Mr. Marco Keiner Director Environment Division Economie

SECRETARÍA DE ESTADO DE MEDIO
AMBIENTE
MINISTERIO DE AGRICULTURA,
ALIMENTACIÓN Y
MEDIO AMBIENTE
DIRECCION GENERAL DE CALIDAD Y
EVALUACION AMBIENTAL Y MEDIO NATURAL
Mr. Marco Keiner
Director
Environment Division
Economie Commission for Europe
Palais es Nations, Room CH.2111
GENEVE 10
28 February 2013
Dear Mr. Keiner,
Thank you so much for your letter of December the 4th.
Spain remains committed to its obligations under the Gothenburg Protocol, was ratified in April
2005, and the Directive 2001/81/EC of the European Parliament and of the Council of 23 October
2001 on national emission ceilings for certain atmospheric pollutants.
As you are aware Spain inventory is based on the latest and best understanding of emission
inventory methodology.
As you state in your letter based on the latest submission ammonia (NH3) and nitrogen oxides
(NOx) Spain indicate an excess of approximately 4% of each (NH3 and NOx).
Spain recently updated 2010 emission inventories as part of the internal reporting under European
Union legislations and Gothenburg Protocol. It is now indicating slightly different figures.
For ammonia emissions the present inventory is supposedly overestimated, as reduction control
techniques have not been implemented to estimate emissions in manure application.
For nitrogen oxides emissions ceiling the Gothenburg Protocol is not fully comparable in its
estimating algorithm (discrepancies in the road transport sector).
According with that, Spain proposes to the Secretariat of CLRTAP to be allowed the possibility to
present a new estimate of emissions as additional information en which to assess the potential
issue of non compliance with the 2010 ceiling of ammonia and nitrogen oxides of the Gothenburg
Protocol.
Spain will present the report before 4th of June 2013.
Please, take note of the attached document “Spain response on aspects to be considered to
assess the compliance issue on NH3 and NOx under the Gothenburg Protocol”
Yours sincerely.
Maj-Britt Larka Abellán
Subdirectora General de Calidad del Aire
y Medio Ambiente Industrial
CORREO
Buzon: sgcamai@magrama.es
PLAZA SAN JUAN
DE LA CRUZ, s/n
28071 - MADRID