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Chapter 3: Physical flow accounts

Draft chapter:
Cover note:
Comment template:
Posted on:17/06/2011
Deadline for comments:29/07/2011
Number of comments:39

Comments from the global consultation
Posted onProvided byComments
02/09/2011UK/Office for National StatisticsPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
Generally happy with the structure of the chapter. Two helpful additions would be: • Bridging tables - these have proved critical to the trust of users of measures of greenhouse gas emissions and energy in the UK. • Illustrative examples of key tables i.e. populated tables We do not currently employ a supply use framework for the UK environmental accounts. Whilst supporting the general principle, we welcome the points raised at 3.1.1 paras 9-12 and would welcome an extension to this section to recognise the importance of a time series perspective.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. Treatment of abstraction/extraction by households would benefit from further clarification. It is blanked out in this table and others and only discussed in para. 149 in relation to household produced electricity. Unclear why government is not treated similarly to households in the supply table.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. Para 71 – agree issue of overlaps. Flaring is a loss but it is also a residual. Should be allocated to the industry doing the flaring.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
  Part III: Any additional comments including those of a more technical nature
[attached]
 Chapter3-UK.pdf;   
25/08/2011Latvia/Central Statistical Bureau of LatviaPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
Chapter ir well structured and understandable.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
No opinion.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
No opinion.
  Part III: Any additional comments including those of a more technical nature
No comments.
23/08/2011Israel/Central Bureau of Statistics IsraelPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
The chapter mostly gives clear and useful recommendations on the preparation of physical flow accounts. The main issues seem to be well covered, and the especially the description of energy flows is comprehensive. The recommended accounting for water could perhaps include more details on types of water, and on types of treatment such as desalination of water. In the recommendations for accounting for materials excluding water product flow accounting could be explained in a less abstract way.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. The structure of the tables and the division into main flows seems useful for analysis, and covers the relevant flows. Worked examples in the various tables would be useful.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. The descriptions are generally clear, and the division into types is reasonable, but perhaps one should say "materials excluding water" to be more exact. In the definition of residuals in par. 59 the term "businesses" should be changed to "industries".
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
  Part III: Any additional comments including those of a more technical nature
The explanation of the treatment of international flows in par. 102 under 3.3.3 is not very clear, could be more explicit and perhaps with examples. Par. 105 says "emissions are attributed to the country of residence of the operator." Par. 109 says "Waste generated by the tourist should be attributed to the country of residence" – how will this treatment be done in practice? In contrast to revenue of a transportation firm or purchases of a tourist, the emissions and waste will be left in the country visited. The scenarios given do not say, whether there will be an import of emissions and waste? "3.4.5 Economy wide Material Flow Accounts (EW-MFA)" the numbering is not consistent.
18/08/2011Sweden/Statistics SwedenPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
Please find enclosed our second answer with more detailed answers to the questions. The physical flows of air emissions and of energy use are one of the most important parts of the environmental accounts as we see it. The most important thing is to be able to combine this information with the rest of the economic information in the systems of the national accounts and also with the economic instruments that are related to environmental issues. The focus is on time series and on comparisons within the economy and the economies. Thus specific mass balances over a year are not a focus. The tables sometimes have very crude classifications like ‘mineral and energy resources'', which are difficult to add together in a meaningful way. We suggest that you also add units in the tables and that way see if meaningful aggregations can be made. On the other hand the text sometimes seems to be on a product or substance (mercury) level, that is unlikely to be captured in the accounts. Here there are other environmental systems management tools, like LCA:s or SFA:s that are better suited to capture the problems and solutions that are of interest. We are unsure of what type of assessment that would give meaningful figures on ‘soil resources'' in an accounting framework. The areas of soil quality and of water quality are local and often better served with more of a modelling approach than the accounts can normally achieve. The system boundary between natural and cultivated biological resources is difficult to find, in particular for the forests. We suggest that the text stick to the classifications that FAO use in their data collections, if there are not very strong reasons for departing from it.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
No. We agree with the comments from IEA about the energy parts. Natural inputs from solar energy and wave and tidal energy (see table 3.4.1) seems only valid to record as uses rather than as supply.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
No. We think that material flows in the economy have their place in the SEEA. However, it is important not to try and incorporate all the ideas on making complete mass balances that govern the thinking in economy wide MFA. To make some exceptions such as that for the harvest approach for biological resources can be accepted provided it reflects the measurement practices that are available. The mass balances in nature are not to be incorporated in the SEEA unless they have a very close connection to economic practices. So, for example, paragraph 43 and paragraph 47 sounds as if there are aims to include more mass flows than what is in the economy. We advice against such system boundary changes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
No. Unfortunately we have problems in understanding the Table 3.2.4. Waste is a truly difficult area that is differently defined by different countries. We agree with the Netherlands and Norway comments on this issue.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
12/08/2011Singapore/Department of StatisticsPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
The text in the document is readable and can be understood. It could be useful to expand Sections 3.6.2 and 3.6.5 (wrongly headed 3.4.5 on page 48) using more concrete examples in each case.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
No opinion.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
No opinion.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
No opinion. On the proposal to record the actual physical flows of goods sent abroad for processing, it would not be easy to implement in practice due to the difficulty in tracking the actual goods'' movements.
  Part III: Any additional comments including those of a more technical nature
Similar to the current SEEA, the revised SEEA''s scope and methodology in computing greenhouse gases (GHG) (e.g. sections 3.3.3, 3.4.3, 3.6.3, etc) are different from the Intergovernmental Panel on Climate Change (IPCC) guidelines for national GHG inventory. It may be useful to have a section in the chapter that identifies and compares the key areas where SEEA and IPCC differ. This would aid countries'' understanding of the similarities and differences between SEEA and IPCC without having to go through and compare the documents. In addition, on the section on treatment of international flows, it may be useful to consult the International Maritime Organization and the International Civil Aviation Organization as they will be able to comment on greenhouse gas emissions from the perspectives of international shipping and aviation respectively.
10/08/2011Malaysia/Department of StatisticsPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
Acceptable
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
No comment
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
No comment
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
No comment
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
No comment
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
No comment
  Part III: Any additional comments including those of a more technical nature
1. The Department of Statistics Malaysia (DOSM) has no experience in developing any environmental account using the SEEA framework. However, DOSM is currently collecting data on environmental protection expenditure and trying to develop one of the SEEA account. 2. DOSM face constrains in developing this account with lack of expertise in this field. 3. DOSM also wants to learn in detail how to develop the SEEA account. Please inform and include us if there is any training/workshop to be conducted in future. 4. Therefore DOSM is unable to contribute fruitful comments for the revision of the SEEA at this moment. However, DOSM would like to be involved in further development of this matter.
