at the

time the ceilings were set. In addition to the time required to prepare revised emission

factors, the lag between introduction of new COPERT versions and implementation of the

new versions by the Member States further delays the recognition of increased

emissions.

56



Differences between the independent assessment and the Member States' views of

reasons for NOX exceedances can also be due to the way in the exceedances are

perceived. A given reason can be attributed to uncertainty or incorrect information in the

original projections, unreliable emission factors, trends that were not anticipated, or

developments beyond the control of the Member State. These viewpoints varied among

the Member States interviewed, which may have led to some similar issues for NOX being

compiled under different headings in the long list in Table 2-1, making the correlation to

the independent assessment less clear.

An additional aspect can be that the national contact persons interviewed for Finland and

Croatia were both technical specialists in NH3 emissions, responsible for preparation and

documentation of the NH3 inventories. Thus there was fairly close agreement between

the interviews and the independent assessment of submitted materials. The primary

contact points for the NOX interviews were largely with policy specialists with broader

responsibilities, with technical experts serving a supporting role. Technical specialist and

policy specialists may describe the reasons for differences in different ways, which could

have contributed to some differences in the compilation of reasons between the

independent assessment and the Member States' views for NOX.

57



3 Estimated Time for Compliance with 2010 and 2020 Commitments

3.1 Estimated time for compliance with the NECD 2010 ceilings

National and GAINS model projections have been analysed to estimate when the eight

Member States are likely to reach their NECD 2010 ceilings. The analysis is based on the

most recent national with-measures (WM) projections submitted under NECD or

CLRTAP53 and the GAINS model current legislation scenario TSAP_Mar13_CLE54. A

summary of the analysis is shown in Table 3-1. The projections assume implementation

of existing EU and national legislation, including the Euro 6/VI vehicle emission

standards, leading to relatively steep emission reductions of NOx emissions by 2020-

2025. The first projections indicating compliance for each Member State are highlighted

in green in the table.

The GAINS model calculates national NOX projections based on fuel sold. In order to

harmonise the analysis and compare the results with countries where the ceiling is based

on fuels used, the GAINS model values corresponding to fuel used emissions have been

estimated, using the ratio of fuel used to fuel sold emissions from road transport55.

Belgium indicates that the GAINS model has been adjusted for Belgium to represent as

closely as possible fuel used emissions, so no conversion is made.

Agricultural NOX emissions from soils and plant production (NFR sector 4.D) are reported

by Austria, Germany and Luxembourg, but not by other Member States and are not

included in the GAINS model projections. To make all the national emissions and

projections totals comparable with the GAINS model, these agricultural emissions are

deducted from Austria's, Germany's and Luxembourg's values in in Table 3-1. The

agricultural emissions are substantial for Germany (104 kt in 2010), moderate for Austria

(6 kt in 2010) and negligible for Luxembourg.

Table 3-1 also shows the GAINS model projection values for 2005 and 2010 in

comparison to the reported NECD emissions for these years, indicating differences in the

GAINS modelling approach compared to reported emissions. The GAINS model

underestimates the 2005 and 2010 emissions - by 1 to 3 percent for France and

Germany to as much as 24 to 25 percent for Croatia and Luxembourg, which suggests

that the GAINS model may underestimate emissions in the projection years for these

Member States. The GAINS model, on the other hand, overestimates Ireland emissions

for 2005 and 2010 by 11 and 20 percent respectively, suggesting the projection years

may also be overestimated. For Belgium, the GAINS model overestimates the 2005 and

2010 fuel used emissions by 3% and 6%.Not surprisingly, the GAINS model projects

earlier compliance than national projections for Austria, Germany and Finland, and later

53 National projection submissions used: Austria – NECD.SUBM11; Belgium – NECD.SUBM12; France – NECD.SUBM12;

Germany – CLRTAP.SUBM13; Ireland – CLRTAP.SUBM13; Croatia – CLRTAP.SUBM13; Finland – NECD.SUBM12 and

CLRTAP August 2013. Luxembourg has not submitted any projections. 54 Amann et al. (2013). Policy Scenarios for the Revision of the Thematic Strategy on Air Pollution. TSAP Report #10, Version

1.2, March 2013, IIASA.

http://www.iiasa.ac.at/web/home/research/researchPrograms/MitigationofAirPollutionandGreenhousegases/TSAP_10-v1-

2.pdf 55 It should be noted that for a country where the difference between fuels sold and fuels used is very large, such as Luxemburg,

this methodology, may be subject to high uncertainties.



58



compliance for Ireland. For France, the GAINS model projections are very close to the

national projections.

Table 3-1 Estimated time for compliance with NECD 2010 ceilings based on the GAINS model CLE

scenario and available national with-measures projections (Nat.) for 2015 to 2030. The

GAINS model projections are compared to reported emissions (Rep.) for 2005 and 2010.

Emissions given in kt/year.

, Reported emissions for previous years, used for

reference, kt Projections, kt

2010 fuel 2005 2010 2015 2020 2025 2030

ceiling basis GAINS Rep. GAINS Rep. GAINS Nat. GAINS Nat. GAINS Nat. GAINS Nat.

NOX

AT 103 sold 229 237 174 192 140 159 99 129 76 65 121

used 163 168 133 147 108 124 82 108 64 56 105

BE 176 sold 300 234 215 174 147 135

used 292 221 200 170

FR 810 sold 1374 1410 1053 1075 847 848 619 620 496 438

DE 1051 sold 1413 1462 1219 1228 991 1076 751 902 615 549

IE 65 sold 142 127 95 79 95 67 86 56 65 47 49

used 135 121 91 75 91 64 82 54 62 45 47

LU 11 sold 48 64 40 46 25 19 12 10

used 14 21 11 18 7 6 4 4

NH3

HR 30 - 29 40 29 38 31 39 32 42 32 33

FI 31 - 34 38 33 38 31 35 31 36 31 31 36



Notes:

a. For AT, BE, IE and LU, values based on fuel used are the basis for compliance assessment. Calculations of

NOX emissions in the GAINS model are based on fuel sold. The GAINS values based on fuel used are

estimated here based on the fuel used/fuel sold ratio from national emissions or projections in the same

year (AT, IE).



c. BE does not report emissions based on fuel sold, so a fuel used/fuel sold ratio cannot be estimated. The

difference between the GAINS value (fuel sold) and national value (fuel used) for 2020 is 4 kt (2%). Belgium

informs that the GAINS model has been adjusted in such a way that it would represent as much as possible

the emissions as estimated in the Belgian inventory based on fuel used, and the actual difference between

fuel used and fuel sold is expected to be larger. The GAINS model values for BE are assumed to represent

fuel used emissions.

d. For AT, DE and LU, NFR (Nomenclature for Reporting) categories 4D1 (emissions from soils) and 4D2

(handling of agricultural products) are deducted from national values for comparability between Member

States and with the GAINS model projections.

e. For LU, fuel sold emissions are about 2½ times larger than fuel used emissions in 2010, making fuel export



59



Conclusions for NECD 2010 ceilings

One Member State (Ireland) may achieve compliance before 2015 with current

legislation.

Ireland is projected to comply with the NOX ceiling shortly after 2015 by national

projections. The level projected for 2015 has already been reached in 2011, but

Ireland indicates that national NOX emissions in 2012 are likely to increase. The

GAINS model, which overestimates emissions in 2005 (11%) and 2010 (20%),

projects compliance shortly after 2020 with current legislation.

Five Member States (Austria, Belgium, France, Germany and Luxembourg) are likely to

achieve compliance with their NOX ceilings between 2015 and 2020 with current

legislation.

Germany is likely to achieve compliance about 2015.

Belgium and France are likely to achieve compliance between 2015 and 2020.

Austria is likely to achieve compliance before 2020 according to the GAINS model,

but national projections submitted in 2011 do not show compliance through 2030.

Luxembourg has not submitted national projections, and fuel export NOX emissions

are significantly larger than national fuel used emissions and vary over time. For this

purpose, the GAINS model projections (which are based on fuels sold) has been

adapted on the basis of on the fuel used/fuels sold ratio in the case of emissions from

road transport sector as reported in2010, by which the analysis shows compliance

shortly after 2010. This result is however more uncertain than the others.

Two Member States (Croatia, Finland) are not likely to reach compliance with their NECD

2010 NH3 ceilings without significant additional measures beyond current legislation.


GAINS model current legislation projections.





unrealistic.

Additional measures

To assess the technical emission reduction potential for the three countries where

projections indicate compliance with the 2010 ceilings after 2020 (Croatia, Finland), the

GAINS model current legislation projections (the CLE scenario56) were compared with

maximum technically feasible reduction (MTFR57) projections for 2025 in Table 3-2. Cost

figures are not available for 2020 but 2025 values are here used as a proxy for emission

reduction potential and costs for 2020.

56 GAINS current legislation scenario: TSAP_Mar13_CLE 57 GAINS TSAP_Mar13_MTFR_2025 scenario; cost level 2005, 4 % interest rate

60



Table 3-2 Estimated annual compliance costs – 2025, based on GAINS model current legislation (CLE)

and maximum technically feasible reduction (MTFR) scenarios

Emission projections (kt) Cost 2025 (MEUR/year)

NEC2010

ceiling

CLE

2020

CLE

2025

MTFR

2025

Difference 2025

CLE – MTFR

CLE

2025

MTFR

2025

Difference 2025

MTFR - CLE

HR NH3 30 32 32 19 13 n.a. 46.9 46.9

FI NH3 31 31 31 24 7 15.8 64.6 48.8

Source: GAINS online. FU: fuel used basis; FS: fuel sold basis.

Table 3-2 shows that there is considerable scope for Croatia and Finland to reach the

2010 ceilings by 2020 at the latest, by adopting additional measures going beyond


3.2 Estimated time for compliance with the 2020 reduction commitments in the

amended Gothenburg Protocol

Table 3-3 gives an overview of when the GP 2020 reduction commitments are likely to be

reached, based on the same national with-measures projections and the GAINS model

current legislation scenario projections presented in Table 3-1 and subject to the same

uncertainty. The GP 2020 reduction commitments are expressed as percent reductions

relative to the reported emission for reference year 2005. Equivalent target values in

kilotons are shown in the table.

Emission values in the table exclude certain agricultural emissions for consistency with

the GAINS model (see Table 3-1 notes). GAINS model fuel used values are estimated

from the GAINS model fuel sold values using the fuel used/fuel sold ratio of the national

values.

National projections are compared to the target values based on reported emissions in

2005. To partially compensate for under- or overestimation by the GAINS model seen in

Table 3-3, the GAINS model projections are compared to target emissions based on the

GAINS model values for 2005 (the GP base year). The earliest projections showing

compliance with their respective targets are highlighted in green in Table 3-3.

61



Table 3-3 Estimated time for compliance with the 2020 reduction commitments in the 2012

Gothenburg Protocol amendments, based on the GAINS model current legislation scenario

and national with-measures projections (Nat.) for 2015 to 2030. Emissions given in kt/year.


GP 2020 reduction

commitment Based on



2015 2020 2025 2030

% fuel


NOX

AT 37 sold 144 149 140 159 99 129 76 65 121

used 102 106 108 124 82 108 64 56 105

BE 41 sold 177 215 174 147 135

used 172 200 170

FR 50 sold 687 705 847 848 619 620 496 438

DE 39 sold 862 893 991 1076 751 902 615 549

IE 49 sold 72 65 95 67 86 56 65 47 49

used 69 62 91 64 82 54 62 45 47

LU 43 sold 27 36 25 19 12 10

used 9 12 7 6 4 4

NH3

HR 1 - 29 40 31 39 32 42 32 33

FI 20 - 27 30 31 35 31 36 31 31 36

Data sources and notes: See Table 3-1.

Conclusions for GP 2020 reduction commitments

Except for Austria, there is little difference between fuel sold and fuel used estimates of

time for compliance with the 2020 NOX reduction commitments.

Five Member States (Austria, Belgium, France, Ireland, Luxembourg) are likely to meet

their GP 2020 commitments based on current legislation.

Ireland is projected to comply shortly after 2015 by national projections and reported

emissions in 2011 have already reached the level projected for 2015, but Ireland

indicates that national NOX emissions in 2012 are likely to increase. The GAINS

model projects compliance between 2020 and 2025, with current legislation.

Luxembourg is projected to comply with its GP 2020 commitment before 2015

according to the GAINS model. Luxembourg questions the assumptions used for

these projections, especially regarding transit traffic through Luxembourg.

Austria, Belgium and France are likely to comply with their respective GP 2020

reduction commitments by 2020 at the latest with measures in accordance with

current legislation. The GAINS model current legislation projection based on fuel sold

suggests compliance closer to 2015 for Austria.

Germany would reach its reductions commitments between 2015 and 2020

according to the GAINS model current legislation projections. However, national

projections do not indicate compliance by 2020, suggesting additional measures may

be needed.

62



Two Member States (Croatia, Finland) are not likely to meet their GP 2020 commitments

for NH3 based without additional measures.






Finland does not appear to reach the target level through 2030 according to both the

national and the GAINS model current legislation projections.

Table 3-2 shows the range of additional reductions and mitigation costs per year in 2025

estimated by the GAINS model associated with technically feasible additional measures

for Croatia and Finland. These measures are largely also applicable for emission

reductions by 2020.

63



4 General Observations and Recommendations

This study of eight cases of non-compliance with the NECD ceilings in 2010 has identified

common denominators as well as country-specific reasons for the exceedances. These

include issues at EU, national and regional levels. This section summarizes key

observations and sets out a number of corresponding recommendations in the context of

a revised NECD.

4.1 Removing disincentives to improved inventory methodology

Fixed kiloton emission ceilings were set in the NECD based on a proposal from the

Commission and the agreed reduction targets in the 1999 Gothenburg Protocol.

Improved emission inventory methodologies, updated and improved emission factors and

the inclusion of new sources have in some cases led to increased reported emissions.

The changed methodology contributes to the non-compliance of several of the Member

States in this study. The NECD provides no mechanism to compensate for this, which

may constitute a disincentive for improving inventories, and could inhibit ambitions for

setting future reduction commitments.

The 2012 Gothenburg Protocol amendments introduce two provisions that can

compensate for increasing emissions due to improvements in methodology – relative

reduction targets and an "adjustment mechanism":

Relative reduction targets maintain a proportional reduction requirement regardless of

whether reported base year emissions increase (or decrease) due to methodology

improvements. Relative targets also cancel out most differences with regard to

emissions based on fuel sold or fuel used.

The GP adjustment mechanism allows parties to propose adjustments in exceptional

circumstances to their emission reduction commitments or to their inventories used

for compliance checking, for non-compliance caused by three types of exceptional

circumstances: 1) inclusion of new emission categories, 2) revised emission factors

due to improved knowledge, and 3) significant changes in methodology since the

commitments were set.

These two provisions will remove earlier barriers to inventory improvements and reporting

of the most scientifically correct emissions, while at the same time alleviating some of the

risks related to uncertainties for emission inventories and projections.

Recommendation 1: Future national commitments for emission reductions under a

revised NECD should be expressed as percentage reductions relative to emissions

in a reference year (as reported at the time of compliance checking). The criteria,

procedures and timetable for checking compliance with the percentage reductions

should be clearly defined.

Recommendation 2: A mechanism should be provided in a revised NECD to enable

Member States to apply for adjustments in exceptional circumstances only to their

emission inventories used for checking compliance, when non-compliance is the

result of certain types of methodology improvements. Guidance should be provided

64



and the process should be transparent. Alignment with the GP adjustment

mechanism should be considered.

4.2 Enhancing the transparency and comparability of emission inventories

The study has encountered issues with some emission inventories which hindered the

assessment of reasons for non-compliance.

A number of "new" source categories have been recognized that were not included in the

RAINS projections made at the time the NECD ceilings were set, including NOX

emissions in the agriculture sector (NFR sector 4.D). However, many Member States do

not estimate the new categories58. Some Member States also do not estimate a

significant number of the "old" categories. EEA59 has estimated the impact of "not

estimated" categories. For most Member States the underestimation is small, but for

others it is a significant percentage of the total emissions. There are default methods for

assessing all categories provided by the joint EMEP/EEA Guidebook. This motivates

strengthening the requirements for completeness of inventory reporting, and to limit

reporting of "not estimated" categories.



on fuels used when comparing with the ceilings60. Seven Member States (AT, BE, IE, LT,

LU, NL, UK)61 may thus use emissions based on fuel used as the basis for compliance

checking. The difference between fuel sold and fuel used emission varies over time, and

can be quite significant especially for the smaller Member States. Belgium only reports

emissions based on fuel used62, so the difference between fuel sold and fuel used is not

known. The possibility to report emissions on the basis of fuel used is inconsistent with

the reporting obligations for climate and energy, which are compiled on the basis of fuel

sold only. The fuel basis is also relevant for GAINS emission projections, because the

GAINS model is based only on fuel sold data. With a change to relative emission

reduction targets, the significance of fuel sold versus fuel used for emission reduction

measures is lessened, enabling reconsideration of permitting compliance checking based

on fuel used.

Basing compliance only on fuel sold emissions remains a problem for smaller Member

States where the transport sector is dominating. Fuel tax differences between

neighbouring States leads to tank tourism, leaving behind an added burden of emissions

based on fuel sold... An adjustment mechanism for inventories taking tank tourism into

account could be considered for exceptional cases as long as the environmental targets

are not compromised.

An Informative Inventory Report (IIR) is essential to document the methodology and

changes in national emission inventories. Most Member States submit an IIR under

CLRTAP, but the NECD does not require an IIR.

58 NECD (via the UNECE reporting guidelines) allows MS to report emissions as "NE" for those sectors where emissions are

known to occur but have not been estimated or reported. 59 EEA, 2013. ibid. 60 The fuel sold or fuel used basis refers to transport emissions. 61 EEA, 2013. NEC Directive status report 2012. 62 EEA, 2013. NEC Directive status report 2012, Table 2.6.

65



Member States report emissions of the four NECD pollutants under the NECD, the

UNECE CLRTAP, and (except for NH3) the UNFCCC and Kyoto protocol, and the

Monitoring Mechanism Regulation63 (MMR) (525/2013) for greenhouse gasses. There are

differences in reporting requirements, submission deadlines, and methodologies. This

motivates further harmonization of reporting requirements among emission instruments

and protocols.

Recommendation 3: A revised NECD should better clarify the methodology and reporting

requirements for emissions, including:

that all source categories have to be reported in accordance with the EMEP

guidelines, reporting templates and EMEP/EEA Guidebook,

that it is made mandatory for all Member States to report road transport emissions

based on fuel sold for all years,

that future reduction commitments and thus reporting of road transport emissions

data be based on fuels sold only, and

that it is made mandatory for all Member States to submit an IIR under the NECD.

Harmonization of methodologies should enable a single IIR document to serve both

the CLRTAP and NECD requirements.

NECD, CLRTAP, UNFCCC and MMR reporting templates include reporting of activity

levels (primarily fuel consumption) associated with emission amounts and projections, for

each source sector. Most Member States report activity data under CLRTAP64

corresponding to reported emissions, but less than half report activity data under

NECD65. Few report projected activity data. Activity data are valuable for interpretation

and monitoring progress of emissions reductions and would make Member State

emissions inventories more transparent. Projected activity data are valuable for

monitoring changes in assumptions for projections.

