Chapter 11 - Adjustments and Emission Ceiling Exceedance

Last updated on 16 Oct 2015 06:19 (cf. Authors)

Emission limits for 2010 onwards and Germany's compliance

With the new emission data for 2013 available, the German national totals and the compliance situation have changed as reflected in the following table:

2010 2011 2012 2013
NOx SO2 NMVOC NH3 NOx SO2 NMVOC NH3 NOx SO2 NMVOC NH3 NOx SO2 NMVOC NH3
National ceilings
Gothenburg 1,081 550 995 550 1,081 550 995 550 1,081 550 995 550 1,081 550 995 550
NEC 1,051 520 995 550 1,051 520 995 550 1,051 520 995 550 1,051 520 995 550
Inventory data
Inventory Total 1,581.06 479.25 1,255.26 643.96 1,550.56 475.59 1,185.11 676.08 1,511.91 459.10 1,151.19 656.29 1,502.34 454.01 1,151.78 672.22
- Forest Fires -0.07 -0.02 -0.20 -0.02 -0.03 -0.01 -0.08 -0.01 -0.04 -0.01 -0.10 -0.01 -0.03 -0.01 -0.08 -0.01
- Aviation (Cruise) -117.22 -1.50 -1.34 -1.29 -111.40 -1.41 -1.19 -1.22 -123.40 -1.53 -1.25 -1.32 -127.84 -1.56 -1.27 -1.34
- Marine bunkers -130.02 -43.38 -14.97 -0.03 -128.33 -43.43 -14.83 -0.03 -118.31 -40.88 -13.77 -0.03 -105.30 -36.23 -12.19 -0.03
= National Total (for Reporting) 1,333.74 434.36 1,238.75 642.63 1,310.81 430.74 1,169.00 674.82 1,270.16 416.69 1,136.06 654.93 1,269.18 416.21 1,138.24 670.85
Exceedances of set emission ceilings
against NEC +282.74 +243.75 +92.63 +259.81 +174.00 +124.82 +219.16 +141.06 +104.93 +218.18 +143.24 +120.85
against Gothenburg +252.74 +243.75 +92.63 +229.81 +174.00 +124.82 +189.16 +141.06 +104.93 +188.18 +143.24 +120.85
Adjustment proposals
= National Total (for Reporting) 1,333.74 434.36 1,238.75 642.63 1,310.81 430.74 1,169.00 674.82 1,270.16 416.69 1,136.06 654.93 1,269.18 416.21 1,138.24 670.85
- DE-A Road Transport -100.32 -95.52 -89.93 -85.07
- DE-B Manure Management -2.06 -191.74 -2.03 -191.71 -2.00 -194.13 -2.01 -198.39
- DE-C Agricultural Soils -102.26 -9.49 -111.06 -8.99 -105.91 -10.02 -106.75 -10.32
= National Total (for Compliance) 1,129.10 434.36 1,037.52 642.63 1,102.20 430.74 968.29 674.82 1,072.32 416.69 931.90 654.93 1,075.35 416.21 929.53 670.85
Remaining exceedances (after adjustment)
against NEC +78.10 +42.52 +92.63 +51.20 +124.82 +21.32 +104.93 +24.35 +120.85
against Gothenburg +48.10 +42.52 +92.63 +21.20 +124.82 +104.93 +120.85

The table above provides a breakdown of the emission data for the years 2010 to 2013 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 2015 onwards for all pollutants but NH3. The details per pollutant are discussed in the next section.

Current situation per pollutant

Excluding the adjustments

For NH3, the emission estimations have been revised significantly since the last submission. Due to various inventory changes including higher emission factors, total emissions went up by about 120 kt, which means compliance will only be possible with additional measures. (2013: 121 kt above the NEC and Gothenburg ceiling of 550 kt).

With respect to NOx, both the NEC and Gothenburg commitments have not been reached between 2010 and 2013. Here, compliance should be reached around 2018.

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.

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.

Including all proposed adjustments…

NOx emissions would reach compliance under Gothenburg (1,081 kt) as of 2013 (1,075.4 kt) whereas the NEC ceiling (1,051 kt) would be undercut around 2017 *.
* based on latest projections data from the current legislation scenario calculated for the UBA project "LUFT 2030"

…emissions of NMVOCs would reach compliance under both Gothenburg and NEC (ceiling for both: 995 kt) as of 2011 (968.3 kt).

Adjustments in detail

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

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