05/08/2011International Energy AgencyPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
Since I have never used national accounts, I found the introduction, accounting framework and principles very heavy reading. There is a lot to cover and in some instances I found the explanations difficult to follow and a bit obscure. Having said that, for people with the right background this may be sufficiently clear. Somewhere there needs to be a detailed explanation of the differences with the energy balance. If supply equals use, what do you do with the statistical difference? What about stock changes (in the sense of an energy balance and not dealing with resources)? As for the definitions, how do you adjust for the territory vs residence difference? What about transport - are you assuming that although the energy balances are constructed with transport as a separate sector, the people filling in the energy account table will have access to the original sources so that they can see what industry or household owned the car/truck? It probably would be useful to go into a bit more detail about the differences in energy accounts and energy balances so that people do not think that they can take the numbers directly from the energy balance. I am sure that there are other differences as well that I don''t know about.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
No/unclear. Unfortunately it is not clear to me what should go where. From the text it appears that there should be deliberate double counting of primary and secondary energy, but based on this document I would be incapable of deciding how to report production, transformation, energy industry own use and TFC in the table. Again, this confusion stems from the fact that I do not have any background in national accounts and am not familiar with this type of table. In Table 3.4.1, if production should be shown under "output of energy products" in the supply table – why don''t we just call it production? In the use table, I am not sure what should be shown in the 3 sections. Chapter 2 says that natural inputs should be the use of the fuels, and under products you would have intermediate consumption. Not sure where I would put numbers – OK for transformation, but what about final consumption and energy industry own use?
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
No opinion. The list of non-fuel energy inputs in Table 3.2.2 is not complete. You should change the last item from "other heat energy" to be "other electricity and heat energy". This is because you could also have electricity from salinity differences (I am sure that there are others that I haven''t thought of as well). This would affect Table 3.4.1 as well. In Table 3.2.3, I assume that "gross ore" is referring to coal and then you have crude oil and raw natural gas. What about non-conventional oils such as oil sands, oil shale, etc.? Also, what about natural gas liquids - when you say "raw" natural gas, does that mean before the NGL''s are removed? Paragraph 48. list is not exhaustive, suggest changing to "Non-fuel energy inputs are classified by different energy sources such as, but not limited to, solar energy, hydropower, wind energy, wave energy and geothermal energy.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
No opinion.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
No opinion.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
No opinion.
  Part III: Any additional comments including those of a more technical nature
I assume that you are recommending the use of joules on a net calorific value basis since this is what is recommended in IRES (recommendation 4.36 on page 15). It is important to be clear on this. I suggest that you clarify this in SEEA paragraphs 8, 48, 87 and especially 134. You might also want to explain the difference between the use of net/gross in energy statistics (for calorific values) and the net/gross for SEEA when you are referring to the physical flows (paragraphs 95-101). Paragraph 138 – in the examples it should be "petroleum products" and not just petroleum. Also, "wood fuel" should be "fuelwood". Paragraph 160 is confusing. Are you saying that IRES final consumption is a broader measure than use in the SEEA? That doesn''t seem right. Paragraph 161 – not clear what the "which" is referring to – better to change to "Similarly, energy accounts, which consistently use national accounts classifications and definitions, can be seen as a re-organization and supplement to the energy statistics and balances". Paragraph 163 – change to "Since one of the main purposes of energy accounts is to link physical and monetary data in a consistent way, this leads to different definitions and a different organisation of the energy data so that it can be aligned with the monetary data in the national accounts."
03/08/2011U.S. Bureau of Economic AnalysisPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
The structure and balance is generally good. We have the following comments regarding structure and readability: 1. Key terms have different meanings at different points in the text. For example, §81 is intended to be the definition of "air emissions," but §206 gives a second description of air emissions that is different to the definition in §81. (In §81 air emissions must be "pollutants," whereas in §206 they do not.) This is confusing. We suggest that all relevant terms are defined once in the text, and that all subsequent references to the term refer back to the paragraph in which the original definition is made. 2. Subject matter requires consolidation. Section 3.3.4 addresses goods for processing, but this subject also appears in §152-153. We have the following additional comment on missing content: 1. The residence principle needs to be expounded further. If the residence principle is the same at that used in the SNA 2008 and BPM6 then this should be stated. In addition, the boundary between residents and non-residents should be described in detail, as in SNA2008 §4.15, so that a third party can use the SEEA manual to distinguish between residents and non-residents. The more difficult borderline cases need to be discussed by way of example. For instance, §106 should discuss the case in which the vehicle never returns to the owner''s country of residence. In this case the SNA-consistent treatment is to pro-rate the emissions between the territories of operation (see SNA2008 §26.35). 2. The examples given in §106 should also state that the resident country reports a corresponding import of fuel in its physical flow accounts, which would be in accordance with the "material balance principle" described in §25 (that is, all material inflows to an economy are equal to outflows and accumulation.)
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
No [detailed comments attached]
 Chapter3-USA.pdf;   
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes. 1. The preamble to this question is misleading; in particular it states that "hence there are no natural inputs of cultivated biological resources". Section 3.2 does not state that there are no natural inputs to cultivated biological resources; it states that the harvest itself is not to be considered a flow into the economy from the environment. This does not preclude other flows into the economy as a result of the cultivation – see §43. 2. The chapter contradicts itself in different places regarding the position of cultivated livestock relative to the boundary between the environment and the economy. For example, §44 states that "These (ecosystem) inputs to the production of cultivated biological resources become embodied in the product itself, i.e. the growth of livestock or growth of the crop." This implies that cultivated livestock can be on the boundary, which seems appropriate for livestock cultivated on pastureland. However §232 states that "For cultivated livestock and fish the flows from the environment to the economy are treated in the same way in both the EW-MFA and the PSUTs." This treatment implies that all cultivated livestock are not on the boundary, which is only true for livestock raised in feeding pens. The chapter needs to distinguish between livestock cultivated on pastureland and livestock cultivated in feeding pens to clarify these issues. A distinction is also relevant for practicalities of measurement: For livestock raised on pastureland, the statistician will likely have to impute the amount of natural inputs based on the observed number of livestock cultivated. For livestock cultivated in feeding pens, no imputation is necessary since the natural inputs are embodied in the cultivated vegetation fed to the livestock. We suggest a paragraph discussing the distinction and the implications for measurement is included in the revised chapter.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
No opinion.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes. §153 states "It is noted that foreign trade statistics normally record the flows of goods sent abroad for processing and the return flows together with other flows of products crossing the borders." This is confusing to users, since they will not know whether a particular country follows a "normal" practice. We recommend "It is noted that foreign trade statistics that comply with SNA 1993 record the flows of goods sent abroad for processing and the return flows together with other flows of products crossing the borders. In this regard physical flows in the SEEA 2012 will follow the SNA 1993 for goods sent abroad for processing".