Activity data to be reported in NECD and CLRTAP templates include fuel consumption by

sector, but there is no breakdown by road transport fuel types (gasoline, diesel, LPG,

etc.). Activity data by fuel type would be very useful for road transport sub-sectors, for

monitoring of changing vehicle fleet composition. MMR templates do include road

transport fuel consumption by fuel type, so these additional activity data in NECD and

CLRTAP templates would contribute to harmonisation of reporting. Aggregate vehicle

mileage is also a useful activity indicator, since road transport emissions in Guidebook

Tier 2 or Tier 3 methodologies are mileage based. Vehicle mileage would permit

calculation of mileage-based indicative emission factors for road transport sub-sectors.

The COPERT 4 software implements the Guidebook's Tier 3 mileage-based emission

methodology for road transport. Two thirds of Member States use various versions of

COPERT 4 to estimate emissions from road transport, and the remaining third use a

variety of other approaches66. Some of the national approaches are based on the same

emission factors as COPERT 4. Some approaches have incorporated new knowledge

about real world vehicle emissions earlier than COPERT, while others are not as up to

date as COPERT. There are few comparisons of the national approaches to the

63 The Monitoring Mechanism Regulation (525/2013) Art. 7.1.b requires Member States to annually report CO, SO2, NOX and

VOC emissions that are consistent with data already reported under NECD and CLRTAP. 64 EEA (2013) EU emission inventory report 1990-2011 under the UNECE Convention on LRTAP. Table A3.1. 65 EEA (2013) NEC Directive status report 2012. Table A3.1 66 EEA (2013). NEC Directive status report 2012, Table 2.6

66



Guidebook approach implemented in COPERT, so the magnitude of differences is not

known. Further harmonization and synchronization of road transport emission

methodologies would improve comparability and compliance checking of emission

inventories.

For Member States where tank tourism is significant (AT, BE, IE, LU), there is an

inconsistency between the requirement to report road transport emissions based on fuel

sold and the Guidebook Tier 3 methodology for road transport (and COPERT software)

that is based on in-country mileage corresponding to fuel used. The Guidebook presently

suggests that the methodology is applicable where "the fuel sold in the region (statistical

consumption) equals the actual consumption of the vehicles operating in the region"67,

which is not true where tank tourism is large. Little guidance is given on reconciling fuel

sold versus fuel used fuel consumption. This is a concern for some Member States,

indicating a need for improved guidance on this topic.

Recommendation 4: NECD guidance should be strengthened to:

encourage Member States using the COPERT software to use the latest available

version in a given reporting year.

promote comparison and harmonisation of national methodologies for road transport

emission estimation.

improve guidance on best practice for calculating road transport emissions due to fuel

export (tank tourism), for Member States where this is significant.

require complete reporting of annual activity data for all inventory years and

projection activity data for all projection years.

include annual reporting of road transport activity data by fuel type (petrol, diesel,

etc.) and also aggregate vehicle mileage.

4.3 Improved national programmes and projections

National programmes of measures for emissions reduction have varied considerably in

content and level of detail. The NECD leaves it to Member States to decide how to

achieve the necessary emissions reductions to meet the ceilings. This study has

encountered national programmes of measures for emissions reduction that are

incomplete, e.g. by omitting estimates of emissions reductions for certain measures or

sectors. This has made it difficult to assess if measures have achieved the intended

reductions, or if the proposed measures were sufficient to meet the ceilings.

Specific requirements for reporting air quality plans are included in the Ambient Air

Quality Directive (2008/50/EC) and the recent Monitoring Mechanism Regulation (MMR)

(525/2013)68 specifies information to be reported on national policies and measures for

GHG emission reduction, every two years. The NECD does not specify what types of

information about policies and measures should be reported in national programmes,

other than quantified estimates of the effects on emissions.

67 EMEP/EEA Guidebook, 2013, section 1.A.3.b.i-iv, page 118 68 Regulation (EU) No 525/2013 of the European Parliament and of the Council of 21 May 2013 on a mechanism for monitoring

and reporting greenhouse gas emissions and for reporting other information at national and Union level relevant to climate

change and repealing Decision No 280/2004/EC. http://eur-

lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:165:0013:0040:EN:PDF

67



Recommendation 5: More detailed requirements on format and content of national

programmes should be considered for the updated NECD. National programmes

under NECD should be consistent with policies and measures on greenhouse gases,

as reported under the Monitoring Mechanism Regulation (525/2013). Hence updates

and reporting of NECD national programmes every two years should be considered.

Detailed implementation guidelines for the preparation of national programmes

should be prepared to assure that all Member States include the same level of

information, including estimates of the expected emission reduction for all measures.

Revisions to programmes should indicate the progress of existing measures in

comparison to the planned reduction.

This study has encountered national emission inventories and national projections that

are not fully comparable with each other, nor comparable with the GAINS model

projections, due to differences in emission categories and methodology. This makes it

difficult to assess progress toward meeting reduction commitments and to develop policy

on future emission reduction commitments. There are also several cases where national

emission projections have not been updated for several years after major methodology

changes, although there is a requirement under the NECD to annually update and report

projections (for 2010).

Most national emission projections provide only a single "with measures" (WM) scenario,

corresponding to existing legislation69. Few include a "with additional measures" (WAM)

projection that would indicate further reduction potential. Among the Member States in

this study, there are varying interpretations of the meaning of WM and WAM, and the

years for which projections are calculated varies. One Member State studied provides

projections only based on fuel used, which complicates the comparison to the GAINS

model projections or to other Member States' projections based on fuel sold. The

EMEP/EEA Guidebook (2013)70 and proposed revision of the EMEP reporting

guidelines71 align the definitions for reporting with those under MMR, and this

harmonisation should be reflected in a revised NECD.

Recommendation 6: NECD guidance on projections should be strengthened regarding

the definitions and numbers of scenarios, the frequency and years for projections,

fuel basis, assessment of uncertainty, and updating of projections when

methodologies change. The two-year frequency for reporting projections specified in

the MMR72 should be considered. Projections prepared for NECD should be

consistent with projections prepared for CLRTAP and MMR.

4.4 Improved policy coherence

Several Member States have mentioned during this study that implementation of other

EU environmental policies has led to increases in NOX emissions, which have contributed

to Member State non-compliance with the NOX ceilings, demonstrating shortcomings as

regards internal policy coordination in the Member States. For instance, EU climate policy

69 The Commission's draft GHG Projection Guidelines (Coenen et al, 2012) uses the clearer expression "with existing

measures" (WEM) rather than "with measures" (WM) to refer to an existing legislation scenario. This terminology is

adopted in the EMEP/EEA Guidebook (2013) chapter on projections. 70 EMEP/EEA air pollutant emission inventory guidebook 2013, http://www.eea.europa.eu//publications/emep-eea-guidebook-

2013 71 TFEIP (2013) Guidelines for Reporting Emission Data Under the Convention on Long-Range Transboundary Air Pollution

(draft v2). http://tfeip-secretariat.org/assets/Meetings/Documents/2013-TFEIP-Istanbul/UNECE-2014-RepGuidelines-draft-

v2-clean-commented.doc 72 MMR Article 14, Reporting on projections.





68



requires Member States to reduce GHG emissions and some Member States have

created incentives for diesel vehicles as part of their climate policies, which has led to

dieselification of vehicle fleets and increases in NOX emissions from transport. One non-

compliant Member State also noted that climate policy gave incentives to decentralized

electricity production using energy-efficient smaller combustion units (less than 50 MW)

for which EU emission limits did not exist, resulting in increasing NOX emissions.

Associated with climate policy, EU renewable energy policy promotes biomass. Several

Member States have reported increases in NOX emissions due to the shift to biomass,

especially from smaller combustion units with less strict emission limits.

One Member State noted that the EU Emission Trading System (ETS) places a financial

value on CO2 emissions, and a financial penalty for non-compliance. There is to date no

similar valuation or financial penalty for NECD non-compliance. This can cause Member

States to disproportionately prioritize GHG reduction measures, to the detriment of their

other pollutant reduction commitments.

Recommendation 7: Member States should improve policy coherence in the

implementation of interlinked environmental and climate and energy policies, e.g. by

comparing emissions and reduction measures for greenhouse gasses to emissions

and reduction measures of air pollutants. Further development of approaches to

establish equivalence factors or valuations for CO2 and non-GHG pollutants could be

helpful for policy comparisons and coherence. The EU should promote such efforts.

4.5 Unified access to emission information

A wealth of emission data is presently available online under the various protocols, and

has been compiled into various datasets73 that are accessible or downloadable online.

The value of these resources would be enhanced for environmental monitoring,

education and research if the various NECD, CLRTAP and MMR national emission

databases were further harmonised to facilitate access and merging of these data

sources. Harmonisation includes establishment of common structures and encoding of

data. Reported activity data under each legal instrument should be included. Inclusion of

historical submission data (values reported in previous years) in the databases would

also facilitate monitoring of progress and coherence of policies, and review of Member

States' requests for adjustments to reduction commitments or inventories.

Recommendation 8: Publically-accessible databases of reported national emission and

activity data under the various emission instruments and protocols should be further

harmonised (common data definitions and encoding) to facilitate access and

merging of these data sources.

73 For example NECD, CLRTAP and MMR emission datasets at EEA http://www.eea.europa.eu/data-and-maps/data and the

CLRTAP online emission database at EMEP CEIP http://www.ceip.at/webdab-emission-database, which also includes

activity and gridded data.

http://www.eea.europa.eu/data-and-maps/data

http://www.ceip.at/webdab-emission-database

69



5 Austria

5.1 Introduction

Status of Austria's NOx reduction commitments

Table 5-1 summarises the status in 2010 and 2011 of Austria's commitments for national

NOx emissions under the NECD and the 1999 CLRTAP Gothenburg Protocol, and for the

reduction commitment for 2020 under the 2012 amendments to the Gothenburg Protocol.

The table lists reported emissions in the GP base years 1990 and 2005, and the two most

recent years, 2010 and 2011. Distance to target is given in kt and as a percent of the

target value (ceiling). Austria's NECD and CLRTAP NOx emission totals are identical for

these years in present reporting.

Table 5-1 Overview of Austria's final 2010 and provisional 2011 NOx emission data submitted under

NECD and CLRTAP.

Austria, NOX Fuel sold basis Fuel used basis

emission

distance to target Emission

distance to target

Year (submission year) kt NOX kt NOX % kt NOX kt NOX %

NECD NOX 2010 ceiling 103 103

1990 (NECD.SUBM12) 195.5 92.5 89.8% 181.6 78.6 76.3%

2010 (NECD.SUBM12) 193.2 90.2 87.5% 147.5 44.5 43.2%

2011 (NECD.SUBM12) 182.7 79.7 77.4% 144.2 41.2 40.0%

CLRTAP NOX 2010 ceiling 107 107

1990 (CLRTAP.SUBM13) 195.5 88.5 82.7% 181.6 74.6 69.7%

2010 (CLRTAP.SUBM13) 193.2 86.2 80.5% 147.5 40.5 37.9%

2011 (CLRTAP.SUBM13) 182.7 75.7 70.8% 144.2 37.2 34.8%

CLRTAP NOx 2020 reduct. 37% 149.6 106.5

2005 (CLRTAP.SUBM13) 237.5 87.9 58.7% 169.0 62.5 58.7%

2010 (CLRTAP.SUBM13) 193.2 43.5 29.1% 147.5 41.1 38.6%

2011 (CLRTAP.SUBM13) 182.7 33.1 22.1% 144.2 37.8 35.5%

* Austria has not ratified the 1999 Gothenburg Protocol

Austria reports emissions both on the basis of fuel sold and fuel used, and bases

compliance with the 2010 ceilings on fuel used emissions. Austria's fuel used NOx

emission was 43% above the 103 kt NECD ceiling in 2010 and 40% above in 2011. NOX

emission declined by 34 kt (33% of the ceiling) from 1990 to 2010, and by 3 kt (3% of the

ceiling) from 2010 to 2011.

NOx emissions based on fuel sold have been much higher than based on fuel used,

reflecting high levels of "tank tourism" due to relatively low fuel prices in Austria compared

to neighbour countries. The difference between fuel sold and fuel used emissions was 46

kt in 2010 and 39 kt in 2011.

Austria agreed to a 5 kt lower NOx ceiling under the NEC Directive compared to the 1999

CLRTAP Gothenburg Protocol ceiling. Austria has not ratified the 1999 Gothenburg

Protocol, but has continued to report emissions to the CLRTAP.

70



Austria's NOX reduction commitment under the Gothenburg Protocol 2012 amendments

is for a 37% reduction between 2005 and 2020. This was based on respecting the

existing 2010 NOx ceiling in the NECD (103 kt) in 2020, based on the 2005 emission

reported at the time the commitments were set. The reported emission for 2005 has risen

slightly since then, resulting in a current 2020 NOx target of 150 kt fuel sold and 107 kt

fuel used (shown in grey in the table).

Fuel sold emissions have declined sharply from 2010 to 2011 compared to fuel used

emissions, making Austria closer to the 2020 target based on fuel sold than based on fuel

used. This suggests that tank tourism has declined rapidly, and may continue to do so in

future.

Summary of conclusions

The main reasons for Austria's non-compliance with the NECD 2010 NOx ceiling are:

NOX emissions from road transport are much higher than expected due to vehicle

NOX emissions (primarily diesel) under real-world driving conditions being much

higher than expected for Euro 1-5/I-V standards. Euro 1-2/I-III vehicles alone were

estimated to account for about 9 kt more NOX in 2010 than projected in 1999 (20% of

Austria's exceedance).



among the EU-15. The number of passenger vehicles increase 48% from 1990 to

2010, a relatively large increase.

Diesel fuel consumption increased 200% from 1990 to 2010, a rate of increase nearly

four times larger than assumed in 1999, while petrol consumption declined 31%. The

share of diesel cars in Austria increased from 14% in 1990 to 55% in 2010. The


increased from 18% in 1990 to 60% in 2010. The resulting dieselification – the

increase in diesel share – was the second highest among the EU-15. Diesel NOX

emission factors are higher than for petrol.




exceeded.

Increased consumption of biofuels due to climate and renewable energy policies has

led to higher NOX emissions.

The outlook for compliance with the NECD 2010 ceiling and the CLRTAP 2020 target is:

Austria is likely to achieve compliance with the NECD 2010 ceiling between 2015 and

2020 with measures in accordance with current legislation.

Austria is likely to comply with its respective CLRTAP 2020 reduction commitment by

2020 with measures in accordance with current legislation. The GAINS model current

legislation projection based on fuel sold suggests compliance closer to 2015.

The reasons for non-compliance and estimation of time for compliance are discussed in

the following sections.

71



5.2 Independent assessment

Legislation, National Programmes and policies and measures

In the context of NECD, Austria agreed to limit its annual nitrogen oxides (NOx)

emissions to 103 kt by 2010. The NECD ceiling is 4 kt lower than the 107 kt ceiling

defined in the context of CLRTAP. However, Austria has not ratified the Gothenburg

Protocol. The NEC Directive (2001/81/EC) has been transposed into the Austrian national

legislation by the Emissionshöchstmengengesetz-Luft (EG-L), BGBl I Nr. 34/2003 (Law

on Emission Values), which explicitly sets the emission ceiling for Austria in accordance

with the targets defined under the NECD.

Projections made at the time the NECD ceilings were set (RAINS model REF scenario74)

showed that Austria would achieve its 2010 NOx emission ceiling with measures in

current EU and national legislation at that time.

The first National Programme (December 2002) developed under NECD presented only

emission reduction measures already adopted prior to the transposition of NECD, with

measures generally referring to the relevant EU Directives. Projections presented in the

Programme suggested that under “Business-as-usual” scenario (“with existing measures”

or "under current legislation"), Austria would exceed its NOx ceiling by 47 kt in 2010. A

study to identify potential additional measures was commissioned, which concluded that

even with implementation of these additional measures, Austria would exceed the NOx

ceiling by 38 to 40 kt in 2010.

The revised programme of 2006 provided an updated list of measures, most of which

were already implemented and were mainly of regulatory nature. It was estimated that

implementation of these measures would reduce NOx emission by 25 kt by 2010, which

would still lead to an exceedance of some 34 kt in 2010.

In 2010, Austria developed a second updated National Programme. This programme

presented emission reduction measures already in place in much more detail as well as

included a number of additional specific measures and policies aimed to reduce NOx

emissions. Implementation of the additional measures was expected to reduce NOx

emissions in 2010 by 11 kt (of which 7 kt in transport sector), and by an additional 1 kt in

2015. However, it is also noted that these additional measures would still not be sufficient

to achieve the 2010 NECD ceiling for NOx before 2015. The programme also stated that

changes in the emission factors for diesel cars resulting from poor real world driving

performance of Euro standards lead to the increase in NOx emissions for year 2010 of 9

kt. However, this change explains only 20% of 2010 NOx emission exceedance.

Methodology, reported emissions and emission projections

Compliance with both the NECD and the GP emission ceilings for Austria is assessed

based on “fuel used”, taking into consideration a significant impact of “fuel tourism”. This

is in line with special provisions for Austria and several other countries75 to avoid unfair

impacts from so-called “tank tourism”. However, the informative inventory report (IIR) also

provides information on emissions based on “fuel sold”. Assessment of road transport

74 IIASA Seventh Interim Report, 1999, available from: http://www.iiasa.ac.at/~rains/reports/ir7.pdf 75 For the following countries compliance with NECD ceilings is assessed based on “fuel used”: Austria, Belgium, Ireland and

Luxembourg.

http://www.iiasa.ac.at/~rains/reports/ir7.pdf

72



emission in Austria is done using GLOBEMI and ARTEMIS76 models. For off-road

transport emission modelling the GEORG emission model is utilised.

Figure 5-1 Major NOX contributing sectors (left scale, kt) and national total NOX emissions in Austria

(right scale, kt), based on fuel used, CLRTAP 2012

The time series of national and major sector NOX emissions from 1990 to 2010 is shown

in Figure 5-1. Overall emissions were reduced by 19% from 1990 to 2010 based on fuels

used, and 1% based on fuels sold. In 2010, the road transport emissions based on fuels

used accounted for approximately 45% per cent of the total emissions. The greatest

emission reduction from 1990 to 2010 of 15 kt (33%) was achieved in passenger car

transport followed by heavy duty vehicles with the reduction of 5 kt (or 14%). These

reductions were achieved despite the fact that the number of registered passenger cars

in Austria has constantly increased during the past 2 decades, with the proportion of

diesel cars increasing from 13.7% in 1990 to 55% in 201077 (see Figure 5-2), and the

dominance of road vehicles in passenger and freight transportation modal splits remained

unchanged.

Activity data used for RAINS model projection development78 suggested that under the

baseline scenario in 2010, 3272 thousand TOE of diesel fuel will be used by transport

sector in Austria; according to Eurostat in 2010, 5396 thousand TOE of diesel fuel were

consumed in transport sector, 64% more than foreseen. Activity data projections used in

76 Austria’s Informative Inventory Report (IIR) 2012, available from:

http://www.umweltbundesamt.at/fileadmin/site/publikationen/REP0380.pdf 77 In 2010 EU-27 average was 31.6% according to the Eurostat data (data for 17 countries was available). 78 IIASA 1998 6th Interim Report, available from: http://gains.iiasa.ac.at/reports/pre-2002/6th interim a2.pdf

0

20

40

60

80

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120

140

160

180

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6

8

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x e

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s, k

t

YearStationary combustion in manufacturing industries and construction: Other (1 A 2 f i)

Residential: Stationary plants (1 A 4 b i)

Public Electricity and Heat Production (1 A 1 a)

Total

Transport: fuel used (1 A 3)

http://www.umweltbundesamt.at/fileadmin/site/publikationen/REP0380.pdf

73



RAINS modelling79 suggested that total energy consumed in transport sector (petrol and

diesel only) will increase by 32%. The latest Eurostat data shows this increase amounted

to 62% (petrol and diesel only).This indicates that while the sector has not achieved as

significant NOx reductions as in other countries (e.g. in Germany emissions from

passenger cars decreased by 74% and in Ireland by 61%), technological improvements

have to some extent compensated for the significant increase in the number of cars.

