Chapter 11 - Adjustments and Emission Ceiling Exceedance

Last updated on 18 Aug 2016 08:48 (cf. Authors)

Emission limits from 2010 onwards and Germany's compliance

With the new emission data for 2014 available, the German national totals and the compliance situation have changed as reflected in the following table:

NOx SOx NMVOC NH3
NATIONAL EMISSION CEILINGS
Gothenburg 1,081 550 995 550
NEC 1,051 520 995 550
INVENTORY DATA
2010 2011 2012 2013 2014 2010 2011 2012 2013 2014 2010 2011 2012 2013 2014 2010 2011 2012 2013 2014
Inventory Total 1,585.60 1,557.15 1,518.04 1,507.82 1,454.59 477.99 473.39 455.29 448.20 424.70 1,251.51 1,181.18 1,148.27 1,123.69 1,054.46 682.95 724.82 706.45 731.33 741.10
- Forest Fires -0.07 -0.03 -0.04 -0.03 -0.02 -0.02 -0.01 -0.01 -0.01 -0.00 -0.20 -0.08 -0.10 -0.08 -0.05 -0.02 -0.01 -0.01 -0.01 -0.00
- 1.A.3.a i - Cruise -107.73 -101.90 -114.24 -119.11 -115.29 -1.38 -1.30 -1.43 -1.46 -1.40 -1.14 -1.01 -1.07 -1.08 -1.06 -1.19 -1.12 -1.23 -1.26 -1.20
- 1.A.3.a ii - Cruise -9.41 -9.50 -9.11 -8.60 -8.73 -0.11 -0.11 -0.10 -0.10 -0.10 -0.21 -0.20 -0.19 -0.19 -0.19 -0.09 -0.10 -0.09 -0.08 -0.08
- 1.A.3.d i -131.65 -129.84 -119.69 -107.67 -106.25 -44.25 -43.98 -41.09 -36.21 -35.16 -14.35 -14.22 -13.22 -11.99 -11.80 -0.03 -0.03 -0.03 -0.03 -0.03
= National Total for Reporting 1,336.73 1,315.88 1,274.96 1,272.41 1,224.29 432.23 427.99 412.67 410.42 388.03 1,235.61 1,165.66 1,133.68 1,110.35 1,041.36 681.61 723.57 705.10 729.95 739.79
EXCEEDANCES OF SET EMISSION CEILINGS
against NEC 285.73 264.88 223.96 221.41 173.29 no exceedance 240.61 170.66 138.68 115.35 46.36 131.61 173.57 155.10 179.95 189.79
against Gothenburg 255.73 234.88 193.96 191.41 143.29 no exceedance 240.61 170.66 138.68 115.35 46.36 131.61 173.57 155.10 179.95 189.79
ADJUSTMENTS (approved & proposed)
= National Total for Reporting 1,336.73 1,315.88 1,274.96 1,272.41 1,224.29 432.23 427.99 412.67 410.42 388.03 1,235.61 1,165.66 1,133.68 1,110.35 1,041.36 681.61 723.57 705.10 729.95 739.79
- DE-A: NOx from 1.A.3.b -151.27 -146.87 -145.10 -142.50 -128.09
- DE-B: NOx and NMVOC from 3.B -2.05 -2.01 -1.98 -1.98 -1.99 -191.74 -191.70 -194.11 -198.36 -199.70
- DE-C: NOx and NMVOC from 3.D -108.78 -119.22 -114.90 -117.64 -120.14 -9.49 -8.99 -10.02 -10.32 -11.34
- DE-D: NOx & NH3 from 3.I -0.16 -0.18 -0.15 -0.18 -0.19 -3.00 -3.40 -2.88 -3.31 -3.58
- DE-D: NOx & NH3 from residues of digested energy crops IE in 3.D NOx Total -37.03 -46.45 -48.58 -57.83 -62.54
= National Total for Compliance 1074.47 1047.60 1,012.82 1,010.12 973.88 432.23 427.99 412.67 410.42 388.03 1,034.38 964.97 929.55 901.67 830.31 641.58 673.71 653.64 668.80 673.66
REMAINING EXCEEDANCES (after adjustment)
NOx SOx NMVOC NH3
against NEC +23.47 +39.38 +91.58 +123.71 +103.64 +118.80 +123.66
against Gothenburg +39.38 +91.58 +123.71 +103.64 +118.80 +123.66
2010 2011 2012 2013 2014 2010 2011 2012 2013 2014 2010 2011 2012 2013 2014 2010 2011 2012 2013 2014

The table above provides a breakdown of the emission data for the years 2010 to 2014 and the four pollutants relevant for Gothenburg and NEC compliance (NOx, SO2, NMVOC, and NH3). Starting from the Germany's emission ceilings required by the Gothenburg protocol and the NEC directive respectively, the Inventory Total values are provided. These include emission amounts that are not considered for compliance (the so-called "Memo Items", e.g. bunkers, aviation etc.). These amounts are subtracted, resulting in the National Total officially used for reporting. These National Totals are then compared to the NEC and Gothenburg ceilings and exceedance amounts are provided wherever an exceedance occurs.

In a next step, the Adjustments as defined by the CLRTAP Guidelines and proposed by Germany are applied to the National Totals. (All details on the proposed adjustments are given below.) Finally, new national totals for compliance checking and the remaining exceedance against both the NEC directive and the Gothenburg protocol are calculated for each pollutant.

As a general result it can be derived that Germany is struggling to comply with its emission reduction commitments, at least for the pollutants NOx, NMVOC, and NH3. Nevertheless, with adjustments taken into account, Germany is optimistic about being in compliance from 2012 onwards for all pollutants but NH3. The details per pollutant are discussed in the next section.

Current situation per pollutant

For NOx, both the NEC and the Gothenburg commitments have been undercut by 2012 and Germany expects to stay in compliance due to a continuing downward trend.

Germany's SO2 emissions have been on a steep and steady decline since the 1980's. Today's numbers are significantly lower than expected when the emission ceilings were established, thus Germany does not have any problems meeting its emission ceiling for sulphur oxides.

The national total emissions of NMVOCs showed a steady downward trend until 2009. After recovery from the "crisis year" 2009 brought the emissions up again in 2010, the national totals returned to the level reached in 2009 where they remain stable since. With the majority of emissions resulting from solvent production and application which is primarily governed by product legislation, action on EU level is needed to further bring down these emissions. With the adjustment in agriculture applied, Germany is, however, currently in compliance with its commitments for this pollutant.

For NH3, emission estimates have been revised significantly over the last years. Due to various inventory changes in both the 2015 and the 2016 submissions, which include higher emission factors, total emissions went up by about 120 kt. The 2016 submission additionally includes the new source “emissions from digested energy crops” for the first time, resulting in extra emissions of about 66 kt for 2014. Given these changes, compliance will only be possible with additional measures, even when taking adjustments into account.

Adjustments in detail

Please refer to the following sub-sections for details on the emission adjustments proposed by Germany:

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