  Part III: Any additional comments including those of a more technical nature
1. It is not clear what the purpose of §119 is. It seems to reiterate §118. 2. §113 should specifically state where the extraction should be recorded in the non-resident country''s accounts. In particular, it should not be recorded in the asset accounts since this would be double-counting. 3. The examples given in §106 i and ii do not inform the description of the residence principle given in §105. Each example begins by *asserting* that the vehicle is a resident of country A. Thus, given that the SEEA attributed emissions to the resident, all emissions are attributed to country A under this assertion. A far more helpful approach would be to describe the transactions and the institutional units involved, then, based on this description, show how one can determine the residency of the institutional units in question.
03/08/2011Italy/IstatPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
To my opinion the Chapter provides a clear overview on the subject of Physical flow accounts, covering the main issues in a balanced manner. Provided that details on individual subjects are covered elsewhere (SEEA-E, SEEA-W, OECD publications on materials flow and resource productivity), the value added of the chapter stems from being very comprehensive and managing to relate to one another issues that are normally dealt with in a separate way. Suggestion for further improvement: the deliberately general nature of the chapter could be stressed at the beginning, and references and connections to the more specific manuals made more specific. This would help readers to understand what the purpose of the chapter is, avoiding the risk that those not too familiar with technical manuals are left with the impression that some necessary details are missing. The text is clear and easily readable.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. The table provides a clear presentation of the main flows that need to be taken into account in physical flow accounting. Particularly helpful is the inclusion of the explanation of the items in the individual cells. My only concern relates to the use table where the cell relating to the use of natural inputs from households is ‘grey'' i.e. not applicable: couldn''t we find here the use of fuelwood gathered by households themselves?
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Please consider replacing the wording of § 33 ‘Natural inputs are all physical inputs that are directly incorporated into economic production processes or that are moved from their location in the environment as a part of economic production processes'' with the following: Natural inputs are all physical inputs that are moved from their location in the environment as a part of economic production processes
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
No opinion.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
  Part III: Any additional comments including those of a more technical nature
§ 8 and § 134. Unit of measurement of energy accounts data. Please mention that in addition to using a common unit representing energy content, energy accounts are also compiled by using the original measures of mass and volume; examples of this exist in the SEEA-E. § 7 …three different sub-systems have developed within the broad supply and use framework – material flow accounting, water accounts and energy accounts For the reader it may not be straightforward that air emission accounts (widely known and developed) are part of flow accounts for materials. Although this is clear from § 3.6, it may be worth specifying from the beginning of the Chapter where air emission accounts can be found. Footnote 1. "net" emissions Please consider adding the words in red: In relation to carbon emissions, in context other than air emission accounts, the term "net" is also used to refer to estimates of emissions measured after deducting carbon captured in managed forests. § 130 Since, in physical terms the water, energy or other material is not lost to the economy (is it environment?) they are not considered losses in the SEEA § 160 text not very clear: ‘It is therefore a broader measure than final consumption in the SEEA to the extent of end-use of energy by industries''
01/08/2011China/National Bureau of StatisticsPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
Fine
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. The equation in paragraph 26 is difficult to understand. Is it correct? In definition, supply = use, so, it''s better to rewrite the equation in this way.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. It'' s need to add a definition of natural resource residual.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes. Table 3.2.4 is not easy to understand.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Solid waste is a subgroup of residual. But in table 3.2.4, solid waste is separate to residuals and products two part. It ‘s better to make clear the relationship between waste and residual.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
  Part III: Any additional comments including those of a more technical nature
It''s better to give the boundary of economy and environment. The are some space blank needed to be added in several sentences: P42 P88 P124 P129 P136
01/08/2011Australia/Australian Bureau of StatisticsPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
This is a consolidated Australian response incorporating input from the Australian Bureau of Statistics, the Bureau of Meteorology and the Department of Resources, Energy and Tourism. The chapter is generally very readable and well-structured. However, it may be useful to provide some worked examples of the tables in relation to describing an entire system. The lack of examples at times makes it difficult to interpret whether the tables adequately maintain relationships of physical flows. A number of issues were raised in comments in relation to chapter 5 which also need to be considered here, including recommendations in relation to soils (e.g. see comments below on nutrients in water/soil). We strongly support the general approach to accounting for waste. However, there is no discussion of hybrid accounts anywhere in chapter 3 or 4 – this is a major omission given that we no longer have a specific hybrid accounts chapter. It means that chapter 6 will need to carry the full weight of discussion of these important accounts In Australia, the boundaries between production" from "natural", "ecosystem" and "economy" inputs such as agriculture may be problematic in terms of multiple uses and reporting units. Tables in the chapter should allow flows between the sub-systems to be quantified. For example, Agricultural production, components of ecosystem and "man-made" nutrients (nutrient balances) and residual run-off back to the environment. Ultimately, any classification will have some limitations. The proposed classification is generally sound. Any combined reporting of forestry, agricultural and fisheries is potentially not useful. The chapter contains a lot of formatting errors e.g. words stuck together etc.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes, partially. We are basically in agreement with this table. Para 6 – Suggest adding in a diagram to show the flows to be referenced here and/or in para 16. The natural resource residuals, and residuals received by waste management and other industries could be removed. Para 16 – suggest a diagram be used to represent the physical flow accounting framework The table generally represents the main flows but there are a number of issues that need to be considered. Ultimately, some measure of "condition" and "capacity/capability will need to be developed to assist with valuation and assessment of trends – recognising that this is a discussion for the ecosystem accounting volume of the SEEA.