A comparison of fuel prices with neighbouring countries shows that fuel prices were

historically lower in Austria due to lower fuel taxes. This has led to significant levels of

“fuel tourism”, meaning that road transport NOx emission calculated based on fuels sold

include emissions from exported fuel. However, this effect is neutralised with regard to

Summary NECD and GP compliance by the possibility to use fuel used as a basis for

compliance checking.

Figure 5-2 Number of diesel and petrol passenger cars registered annually in Austria (left scale) and

the total number of vehicles (right scale) (EUROSTAT data)

The reasons for Austria's non-compliance with the NECD 2010 NOx ceiling are

summarised in Table 5-2. The contribution to the exceedance is given where it can be

estimated.

79 IIASA 1998 6th Interim Report, available from: http://gains.iiasa.ac.at/reports/pre-2002/6th interim a2.pdf

0

500

1000

1500

2000

2500

3000

3500

4000

4500

5000

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2000

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3000

Tota

l: 1

00

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icle

s

By

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gin

e t

ype

: 1

00

0s

of

veh

icle

s

Year

Total Diesel cars Petrol cars

74



Table 5-2 Main reasons for Austria's non-compliance with the NECD 2010 NOx ceiling, based on the

independent assessment. Quantified contribution to exceedance is given in kt and percent

where possible.

Contribution to

44.5 kt

Reason kt NOx %

Euro standard performance for diesel cars: Overestimation of 2010

reductions from road transport due to poor real world driving performance of

Euro standards (Euro I-III and Euro 1-2)

980 20

Increase in the total number of passenger cars:

- Significant increase in the number of passenger vehicles: 48% from

1990 to 2010 compared to 36.5% in BE, 38% in DE, 40% in NL, 37% in

UK81

- Significant increase in the total energy consumption in transport sector:

63% from 1990 to 2010 compared to 29% total in EU-27

Unexpectedly high “dieselification” of road transport fleet: Increase in

proportion of diesel cars from 14% in 1990 to 55% in 2010. 2010 Baseline

activity projection used in RAINS82 underestimated diesel fuel consumption by

transport sector in 2010 by 64% or 2124 thousand TOE.

Increase e.g. due to:

- Lower diesel prices compared to petrol prices

- Fiscal policy favouring vehicles with lower fuel consumption and lower

CO2 emissions

Unexpected increase in energy consumption: In 1998 National activity data

projection (used in RAINS modelling83) underestimated energy consumption in

2010

- Primary energy consumption was expected to increase by 14% from

1990 to 2010; the actual increase was 38%

- Energy consumed in transport sector was expected to increase by

32%; actual increase amounted to 62% (diesel and petrol only)

Inadequate emission scenarios at the time of setting the ceilings: in 1999

RAINS REF84 scenario projected that the ceiling (103 kt) could be achieved by

2010 with existing measures in current legislation at the time.

- The reported 1990 emission has not changed significantly, so the issue

is mainly related to incorrect activity projections.

80 Programm der österreichischen Bundesregierung zur Einhaltung der nationalen Emissionshöchstmengen für bestimmte

Luftschadstoffe gemäß § 6 Emissionshöchstmengengesetz-Luft (2010). 81 Due to incomplete data available from Eurostat is it impossible to adequately estimate EU-27 average. 82 IIASA 1998 6th Interim Report, available from: http://gains.iiasa.ac.at/reports/pre-2002/6th interim a2.pdf 83 IIASA 1998 6th Interim Report, available from: http://gains.iiasa.ac.at/reports/pre-2002/6th interim a2.pdf 84 IIASA Seventh Interim Report, 1999, available from: http://www.iiasa.ac.at/~rains/reports/ir7.pdf

http://gains.iiasa.ac.at/reports/pre-2002/6th%20interim%20a2.pdf



75



Contribution to

44.5 kt

Reason kt NOx %

Late and inadequate implementation measures: Despite updated national

emission projections indicating that without additional measures, NOx ceilings

would be exceeded in 2010, no additional measures were proposed in National

Programmes of 2002 or 2006 beyond the existing legislation. Only the updated

National Programme of 2010 proposed additional measures, which still would

not be enough to reach the target before 2015.

Adopted fuel tax policy made fuel prices in Austria significantly lower

compared to neighbouring countries: this stimulated “tank tourism”– NOx

emissions estimated based on fuel sold are 31% higher than emissions based

on fuel used.

5.3 Main reasons for non-compliance as identified by Austria

The reasons for Austria's non-compliance with the NECD 2010 NOX ceiling are

summarised in Table 5-3. This is based on a telephone interview 12 December 2012 and

subsequent email correspondence with an official of the Federal Ministry of Agriculture,

Forestry, Environment and Water Management. Official correspondence between the

Ministry and the Commission in 2010, 2011 and 2012 regarding non-compliance with the

NECD ceiling and revision of the Gothenburg Protocol was also reviewed.

Table 5-3 includes any Austrian estimates of NOX amounts attributable to specific issues

that were provided during the interview. The preceding section on the independent

assessment includes additional estimates of these contributions calculated by this study

based on various sources, including Austrian submissions and reports.

Table 5-3 Reasons for Austria's non-compliance with the NECD 2010 NOX ceiling as identified by

Austria. Quantified contributions to NOX emission exceedance are given in kt and percent,

where provided by Austria.

Contribution

Reason kt NOX %

The failure of Euro I-III (HDV) and Euro 1-2 (LDV) diesel standards was

already known in 2006 to give 10 kt higher NOx emission than assumed when

the ceiling was set.

10 22%

The share of diesel cars in Austria increased from 14% in 1990 to 55% in

2010. The share of vehicle kilometres driven in the country (ie. fuel used

basis) by diesel cars increased from 18% in 1990 to 60% in 2010, which had

not been anticipated when the ceilings were set (figures based on cars only,

without light and heavy duty vehicles).

About 60% of Austria's NOx emissions are from mobile sources for which

emission limits have been set on the EU level.

76



Contribution

Reason kt NOX %

The 1999 RAINS emission projections on which the NECD ceiling was based

were overly optimistic and were not a good basis for defining a realistic and

implementable emission target for Austria (underestimation of activities and

overestimation of the effect of technology).

The 1999 RAINS projections indicated that measures in existing legislation

would be sufficient to meet the ceiling by 2010.

The large gap between projected emissions and real emissions could not be

compensated by proportionate measures. The 40% gap between the 1999

projection and the actual 2010 NOX emissions corresponds to total NOX

emissions from power plants and manufacturing industries, or to emissions

from cars plus residential heating.

Austria is a transit country and cannot restrict international mobility. Decisions

of the European Court have confirmed the priority of the free movement (road

transport) of goods over environmental considerations. The increase in transit

road transport has contributed to higher NOX emissions.

Increasing use of biofuels is an important part of GHG reduction policy and

renewable energy policy, including in plants that are part of the EU CO2

emission trading system. The share of biogenic fuels in energy transformation

input increased from 1% in 1990 to 10% in 2010. In manufacturing industries,

the share of biogenic fuels in final energy consumption increased from 10% to

15%. Biofuels generally have higher NOx emissions.

Regarding NOX emission reduction measures implemented between 2000 and 2010,

Austria notes that it was very difficult to get a consensus on a complete set of measures

for a national programme, especially due to the fact that reduction demand increased

continuously with new measurement data from vehicle testing and with new projections.

The programme of February 2010 comprises several measures that had started earlier:

Various tax measures, for example, had been implemented in 2007, mileage based road

toll for heavy duty vehicles had been implemented in 2004. The new emission abatement

installation of the refinery started operation in 2007, and the decision for that installation

was of course taken much earlier. Measures for mobility management and

environmentally sound transport started in 2004 and were later continued under the

programme title “klima:aktiv mobil”. Technical standards and subsidies to improve the

energy efficiency of buildings were introduced or optimised in the last decade (under the

jurisdiction of the Federal Provinces).

5.4 Expected time of compliance with the 2010 Ceilings

On the basis of recent emission projections from the GAINS model (CLE current

legislation scenario) and the available national projections (submitted in 2011) shown in

Table 5-4, an estimate was made for when Austria may reach its 2010 ceiling.

77



Table 5-4 Summary of projection analysis on the year for Austria to attain the NECD 2010 NOX ceiling

(103 kt, fuel used). Emissions in kt/year – fuel sold (fuel used based emissions in brackets)

, Reported emissions for previous

years, used for reference, kt Projections, kt

2010 fuel 2005 2010 2015 2020 2025 2030


103 sold 229 237 174 192 140 159 99 129 76 65 121

used 163 168 133 147 108 124 82 108 64 56 105


(with measures) projections from NECD and CLRTAP submissions through March 2013.

Notes:

a. Values based on fuel used are the basis for compliance assessment.

b. Calculations of NOX emissions in the GAINS model are based on fuel sold. The GAINS values based on

fuel used are estimated here based on the fuel used/fuel sold ratio for road transport emissions from

national emissions or projections in the same year.

c. NFR categories 4D1 (emissions from soils) and 4D2 (handling of agricultural products) are deducted from

the national values to enable comparison with the GAINS model projections.

Conclusion for NECD 2010 ceiling

Austria is likely to achieve compliance with its NECD 2010 NOX ceiling between

2015 and 2020 with measures based on current legislation.

5.5 Impact on future reduction commitments

Table 5-5 gives an estimation of when the GP 2020 ceilings is likely to be reached, based

on the latest available national emission projections and the results of GAINS model

projection (scenario: TSAP_Mar13_CLE (current legislation)). Comparisons are based on

reductions from the GP base year emissions for 2005. The target for national projections

is based on the reported 2005 emission. To minimize the effect of any GAINS model bias,

while the target for GAINS model projections is based on the GAINS model estimates for

2005 emissions.

Table 5-5 Estimated compliance period – Gothenburg protocol (GP) – Austria. Emissions in kt/year –

fuel sold.


GP 2020 reduction

commitment Based on



2015 2020 2025 2030

% fuel


37 sold 144 149 140 159 99 129 76 65 121

used 102 106 108 124 82 108 64 56 105



Notes: see notes under Table 5-4.

Conclusion for GP 2020 reduction commitment

Based on the analysis made, Austria is likely to comply with its GP 2020 reduction

commitment by 2020 with measures in accordance with current legislation. The

GAINS model current legislation projection based on fuel sold suggests

compliance closer to 2015.

78



79



6 Belgium

6.1 Introduction

Status of Belgium's NOx reduction commitments

Table 6-1 summarises the status in 2010 and 2011 of Belgium's commitments for national





target value (ceiling). Belgium's NECD and CLRTAP NOX emission totals are identical for

1990, 2005 and 2010 in present reporting, but there is a small difference (0.058 kt)

between the NECD and CLRTAP preliminary values for 2011 (not visible in the table).

Table 6-1 Overview of Belgium's final 2010 and provisional 2011 NOx emission data submitted under

NECD and CLRTAP.

Belgium, NOX Fuel sold basis Fuel used basis

emission distance to target emission distance to target



1990 (NECD.SUBM12) 401.5 225.5 128.1%

2010 (NECD.SUBM12) 220.7 44.7 25.4%

2011 (NECD.SUBM12) 210.1 34.1 19.4%


1990 (CLRTAP.SUBM13) 401.5 220.5 121.8%

2010 (CLRTAP.SUBM13) 220.7 39.7 22.0%

2011 (CLRTAP.SUBM13) 210.1 29.1 16.1%

CLRTAP NOX 2020 reduct. 41% 172.1

2005 (CLRTAP.SUBM13) 291.8 119.6 69.5%

2010 (CLRTAP.SUBM13) 220.7 48.6 28.2%

2011 (CLRTAP.SUBM13) 210.1 37.9 22.0%

Belgium reports only emissions based on fuel used to both NECD and CLRTAP, although

the UNECE Guidelines on Reporting require reporting of emissions based on fuel sold.

Belgium has chosen to base compliance with the 2010 ceilings on fuel used emissions.

Belgium's NOX emission based on fuel used was above the 176 kt NECD ceiling by 45 kt

(25%) in 2010, and 34 kt (19%) above in 2011. NOx emission declined nearly 11 kt (24%)

from 2010 to 2011, and 191 kt (45%) from the 1990 base year to 2011.

Belgium agreed to a 5 kt lower NOX ceiling under the NEC Directive compared to the

CLRTAP Gothenburg Protocol ceiling. For the 2012 Gothenburg Protocol amendments,

Belgium agreed to a 41% NOX reduction by 2020 from the base year 2005. This is

equivalent to a 2020 NOX target of 172 kt based on the currently reported 2005 fuel used

emission. This 2020 target is 4 kt (2%) lower than the NECD 2010 ceiling.


The main reasons for Belgium's non-compliance with the NECD 2010 NOx ceiling are:

80



Vehicle NOX emissions (primarily diesel) under real-world driving conditions are much

higher than expected for Euro 1-5/I-V standards. Belgium has estimated an additional

NOX emission of 54 kt (121% of the 2010 exceedance) due to vehicle emission factor

changes since the 1999 projections.

Improved inventory methodology has increased the 1990 base year NOX emission by

14% compared to the value used in the 1999 RAINS projections, and 18% compared

to the 2001 NECD submission. A 14% base year increase effectively adds an

additional 51 kt NOX reduction needed to meet the fixed 2010 ceiling (113% of the

2010 exceedance);

Inventory improvements have added emission sources in the off-road transport sector

not reported at the time the ceilings were set: SSS (heavy fuel oil), off-road

construction and industry vehicles and other off-road sources. These give 16 kt

additional NOX emission in 2010 (36% of the 2010 exceedance);

Diesel fuel consumption (fuel sold) and the diesel share of road transport increased

from 1990 to 2010 more than expected in 1999, although the differences were near

average for the EU-15. Belgium was projected to have the highest diesel share

among the EU-15 (68%), but the actual share in 2010 was even higher (85%);

The regions did not all update their versions of COPERT when new "real world"

emission factors were introduced, which lead to underestimation of vehicle NOX

emissions when the National Programmes of measures were developed;

Delayed update of the transport emission estimation methodologies and hence

underestimated emission projections: The 2006 National Programme based emission

projections on RAINS emission factors without taking into consideration improved

methodologies and available information on Euro standards real world driving

performance leading to underestimation of emission projections for 2010 by about 57

kt (34% of the 2010 NECD NOx ceiling, or 128% of the 2010 exceedance).

Climate policy in stationary engine legislation (less than 50 MW) in the Flemish region

stimulated decentralized electricity generation using small cogeneration plants (CHP)

with high specific NOx emissions. Emission limit values have now been strengthened.


Belgium is likely to achieve compliance with its NECD 2010 ceiling between 2015 and

2020 with current legislation.

Belgium is likely to comply with their respective CLRTP 2020 reduction commitment

by 2020 at the latest with measures in accordance with current legislation.





In Belgium, the NECD was not transposed on the Federal level but integrated in the

regional legal systems individually by each of the regions. In order to reach national

NECD targets, the national ceilings had been divided into a national sub-ceiling for

81



transport (68 kt NOx) and individual ceilings for stationary sources in the Flanders (58 kt

NOx), Walloon (46 kt NOx) and Brussels (3 kt NOx) regions. These sub-ceilings were

integrated in the relevant legal acts85. The sub-ceiling for the transport sector was also

broken down into three regional parts, however it was recognised that a large number of

the emission reduction measures targeting transport sector were to be implemented on

the Federal level.

National Programmes under the NECD combined regional programmes developed by

each region individually, with the Federal programme covering the issues defined as the

responsibility of the Federal government. These regional programmes developed and

adopted in 2002 and 2003 varied in the level of detail and the nature of the measure

proposed.

The programmes were revised in in 200686. The 2006 National Programme encompassed

the measures and aspects in the regional programmes. Belgium provided a detailed list

of 99 policies and measures on emission reduction. Technological measures (e.g. vehicle

emission standards) related to the transport sector were designated at the Federal level,

due to the fact that they are enforced by the EU. The regions also developed their own

measures related to the transport sector, aimed at “development of mobility”, such as

promotion of environmentally friendly vehicles, regulation of traffic and promotion of use

of public transportation. In addition, Federal measures also regulate the NOx emissions

from heating installations (installations with gaseous and liquid fuels with a thermal power

up to 400 kW). As in the previous period, the regions have chosen slightly different

approaches in the 2006 programme.

In 2010, in response to the request from the EC87 for additional information, Belgium

presented information on a large number of both fiscal and voluntary measures aimed at

promotion of use of public transport and bicycles, eco-driving, selection of energy-efficient

and low-emission vehicles, improvement of the efficiency of transport systems and

sustainable spatial planning. Additionally, the issues of CO2 and NOX emissions from

small boilers were addressed on the Federal level: Royal Decree of 17 July 2009 sets the

nitrogen oxide (NOX) and carbon monoxide (CO) emission levels for central heating

boilers and liquid or gas fired boilers of nominal heat input not exceeding 400 kW and

Royal Decree of 12 October 2010 now regulates the minimum efficiency requirements

and pollutant emission levels of solid fuel heaters.


Belgium’s three regions – Flemish, Walloon and Brussels Capital regions – have

individual responsibility for development of emission inventories. Each region is

responsible for activity data collection and selection and/or development of the

appropriate methodology and emission factors for emission calculation. Consequently,

approaches and emission factors used by different regions, although generally similar,

vary. For instance, until recently (prior the 2013 CLRTAP submission) Brussels Region

and the Walloon region used the COPERT III model for calculation of emissions from

road transport sector, while Flemish Region used a different model based on COPERT

for estimation of fuel consumption and modified emission factors based on MEET and

German emission factors (which for many vehicle categories are higher than those

presented in COPERT III).

85 Appendix A - Member State National Programme Assessment. National Emission Ceilings Directive Review, Task 1 – In

Depth Analysis of the NEC National programmes. Final Report, July 2005 86 NEC Reduction Programme 2006. Belgium. 87 Ref. Ares(2010)337747 - 15/06/2010

82



Inventory reports submitted by the regions are later compiled into a single inventory by

the Belgian Interregional Environmental Agency (IRCELIN). Belgium has chosen an

option of reporting emissions based on “fuel used” and provides no additional information

on the emissions calculated based on the “fuel sold”.

According to the 2006 National Programme the significant changes in emission

estimations approaches affected transport sector emissions. When the transport

emissions for the whole country were calculated using a more advance approach applied

in the Flemish Region and the latest emission factors for ARTEMIS database, as well as

updated methodologies for off-road transport, the NOx emissions in 2010 were 57 kt

higher than if estimated using original RAINS emission factors (41 kt of this from road

transport).

Figure 6-1 NOX contributing sectors in Belgium, fuel used, 2012 NECD submission (kt)

The total NOx emissions in Belgium decreased by 45% from 1990 to 2010. Figure 6-1

shows the major NOx emission sources in Belgium. According to the 2012 IIR, the

reduction in the NOx emissions in the public electricity and heat production sector

compared to 1990 is driven by closure of some of the coal power plants, shift to cleaner

fuels, improvements of the efficiency and use of modern technologies in the sector

(Figure 6-2). National statistics on the modal split of the passenger transport show a

decrease in the intensity of use of passenger cars, compared to the railway and busses

from the beginning of 2000s. Meanwhile, the total number of registered passenger cars

has increased by 30% from 1992 to 2009 with the total energy consumed by transport

sector increasing by 31.6%88 (instead of 37% projected in 199889). Additionally, a trend

88 Petrol and diesel only

401.4

332.1291.0

265.3262.5

238.7

207.5220.7

0

50

100

150

200

250

300

350

400

450

1990 1995 2000 2005 2010

kt

Other sectors1 A 2 c Stationary combustion in manufacturing industries and construction: Chemicals1 A 2 a Stationary combustion in manufacturing industries and construction: Iron and steel1 A 3 b ii Road transport:Light duty vehicles1 A 2 f i Stationary combustion in manufacturing industries and construction: Other2 A 1 Cement production1 A 4 b i Residential: Stationary plants1 A 1 a Public electricity and heat production1 A 3 b i Road transport: Passenger cars1 A 3 b iii Road transport:, Heavy duty vehiclesNational total for the entire territory

83



towards dieselification of road transport fleet can be notices: the proportion of diesel cars

has increased from 29% in 1992 to 59% in 2009 (Figure 6-3). In 1998, consumption of

diesel in the transport sector was expected to increase by 68% from 1990 to 2010,

constituting 68% of the total energy consumed by this sector. The latest Eurostat data

shows that diesel consumption in transport sector increased by 97% and making up 85%

of the energy consumed by transport sector. At the same time, the total primary energy

consumption in Belgium increased by 18%, which is lower than the 28% increase

expected at the time of RAINS projections development90.

Figure 6-2 Final energy consumption in Belgium by sector and fuel type, 1000s TOE (Eurostat)

Figure 6-3 Number of registered passenger cars in Belgium by engine type (Eurostat)

Beginning with submission year 2004, Belgium reported NOX projections for year 2010

that were above the 176 kt NECD ceiling. The NOX emission projection for the “with

89 Petrol and diesel only. IIASA 1998 6th Interim Report, available from: http://gains.iiasa.ac.at/reports/pre-2002/6th interim

a2.pdf 90 Footnote 89.

0

2000

4000

6000

8000

10000

12000

10

00

s TO

E

Residential Solid

Residential Oil

Residential Gas

Transport Oil

Industry Solid

Industry Oil

Industry Gas

0

1000

2000

3000

4000

5000

6000

0

500

1000

1500

2000

2500

3000

3500

10

00

s To

tal

10

00

s D

iese

l or

Pe

tro

l

Diesel Petrol Total

84



measures” scenario submitted in 2012 indicated that 2010 ceiling could be achieved by

2020 (170 kt).

Summary

The reasons for Belgium's non-compliance with the NECD 2010 NOx ceiling are

summarised in Table 6-2. The contributions to the exceedance are given in kt where they

can be estimated.

Table 6-2 Reasons for Belgium's non-compliance with the NECD 2010 NOx ceiling, based on the

independent assessment. Contribution to exceedance is given in kt and percent where

possible.

Reason Share of 44.7

kt exceedance

kt

NOx

%


reductions from road transport due to higher real world driving

emissions of the Euro standards

4191 92%

Inclusion of emission sources in the off-road transport sector previously

not reported: Inclusion of SSS (heavy fuel oil ), off-road construction and

industry vehicles and other off-road lead to increase of NOx emission in

2010 equal to 10% of the NECD ceiling

1692 36%


proportion of diesel cars from 29% in 1992 to 59% in 2009. Baseline

activity projection used in RAINS93 underestimated diesel fuel

consumption by transport sector in 2010 by 17% or 1078 thousand TOE.


- Lower price of diesel fuel compared to petrol

- Earlier (changed now) implemented policy favouring vehicles

with lower fuel consumption and lower CO2 emissions

Improved inventory methodology: changed EFs and activity data

- 18% increase in reported 1990 emission from 2001 to 2012

(NECD submissions)

- 14% increase in 1990 emission estimations: 1999 RAINS94 vs.

2012 NECD

Delayed update of the transport emission estimation methodologies and

hence underestimated emission projections: 2006 National Programme

based emission projections on RAINS emission factors without taking

into consideration improved methodologies and available information on

Euro standards real world driving emissions, leading to underestimation

of emission projections for 2010 by about 57 kt or 34% of the NECD NOx

ceiling.

91 NEC reduction programme 2006: Belgium, available from:

http://ec.europa.eu/environment/air/pdf/nat_prog/nec_belgium_2006.pdf 92 NEC reduction programme 2006: Belgium, available from:

http://ec.europa.eu/environment/air/pdf/nat_prog/nec_belgium_2006.pdf 93 IIASA 1998 6th Interim Report, available from: http://gains.iiasa.ac.at/reports/pre-2002/6th interim a2.pdf 94 IIASA Seventh Interim Report, 1999, available from: http://www.iiasa.ac.at/~rains/reports/ir7.pdf

http://ec.europa.eu/environment/air/pdf/nat_prog/nec_belgium_2006.pdf

http://ec.europa.eu/environment/air/pdf/nat_prog/nec_belgium_2006.pdf



85



6.3 Reasons for non-compliance as identified by Belgium

Belgium's perspective on the reasons for non-compliance with the NECD 2010 NOX

ceiling was obtained through a telephone interview with an official of the Environmental

Administration of the Flemish Government and subsequent written replies to questions,

and documents provided. The reasons identified by Belgium for non-compliance are

summarised in Table 6-3. The quantitative contributions to the exceedance are given as

provided by Belgium.

Table 6-3 Reasons for Belgium's non-compliance with the NECD 2010 NOx ceiling as identified by

Belgium. Contribution to NOx emission exceedance is given in kt and percent where

provided by Belgium.

Share of 44.7 kt

exceedance

Reason kt NOx %

It was assumed when defining the ceiling that real world vehicle emissions

would follow the Euro emission standards. Real world emissions for Euro 3

and 4 diesel cars and LDV and Euro VI diesel HDV are significantly higher

than the test cycle emission standards. Fully compensating for the failure

of the Euro standards would in Belgium only be possible with very

unrealistic and drastic measures (for example a drastic reduction in total

km driven)

54 121%

Emissions from off-road subsectors are now reported that were not

included in the inventory or RAINS projections at the time the ceiling was

set.

12 30%

New knowledge (improved emission factors) for off-road subsectors

included at the time the ceiling was set has raised NOx emissions in these

subsectors.

4 9%

For the Flemish region, climate policy in legislation on stationary engines

< 50 MW has stimulated cogeneration (CHP) in recent years. This has

resulted in a significant increase of small stationary CHP gas engines in

Flanders (for example in greenhouses). These installations have very high

specific NOx emissions. Flanders has now strengthened emission limit

values for diesel and gas engines.


On the basis of recent emission projections from the GAINS model (CLE - current

legislation) and national scenario estimates were made for when Belgium may reach its

2010 ceiling, shown in Table 6-4.

Table 6-4 Summary of projection analysis for Belgium on the year to attain the 2010 ceiling (176 kt).

Emissions in kt/year



2010 fuel 2005 2010 2015 2020 2025 2030


86





2010 fuel 2005 2010 2015 2020 2025 2030


176 sold 300 234 215 174 147 135

used 292 221 200 170



Notes:

a. For BE, values based on fuel used are the basis for compliance assessment.

b. BE does not report emissions based on fuel sold, so a fuel used/fuel sold ratio cannot be estimated. The

difference between the GAINS value (fuel sold) and national value (fuel used) for 2020 is 4 kt (2%). Belgium

informs that the GAINS model has been adjusted in such a way that it would represent as much as possible

the emissions as estimated in the Belgian inventory based on fuel used, and the actual difference between

fuel used and fuel sold is expected to be larger. No adjustment is made of the GAINS model values to fuel

used basis.

Although the GAINS model is based on fuel sold emissions, Belgium indicates that the

GAINS model has been adjusted for Belgium to represent fuel used emissions as closely

as possible. The difference between the GAINS model value (fuel sold) and national

value (fuel used) for 2020 is 4 kt (less than 3%). Belgium informs that the GAINS model

has been adjusted in such a way that it would represent as much as possible the

emissions as estimated in the Belgian inventory based on fuel used. Belgium expects the

actual difference between fuel used and fuel sold to be larger.


Based on the analysis made, Belgium is likely to achieve compliance with its NECD

2010 ceiling between 2015 and 2020 with current legislation.


Table 6-5 gives an estimation of when the GP 2020 ceiling is likely to be reached, based

on the latest available national emission projection(s) and the results of GAINS model

projection (scenario: TSAP_Mar13_CLE (current legislation)). Comparisons with the

targets are based the 2005 base year emissions. The reported 2005 emission is the basis

for the 2020 target for national projections. To compensate for any bias in the GAINS

model, the GAINS model value for 2005 is used at a basis for the GAINS 2020 target.

Table 6-5 Estimated time for compliance – Gothenburg protocol (GP) – Belgium. Emissions in

kt/year.


GP 2020 reduction

commitment Based on



2015 2020 2025 2030

% fuel


41 sold 177 215 174 147 135

used 172 200 170



Notes: (see text under Table 6-4)

87




Based on the analysis made, Belgium is likely to comply with their respective

CLRTP 2020 reduction commitment by 2020 with measures in accordance with


6.6 Observations and recommendations for Belgium

Issue: Fuel sold emissions are not submitted by Belgium to NECD or CLRTAP, as

required by EMEP Guidelines for Reporting.

Recommendation:

Consider introduction of nitrogen oxides emission assessment on the basis of fuel

sold in parallel to existing practice based on fuel used.

Issue: Regions have been using different methodologies for emission estimation for road

transport which complicates aggregation and comparison of the results.

Recommendation:

Consider centralised calculation of road transport emissions at the Federal level, to

ensure the same methodology is applied for all regions, consistent treatment of fuel

tourism by the regions, and to facilitate calculation and reporting of national

emissions based on fuel sold.

88



89



7 France

7.1 Introduction

Status of France's NOx reduction commitments

Table 7-1 summarises the status in 2010 and 2011 of France's commitments for national





target value (ceiling). France's NECD and CLRTAP NOx emission totals are identical for

these years in present reporting.

Table 7-1 Overview of France's final 2010 and provisional 2011 NOx emission data submitted under

NECD and CLRTAP.

France, NOX Fuel sold basis Fuel used basis



NECD NOX 2010 ceiling 810

1990 (NECD.SUBM12) 1842.1 1032.1 127.4%

2010 (NECD.SUBM12) 1075.3 265.3 32.7%

2011 (NECD.SUBM12) 1005.0 195.0 24.1%

CLRTAP NOX 2010 ceiling 860

1990 (CLRTAP.SUBM13) 1842.1 982.1 114.2%

2010 (CLRTAP.SUBM13) 1075.3 215.3 25.0%

2011 (CLRTAP.SUBM13) 1005.0 145.0 16.9%

CLRTAP NOx 2020 reduct. 50% 704.8

2005 (CLRTAP.SUBM13) 1409.5 704.8 100.0%

2010 (CLRTAP.SUBM13) 1075.3 370.5 52.6%

2011 (CLRTAP.SUBM13) 1005.0 300.2 42.6%

France only reports NOx emissions with respect to fuel sold, under both NECD and

CLRTAP. France's NOx emission was 265 kt (33%) above the 810 kt NECD ceiling in

2010 and 195 kt (24%) above in 2011. NOx emission declined 70 kt (7%) from 2010 to

2011.

France agreed to a 50 kt lower NOx ceiling under the NEC Directive (810 kt) compared to

the CLRTAP Gothenburg Protocol ceiling (860 kt).

For the 2012 Gothenburg Protocol amendments, France agreed to a 50% NOx reduction

by 2020 from the base year 2005. This is equivalent to a 2020 NOx target of 705 kt based

on the presently reported 2005 fuel sold emission (shown in grey in the table). The 2020

NOx target is 105 kt (13%) lower than the NECD 2010 ceiling.

90




The main reasons for France's non-compliance with the NECD 2010 NOx ceiling are:


higher than expected for Euro 1-5/I-V standards. France has estimated an additional

2010 NOX emission of 152 kt (57% of the 2010 exceedance) due to vehicle emission

factor changes from COPERT III to COPERT 4 v9.0. An ETC/ACC study estimated

282 kt additional NOX in 2010 (106% of 2010 exceedance) due to revisions of

exhaust emission factors from the 1999 RAINS projections to COPERT 4 v8.0.

Inventory improvements added emissions from non-road mobile engines that were

not in the original inventory or RAINS projections, increasing the 2010 NOX emission


The diesel share of road transport fuel consumption (fuel sold) increased to 80% in

2010, compared to 54% assumed in 1999 RAINS projections – the third largest

dieselification among the EU-15. However, total road transport fuel consumption

increased less than assumed in 1999, which more than offset the NOX increase due

to dieselification.


France is likely to achieve compliance with its NECD 2010 ceiling between 2015 and

2020 with current legislation.

France is likely to comply with its respective CLRTAP 2020 reduction commitment by

2020 with measures in accordance with current legislation.





NEC Directive has been transposed into France’s national legislation by Ministerial Order

of July 8, 200395, explicitly adopting the NECD national emission ceilings.

The first French National Programme was finalised in 2003 and provided a description of

existing and planned policies and measures and emission projections under a number of

scenarios. Regarding emissions from the transport sector, France stated that is has

followed all the requirements of the EU by implementing the legislation relevant to the

transport emissions. There were no additional transport sector related measures

presented in the programme and it stated that additional measures in the sector are

required on the European level in order to control emissions.

Emission projections presented in the 2003 National Programme suggested that under

“business-as-usual” scenario, i.e. taking into consideration measures already

implemented, in 2010 NOx emission in France would reach approximately 990 kt, while

additional measures would reduce the emission to the level of 840 kt, still exceeding the

NECD ceiling by some 30 kt.

95 Arrêté du 8/7/2003 portant approbation du programme national de réduction des émissions de polluants atmosphérique (SO,

NOX, COV et NH) JORF du 30/10/2003 p. 18556

91



Revision of the National Atmospheric Pollutant Reduction Programme was completed in

February 2007. France acknowledged that with the measures already in place, NOx

emissions will exceed NECD ceiling in 2010 by 295 kt. The main reasons for this were

identified as the inclusion of NOx emissions from the fertilizer application (previously not

estimated) and the change in the emission factors for road transport included in the new

COPERT 4 model. According to the national programme, the difference between the

emissions in road transport sector estimated with COPERT III and COPERT 4 for France

was about 140 kt96. Implementation of additional measures was expected to reduce the

exceedance of the NOx ceiling by 239 kt (81%).


Figure 7-1 NOx emission trends in the national total and major contributing sources in France (CEIP

database, submitted before 2013)

The time series of national total NOX emission and major sectors for 1990 to 2010 are

shown in Figure 7-1. NOx emissions in France have decreased by 42% from 1990 to

2010. The sectors with the largest decreases in emissions were the mobile combustion

sector, passenger cars, stationary combustion and public electricity and heat production.

These have decreased by 62%, 62%, 45% and 43% respectively from 1990 to 2010.

According to the 2012 IIR, NOx emission reductions in the transport sector are driven by

the technological changes. At the same time the total number of registered cars has

increased by 28% from 1991-2006. The country also experienced an unexpected rate of

dieselification of transport fleet, with the proportion of diesel cars increasing from 18% in

1991 to 50% in 2006.

Activity data projections97 used in the RAINS modelling at the time the ceilings were set

expected consumption of petrol to increase by 15% and diesel to increase by 40% from

1990 to 2010. The latest Eurostat data indicates that petrol consumption has decreased

96 According to the National Programme 2006 the difference was between 137 and -148 kt depending on the estimation

scenario. 97 IIASA 1998 6th Interim Report, available from: http://gains.iiasa.ac.at/reports/pre-2002/6th interim a2.pdf

0

200

400

600

800

1000

1200

1400

1600

1800

2000

0

100

200

300

400

500

600

700

Tota

l, kt

Sect

ors

, kt

National totalRoad Transport:, Passenger carsRoad Transport:, Heavy duty vehiclesRoad Transport:, Light duty vehiclesAgriculture/Forestry/Fishing: Off-road Vehicles and Other MachineryPublic Electricity and Heat Production

92



by 58% while diesel increased by 79%. The total energy consumed by transport sector

(petrol and diesel only) has increased by 8% instead of the projected 27%. NOx

emissions from the public heat and electricity production sector as well as in industrial

stationary combustion have decreased considerably during the last decade. This

coincided with the gradual shift from oil and solid fuel to gas in both sectors, as well as

general reduction (22%) in the final energy consumption by the industrial sector (Figure

7-2). The total primary energy consumption in France has increased by 20% from 1990 to

2010, which is slightly lower than the 22% increase foreseen for RAINS model projections

at the time the ceilings were set98.

Figure 7-2 Final energy consumption by sector and fuel type in France (Eurostat)

Emission projections reported in France’s 2013 CLRTAP submission suggest that under

“with measures” scenario in 2015, NOx emission in France will still be 38 kt above the

2010 NECD ceiling, declining to 620 kt by 2020.

Summary

The reasons for France's non-compliance with the NECD 2010 NOx ceiling identified by

the independent assessment are summarised in Table 7-2. The contribution to the

exceedance is given in kt where it can be estimated.

98 Supra note 97

0

2000

4000

6000

8000

10000

12000

14000

16000

18000

20000

10

00

s TO

E

Residential: Solid fuels Industry: Solid fuels

Industry: Oil Residential: Oil

Industry: Gas Residential: Gas

93



Table 7-2 Reasons for France's non-compliance with the NECD 2010 NOx ceiling, based on the


possible.

Contribution to

exceedance of 265.3 kt

Reason kt NOx %

Euro vehicle standard performance: Overestimation of 2010

reductions from road transport due to higher real world driving

emissions for the Euro standards

approx. 140

kt99

52.8


share of diesel cars from 18% in 1991 to 50% in 2006. Baseline

activity projection used in RAINS100 underestimated diesel fuel

consumption by transport sector in 2010 by 14% or 3836 thousand

TOE.


- Lower price of diesel fuel compared to petrol, and

- Fiscal policies favouring vehicles with lower CO2 emission and

engine capacity

No actions planned in the National Programmes with regards to the

transport sector as this was seen as the responsibility of the EU

legislation

Underestimated emission projections: overestimation of expected

reduction from the planned measures at the time of development of

2002 National Programme projections

- BAU scenario - 990 kt

- With additional measures - 840 kt

7.3 Reasons for non-compliance as identified by France

The reasons for non-compliance with the NOX ceiling for France were compiled from 1)

France’s reply to the Commission’s 2010 request to France for information about the NOX

ceiling, 2) a telephone interview and written reply to questions provided by an official of

the Ministry of Environment, Sustainable Development and Energy.

France identifies two main reasons for exceedance of the NECD 2010 emission ceiling

for NOX:

a. Change of methodologies for estimating NOx emissions from road traffic and

several other sources, and

b. Characteristics of the French road vehicle fleet.

99 According to the National Programme 2006 the difference was between 137 and -148 kt depending on the estimation

scenario. 100 IIASA 1998 6th Interim Report, available from: http://gains.iiasa.ac.at/reports/pre-2002/6th interim a2.pdf

94



Even when taking into account the methodological changes described below, the

exceedance remains but at a small level.

Emissions of NOx in 1990 and 2010, according to the most recent estimation (December

2012), are shown in Table 7-3.

Table 7-3 Total and road traffic NOx emission for France in 1990 and 2010. Source: December 2012

submission.

Inventory year

Total NOx emissions

NOx emissions from road

traffic

Proportion of NOx

emissions due to road

traffic

1990 1842 1144 62%

2010 1075 592 55%

Reduction -42% -48%

According France’s latest inventory submission (December 2012), NOx emissions from

road traffic were 56% of the total in 2011, compared to 62 % in 1990. From 1990 to 2010,

total NOx emissions have decreased by 42 %. The road traffic NOx emissions have

decreased by 48 %.