 Chapter3-Australia1.pdf;   
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes, partially. Paras 35 – 38 and 45 – 47. Table 3.2.2. Treatment of soil nutrients – soil nutrients should be part of natural resources. They are identifiable and measurable and pass the production boundary when they leave the soil and enter the plant. (i.e. they are within the asset boundary while in the soil, but enter the production process when then leave the soil (or water) and enter the plant. This treatment is the same as for soil water, in which water is a natural resource contained in the soil, within the asset boundary and also enters the production boundary when the water is taken up by plants and hence is recorded in the PSUT. Also suggest just calling these ‘nutrients'' rather than ‘soil nutrients'' and stating that they can be within the soil or water. This avoids the problem of having to account for the mobility of nutrients (i.e. they are usually absorbed when they are dissolved in water). The full mass balance for nutrients would occur in the physical accounts. This treatment of nutrients allows the ecosystem inputs to be re-named ‘atmospheric inputs''. This re-naming is important as ecosystem inputs are broader than those mentioned and the specific identification of a limited number of them in Vol 1 may hinder the broader articulation of ecosystem input which will occur in Vol 2. Para 40 Follow first sentence with a brief description of why this distinction is made. Para 45 (and subheading) – change ‘ecosystem inputs'' to ‘atmospheric ecosystem inputs'' Para 46 – after effecting our suggested changes, this paragraph becomes redundant (i.e. delete it) A number of issues were raised in comments in relation to chapter 5 which also need to be considered here, including recommendations in relation to soils. There are boundary, multiple use, productive capacity, condition and classification issues to consider. It would also seem logical to include agricultural production from natural systems. It is also unclear how users might account for agricultural land alienation and changes in condition or production capacity and to "un-mix" factors relating to climate variability and management i.e productive capacity and actual production may be highly related to climate variability. Tables should allow flows between the sub-systems to be quantified. For example, Agricultural production, components of ecosystem and "man-made" nutrients (nutrient balances) and residual run-off back to the environment. We therefore propose that ‘nutrients'' be considered a natural input.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes. While we accept the proposed approach, we suggest two clarifications in the text as it currently stands. Para 227 Second last sentence: these practical choices are not for ‘reliable'' measurement – they are for ‘convenient'' measurement. E.g. excluding water from EW-MFA doesn''t make the measure more reliable, but it is easier and slightly less meaningless. Para 231 The consequence described in the first sentence is redundant since EW-MFA almost completely ignores water flows and therefore applying a harvest approach should cause no impact on reporting of water within EW-MFA. Possibly a different example could be used?
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes, partially. [detailed comments attached]
 Chapter3-Australia2.pdf;   
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes. A comment about treatment of inter-regional movement of goods sent for processing would complete the discussion (i.e. the fact that such movements require no special treatment for national statistics).
  Part III: Any additional comments including those of a more technical nature
[attached]
 Chapter3-Australia3.pdf;   
29/07/2011Belgium/Federal Planning BureauPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
The general strategy to squeeze each and every physical economic environmental account into a SUT framework feels somewhat uneasy. PSUT are needed when one wants to analyse the supply and the use of (a set of) specific products by the different economic agents in an economy. However, some environmental accounts do not aim at this type of analysis. As a consequence, there is no need to fit them to a SUT framework, and doing so is cumbersome and can lead to inconsistencies, as is the case for EW-MFA. Emission accounts only deal with the supply of emissions, not with their use. In the current set-up of the PSUT the environment is added as the user of these emissions in order to fit emission accounts into the PSUT framework. There is no need for a supply-use balance of emissions like there is in the case of energy, water or materials. Adding the environment as a supplier and a user to the SUT framework is inconsistent with the monetary SUT in which all suppliers and users are economic agents. In paragraph 7 it is written that the PSUT consist of 3 subsystems: energy, water and materials. The distinguishing feature between these subsystems is not really clear. It seems to be the unit of measurement (energy content, volume and mass), according to paragraph 8. Water is also a material, but still water accounts are not material flow accounts. As concerns material flow accounts, it is stated that they are "generally" expressed in terms of mass. So apparently this is not always the case. And so much for the distinguishing feature between the subsystems. In my opinion there is simply no such thing as a general PSUT framework consisting of three subsystems in which all physical economic environmental accounts can be classified. PSUT can be developed for different goods (water, energy, materials, waste, chemicals,...), and these form a specific class of economic environmental accounts, and there are other, non-SUT economic environmental accounts, like emission accounts and EW-MFA. There are also economic environmental accounts which combine SUT with non-SUT elements, like the forest accounts. The structure of the chapter thus seems to put too much weight on the PSUT framework. This framework is presented as an all encompassing template for the physical flow accounts, while it is only part of a broader set of economic environmental flow accounts.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. Overall table 3.2.1 correctly presents the main flows. Still, it seems to exclude the possibility for households to extract natural inputs like water or forest products. Households might extract water, add pollutants to it, and discharge this water into the sewage system. This should also be recorded in the physical supply and use tables. It would probably also be better to use the title "Government final consumption" for cell G, as the government''s intermediate consumption should be recorded in cell E as one of the industries.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
No. It is very strange to consider the non-fuel energy inputs not to be natural resource inputs. Solar energy, wind energy, geothermal energy.... If those are not natural resources, what is ? Well, according to chapter 3, natural material inputs are. Therefore it would be better to rename the first class of natural inputs "natural material inputs" instead of "natural resource inputs". This distinguishes these material inputs from the non-material inputs. The latter consist of non-fuel energy inputs on the one hand, and of ecosystem inputs on the other hand. On a microscopic level these inputs of course also consist of material, but in general we understand a material to be something we can touch, something we can hold. It is quite counterintuitive to consider oxygen to be a material for instance, especially when it is free in the air. When pure oxygen is locked in a container to be used in a production process, then the container of oxygen becomes a material that can be handled and used. The content of table 3.2.3 does not correspond to its title. The title says the table is about the treatment of natural resource inputs. According to table 3.2.2 natural resource inputs are a class of natural inputs, and according to table 3.2.1 natural inputs are to be distinguished from products and residuals. Now, table 3.2.3 also discusses products and residuals. It shows the destination of natural material inputs. As explained in paragraph 36, they either end up being incorporated into products, or they end up as residuals in the environment. A title more appropriate for table 3.2.3 would thus be "Destination of natural material inputs" or even "Use of natural material inputs". A reference to table 3.2.1 would be helpful here (natural material input is to be recorded in cell A on the supply side, and in cell B on the use side). Furthermore, other biological resources should read "other natural biological resources", timber resources should read "natural timber resources", and fish resources should read "natural fish resources", since table 3.2.3 treats natural inputs only, and not products, a category to which cultivated timber, fish and other biological resources belong. Paragraph 88 and table 3.2.5 talk about natural resource inputs. What is meant here is once again "natural material inputs". However, as concerns the biological resources (timber, fish and other), the residuals are probably more or less the same whether they are natural or cultivated. So in fact, not only natural material inputs should be the subject of this paragraph and table, but also cultivated biological products.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes. The section on EW-MFA should be 3.6.5 instead of 3.4.5. According to the definition of material flow accounts in chapter 3, EW-MFA are no material flow accounts. Otherwise there would be no need for an exception. The fact that an exception needs to be made for EW-MFA, which clearly is a physical flow account, and even a material flow account, demonstrates that it not the correct strategy to try and squeeze every single physical flow account into a SUT framework. The latter is only useful if one wants to obtain insight into the supply and the use of specific goods by the different economic agents acting within the economy.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
No. Table 3.2.4 is entitled "Treatment of solid waste as residuals and products". The criterion to be used to distinguish between solid waste as a residual or as a product is clear. But there is only one criterion to do this. So there is no need for the second part of the table, which tries to say something about when to consider a good as waste or not. This is an entirely different subject, not covered by the title of the table. It simply does not belong in this table. The table now says that if solid waste does not need any processing or treatment by the receiving unit it is not solid waste. This is a logical impossibility. If a good is solid waste, it cannot be not solid waste. The criterion proposed in table 3.2.4 to decide whether or not a good is solid waste is certainly not correct. Solid waste can be used as a product without any treatment by the receiving unit, e.g. when the solid waste is burnt as a source of energy. When a good is to be considered solid waste or not is not up to the economic environmental accountant to decide. We do not need to make that decision. The economic environmental accountant will receive data on solid waste, and has to decide whether to treat it as a product or a residual.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
  Part III: Any additional comments including those of a more technical nature
Paragraph 149 refers to energy production by the households. This implies that in the supply table of table 3.4.1 the row for electricity in the column of the households should be left open, while in the use table this should be the case for the rows for fuel wood and solar energy. It is also written "The activity should be allocated to the relevant industry". Since we are talking about the households, this should probably read "The activity should be allocated to the households". Table 3.5.1 makes the distinction between different types of water abstraction. It is unclear in the table that "precipitation" only contains collected rain water, while non-collected precipitation is part of soil water. The category "precipitation" would better be replaced by "collected precipitation" or "collected rain water". In the supply table it should also be possible for households to supply water retained for own use. Currently this cell cannot be filled with data. Section 3.6.1: It is confusing to call every account expressed in mass a material flow account (or physical flow account for materials). Water is a material, as are many energy vectors. The third subsystem is simply not a subsystem of the PSUT framework. Only parts of section 3.6.1 can be considered to be a subsystem of this framework. "Physical mass flow accounts" seems to be a better title for section 3.6. Section 3.6.3 treats emissions as materials. Although microscopically they consist of material, it creates confusion with the materials treated in material flow accounts for which supply and use by economic agents can be determined, materials which can be used in production processes. Emission accounts do not fit into a SUT framework. Section 3.6.4 for solid waste accounts should not be seen as a subsection of material flow accounts. It is a separate account for a very specific type of goods, which incorporates many different materials. Paragraph 224 would be clearer if it would start as follows: Second, next to solid waste as a residual, the account also considers flows of solid waste that are products following the distinction... As written currently, the sentence seems to imply that solid waste as a residual is not considered.
29/07/2011Romania/National Institute of StatisticsPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
The structure of the chapter is good, the major topics are included.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. The structure of chapter is adequate for the physical environmental flows to the economy, within the economy and from the economy to the environment. The general set-up of table 3.2.1 is appreciated, but there are some missing spaces between words.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes, because all natural inputs are directly incorporated into the process of economic production.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
No. As you say, because of the differences in treatment, particularly with regard to the use of the "harvest" production, the EW-MFA boundary and the SEEA boundaries are not aligned. In this case is better not including EW-MFA in SEEA – accounts.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
No. It isn''t very clear the definition of solid waste. We think that there are not the same definitions for solid waste in all the countries, because is typically defined by the legal system.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
29/07/2011Germany/Federal Statistical OfficePart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
Chapter 3 is a very comprehensible overview on the concepts of the physical flow accounts. The definitions are clear, problematic issues are clearly understandable and the shape of the result tables is given in a compact manner. However, for compiling detailed accounts more information will be necessary by way of handbooks, compilation guides or the like. As far as compilation guides exist (e.g. Eurostat Manual for Air Emission Accounts, Nov 2008) these should be mentioned – following the example of § 229.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. However, some flows from the environment are directly used by households and should be named in the lower part of table 3.2.1 (use table). Examples are hunting and gathering, fruit and vegetables from private gardens, fuel wood collected by private households. See also chapt. 2, §103.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. Two remarks concerning table 3.2.3: a) One item in the last column reads "unextracted harvest" which is contradictory in itself. We propose to replace it by the common term "unused extraction" or "unused harvest". b) The head of the second column reads "extraction incorporated into products". This is not correct for excavated soil which usually is not incorporated into products. We therefore propose to find a new heading, e.g. "extraction entering into production processes or moved as part of an economic production process" (see also chapt. 2, § 78). Point b) also is valid for §§36 and 37. The wording should be adapted accordingly. In addition, the choice of words should make clear, that unused extraction enters the economy (as the extraction of the whole amount is necessary for extracting the used parts) and then immediately leaves the economy and flows back to the environment (§37). The second sentence in §36 in contrast gives the impression that some amounts of extracted resources do not enter the economy. Remark regards Table 3.2.2 "Classes of natural input": The inputs which are listed on level 2 under the heading "ecosystem inputs" are material inputs which could be also mentioned under the first item "natural resource inputs". Hence, the term "ecosystem input" should be deleted, also, because ecosystem inputs or services are usually understood as non-material functions for economy or society.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes. Concerning biological resources and ecosystem inputs it should be mentioned somewhere in chapt. 3.2.2 (§§ 39 to 47) – as already is the case in chapt. 3.4.5 (§§ 226-234) - that there are differences in boundaries for PSUT and EW-MFA.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes. Remarks related to table 3.6.2 (Solid waste account): In the physical supply table for solid waste in the first block the "generation of solid waste" is restricted to "other industries", "households" "imports" and "environment" . But it is evident that the sector "waste management" is also producing waste – so called "secondary waste", which also belongs to "generation of waste". It might be, that the intention is to incorporate "secondary waste" under the block "transaction in solid waste", but there are only "products" listed, which have only a small share in the total amount of secondary waste. Proposal: Establish possibility to introduce also secondary wastes . In the physical use table for solid waste, "Other industries" and "households" are excluded from "collection and disposal of solid waste". This seems correct for household, but not for industries. Industries can directly transport their waste to other industrial branches (cement industry, chemistry etc.) for further (before all energetic) utilisation. Para 221: Please add the following: It should be noted that in Europe flows of solid waste directly to environment are illegal.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes. We agree to the proposed accounting of processed goods, e.g in §118.