This low decrease of emissions in road traffic is due to the singular characteristics of the

French fleet of vehicles combined with the fact that reduction of NOx emissions due to

Euro vehicle standards is less effective than expected. The difference between

theoretical Euro emission standards and actual on-road emissions is very significant.

Furthermore, the use of DPFs for diesel cars has increased emissions of NO2, as shown

by European studies.

Diesel cars are used for longer trips. The diesel share of passenger cars (PC) mileage is

71% in 2010. Diesel LDV represented 95% of LDV mileage in 2010. In comparison, the

diesel share of LDV mileage is very low in Switzerland. The tremendous increase in the

use of diesel cars is mainly due to the lower fuel consumption of diesel vehicles

compared to gasoline cars, and that diesel fuel is cheaper than gasoline in France. Most

importantly, the ambitious European and national climate policies to reduce CO2

emissions of vehicles, has led France to develop and promote the use of diesel cars. This

is one of the reasons why diesel fuel is cheaper than gasoline in France.

Table 7-4 shows the impact of changes in methodology since the NEC Directive went into

force.

95



Table 7-4 Comparison of French NOx emissions in 2010 for current methodology compared to the

methodology in place at the time the NEC Directive was established, based on the French

submission in December 2012.

NOx kt National total in 2010 according

to the 2012 submission

National total in 2010 with older methodologies

Difference

Total emissions 1075 883 -192

Road transport 592

(COPERT 4)

439

(COPERT III)

-152

Light fuel oil Off-road mobile engines from industry

16 3 -12

Light fuel oil Off-road mobile engines from agriculture forestry

117 90 -27

France based its 2010 NOx ceiling on IIASA RAINS projections at the time of the

negotiations. In the REF scenario of IIASA (1998), NOx emissions from road transport

were projected to decrease almost 69%, from 1045 kt in 1990 (French inventory in 1997)

to 329 kt in 2010. Actual road transport NOx emissions in 2010 were 592 kt (French

inventory for 2010 using COPERT 4), a 43% reduction from the 1990 level. The 1998

IIASA RAINS projection using the REF scenario underestimated the 2010 road transport

NOx emission by 80%.

Summary

The reasons non-compliance with the NECD 2010 NOx ceiling identified by France are

summarised in Table 7-5. The contribution to the exceedance is given in kt where it can

be estimated.

Table 7-5 Reasons for France's non-compliance with the NECD 2010 NOx ceiling as identified by

France. Contribution to NOx emission exceedance is given in kt and percent where

provided by France.

Share of 265.3 kt

Reason kt NOx %

The change in methodology (emission factors) for road transport

between COPERT III and COPERT 4

152 57%

Inclusion of off-road mobile engines from agriculture and forestry

that were not in the original inventory or RAINS projections

27 10%

Inclusion of off-road mobile engines from industry that were not in

the original inventory or RAINS projections

12 5%

Ambitious EU and national climate policies have led to promotion of

diesel vehicles and lower diesel fuel prices, which has resulted in

tremendous growth in the use of diesel cars.

The total of the NOX emission increases given in Table 7-5 is 191 kt. This accounts for

72% of the NOX exceedance in 2010, leaving 75 kt (28% of the exceedance) to be

accounted for.

96




On the basis of recent emission projection from the GAINS model (CLE - current

legislation) and national current legislation projections shown in Table 7-6, an estimate is

made for when France may reach its 2010 ceiling.

Table 7-6 Summary of projection analysis for France on the year to attain the 2010 ceiling (810 kt).

Reported emissions for previous


2010 fuel 2005 2010 2015 2020 2025 2030


810 sold 1374 1410 1053 1075 847 848 619 620 496 438




Based on the analysis made, France is likely to achieve compliance with its NECD

2010 ceiling between 2015 and 2020 with current legislation.


Table 7-7 gives an estimation of when the GP 2020 ceiling is likely to be reached, based

on the latest available national emission projection(s) and the results of GAINS model

projection (scenario: TSAP_Mar13_CLE (current legislation)). National projections are

compared to a target level based on the currently reported emission in 2005. To minimize

any bias in GAINS model projections, the GAINS model projections are compared to a

target level based on the GAINS projection for 2005.

Table 7-7 Estimated compliance period – Gothenburg protocol (GP) – France. Emissions in kt/year.


GP 2020 reduction

commitment Based on



2015 2020 2025 2030

% fuel


50 sold 687 705 847 848 619 620 496 438




Based on the analysis made, France is likely to comply with its respective CLRTAP

2020 reduction commitment by 2020 with measures in accordance with current

legislation.

97



8 Germany

8.1 Introduction

Status of Germany's NOX reduction commitments

Table 8-1 summarises the status in 2010 and 2011 of Germany's commitments for

national NOx emissions under the NECD and the 1999 CLRTAP Gothenburg Protocol,

and for the reduction commitment for 2020 under the 2012 amendments to the

Gothenburg Protocol. The table lists reported emissions in the GP base years 1990 and

2005, and the two most recent years, 2010 and 2011. Distance to target is given in kt and

as a percent of the target value (ceiling). Germany's NECD and CLRTAP NOx emission

totals are identical for these years in present reporting.

Table 8-1 Overview of Germany's final 2010 and provisional 2011 NOx emission data submitted

under NECD and CLRTAP.

Germany, NOX Fuel sold basis Fuel used basis



NECD NOX 2010 ceiling 1051

1990 (NECD.SUBM12) 2875.0 1824.0 173.5%

2010 (NECD.SUBM12) 1331.9 280.9 26.7%

2011 (NECD.SUBM12) 1292.9 241.9 23.0%

CLRTAP NOX 2010 ceiling 1081

1990 (CLRTAP.SUBM13) 2875.0 1794.0 166.0%

2010 (CLRTAP.SUBM13) 1331.9 250.9 23.2%

2011 (CLRTAP.SUBM13) 1292.9 211.9 19.6%

CLRTAP NOx 2020 reduct. 39% 961.0

2005 (CLRTAP.SUBM13) 1575.4 614.4 63.9%

2010 (CLRTAP.SUBM13) 1331.9 370.9 38.6%

2011 (CLRTAP.SUBM13) 1292.9 331.9 34.5%

Germany only reports NOX emissions with respect to fuel sold, under both NECD and

CLRTAP. Germany's NOX emission was 281 kt (27%) above the 1051 kt NECD ceiling in

2010 and 242 kt (23%) above in 2011. NOX emission declined 39 kt (3%) from 2010 to

2011.

Germany agreed to a 30 kt lower NOX ceiling (1051 kt) under the NEC Directive

compared to the CLRTAP Gothenburg Protocol ceiling (1081 kt).

For the 2012 Gothenburg Protocol amendments, Germany agreed to a 39% NOx

reduction by 2020 from the base year 2005. This is equivalent to a 2020 NOx target of

961 kt based on the presently reported 2005 fuel sold emission (shown in grey in the

table). The 2020 NOx target is 90 kt (9%) lower than the NECD 2010 ceiling.

98




The main reasons for Germany's non-compliance with the NECD 2010 NOx ceiling are:


higher than expected for Euro 1-5/I-V standards. An ETC/ACC study estimated 210 kt

additional NOX in 2010 due to revisions of exhaust emission factors from the

COPERT II to COPERT 4 v8.0 (75% of 2010 exceedance).


in the 1999 RAINS projections. In spite of an overall 8% decline in road transport fuel

consumption from 1990 to 2010, the increase of heavy duty vehicle activity and

change in fleet composition compared to the 1999 assumptions accounts for 113 kt of

additional NOX in 2010 (40% of the 2010 exceedance).

Greatly increased biomass combustion in energy and manufacturing industries and

small combustion gave an additional 106 kt NOX emission in 2010 (38% of the 2010

exceedance).

Inventory improvements added NOX emissions from agriculture that were not

included at the time the ceilings were set, increasing 2010 emissions by 99 kt (35% of

the 2010 exceedance).

National projections made through 2009 overestimated the expected NOX reductions

from planned measures.


Germany is likely to achieve compliance with NECD 2010 ceiling about 2015 with


Germany would reach its CLRTAP 2020 reduction commitment between 2015 and

2020 according to the GAINS model current legislation projections. National

projections do not indicate compliance by 2020, suggesting additional measures may

be needed.





NECD requires Germany to not to exceed NOx national emission ceilings of 1051 kt from

2010 onwards. The Regulation of July 13, 2004101 directly implements NECD sets

emission ceilings correspond to the ceilings in the Directive.

The German National Programme of 2002102 published in 2001 provides a list of

measures that were either already in force or planned to be implemented prior to 2010.

The programme also quantifies the impacts of a number of these measures. Most of the

101 Verordnung zur Umsetzung EG-rechtlicher Vorschriften, zur Novellierung der Zweiundzwanzigsten Verordnung zur

Durchführung des Bundes-Immissionsschutzgesetzes (Verordnung über Immissionswerte für Schadstoffe in der Luft) und

zur Aufhebung der Dreiundzwanzigsten Verordnung zur Durchführung des Bundes-Immissionsschutzgesetzes

(Verordnung über die Festlegung von Konzentrationswerten) vom 13 Juli 2004 102 National Programme of the Federal Republic of Germany pursuant to Article 6 of Directive 2001/81/EC of 23 October 2001

on national emission ceilings for certain atmospheric pollutants (NEC Directive). August, 2002

99



measures are of a regulatory nature, with a number of instruments related to fiscal,

economic, voluntary or informational activities. According to the emission projections

presented in the programme, NOx emissions would reach 1124 kt in 2010 based only on

implementation of existing measures, while implementation of additional measures would

bring the emission below the NECD ceiling to the level of 1013 kt.

The revised National emission reduction programme of 2006 was submitted by Germany

in February 2007.103 All the implemented and planned measures presented in the

programme were in the form of regulations (except for the Federal ambient pollution

control act), and some of them transposed EU Directives. Projections in 2006 indicated

that implementation of the adopted measures would leave Germany 61 kt NOx above the

ceiling, while integration of additional planned measures would bring the country below

the ceiling, i.e. 1050 kt. In 2009, Germany introduced the Integrated Strategy for the

Reduction of Nitrogen Emissions104, which presented emission reduction potentials and

policy recommendations directly and indirectly impacting NOx emission.


Together with the data required under the NECD, Germany provides Informative

Inventory Reports (IIR) which present information on the methodologies used in the

emission estimations and analysis of the trends.

NOX emissions in Germany have decreased by 54% from 1990 to 2010. According to the

emission data submitted by Germany in 2012 NECD, the major sectors for NOx emission

were the transport sector (particularly heavy duty vehicles, passenger cars and light duty

vehicles), public electricity and heat production and other stationary combustion sources

in manufacturing and construction industries. The largest decrease in NOx emissions

occurred in the passenger car sector and stationary combustion, with 73% and 72%

reduction respectively. According to the 2012 IIR, the NOx emission reductions in the

road transport sector were driven by the technological improvement, i.e. use of catalytic

converters. Although the total number of registered cars has increased by 33% from 1991

to 2010, the total energy (petrol and diesel only) consumed in the transport sector has

decreased by 8%. Emission data projections used for RAINS modelling105 at the time the

ceilings were set expected 23% increase in energy consumption in this sector. In

Germany, the number of petrol cars significantly exceeds the number of diesel cars both

for total registered cars (73%) and newly registered vehicles (58%), which is relatively

unusual for the EU where the number of newly registered diesel cars exceeds that of

petrol cars. Nevertheless, the share of registered diesel cars has increased from 14% in

1991 to 27% in 2010. While the activity data projections106 at the time the ceilings were

set suggested that diesel consumption in the transport sector will increase by 72% from

1990 to 2010, the latest Eurostat data shows this increase was only 45%. This low level

of passenger transport fleet dieselification in Germany compared to other European

countries might be explained by the tax policies favouring petrol over diesel cars.

NOX emissions in the public electricity and heat production sectors decreased until the

early 2000s as the result of decreasing use of lignite by power plants. An increasing trend

can be seen from 2002, which according to the IIR 2012 information, is the reflection of

103 Nationales Programm zur Verminderung der Ozonkonzentration und zur Einhaltung der Emissionshöchstmengen gemäß § 8

der 33 BimSchV 104 Integrated Strategy for the Reduction of Nitrogen Emissions. Federal Environment Agency, April 2009, available at

http://www.umweltdaten.de/publikationen/fpdf-l/3814.pdf 105 IIASA 1998 6th Interim Report, available from: http://gains.iiasa.ac.at/reports/pre-2002/6th interim a2.pdf 106 Supra note 105

http://www.umweltdaten.de/publikationen/fpdf-l/3814.pdf

100



the growing consumption of the biogas, wood and other biomass in this sector. The total

primary consumption of energy in Germany has decreased by 7%, which is a 4% greater

decrease than projected at the time of the RAINS projections development.

According to the IIR 2012, a completely new methodology for emission projections is

used in Germany since 2010. This method allows for integrated assessment of

greenhouse gas emission and air pollution as well as calculation of emissions under

various scenarios. The latest projections (IIR 2012) indicate that in 2015 NOx emission in

Germany will decline to 1182 kt, which is 131 kt above the 2010 NECD ceiling. The NOx

emission level is projected to drop to 1013 kt by 2020.

It should be noted that Germany's national inventories include NOx emissions from two

agricultural sectors that were not originally included in the RAINS model, i.e. 4.D.1.a

synthetic N-fertilizers and 4.D.2.a farm-level agricultural operations including storage,

handling and transport of agricultural products. These two sectors were responsible for

total of 99 kt of NOx emission in 2010 – 7% of the total national emissions and 35% of the

NECD ceiling exceedance in 2010.

Summary

The reasons for Germany's non-compliance with the NECD 2010 NOx ceiling are


estimated.

Table 8-2 Reasons for Germany's non-compliance with the NECD 2010 NOx ceiling, based on the


possible.

Contribution to

280.9 kt

Reason kt NOx %

Inclusion of previously not estimated emission sectors: In 2010 the

4.D.1.a and 4.D.2.a sectors contributed 99 kt of NOx emission, or 7% of the

total national emissions and 35% of the NECD ceiling exceedance

99 35%

Euro standard performance for cars: Overestimation of 2010 reductions

from road transport due to higher NOX emissions in real world driving

conditions than the test cycle emissions for the Euro standards

Changes in base year emission estimations

6% increase in base year emission estimations: 2000 CLRTAP vs. 2012

CLRTAP submission

8% increase in base year emission estimations: RAINS vs. 2012 CLRTAP

submission

101



Contribution to

280.9 kt

Reason kt NOx %

Underestimated emission projections: overestimation of expected reduction

from the planned measures


- With existing measures 1,124 kt

With additional measures 1,013 kt


- With existing measures 1,112 kt

With additional measures 1,050 kt

Recent growth in consumption of biofuels

Unexpectedly high “dieselification” of the road transport fleet: Increase in

proportion of diesel cars from 14% in 1991 to 27% in 2010. A major contributor

to the increase is lower diesel fuel prices compared to petrol.

8.3 Reasons for non-compliance as identified by Germany

A list of questions was sent to Germany in January 2013 and following a reply, a

telephone interview was held on 29 January with an official from the Federal Ministry for

the Environment, Nature Conservation and Nuclear Safety, and five specialists from the

Federal Environment Agency. Additional information was received after the telephone

interview.

The reasons identified by Germany for the non-compliance with the NECD 2010 NOx

ceiling are summarised in Table 8-3. The contribution to the exceedance is given in kt

where it has been provided by Germany.

Table 8-3 Reasons for Germany's non-compliance with the NECD 2010 NOx ceiling as identified by

Germany. Contribution to NOx emission exceedance is given in kt and percent where

provided by Germany.

Share of 280.9 kt

Reasons for exceedance of 2010 NOx ceiling kt NOx %

It was assumed that the implementation of Euro 3/4 and Euro III-IV

would strongly reduce overall emissions. Real-world driving NOx

emissions are significantly higher than the test-cycle emission limits.

The Euro 5 emission standards have also failed. 18 6%

The proportion of diesel passenger cars is significantly higher than

projected at the time the ceiling was set.

Traffic volumes are higher than originally projected in 1999.

There are higher NOx emissions from biomass combustion due to

"Energiewende". In 2010 this gave an additional 77 kt from energy

and manufacturing industries and 29 kt from small combustion.

106 38%

Delayed and weak EU emission standards for non-road mobile

machinery.

102



Inclusion of agricultural NOx emissions into the inventory increased

emissions by ca. 100 kt/a. These are not fully available for reduction

(so reduction as percentage of 1990 emissions was reduced from

ca. 60% to ca. 55%)

100 36%

The emission inventory at the time NEC ceilings were set was much

less complete and reliable than nowadays. For example, agricultural

emissions and incomplete source disaggregation in other sectors.

Emission projections at the time NEC ceilings were set were less

reliable in many ways. This includes traffic volumes, percentage of

diesel vehicles, vehicle emission factors and energy split (nuclear,

biomass)

The improvement in inventory methodology has in some cases

resulted in an increase of total assessed emissions (IIR 2012).

The difficulty to give reliable estimates for the energy sector, due to

annual changes.



legislation) and national projections, estimates were made for when Germany may reach

its 2010 ceiling in Table 8-4.

Table 8-4 Summary of projection analysis for Germany on the year to attain the 2010 ceiling (1051

kt). Emissions in kt/year – fuel sold



2010 fuel 2005 2010 2015 2020 2025 2030


1051 sold 1413 1462 1219 1228 991 1076 751 902 615 549



Notes: NFR categories 4D1 (emissions from soils) and 4D2 (handling of agricultural products) are deducted

from national values to ensure a coherent approach between Member States and enable comparison with the

GAINS model projections.


Based on the analysis made, Germany is likely to achieve compliance with NECD

2010 ceiling in about 2015 with current legislation.

8.5 Impact on Future Reduction Commitments

Table 8-5 gives an estimation of when the GP 2020 ceilings are likely to be reached,

based on the latest available national emission projection(s) and the results of GAINS

model projection (scenario: TSAP_Mar13_CLE (current legislation)). National projections

are compared to a target level based on the currently reported emission in 2005. To

minimize any bias in GAINS model projections, the GAINS model projections are

compared to a target level based on the GAINS projection for 2005.

103



Table 8-5 Estimated time for compliance – Gothenburg protocol (GP) – Germany. Emissions in

kt/year – fuel sold.


GP 2020 reduction

commitment Based on



2015 2020 2025 2030

% fuel


39 sold 862 893 991 1076 751 902 615 549





Based on the analysis made, Germany would reach its CLRTAP 2020 reduction

commitment between 2015 and 2020 according to the GAINS model current

legislation projections, while national projections indicate compliance only after

2020. This would suggest that additional measures may be needed to ensure

compliance.

8.6 Observations and recommendations for Germany

Issue: Germany applies national methodology for the assessment of emissions from road

transport (and also for non-road mobile machines). This methodology is considered better

by the country, however complicates inter-country comparison.

Recommendation:

Consider comparing the national methodology for road transport to the

Guidebook methodology (COPERT 4) for the assessment of emissions from road

transport.

104



105



9 Ireland

9.1 Introduction

Status of Ireland's NOx reduction commitments

Table 9-1 summarises the status in 2010 and 2011 of Ireland's commitments for national



Ireland has not ratified the Gothenburg Protocol. The table lists reported emissions in the

GP base years 1990 and 2005, and the two most recent years, 2010 and 2011. Distance

to target is given in kt and as a percent of the target value (ceiling). Ireland's NECD and

CLRTAP NOx emission totals are identical for these years in present reporting.

Table 9-1 Overview of Ireland's final 2010 and provisional 2011 NOx emission data submitted under

NECD and CLRTAP.

Ireland, NOX Fuel sold basis Fuel used basis




1990 (NECD.SUBM12) 122.6 57.6 88.6% 128.2 63.2 97.2%

2010 (NECD.SUBM12) 78.9 13.9 21.4% 75.4 10.4 16.0%

2011 (NECD.SUBM12) 70.5 5.5 8.5% 67.6 2.6 4.1%

CLRTAP NOX 2010 ceiling 65* 65*

1990 (CLRTAP.SUBM13) 122.6 57.6 88.6% 128.2 63.2 97.2%

2010 (CLRTAP.SUBM13) 78.9 13.9 21.4% 75.4 10.4 16.0%

2011 (CLRTAP.SUBM13) 70.5 5.5 8.5% 67.6 2.6 4.1%


2005 (CLRTAP.SUBM13) 127.4 62.4 96.1% 120.9 59.2 96.1%

2010 (CLRTAP.SUBM13) 78.9 13.9 21.4% 75.4 13.8 22.3%

2011 (CLRTAP.SUBM13) 70.5 5.6 8.5% 67.6 6.0 9.7%

* Ireland has not ratified the 1999 Gothenburg Protocol

Ireland reports emissions both on the basis of fuel sold and fuel used, and has chosen to

base compliance with the 2010 ceilings on the fuel used emissions. Ireland's NECD and

Gothenburg Protocol NOx ceilings for 2010 are the same (65 kt).

Ireland's fuel used NOx emission was 16% above the 65 kt NECD ceiling in 2010 and 4%

above in 2011. From 2010 to 2011, NOx emission decreased 8 kt (11%) based on fuel

sold and 8 kt (10%) based on fuel used. If the same rate of decline continues for 2012

emissions, Ireland will comply with the NECD 2010 NOx ceiling in 2012, for both fuel sold

and fuel used emissions. Ireland notes that NOX emissions in 2012 are likely to increase

rather than decrease.

For the 2012 Gothenburg Protocol amendments, Ireland agreed to a 49% NOx reduction

by 2020 from the base year 2005. This is equivalent to a 2020 NOx target of 65 kt for fuel

sold and 61 kt for fuel used, based on the presently reported 2005 emissions (shown in

grey in the table). The 2020 target based on fuel sold is unchanged from the 2010 ceiling

and the 2020 target based on fuel used is 3 kt (5%) lower than the 2010 ceiling. Just as

106



for the 2010 ceiling, if the rate of decline seen from 2010 to 2011 continues in 2012, the

new 2020 target could be reached in 2012, for both fuel sold and fuel used emissions.


The main reasons for Ireland's non-compliance with the NECD 2010 NOx ceiling are:

Vehicle NOx emissions (primarily diesel) under real-world driving conditions are much

higher than expected for Euro 1-5/I-V standards. An ETC/ACC study estimated 20 kt

additional NOX in 2010 (144% of 2010 exceedance based on fuel sold) due to

revisions of exhaust emission factors from the 1999 RAINS projections to COPERT 4

v8.0. Ireland attributes 15 kt to the failure of the Euro standards (144% of the 2010

exceedance based on fuel used).

Ireland had the second highest growth in overall road transport fuel consumption (fuel

sold) among the EU-15. Ireland's 60% diesel share in 2010 was not unusual among

the EU-15, but it was much higher than assumed in 1999. The ETC/ACC study

estimated the increase in vehicle activity and change in fleet composition compared

to the 1999 RAINS assumptions added 5 kt to the 2010 NOX emission (36% of the

2010 exceedance based on fuel sold).

Economic growth was much higher than assumed in 1999, particularly in the

construction industry. GDP increased 127% from 1995 to 2008, but has declined 6%

from 2008 to 2010.

Inventory improvements added emissions from agriculture (fishing) that were not

included at the time the ceilings were set, adding nearly 2 kt to the 2010 NOX

emission (18% of the 2010 exceedance).

Reduction of CO2 emissions via combustion units below 50 MW has increased NOX

emissions.


Ireland is projected to comply with the NECD 2010 ceiling shortly after 2015 by

national projections. The level projected for 2015 has already been reached in 2011,

so compliance could be obtained before 2015. The GAINS model, which

overestimates emissions in 2005 (11%) and 2010 (20%), projects compliance shortly

after 2020 with current legislation.

Ireland is projected to comply with its CLRTAP 2020 reduction commitment shortly

after 2015 by national projections and reported emissions in 2011 have already

reached the level projected for 2015. The GAINS model projects compliance between

2020 and 2025, with current legislation.





According to NECD Annex I, Ireland was to attain 65 kt NOx emissions by 2010, which

corresponds to the ceilings established in Gothenburg’s Protocol. The NEC Directive is

107



transposed to Irish system through European Communities (National Emission Ceilings)

Regulations 2004107 reflecting emission ceilings set in the Directive.

Ireland’s first National Programme under the NECD was published in June 2003. The

programme presents measures that were already in place and additional measures that

were planned to be implemented before 2010, including regulatory, fiscal and voluntary

measures. The programme identifies the transport sector as being the most problematic,

and indicates the need for assessment of cost and benefits of proposed measures and

development of synergies with other relevant programmes and strategies including

climate change strategy. The projections presented in the National Programme show that

even the implementation of additional measures proposed in the programme would not

bring the NOx emission level below the 2010 NECD ceiling, exceeding it by 17 kt.

The National Programme concluded that taking into consideration the knowledge

available at the time and the national circumstances, achievement of NOx emission

ceiling would be prohibitively expensive for the national economy.

The review of the national programme was finished in 2007. The revised programme

stated that Ireland is in a difficult position regarding NOx emissions and additional

measures are needed to move closer to the ceiling. Besides providing the list of

implemented measures, the programme included examples of additional measures and

assumptions required to further reduce NOx emissions, such as renewable energy

making up 18% of total energy consumed by 2010 (linear increase to 30% by 2020),

increase of wind energy component up to 14% of total energy production, assumption of

strict BAT (500 mg/m3) for cement sector, examination of viability of retrofitting scheme

for HDVs and captive fleets.

The incorporated emission projections demonstrated that under “with measures” scenario

NOx emission ceiling will be exceeded by 33 kt in 2010, while emission estimated based

of “with additional measures” scenarios would leave Ireland 28 kt above the ceiling.


Compliance with the CLRTAP and NECD ceilings for Ireland is assessed based on “fuel

used”. For the purpose of the emission reporting (both under CLRTAP and NECD

submissions) national emissions are reported based on “fuel sold” (using data from the

energy balance), together with the national total and emissions from the transport sector

calculated based on “fuel used”.

According to the 2012 NECD submission, the total NOx emission in Ireland in 2010 was

79 kt based on “fuel sold” and 75 kt based on “fuel used”, which are 14 kt or 10 kt above

the ceiling. From 1990 to 2020, the total NOx emission have decreased by 36% based on

fuel sold and by 41% based on fuel used.

At the beginning of the 1990s, the main source of NOx emissions in Ireland was public

electricity and heat production sector, which according to the 2012 IIR experience a

decline in the emissions of 75% or 35 kt by 2010. This can be explained by the significant

change from oil and solid fuels to gas. Road transport NOx emissions contributed 50% of

total (based on fuel used) in 2010.

107 European Communities (National Emissions Ceilings) Regulations 2004. SI n° 10 of 13/1/2004

108



While NOx emissions in passenger transport have decreased dramatically (61%),

emissions from heavy vehicles and light duty vehicles have been increasing during the

same period (5% and 87% respectively), with a slight decline after 2008, which coincides

with the economic downturn.

Reductions in NOx emissions from passenger cars and heavy-duty vehicles resulting

from the technology improvements (such as use of catalytic converters), in Ireland have

been largely offset by the significant increase in the number of passenger cars (119%

from 1992 to 2007108) as well as growing freight volumes (55% increase in the volume of

national road freight transport (2000-2011) and increase in from proportion of freight

transported by road from 90% in 1990 to 99% in 2010). Moreover, the role of diesel cars

in the road transport fleet has become more significant. The share of diesel cars in

Ireland has increased from 12% in 1992 to 18% in 2007. The volume of used diesel fuel

in transport sector has increased by 241% from 1990 to 2010, which is a much greater

increase than had been expected at the time the ceilings were set109 (141%). The total

final energy consumed by transport sector has increased by 130% from 1990 to 2010.

The comparison of prices for diesel and petrol fuel in Ireland shows no observable

preference between the two fuel types. At the same time, fuel prices were in general

lower in Ireland than in the UK, which explains the significant impact of “fuel tourism”.

According to the Pilot response110 submitted by Ireland in 2010, the difference between

the vehicle emissions calculated based on knowledge at the time the ceilings were set

ant emissions based on the recent knowledge of real world driving emissions amounted

to 15 kt (23% of the NOx ceiling, 144% of the 2010 exceedance).

Emissions from stationary combustion in manufacturing industry have increased by 16%

since 1990. According to the IIR 2012, the main contribution to this increase came from

the cement production sector which experienced significant growth during the last decade

driven by the high economic growth, which was not foreseen at the time the ceilings were

set.

The most recent emission projections submitted in March 2013 (CLRTAP) indicate that

NOx emissions in Ireland in 2020 will decline to 56 kt based on the “with measures”

scenario, or 54 kt “with additional measures”, both below the 2010 ceiling and the GP

2020 reduction target.

Summary

The reasons for Ireland's non-compliance with the NECD 2010 NOx ceiling are


be estimated.

108 In comparison to 36.5% in BE, 38% in DE, 40% in NL, 37% in UK; due to incomplete data available from Eurostat is it

impossible to adequately estimate EU-27 average. 109 IIASA Seventh Interim Report, 1999, available from: http://www.iiasa.ac.at/~rains/reports/ir7.pdf 110 Pilot Response by Ireland (Reference - 13.8.4 vol 2) in response to the Pilot request (Reference - DG ENV C.3 PV/cl Ares

(2010))


109



Table 9-2 Reasons for Ireland's non-compliance with the NECD 2010 NOx ceiling, based on the


possible.

Contribution to

exceedance of

10.4 kt

Reasons kt %

Euro standard performance for cars: Overestimation of 2010 reductions

from road transport due to poor “on-road” performance of Euro standards

15 kt

(2009)111 144%

Inclusion of new emission category previously not estimated: New

category include: 1 A 4 c iii Agriculture/Forestry/Fishing: National fishing 1.86112 18%

Unexpected economic growth: Increase in economic activity, particularly

construction industry until 2008 (126.5% increase in GDP from 1995 to

2008, and 6% decrease from 2008 to 2010)

Unexpectedly high “dieselification” of road transport fleet (although of

a moderate rate compared to the EU average): proportion of diesel cars

increased from 12% in 1992 to 18% in 2007. The baseline activity

projection used in RAINS113 underestimated diesel fuel consumption in the


The increase was in part due to fiscal policies favouring vehicles with lower

CO2 emissions.

Increase in the share and total volume of freight transported by road:

The share of freight transported by road increased from 90% in 1991 to

99% in 2010, and the volume of freight transport by road increased by 55%

from 2000 to 2011.

Increase in the total number of passenger cars and increase in total

energy consumed by the transport sector:

- Increase in total number of passenger cars: 119% from 1992 to

2007

- Total energy consumption in the transport sector increased 130%

from 1990 to 2011

9.3 Reasons for non-compliance as identified by Ireland

The reasons for non-compliance with the NECD NOx ceiling for 2010 as identified by

Ireland are based on a telephone interview with an official from the Department of

Environment, Community and Local Government on 8 March 2012 and documents

provided or referenced by the official.

The reasons for Ireland's non-compliance with the NECD 2010 NOx ceiling are

summarised in Table 9-3. The contribution to the exceedance is given in kt where

provided by Ireland.

111 Pilot Response by Ireland (Reference - 13.8.4 vol 2) in response to the Pilot request (Reference - DG ENV C.3 PV/cl Ares

(2010)) 112 Ireland’s IIR 2012 113 IIASA 1998 6th Interim Report, available from: http://gains.iiasa.ac.at/reports/pre-2002/6th interim a2.pdf

110



Table 9-3 Reasons for Ireland's non-compliance with the NECD 2010 NOx ceiling as identified by

Ireland. Contribution to NOx emission exceedance is given in kt and percent where

provided by Ireland.

Share of 10.4 kt

Reason kt NOx %

Failure of the Euro standards. 15 144%

Actual economic growth in Ireland since 1990 has been much

higher than foreseen at the time the ceiling was set

Due to high economic growth, transport activity in 2010 was much

higher than projected in 1999.

Construction activity in 2010 was higher than projected in 1999.

The vehicle fleet in Ireland is comparatively young, but the smaller

reductions in real world diesel NOx emissions, or even increase in

the case of Euro 5, reduces the benefit of rapid fleet turnover on

NOx emissions.

Implementation of emission reduction technologies has been

greater than projected in 1999, but this has been insufficient to

compensate for the unexpected growth and Euro failure.



legislation) estimates were made for when Ireland may reach its 2010 ceiling in Table

9-4.

Table 9-4 Summary of projection analysis for Ireland on the year to attain the 2010 ceiling (65 kt).

Emissions in kt/year



2010 fuel 2005 2010 2015 2020 2025 2030


65 sold 142 127 95 79 95 67 86 56 65 47 49

used 135 121 91 75 91 64 82 54 62 45 47



Notes:

a. Values based on fuel used are the basis for compliance assessment. Calculations of NOX emissions in the

GAINS model are based on fuel sold.

b. The GAINS values based on fuel used are estimated here based on the fuel used/fuel sold ratio from

national emissions or projections in the same year.


Based on the analysis made, Ireland is projected to comply with the NOX ceiling

shortly after 2015 by national projections. The level projected for 2015 has already

been reached in 2011, but Ireland indicates that national NOX emissions in 2012 are

likely to increase. The GAINS model, which overestimates emissions in 2005 (11%)

and 2010 (20%), projects compliance shortly after 2020 with current legislation.

111





based on the results of GAINS projection (scenario: TSAP_Mar13_CLE (current

legislation)). National projections are compared to a target level based on the currently

reported emission in 2005. To minimize any bias in GAINS model projections, the GAINS

model projections are compared to a target level based on the GAINS projection for

2005.

Table 9-5 Estimated time for compliance – Gothenburg protocol (GP) – Ireland. Emissions in kt/year.


GP 2020 reduction

commitment Based on



2015 2020 2025 2030

% fuel


49 sold 72 65 95 67 86 56 65 47 49

used 69 62 91 64 82 54 62 45 47





Based on the analysis made, Ireland is likely to comply shortly after 2015

according to national projections. Reported emissions in 2011 have already

reached the level projected for 2015 by the national projection, but Ireland

indicates that national NOX emissions in 2012 are likely to increase. The GAINS

model projects compliance between 2020 and 2025, with current legislation.

112



113



10 Luxembourg

10.1 Introduction

Status of Luxembourg's NOX reduction commitments

Table 10-1 summarises the status in 2010 and 2011 of Luxembourg's commitments for

national NOx emissions under the NECD and the 1999 CLRTAP Gothenburg Protocol,




as a percent of the target value (ceiling). Luxembourg's NECD and CLRTAP NOx

emission totals are different for these years in present reporting, apparently due to

differences in source categories included in the NECD and CLRTAP inventory reporting.

Table 10-1 Overview of Luxembourg's final 2010 and provisional 2011 NOx emission data submitted

under NECD and CLRTAP.

Luxembourg, NOX Fuel sold basis Fuel used basis




1990 (NECD.SUBM11) 41.5* 30.5 277.2% 23.8 12.8 116.3%

2010 (NECD.SUBM12) 46.1 35.1 319.4% 17.9 6.9 63.0%

2011 (NECD.SUBM12) 48.2 37.2 338.1% 18.0 7.0 64.0%


1990 (CLRTAP.SUBM13) 38.7 27.7 252.1% 21.0 10.0 91.1%

2010 (CLRTAP.SUBM13) 45.8 34.8 316.4% 17.6 6.6 60.0%

2011 (CLRTAP.SUBM13) 47.9 36.9 335.1% 17.7 6.7 60.9%


2005 (CLRTAP.SUBM13) 61.8 26.6 75.4% 18.9 8.1 75.4%

2010 (CLRTAP.SUBM13) 45.8 10.6 30.1% 17.6 6.8 63.1%

2011 (CLRTAP.SUBM13) 47.9 12.6 35.9% 17.7 6.9 64.1%

* Luxembourg has not reported the 1990 NOx emission under NECD based on fuel sold. The 1990 NECD fuel sold value is

estimated from the fuel used value (NECD.SUBM11), adjusted by the difference between CLRTAP 1990 fuel sold and fuel used emissions (CLRTAP.SUBM13).

Luxembourg reports emissions both on the basis of fuel sold and fuel used, and has

chosen to base compliance with the 2010 ceilings on the fuel used emissions.

Luxembourg's fuel used NOX emission was 63% above the 11 kt NECD ceiling in 2010

and 64% above in 2011. NOX emissions increased slightly from 2010 to 2011 based on

fuel used (0.1 kt, 0.6%), and 2.1 kt (5%) based on fuel sold.

Emissions based on fuel sold have been much higher than based on fuel used, due to

high levels of "tank tourism" in Luxembourg. Reported NOx emissions based on fuel sold

were 74% higher than the fuel used emission in 1990, increasing to 227% higher than

fuel used in 2005 before declining to the present 168% greater than fuel used emissions.

The difference between fuel sold and fuel used NOx emissions was 28 kt in 2010 and 30

kt in 2011.

114



The Gothenburg Protocol 2020 reduction commitment for Luxemburg – 43% NOX

reduction between 2005 and 2020 – was based on the need to continue to respect the

existing 2010 NOx ceiling in the NECD (11 kt NOx). The equivalent NOX target value in

2020 is also 11 kt (rounded) based on the presently reported 2005 fuel used emission.

The target based on fuel sold is 35 kt (targets shown in grey in the table).


The main reasons for Luxembourg's non-compliance with the NECD 2010 NOx ceiling

are:


higher than expected for Euro 1-5/I-V standards.


assumed in 1999 RAINS projections.


additional 30% of the population. Non-resident commuter traffic was not included in

projections at the time the ceilings were set.

Primary energy consumption in 2010 was 51% greater than assumed for the 1999

RAINS projections. In contrast, almost all other EU-15 states had lower primary

energy consumption in 2010 than was assumed in 1999.

Luxembourg had the greatest increase (146%) in road transport fuel consumption

(fuel sold) from 1990 to 2010 among the EU-15. The difference in growth rate from

that assumed in 1999 (21%) was also the largest among the EU-15. NOX emissions

from heavy duty diesel vehicles increased 59% from 1990 to 2010, while emissions

declined in this sector in many Member States.

Diesel fuel consumption for road transport increased 287% (fuel sold114) from 1990 to

2010 - the largest percentage increase among the EU-15 - while petrol consumption

only declined by 15%. The diesel share of road transport fuel consumption was 83%

in 2010, twice the share estimated when the ceilings were set (41%). The high

dieselification is largely the result of climate policy to reduce CO2 emissions, including

CO2-based vehicle tax and diesel fuel tax incentive.


electricity previously imported and adding 0.5 kt NOX (8% of the 2010 exceedance).





The GAINS model, with a rough adjustment to fuel used basis, projects Luxembourg

to comply with the 2010 ceiling shortly after 2010. Without a national projection or

estimate of future fuel export for adjustment of the GAINS projections, this result is

much more uncertain than the others.

Luxembourg is likely to comply with its CLRTAP 2020 commitment before 2015

according to the GAINS model.