  Part III: Any additional comments including those of a more technical nature
§131: The net accounting of output is not quite clear. If losses during extraction "can be recorded", output would include these flows also. What does that mean: "In the derivation of measures of output in physical terms, losses during extraction should be netted off total amounts extracted"? Isn''t there a contradiction to the gross accounting of output? §148: It is important to have information on energy produced and used on own account and to have explicitly the distinction between energy and non-energy use. The reason is that it must be possible to connect correctly energy use with air emissions. These aspects should be added in this para. General remark on section 3.6.3 Accounting for emissions: The very important split of CO2 emissions in a) biomass CO2 emissions and b)CO2 emissions from fossil fuels should be considered in order to be able to produce a transition SEEA reporting to reporting following the Kyoto protocol. Table 3.6.1 (page 43) is not easy to understand and even more difficult to complete. We assume that data on "Generation of air emissions" refers to gross-emissions which are not emitted and which can be specified as potential emissions. Data on "Capture, transfer and storage of air emissions by industry" should then contain the emissions which are captured by environment protection facilities dedicated to reduce the emissions. Finally, to our understanding, the "net air emissions to the environment" are those which are crossing the border between economy and environment and usually called emissions. If the logic between the three blocks of the table is like described above, then this would be quite unusual, enormously demanding and additional refinement at least regards the classification of material captured would be needed. The differentiation of a)gross air emissions, b)capture, transfer and storage of emission and c) net air emissions might make sense for CCS but not for emissions avoided by end-of-the-pipe technologies for example. In most cases data production for a) and b) would not be possible. Up to now in all air emission reporting schemes (Kyoto reporting, NAMEA Air emission accounts) only the net air emissions have to be reported. The material or substances captured cannot be classified as pollutants. These material can only be classified as various types of waste (slag, ash, fin ash, gypsum etc.) The heading of the EW-MFA part (§§ 226-234) should be numbered 3.6.5 (not 3.4.5). Concerning §227: EW-MFA do not only look at the input side from the environment but with view to a national economy also look at input from the rest of the world (imports) and on the other hand include the output side, that means material leaving the economy (air emissions, exported goods, dissipative losses, etc.). This aspect should be added in this §.
29/07/2011Austria/Statistics Austria, UmweltbundesamtPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
In general the chapter is well structured. But we want to propose to give more examples to present the methodology in a more tangible way and the presentation of different kinds of physical flow accounts for materials in section 3.6 is too short.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
No. Supply table: Also government (e.g. schools) produces residuals. If government consumption is considered also government production of residuals must be considered. Heading of the supply table: “Government” and “Accumulation” should be there instead of blank cells.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
No. Ad table 3.2.2: The disaggregation into "natural resources inputs" and "ecosystem inputs" seems to be arbitrary. The former contains solid and aqueous natural resources the latter gaseous natural resources and "soil nutrients". It is unclear how to discern between mineral resources, soil resources and soil nutrients as the former is the umbrella term for the latter each. Maybe "soil nutrients" should be treated as subcategory of "soil" and "soil" as subcategory of "mineral resources". It would be more consistent to have following categories: ? Solid natural resources • Metals and metallic ores • Minerals for nuclear energy • Non-metallic minerals - Soil - other non-metallic minerals • Fossils • Timber • Fish • Other biological ? Water resources ? Air resources • Nitrogen from air, oxigen…. ? Non-fuel energy • Solar energy….. Instead of "other heat energy" "other ambient energy" or "other environmental energy" should be used. Ad natural resource residuals: The energy resources in the category "Mineral and energy resources" seem to be taken into account in both the material flow model and the energy flow model. Special care has to be taken that the "natural resource residuals" of the "Mineral and energy resources" and the "energy losses" are consistent. Ad Ecosystem inputs: A reference to ecosystem services would be useful. Even if the ecosystem services accounts are still under development it would be important to describe the commonalities and differences between ecosystem inputs and ecosystem services. Table 3.2.2: The distinction between natural resources inputs and ecosystem inputs is not clear. Either it needs to be better explained why it should be separated or all of these inputs should be considered natural resource inputs. This should be reconsidered.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
No. If a material is waste or not is defined by international and national legislation. The guideline provided by table 3.2.4 may be helpful if no further information exists, however, the official legal qualification should have precedence. Thus all materials/products which are legally classified as waste should enter the columns "Waste collection, treatment and disposal industry" in table 3.6.2 as waste, so that a total waste balance can be generated. Even waste which is sold as product directly from the primary waste owner to the secondary user (e.g. scrap) should enter the waste management sector as waste. This should be done in section 3.2 and in section 3.6 as well.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
  Part III: Any additional comments including those of a more technical nature
General comment: Instead of the term "firm" one should only use the term "enterprise" as this is consistent with the legal definition of this type of institutional unit (at least in the European Union). Comments on waste: In Table 3.6.2 the waste treatment category "other treatment" is missing, as physical-chemical treatment and mechanical-biological treatment is not represented by the categories shown. Probable also a category "radioactive waste storage" needs to be introduced as radioactive waste cannot be handled by either of the treatment types shown. Table 3.2.2: The distinction between natural resources inputs and ecosystem inputs is not clear. Either it needs to be better explained why it should be separated or all of these inputs should be considered natural resource inputs. This should be reconsidered.
29/07/2011Philippines/National Statistical Coordination BoardPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
Kindly check for typographical errors.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. Table 3.2.5 is a good starting point in identifying the natural resources residuals and can possibly be made more comprehensive.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes. More examples or cases would help in understanding the treatment of solid waste.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes. However, the treatment of such goods should be made clearer in the central framework.