115







Luxembourg’s NECD NOx ceiling for 2010 is 11 kt. The same ceiling value is given in the

Gothenburg Protocol. These requirements have been transposed into national legislation

by Regulation of November 8, 2002115, which explicitly states the values of national

emission ceilings and presents a basis for development and submission of a programme

for progressive reduction of the pollutants at issue.

Luxembourg’s first National Programme under NECD was completed in 2003. The

programme presented policies and measures implemented at the time of the National

Programme development (“Business-as-usual”). Additionally, planned measures with

estimated emission reductions and some additional measures were included in the

programme. Projections under the “business-as-usual” scenario indicated that the NOX

emission in 2010 would be 14.2 kt, which is more than 4 kt (29%) above the ceiling.

Luxembourg acknowledged the need for additional policies and measures. According to

the 2003 programme, implementation of all proposed measures, including the most

expensive and economically unfeasible measures, would reduce the NOX emission to a

level below the NECD ceiling, i.e. 10.9 kt.

The revised National Programme116 was published in December 2008, two years after the

deadline provided by the NECD. NOX emissions projections in the 2008 National

Programme are lower than those in the 2002 National Programme (due to changes in

emission factors). NOX emission projections under the “business-as-usual” scenario were

expected to be 1.7 kt (15%) above the NECD ceiling. However, the review of the

programme provided no information on the planned measures which could be

implemented in order to bring the NOX emission under the ceiling by 2010.

In 2010, Luxembourg provided information117 on additional measures that were

considered to be necessary for progress towards the NOx ceiling. These mostly focused

on transport sector. It was argued that these additional measures were expected to

“reduce NOx emissions to 11 kt by 2010, or at least as soon as possible”.


Luxembourg has not submitted any Informative Inventory Reports (IIR) together with their

emission inventory data since 2008. There is thus no information on the inventory or

projection methodologies or the activity data used. Annual submissions included only a

single inventory year each year until 2011, when recalculated emissions for years 1990 to

2009 were submitted.

Luxembourg is among the countries which base compliance with the NECD ceilings on

“fuel used” emissions. The 2012 submission indicated that the difference between the

total annual NOx emissions based on fuel sold and fuel used in 2010 was 28.3 kt (257%

of the NECD ceiling).

115 Règlement grand-ducal du 8 novembre 2002 portant application de la directive 2001/0081/CE fixant des plafonds d'émission

nationaux pour certains pollutants atmosphériques Mémorial A n° 129 du 02/12/2002 p. 3032 116 Révision du programme national de réduction des émissions de SO2, NOx, COV et NH3, décembre 12, 2008 117 Reference: AEV/NEC/DGENV15_06_2010 M10/1772

116



Notable differences in the total NOx emission reported in different years by Luxembourg

can be identified, signalling that recalculation took place. However, no details on the

reasons for or nature of these changes are provided.

The NECD emission inventory submitted in 2012 shows total NOx emissions in

Luxembourg in 2010 based on “fuel used” were 17.9 kt, which is 6.9 kt or 63% above the

NECD ceiling. Total NOx emissions based on fuel sold have increased by 19% from 1990

to 2010, while emissions based on fuel used have increased 14%.

The major NOx emission contributing sector in Luxembourg in 2010 was road transport.

Heavy duty vehicles are responsible for more than 56% of total emission (based on “fuel

sold”). When assessed based on “fuel used” (NECD 2011 submission) different major

emitting sectors can be identified, i.e. public electricity and heat production, heavy duty

vehicles and stationary combustion in manufacturing industries and construction each

contribute approximately 16% of total NOx emission, closely followed by passenger

transport with 15% of total emissions. Only in the stationary combustion sectors have

NOx emissions decreased from 1990 to 2010 (6%). Emissions in other major NOx

contributing sectors have increased during the same period.

The upward trend in the NOx emissions in the road transport sector coincides with the

growth in the total number of registered vehicles (52%), as well as significant increase in

the share of diesel cars in Luxembourg in the past decade (from 17% in 1993 to 62% in

2009). The energy consumption in transport sector (petrol and diesel only) has increased

by 146% from 1990 to 2010. In contrast, at the time the ceilings were set118, this increase

was expected to reach only 21%. Moreover, 1998 activity data projections indicated that

diesel consumption would increase by 17%, while the latest Eurostat data shows that the

actual increase amounted to 305%. The share of road transport in the freight transport

sector has also increased by more than 10% since 1990. The price of diesel fuel in

Luxembourg has been significantly lower than petrol prices during the reviewed period.

Moreover, fuel prices were also considerably lower compared to the neighbouring

countries, which explains the significant impact of “fuel tourism” in the country.

In the past two decades, final energy consumption in the industrial sector has significantly

decreased (60%), particularly in oil and solid fuels. A considerable impact on the NOx

emissions was brought about by the new co-generation power plant with the capacity of

350 MW which went online in 2002. According to the national estimations this resulted in

additional NOx emissions of approximately 0.5 kt. The increase in population of 33% from

1990 was presented as one of the significant factors responsible for the increase in the

energy consumption, particularly in transport sector.

Luxembourg submitted no emission projections other than those presented in the both

editions of National Programmes.

Summary

The reasons for Luxembourg's non-compliance with the NECD 2010 NOX ceiling are


be estimated.

118 IIASA 1998 6th Interim Report, available from: http://gains.iiasa.ac.at/reports/pre-2002/6th interim a2.pdf

117



Table 10-2 Reasons for Luxembourg's non-compliance with the NECD 2010 NOx ceiling, based on the


possible.

Contribution to

exceedance of

6.9 kt

Reason kt NOx %

New co-generation plant installed in 2002 0.5119 8%

Unexpected increase in total number of passenger cars and energy

consumption in transport sector:

- Increase in total number of passenger cars: 52%

- Increase in total energy consumption in transport sector: 145%

compared to the projected 21%120 (petrol and diesel only)

Incorrect assumption at the time of GP/NECD negotiations: activity data

projection used for RAINS modelling underestimated primary energy

consumption in 2010 by 1560 thousand TOE or 51%

Unexpectedly high “dieselification” of road transport fleet: proportion of

diesel cars increased from 17% in 1993 to 62% in 2009. Baseline activity

projection used in RAINS121 underestimated diesel fuel consumption by



- Fiscal policies favouring vehicles with lower CO2 emissions

- Lower diesel fuel prices compared to petrol


reductions from road transport due to poor “on-road” performance of Euro

standards

Underestimated emission projections: overestimation of expected reduction

from the planned measures

2002 National Programme projections:

With Measures 12.9 kt

With additional measures 10.9 kt

2006 National Programme projections:

Business-as-usual 12.7 kt

2006 Review of National Programme provided no information on

implementation of existing measures or planned measures

10.3 Reasons for non-compliance as identified by Luxembourg

The reasons for non-compliance with the NECD 2010 NOx ceiling as identified by

Luxembourg are summarised in Table 10-3. The contribution to the exceedance is given

in kt where it can be estimated.

119 The letter to Commissioner for Environment of the EC from Department of Environment of Ministry of Sustainable

Development and Infrastructure of Luxembourg of 25 April 2012. 120 IIASA 1998 6th Interim Report, available from: http://gains.iiasa.ac.at/reports/pre-2002/6th interim a2.pdf 121 IIASA 1998 6th Interim Report, available from: http://gains.iiasa.ac.at/reports/pre-2002/6th interim a2.pdf

118



Table 10-3 Reasons for Luxembourg's non-compliance with the NECD 2010 NOx ceiling as identified

by Luxembourg. Contribution to NOx emission exceedance is given in kt and percent

where provided by Luxembourg.

Share of 6.9 kt

Reason kt NOx %

The failure of the Euro vehicle emission standards.

The population has increased much more rapidly than assumed at

the time the ceiling was set: 33% from 1991 to 2010.

The number of non-resident commuters has also increased sharply,

now equivalent to about 30% of the population. Commuters mostly

use cars, and the non-resident commuter traffic was not included in

projections at the time the ceiling was set.

Energy demand has increased more rapidly than assumed at the

time the ceiling was set, due to population and commuter growth.

The CO2-based vehicle tax and diesel fuel tax incentives to reduce

CO2 emissions have succeeded, but the resulting dieselification of

the car fleet has increased NOx emissions.

The high living standard is accompanied by high fleet turnover and a

relatively young vehicle fleet. The failure of Euro 4 and 5 diesel NOx

standards (or even an emission increase for Euro 5) eliminates the

advantage of rapid penetration of new vehicle emission standards.

A new gas turbine CHP power plant has come online since 2002,

providing electricity that was previously imported. This may not have

been included in the projections at the time the ceiling was set.

0.5 7%

Extensive new residential and commercial construction means a

relatively high proportion of small combustion units are recent high-

efficiency and low-emission units. The default NOx emission factors

used for domestic heating (1A4) probably assume an older average

technology, resulting in higher NOx emissions in this sector than

actually occurs.

Combustion of biomass has increased (doubled) during the last

decade, with higher NOx emissions. The current impact is not very

big, but will increase in the coming years.



legislation) estimates were made for when Luxembourg may reach its 2010 ceiling in

Table 10-4.

119



Table 10-4 Summary of projection analysis for Luxembourg on the year to attain the 2010 ceiling (11

kt). Emissions in kt/year – fuel sold (fuel used based emissions in brackets)



2010 fuel 2005 2010 2015 2020 2025 2030


11 sold 48 64 40 46 25 19 12 10

used 14 21 11 18 7 6 4 4



Notes:

a. Values based on fuel used are the basis for compliance assessment. Calculations of NOX emissions in the

GAINS model are based on fuel sold. The GAINS values based on fuel used are estimated here based on

the fuel used/fuel sold ratio for road transport from national emissions or projections in the same year. The

2011 fuel used/fuel sold ratio for reported emissions from the road transport sector is used for all projection

years.



c. NFR (Nomenclature for Reporting) categories 4D1 (emissions from soils) and 4D2 (handling of agricultural

products) are deducted from national values to ensure a coherent approach between Member States and

enable comparison with the GAINS model projections.

d. Fuel sold emissions are about 2½ times larger than fuel used emissions in 2010, making fuel export




Luxembourg has not submitted national projections, and fuel export NOX

emissions are significantly larger than national fuel used emissions and vary over

time. The analysis shows that if the GAINS model projections (which are based on

fuels sold) are adapted to instead assess projections for fuels used (by applying

the same fuel used/fuels sold ratio for emissions from the road transport sector as

reported in 2010), Luxemburg should reach compliance already shortly after

2010.this result is for the above reasons more uncertain than the others. In

addition, Luxembourg has questioned the assumptions used for the GAINS model

projections, especially regarding transit traffic through Luxembourg.



based on the results of GAINS model projection (scenario: TSAP_Mar13_CLE (current

legislation)). Comparisons are based the baseline values for 2005 from Annex II, Table 3

of the Gothenburg Protocol. In addition, baseline values based on national reports and

GAINS model estimates for 2005 are presented for information.

120



Table 10-5 Estimated compliance period – Gothenburg protocol (GP) – Luxembourg. Emissions in

kt/year – fuel sold (fuel used based emissions in brackets)


GP 2020 reduction

commitment Based on



2015 2020 2025 2030

% fuel


43 sold 27 36 25 19 12 10

used 9 12 7 6 4 4



Notes: See notes under Table 10-4.

It must be noted that Luxembourg questions the assumptions used for these GAINS

projections, especially regarding transit traffic through Luxembourg.


Based on the analysis made Luxembourg is likely to comply with its CLRTAP 2020

commitment before 2015 according to the GAINS model (based on fuels sold), but

no national projections are available for comparison, making this conclusion more

uncertain that the others.

10.6 Observations and recommendations for Luxembourg

Issue: National emission projections are not available for the years after 2010.

Recommendation:

Develop national emission projections, in order to estimate future compliance

and the possible need for additional measures to meet the reduction

commitments.

Issue: No information on methodologies and activity data used for emission estimation is

available.

Recommendation:

Develop and submit IIR presenting detailed descriptions of the methodologies

and activity data used for emission estimation.

121



11 Croatia

11.1 Introduction

Status of Croatia's NH3 reduction commitments

Croatia became a Member of the EU in July 2013. NECD 2010 ceilings for Croatia are

set equal to the Gothenburg Protocol 2010 ceilings122. Croatia did not have NECD

ceilings previously, and has not reported yet under NECD. Croatia has reported under

CLRTAP. Table 11-1 summarises the status of Croatia's commitment for national NH3

emissions in 2010 and 2011 under NECD and the 1999 CLRTAP Gothenburg Protocol,




as a percent of the target value (ceiling).

Table 11-1 Overview of Croatia's final 2010 and provisional 2011 NOx emission data submitted under

NECD and CLRTAP.

Croatia, NH3 emission distance to target

Year (submission year) kt NOX kt NOX %

NECD/CLRTAP NH3 2010 ceiling 30

1990 (CLRTAP.SUBM13) 50.9 20.9 69.7%

2010 (CLRTAP.SUBM13) 38.1 8.1 27.1%

2011 (CLRTAP.SUBM13) 36.8 6.8 22.7%

CLRTAP NH3 2020 reduction 1% 40.0

2005 (CLRTAP.SUBM13) 40.4 0.4 1.0%

2010 (CLRTAP.SUBM13) 38.1 -1.9 -4.7%

2011 (CLRTAP.SUBM13) 36.8 -3.2 -7.9%

Croatia's reported NH3 emission was 8 kt (27%) above the 30 kt CLRTAP ceiling in 2010

and 7 kt (23%) above in 2011. Croatia's reported NH3 emission declined 1.3 kt (3%) from

2010 to 2011.

For the 2012 Gothenburg Protocol amendments, Croatia agreed to a 1% NH3 reduction

by 2020 from the base year 2005. This is equivalent to a 2020 NH3 target of 40 kt based

on the presently reported 2005 emission. This target is 10 kt (33%) higher than the NECD

2010 ceiling. Croatia's NH3 emission has been under the GP 2020 target since 2008. The

reported NH3 emission for 2010 is 1.9 kt (5%) below the GP 2020 target, and the

preliminary 2011 NH3 emission is 3.2 kt (8%) below it.


The main reasons for Croatia's non-compliance with the NECD 2010 NH3 ceiling are:

National NH3 emission factors in use at the time the CLRTAP ceilings were set

underestimated NH3 emissions significantly. Croatia began to use the EMEP/EEA

122 Croatia’s NECD 2010 ceilings are established in Council Directive 2013/17/EU of 13 May 2013 adapting certain directives in

the field of environment, by reason of the accession of the Republic of Croatia. http://eur-

lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32013L0017:EN:NOT



122



Guidebook emission factors in 2003, which increased the 1990 GP base year NH3

emission from the 37 kt level listed in the Gothenburg Protocol to nearly 56 kt, a 50%

increase. Further improvements (improved agricultural activity data) have revised the

base year emission to the present 51 kt level. The fixed 30 kt ceiling required a 7 kt

(19%) emission reduction from the original GP base year emission, but the improved

methodology increased the required emission reduction by 14 kt (173% of the

exceedance in 2010). Although Croatia has reduced annual NH3 emissions by 13 kt

compared to 1990, which is nearly twice the reduction foreseen when the ceiling was

set, it is still 7 kt above the ceiling.


emission reductions were first adopted in 2008. These included a national NH3 ceiling

of 45 kt rather than the 30 kt CLRTAP ceiling. Proposed reduction measures were

insufficient to meet the CLRTAP and NECD 2010 ceiling.


Croatia shows continued exceedance of the NECD 2010 NH3 ceiling through 2030

according to both national and GAINS model current legislation projections. Based on

this analysis, Croatia is not likely to reach compliance with its NECD 2010 ceiling

without additional measures beyond current legislation.










Croatia is a party to the Gothenburg Protocol, which sets a 2010 ceiling of 30 kt for NH3.

The GP 2010 ceilings are now adopted as Croatia's NECD 2010 ceilings122. Regulation

on emission quotas for certain pollutants in the Republic of Croatia (OG No. 141/08)

transposes requirements set forth by CLRTAP and sets the national ammonia emission

ceilings at the level of 45 kt, which is 50% higher than the ceiling Croatia agreed to under

the Gothenburg Protocol.

The Regulation on emission quotas also prescribes the development of a programme for

gradual reduction of emissions of certain pollutants in the Republic of Croatia until year

2010 with emission projections for the period from 2010 to 2020. This corresponds to the

NECD requirement for development of national programmes.

The National Programme developed in 2008 identified three measures for the reduction

of ammonia emissions implemented at the time of programme development: effective

manure management, national use of mineral fertilizers based on soil analysis and

nutrient balance and reduction of emissions from production of NPK fertilizers.

Implementation of these measures was closely related to integration of EU Directives,

particularly the Nitrate Directive, which indirectly influences NH3 emissions into

atmosphere.

123



In August 2013, Croatia adopted a new regulation (OG 108/13) establishing the

GP/NECD 30 kt NH3 ceiling and repealing the national 45 NH3 kt ceiling. Croatia indicates

that the National Programme is to be revised as necessary.


Since Croatia was not an EU Member State until July 2013, it has not yet submitted

emission inventories under the NECD. Information on the emission inventories and

emission projections submitted by Croatia under the Gothenburg Protocol have been

analysed in this study.

Croatian emission inventories are currently based on the methodologies and emission

factors presented in the EMEP/EEA Emission Inventory Guidebook. Before 2003, the

methodology for estimation of NH3 emissions used national emission factors for the

agricultural sector based on expert opinion. The change to EMEP/EEA Guidebook

emission factors in 2003 resulted in a significant increase in NH3 emissions for the whole

time series. The 1990 GP base year emission of NH3 was given as 37 kt in the 2002 IIR

submission, but was raised to 56 kt in the 2007 IIR submission – an increase of 50% due

to the change in emission factors. This recalculated time series was used by Croatia in

the development of the Regulation on emission quotas (2008).

Total ammonia emissions have decreased by 26% from 1990 to 2010. According to

Croatia’s CLRTAP 2012 IIR, the agricultural sector is responsible for 78% of the NH3

emissions. The “Other chemical industry” sector (NFR 2 B 5 a) and Wastewater treatment

(NFR 6 B) are the other major contributors of NH3 emissions with 10% and 8%

respectively. Ammonia emissions in 2010 have decreased by 26% compared to 1990,

mainly as the result of the significant decrease in the livestock population. The 2010 NH3

emission exceeded the 30 kt Gothenburg Protocol ceiling by 25%, but was below the 45

kt national NH3 ceiling set in the Croatian national Regulation of emission quotas.

The emission projections developed as part of the National Programme indicated that the

45 kt national NH3 emission ceiling will be achieved under the “business-as-usual”

scenario by 2010, while the 30 kt Gothenburg Protocol ceiling for NH3 will not be reached

by 2010 or by 2020, even with additional measures implemented – remaining more than

10 kt (30%) above the ceiling.

At the time the NECD was being developed in 1999, the RAINS model NH3 projections

for the REF and H1 scenarios123 indicated that Croatia would achieve an ammonia

emission of 37 kt by 2010, an 8% reduction from the 1990 emission listed as 40 kt124.

Croatia had already accepted an even lower ammonia ceiling of 30 kt under the

Gothenburg Protocol, which listed Croatia's 1990 NH3 emission as 37 kt (GP Annex II,

Table 3).

Summary

The reasons for Croatia's non-compliance with the NECD 2010 NH3 ceiling are


be estimated.