  Part III: Any additional comments including those of a more technical nature
In paragraph 109. "Waste generated by the tourist should be attributed to the country of residence and should be deducted from the total emissions and waste generated within the visited country." Can this statement be elaborated further considering that this chapter is about physical flow account?
29/07/2011Mauritius/Central Statistics OfficePart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
Some charts showing the physical flows would enhance the empirical process involved in the accounting framework (see for example [attached] ON WATER CYCLE):
 Chapter3-Mauritius.pdf;   
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. A note could be added below the table indicating any flexibility allowed in adding items that might not have been covered, may be for instance own use of compost from households.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
No opinion. Any comment about agricultural residues?
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
No opinion. Difficult to quantify cultivated biological resources as most of the inputs necessary to produce the resource is complex and at the same time important.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
  Part III: Any additional comments including those of a more technical nature
45 TO 47: ECOSYSTEM INPUTS. DOES IT INCLUDE ECOSYSTEM GOODS AND SERVICES? EG. THE BENEFITS OF WELL MAINTAINED BEACHES FOR TOURISM.
29/07/2011Poland/CSOPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
The general view is (as already expressed for chapter 5) that the document is comprehensive and systematic, which is convenient for the user. However, there are some differences with respect to previous and other international documents and frameworks of a similar (environmental) scope and this fact should be clearly underlined in the preface to allow for easy comparisons.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. We strongly support this approach. We believe it is consistent and comprehensive.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. We suggest to distinguish stronger the differentiation for water use in item 50, page 12: hydropower ... may be reflected in entries for non-fuel energy inputs or entries concerning water resources. Otherwise, it may lead to some misunderstanding as to how to account hydropower. This is to understand that entries for hydropower cannot be reflected both as non-fuel energy inputs and water resources, otherwise we would have some kind of repeated accounting only for hydropower.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes. This treatment is appropriate as there may be residuals from processing abroad that do not return to the country of origin.
29/07/2011Lithuania/Statistics LithuaniaPart II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
No opinion.
28/07/2011Canada/Statistics CanadaPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
The chapter covers the subject very well.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. Natural resource residuals is a useful term, and is preferable to unused extraction since there may in fact be uses for those residuals that are distinct from their role in the production of goods.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes. This treatment ensures that inputs are accurately described in a physical sense.
  Part III: Any additional comments including those of a more technical nature
Para 46 should clarify the treatment of irrigation water with regard to cultivated plants. Paras 48-50 It would be more consistent to measure the total amount of energy incident on the energy producing apparatus (i.e. electricity output over the efficiency of the apparatus) as the natural resource input with the difference between this natural resource input and produced energy being recorded as a natural resource residual (heat). Uranium deserves similar treatment and special mention since the energy content of the ore is not commonly measured. Para 51 it should note that if a product reaches a point of zero monetary value it becomes classed as a residual. Para 54 brings to mind the issue of crop residues and where they are to be recorded as residuals. The proper treatment is worth stating in this paragraph. Para 67 the term consignment should be changed to disposal – consignment has a specific meaning in terms of waste management. Paras 95-101 The gross and net discussion could also mention the case of water use. A portion of the water abstracted by the water supply and distribution industry is actually used by that industry (for cleaning filters, for example) but the rest is passed along to other consumers. This is another case where net and gross treatments may be required. Para 142 the notion of the supply and use of an energy loss is unusual. Use of the term residual might be clearer. Para 178 the punctuation in the first sentence is unclear. Table 3.5.1. Should households not be able to abstract water (e.g. from wells) in the use part of the table? It is currently greyed out. In addition, should the water consumption row in the supply table not be greyed out? Paras 183-189 This discussion could benefit from a diagram. It is somewhat difficult to follow—particularly paras 188 and 189. Para 192 Our preference is to suggest that "water use" be the term used to describe economic consumption with the caveat that this should be net of water abstracted solely for the purpose of supplying it to other economic units. (i.e. it would be useful to define a water use vector that could be applied to hybrid accounts models – this could also be included in the final two paras of the section.) There is no mention of the creation of water through fuel combustion. These flows may not be large compared to bulk flows of water, but it is worth mentioning for the sake of completeness – it would be a necessary item to balance the flow of oxygen into the economy for combustion, for example.
28/07/2011Palestine/Central Bureau of StatisticsPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
The structure of the chapter, the balance of material and the coverage of the chapter are good.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
28/07/2011Colombia/DANEPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
i)En la página 48 la numeración 3.4.5 corresponde es a 3.6.5; ii) Es importante que el documento final de cada capitulo este disponible en español para consulta global, si es posible antes de la edición del volumen completo. igualmente se considera indispensable que los documentos finales tengan traducción oficial al español, para asegurar la correcta interpretación de los conceptos y términos que hacen parte integral del marco central del SEEA; iii) Es importante plantear grafica y conceptualmente la relación de los flujos físicos de energía, residuos y agua, con la cuenta de emisiones. iv) Es importante para la conceptualización contar con el glosario de términos
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. Pagina 6. Se recomienda que la tabla 3.2.1 "General physical suply and use table" se complemente con un ejemplo numérico de los flujos físicos, y se adjunte al final de la tabla el nombre de las siglas por ejemplo: C, F, Q. Lo anterior para que el lector pueda tener un mayor entendimiento de como funcionan estos flujos dentro de la contabilidad.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
En el contenido de la sección 3.2 se explicita que se debe ser consistente con la propuesta de las cuentas de activos donde el crecimiento y la cosecha se consideran recursos biológicos cultivados dentro de la economía y no como inputs naturales; y en la sección 3.6 se establece que no se deben contabilizar dentro de la cuenta de emisiones la captura natural de los bosques y suelos. ¿Con lo anterior, se puede interpretar que la captura de CO2 durante el crecimiento de las plantaciones forestales si se contabilizan dentro de la cuenta de emisiones, y así mismo, las emisiones de GEI durante el aprovechamiento de las mismas?