123 IIASA Seventh Interim Report (1999) Cost-effective control of acidification and ground-level ozone:

http://webarchive.iiasa.ac.at/~rains/reports/ir7.pdf

124 Amann, M., Bertok, I., Cofala, J., Gyarfas, F., Heyes, C., Klimont, Z., & Schöpp, W. (1999). Integrated Assessment Modelling

for the Protocol to Abate Acidification, Eutrophication and Ground-level Ozone in Europe. IIASA, for the Netherlands

Ministry of Housing, Spatial Planning and the Environment. http://www.iiasa.ac.at/rains/dutch/dutch2.pdf


http://www.iiasa.ac.at/rains/dutch/dutch2.pdf

124



Table 11-2 Reasons for Croatia's non-compliance with the NECD 2010 NOx ceiling, based on the

independent assessment. Contribution to exceedance is given in kt and percent of

exceedance where possible.

Share of 8.1 kt

2010 exceedance

Reason kt NH3 %

Improved inventory methodology for the agricultural sector increased the GP

base year 1990 NH3 emission by 14 kt or 38%:

14 173%

Changes in methodology for emission estimation from agricultural

sector (changes in emission factors from national to EMEP/EEA

Guidebook)

Improvements in the activity data quality for agricultural sector

Incorrect assumptions made at the time of GP ceilings negotiations and

inadequate ceilings accepted. At the time of NECD development, the RAINS

model REF and H1 scenarios projected125 2010 NH3 emission of 37 kt for

2010 compared to the accepted GP ceiling of 30 kt

Insufficient political and policy actions:

National regulation integrating national emission ceilings was adopted

only in 2008

National programme for reduction of emissions adopted as late as 2008

National regulation and National programme were developed based on

the recalculated ammonia emission and set the national ammonia

emissions ceiling at the level of 45 kt rather than at 30 kt as in the GP.

11.3 Reasons for non-compliance as identified by Croatia

Summary

The reasons for Croatia's non-compliance with the NECD 2010 NH3 ceiling are


be estimated.

125 IIASA Seventh Interim Report (1999) Cost-effective control of acidification and ground-level ozone, available from:



125



Table 11-3 Reasons for Croatia's non-compliance with the NECD 2010 NH3 ceiling as identified by

Croatia. Contribution to NH3 emission exceedance is given in kt and percent where

provided by Croatia.

Share of 8.1 kt 2010

exceedance

Reason kt NOx %

Improved inventory methodology for agricultural sector:

Changes in methodology for emission estimation from agricultural

sector (changes in emission factors from national to EMEP/EAA

Guidebook)

Improvements in the activity data quality for agricultural sector

Important role of agricultural sector in the national economy – only “win-

win”, cost-effective policy options for farmers are acceptable

Poor activity data quality delayed development of accurate emission

estimations and projections



legislation) and national scenarios estimates were made for when Croatia may reach its

2010 ceiling in Table 11-4.

Table 11-4 Summary of projection analysis for Croatia on the year to attain the NECD 2010 ceiling (30

kt). Emissions in kt/year.



2010 fuel 2005 2010 2015 2020 2025 2030


30 - 29 40 29 38 31 39 32 42 32 33





GAINS model current legislation projections. Based on this analysis, Croatia is not

likely to reach compliance with its NECD 2010 ceiling without additional measures

beyond current legislation.

In order to assess emission reduction potential for Croatia where projections indicate

compliance with NEC2010 after 2020, GAINS model projections for current legislation

(scenario CLE: TSAP_Mar13_CLE) are compared with those for maximum feasible

reduction (MFR_2025; cost level 2005, 4 % interest rate) in Table 11-5.

126



Table 11-5 Estimated compliance costs – 2025 - Croatia

Emissions

(kt)

Difference

2025

(kt)

Compliance cost

2025

(MEUR/year)

Additional cost

(MEUR/year)

NEC2010 CLE

2020

CLE

2025

MFR

2025

CLE - MFR CLE MFR Difference 2025

MFR - CLE

30 32 32 19 13 n.a. 46.9 0

Source: GAINS online

Implementation of additional measures within the framework created by MFR could

allow Croatia to achieve NEC2010 before 2025.



based on the latest available national emission projection and the results of GAINS model

projection (scenario: TSAP_Mar13_CLE (current legislation)). Comparisons are based

on the baseline values for 2005 from Annex II, Table 3 of the Gothenburg Protocol. In

addition, baseline values based on national reports and GAINS model estimates for 2005

are presented for information.

Table 11-6 Estimated compliance period – Gothenburg protocol (GP) – Croatia. Emissions in kt/year.


GP 2020 reduction

commitment Based on



2015 2020 2025 2030

% fuel


1 - 29 40 31 39 32 42 32 33









127



12 Finland

12.1 Introduction

Status of Finland's NH3 reduction commitments

Table 12-1 summarises the status of Finland's two commitments for national NH3

emissions in 2010 and 2011 under the NECD and the 1999 CLRTAP Gothenburg

Protocol, and for the reduction commitment for 2020 under the 2012 amendments to the

Gothenburg Protocol. The table lists reported emissions in the base years 1990 and


as a percent of the target value (ceiling). Finland's NECD and CLRTAP NH3 emission

totals are identical for these years in present reporting.

Table 12-1 Overview of Finland's final 2010 and provisional 2011 NH3 emission data submitted under

NECD and CLRTAP.

Finland, NH3 emission distance to target

Year (submission year) kt NOX kt NOX %

NECD NH3 2010 ceiling 31

1990 (NECD.SUBM12) 38.7 7.7 25.0%

2010 (NECD.SUBM12) 37.5 6.5 21.1%

2011 (NECD.SUBM12) 37.3 6.3 20.4%

CLRTAP NH3 2010 ceiling 31

1990 (CLRTAP.SUBM13) 38.7 7.7 25.0%

2010 (CLRTAP.SUBM13) 37.5 6.5 21.1%

2011 (CLRTAP.SUBM13) 37.1 6.1 19.5%

CLRTAP NH3 2020 reduction 20% 30.2

2005 (CLRTAP.SUBM13) 37.8 7.6 25.0%

2010 (CLRTAP.SUBM13) 37.5 7.3 24.2%

2011 (CLRTAP.SUBM13) 37.1 6.8 22.5%

Finland's reported NH3 emission was 21% above the 31 kt ceiling in 2010 and 20% above

in 2011. Finland's reported NH3 emission declined 0.4 kt (1%) from 2010 to 2011.

The Gothenburg Protocol reduction commitment for Finland, 20% reduction between

2005 and 2020 was based on the need to continue to respect the existing NH3 2010

ceiling in the NECD (31 kt). This is equivalent to a 2020 NH3 target of 30 kt based on the

presently reported 2005 emission. This target is 1 kt (3%) lower than the 2010 ceiling.

The 2010 and preliminary 2011 NH3 emission totals are 7 kt above this 2020 target.


The main reasons for Finland's non-compliance with the NECD 2010 NH3 ceiling are:


data), and addition of transport, energy, solvent use and waste management source

sectors, increased the 2010 NH3 emission by 6 kt (89% of the 2010 exceedance)

compared to the methodology at the time the ceiling was set.

128



No specific measures were planned for reduction of ammonia emissions. The

National Programmes only referred to other EU policies, such as the Nitrate Directive,

and overestimated the effectiveness of those policies.















unrealistic. Finland is not likely to reach compliance with its NECD 2010 ceiling

without additional measures beyond current legislation.

Finland does not reach the CLRTAP 2020 target level through 2030 according to both

the national and the GAINS model current legislation projections; additional

measures are needed.



Finland’s NECD 2010 ceiling for ammonia is 31 kt. The NEC Directive is not directly

transposed into the Finnish legal system and the emissions ceilings are only stated in the

Air Pollution Control Programme 2010 (National Programme), developed in accordance

with section 26 of the Environmental Protection Act126.

Finland’s first National Programme was developed in 2002, mainly relying on policy

stemming from the National Climate Strategy and focused on measures related to the

energy and transport sectors. The only measure affecting NH3 emissions was the Agri-

environmental support system, a voluntary support mechanism aimed to reduce air and

water pollution caused by agriculture. No mandatory regulatory or fiscal measures

targeting ammonia emissions were proposed in the context of this programme. Reference

is made to the Nitrate Directive as a policy tool with potential for reducing ammonia

emissions.

The National Programme was revised in 2006. The Ministry of the Environment of Finland

concluded that there was no need to update the original programme, as the existing

measures were considered sufficient to comply with the emission ceilings. No additional

measures targeting ammonia emissions were implemented.

126 Section 26 of Environmental Protection Act, 86/2000, “National plans and programmes” refers to the general principles of the

development and adoption of the national plans and programmes referred to in the acts of the European Union.

http://www.finlex.fi/fi/laki/kaannokset/2000/en20000086.pdf

http://www.finlex.fi/fi/laki/kaannokset/2000/en20000086.pdf

129




Although not required by NECD, Finland has routinely submitted detailed Informative

Inventory Reports (IIR) each year providing information on the methodologies and

approaches used in the emission estimation. In 2009, a study conducted in Finland

presented a new model for the calculation of ammonia emissions from agricultural

sources, accounting for the most current knowledge on manure management and

ammonia volatilization in Finland. Application of this model, together with the estimation

of ammonia emission from sources previously not accounted for (energy and transport

sectors) resulted in an increase in the total reported NH3 emissions for the whole time-

series.

Finland's total ammonia emissions decreased by 3% from 1990 to 2010, according to the

2012 reporting. In 2010, the agricultural sector was responsible for more than 90% of

ammonia emissions127 with passenger cars contributing around 7%. Although ammonia

emissions in the agricultural sector have decreased from 1980 to 2010 emissions (from

44 kt in 1980 to 34 in 2010) a recent tendency of slow increase of emissions from

agriculture can be noticed.

According to the analysis of ammonia emissions provided in Finland's NECD IIR 2012,

the fluctuations in the emissions from the agricultural sector can be explained by

significant changes in the economic structure of the sector, which took place after Finland

joined the EU in 1995. These changes led to a significant decrease in the total number of

livestock. Fertilizer use has also become more efficient. However, during the same period

the value of N excretion per animal has significantly increased (partly due to the

increased productivity of the livestock). Consequently, the contribution of the agricultural

sector to the total ammonia emissions has not changed significantly since 1990. The

contribution of the transport sector to the annual NH3 emissions in Finland has increased

from 5% in 1990 to 7% in 2010, which according to the IIR 2012 is the result of the

growth in road traffic and the number of cars with catalysts.

History of NH3 reporting

Finland's NH3 emissions reported through 2006 showed emissions declining from 38 kt in

1997 to a level of 33 kt in 2001 to 2004. In the 2007 submission, the 2005 emission was

reported at 36 kt, a 3 kt (9%) jump from the total reported for 2004. This was the first

indication of revised methodology and activity data for the NH3 calculations.

The CLRTAP reporting in 2008 presents recalculated emissions for 1990 to 2001 with

moderate changes, but the 2011 submission to CLRTAP included substantial revision of

the emissions from 1990 to 2009. The recalculated NH3 emissions from 1997 to 2007

were raised by 2 to 5 kt (5% to 14%), close to the presently reported values for these

years. The latest reporting shows NH3 emissions at 37 to 38 kt for years 2002 to 2011,

with only small variations.

Projections for 2010

Finland reported a current legislation projection of 31 kt for 2010 NH3 emission under

NECD, through 2008. The official NECD reporting in 2009 and 2010 did not include a

projection for 2010, although the 31 kt value continued to appear in the IIRs (Chapter 13)

through March 2013.

127 According to the NECD emission inventory submitted in 2012.

130



In March 2011, Finland reported a 2009 NH3 emission of 37 kt, and the CLRTAP IIR

stated that the NH3 emission was "projected to be about 37 kilotonnes in 2010 and

around 35 kilotonnes in the years after that". The NECD submission in December 2011

reported the preliminary 2010 NH3 emission of 37 kt, and referred to this as the projection

for 2010.

No documentation of the projection methodology is given in the IIR's through 2011, but

the memos presenting the annual emissions and 2010 projections listed RAINS model

scenarios for the SO2 and NOX projections. The various RAINS model scenarios at the

time the ceilings were set all gave a NH3 projection of 31 kt, including the "H1" scenario128

that was the basis for the Commission's proposal for national emission ceilings129. This

suggests that through 2008, Finland continued to report the RAINS NH3 projection value,

equal to the NECD NH3 ceiling, as its official 2010 NH3 projection.

Projections beyond 2010

Beginning in 2009, the IIRs include NH3 projections for 2020 and 2050 that are slightly

below the 31 kt ceiling, indicating compliance with the NECD 2010 ceiling. As mentioned

above, the March 2011 IIR acknowledges that NH3 emissions in 2010 and after will be

above the ceiling, but Chapter 13 in the IIRs continues to present the same below-ceiling

projection values for 2020 and 2050, through the March 2013 CLRTAP IIR.

NRF spreadsheets submitted from 2008 to March 2012 include Table 2A-WM with the

NH3 projection values for 2020 and 2050 showing compliance with the ceiling. In

December 2012, the submitted NFR Table 2A-WM shows new NH3 projection values for

2020, 2030 and 2050 of 36 to 38 kt, although the IIR continues to list the previous

projection values. This inconsistency indicates a lag in updating of the IIR after

projections are revised in the NFR spreadsheets.

In August 2013, Finland submitted a new CLRTAP NFR Table 2A-WM with national

current legislation projections for 2010, 2015, 2020, 2030 and 2050. These projections

range from 35 kt in 2015 to 37 kt in 2050 – all exceeding the 2010 NECD ceiling and the

new GP 2020 reduction commitment by 13% to 19%. Documentation of the methodology

for these new projections has not yet been reported.

Summary

Finland continued to report the same projection value for 2010 given by the RAINS model

at the time the ceilings were set – equal to the ceiling – through the 2008 submission.

The first reported indication that NH3 emissions were higher than previously reported

came in 2007 with a significant increase calculated for the 2005 emission. The full impact

of revised methodology was not clear until the March 2011 CLRTAP submission where

Finland acknowledges that the 2010 NH3 ceiling will not be met. New projections showing

non-compliance in 2020 and 2050 are first reported in December 2012, with a full set of

new projections reported in August 2013. The late methodology change, prolonged

period for recalculations to be completed, and the lack of updated NH3 projections until

after 2010 are all likely to contribute to the lack of additional reduction measures.

128 Amann, M., Bertok, I., Cofala, J., Gyarfas, F., Heyes, C., Klimont, Z., & Schöpp, W. (2000). Cost-effective Control of

Acidification and Ground-level Ozone: Further Analysis. Eighth Interim Report, Part 1, January 2000.

http://ec.europa.eu/environment/air/pdf/documents/cost1.pdf 129 Proposal for a Directive of the European Parliament and of the Council on national emission ceilings for certain atmospheric

pollutants. COM(99)0125 final. http://eur-

lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:51999PC0125%2801%29:EN:NOT

131



The reasons for Finland's non-compliance with the NECD 2010 NOx ceiling are

summarised in Table 12-2. The contribution to the exceedance in kilotons is given where

it can be estimated.

Table 12-2 Reasons for Finland's non-compliance with the NECD 2010 NOx ceiling, based on the


possible.

Contribution to

exceedance of

6.5 kt

Reason kt NH3 %

Improved inventory methodology:

Changes in methodology for emission estimation from

agricultural sector (including changes in emission factors and

activity data)

2.1

32.3

Inclusion of transport, energy, solvent use and waste

management sectors in the estimation of ammonia emissions

2.8 43.1

Difference in assumptions and EF used in RAINS model and the

current national methodology: RAINS underestimated emissions for

agricultural sector for 2010 (significant differences in both emission

factors and number of livestock between national model and RAINS

model) by 3.7 kt 130or 11.9% of NECD ceilings

No specific measures planned for reduction of ammonia emissions

(except for references to other EU policies, such as the Nitrate

Directive)

Emission projections for 2010 underestimated NH3 emissions: NH3

emission projections remained at the level projected at the time the

ceilings were negotiated, through 2008. Exceedance of the 2010 ceiling

was first acknowledged in 2011, and updated projections were first

reported in March 2012. The late indications of exceedance contributed

to the lack of policy response to plan and implement additional

measures.

12.3 Reasons for non-compliance as identified by Finland

The reasons for Finland's non-compliance with the NECD 2010 NH3 ceiling are


estimated.

130 Comparison of emission estimated based on the RAINS emissions factors, old Finnish methodology and Updated Finnish

methodology were provided by the Ministry of Envronment of Finland for the purpose of this study,

132



Table 12-3 Reasons for Finland's non-compliance with the NECD 2010 NH3 ceiling as identified by

Finland. Contribution to NH3 emission exceedance is given in kt and percent where

provided by Finland.

Contribution to

exceedance of 6.5 kt

Reason kt NOx %

Change in methodology:

- New national methodology/RAINS methodology for 2010 3.7 56.9

- New national methodology/Old national methodology for 2010

(including new sectors)

2.1 32.3

Inclusion of new emission sectors: Energy, transport, solvent use and

waste management

Incorrect RAINS model projections: BAU scenario assumed 31 kt

level will be achieved with no additional measures, due to the decrease

of number of livestock

Poor quality of activity data in agricultural sector at the time of

GP/NECD ceilings negotiation (and until now) – leading to incorrect

projections

Less significant impact of Agri-Environmental support system than

initially expected due to its focus on fertilizer use rather than manure

management



legislation) and national scenarios estimates were made for when Finland may reach its

2010 ceiling in Table 12-4.

Table 12-4 Summary of projection analysis for Finland on the year to attain the 2010 ceiling (31 kt).

Emissions in kt/year.



2010 fuel 2005 2010 2015 2020 2025 2030


31 - 34 38 33 38 31 35 31 36 31 31 36





legislation projections but just equalling the ceiling in 2015 and thereafter,

according to the GAINS model. However, the GAINS model underestimates

Finland's NH3 emissions in 2005 (10%) and 2010 (13%), which may indicate that this

projection is unrealistic. Based on this analysis, Finland is not likely to reach

compliance with its NECD 2010 ceiling without additional measures beyond current

legislation.

133



In order to assess emission reduction potential for Finland where projections indicate

non-compliance with NEC2010 in 2020 and later, GAINS model projections for current

legislation (scenario CLE: TSAP_Mar13_CLE) are compared with those for maximum

feasible reduction (MFR_2025; cost level 2005, 4% interest rate) in Table 12-5.

Table 12-5 Estimated annual compliance costs – 2025 - Finland

Emissions

(kt)

Difference

2025

(kt)

Cost 2025

(MEUR/year)

Additional cost

(MEUR/year)

NEC2010 CLE

2020

CLE

2025

MFR

2025

CLE - MFR CLE MFR Difference 2025

MFR - CLE

31 31 31 24 7 15.8 64.6 48.8

Source: GAINS online

Implementation of additional measures within the framework created by MFR could

allow Finland to keep its emissions below the ceiling.


Table 62 gives an estimation of when the GP 2020 ceilings are likely to be reached,

based on the latest available national emission projection(s) and the results of GAINS

model projection (scenario: TSAP_Mar13_CLE (current legislation)). Comparisons are

based the baseline values for 2005 from Annex II, Table 3 of the Gothenburg Protocol. In

addition, baseline values based on national reports and GAINS model estimates for 2005

are given for information.

Table 12-6 Estimated compliance period – Gothenburg protocol (GP) – Finland. Emissions in kt/year.


GP 2020 reduction

commitment Based on



2015 2020 2025 2030

% fuel


20 - 27 30 31 35 31 36 31 31 36




Based on the analysis made of both national and the GAINS model current

legislation projections, Finland is unlikely to reach the CLRTAP 2020 commitment

without significant additional measures.

134



135



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136



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http://www.unece.org/env/lrtap/multi_h1.html

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