  Part III: Any additional comments including those of a more technical nature
i) El párrafo 137, 155 Y 156 menciona que se deben registrar en las tablas de oferta utilización los productos energéticos usados como energético, sin embargo, es importante resaltar que de acuerdo a la propuesta del formato de la tabla 3.4.1, se registra la cantidad de energético usado como materia prima (transformación de energía). ii) El párrafo 145 habla de los componentes de la tabla de oferta y utilización de los productos energéticos; no se observa la variable de variación de existencias, no hace parte de los componentes de la tabla 3.4.1? iii) El párrafo 154 menciona que el combustible consumido por residentes en el exterior debe ser contemplado en las cuentas de importación y el combustible consumido por no residentes en el territorio nacional debe ser excluido de las exportaciones, se hace importante dejar claro que para lograr esta desagregación de la información, debe haber un registro del valor y de la cantidad de combustible comprado por los no residentes en el territorio nacional, ya que el seguimiento se hace para el transporte de carga, pero no para el transporte particular; además de lo anterior, también es importante resaltar la diferencia entre la información que se consolida para las importaciones y exportaciones concerniente al uso de combustibles de residentes y no residentes, y la variable de Bunkers internacionales. iv) Página 17, tabla "3.2.4 2 treatment of solid waste as residuals and products". No es claro para el lector las relaciones establecidas en la tabla. v) Página 23, párrafo 106. Se recomienda integrar a la explicación un grafico. vi) Página 43, tabla " 3.6.1 Air emissions account" es importante definir los conceptos de "capture, transfer and storage " vii) Página 43, párrafo 209 y 210. se recomienda integrar una gráfica que establezca la relación entre territorio y residencia; es importante que se haga referencia a otras actividades sobre los cuales se debe aplicar el principio de residencia (por ejemplo entes extraterritoriales como las embajadas). viii) ¿para las exportaciones e importaciones de productos, se puede hablar de principio de residencia? ix) En el capítulo 3 la tabla 3.5.1 Tabla de utilización y oferta unidades físicas, es diferente a las tablas de utilización y oferta que se presentan en el Sistema de Cuentas Ambientales y Económicas Integradas del Agua SCAEI-A y en las Recomendaciones Internacionales para Estadísticas del Agua RIEA, adicionalmente, esta tabla no aparece en ninguno de los manuales mencionados anteriormente. Una de las características mencionada en el SCAEI-A es el vinculo que existe entre este y el SCAEI los cuales comparten una estructura y un conjunto de definiciones y clasificaciones (p.1.12 SCAEI-A), el manejar tablas de oferta y utilización diferentes en los dos manuales, puede ser confuso al momento de hacer la implementación del sistema y difiere de la coherencia y consistencia promulgadas por el mismo. No queda claro donde se debe registrar el agua que es entregada al alcantarillado y a que se refieren las siguientes variables: Tabla de utilización: reusó de agua usada; Tabla de oferta: diferencia entre agua suministrada a otras unidades económicas y distribución total del agua captada, agua retenida para uso propio
28/07/2011Macao, China SAR/Statistics and Census ServicePart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
This chapter is well structured and easy to understand.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
No opinion.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
No opinion.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes. The criteria mentioned in section 3.2 are difficult to be applied in practice.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes. The physical flows of goods sent abroad for processing should be recorded on a gross instead of net basis. Otherwise the environmental impact of the processing activity cannot be fully accounted for.
27/07/2011France/Ministry in charge of EcologyPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
Filling the tables by domain (3.4.1., 3.5.1., 3.6.1. and 3.6.2.) with a fictive data set, like in the volume of the SEEA-land dedicated to water accounts, might be helpful.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. Table 3.2.1. : - It may be added "final use" between brackets to the header "Households". - We suggest to leave blank the cell products/households for possible own account production (e.g. electricity from solar panels). The same remark applies to table 3.4.1.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. * Table 3.2.2: the category "Mineral and energy resources" might be changed for "Mineral and fossil fuels resources" in order to anticipate the existence of non-fuel energy input below in the same table. * Table 3.2.3: we suggest to add a category "Unused extraction" for the cell that corresponds to "Soil resources/Natural resource residuals".
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes. Table 3.2.4: We have detected a mistake in the down right cell (no processing/non benefit): it should be written "Residuals – not solid waste".
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
No opinion. We understand the possible negative consequences of determining the SEEA principles on this issue in accordance to the new SNA rules, especially on MFA statistics and IO analysis. However: - It does not seem to us that this loss of information (imports of crude oil, exports of petrol) incurred by the underlying treatment of concerned physical flows would entail changes in the air emission accounts. In particular it would not run counter to the respect of residence principle for the emissions recording. - The alternative treatment which is proposed in 3.3 probably implies the need of collecting - with increasing difficulties - disaggregated data. Moreover these data will not be consistent with national accounts which are used for the constitution of IO tables. So we are doubtful about the best treatment to be adopted on this issue.
  Part III: Any additional comments including those of a more technical nature
About water accounts (Section 3.5), we would like to know if the revision of the 2007 SEEA-W is scheduled.
27/07/2011Czech Republic/Czech Statistical OfficePart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
There are a lot of references to Chapter 2 in the text. It is therefore quite unpractical that global consultation on Chapter 2 follows the global consultation on Chapters 3 and 4. There are quite a lot of typesetting mistakes in the text, particularly two words are joined into one word many times.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
No. We think that natural resource inputs are incorrectly defined for soil resources in Table 3.2.3. Soil resources can be used in production of commodities, but more often there are only moved from place to place in order to reach other natural resources, to build infrastructures or to do some landscaping. We think that the flows which were only moved should be classified as natural resource residuals. This approach would be consistent with EW-MFA and the fact that also mining overburden is classified as nature resource residual.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
No. We would like to recommend the usage of the definition which has been done by the DIRECTIVE 2008/98/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 19 November 2008 on waste and repealing certain Directives.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes. The alternative treatment seems reasonable. The Chapter 3.3.4, in particular the part on monetary flows, is, however, very hard to understand for someone who is not an expert at this specific field. We would recommend elaborating on this Chapter a bit more. Para 119 says that emissions of an oil refinery are attributed to the country in which the processing plant is located. If this processing plant is owned by some foreign subject, employees are from abroad and all production is sent abroad for consumption, does this way of attribution not violate the residential principle? We think that some clarification on this point would be helpful (maybe also in other parts of the text such as para 68 and Chapter 3.3.3).
  Part III: Any additional comments including those of a more technical nature
Para 64. The statistics usually does not distinguish between controlled and uncontrolled landfill sites, moreover the technical properties of controlled landfill sites can differ across countries and there are often some unwanted and unrecorded leakages even from controlled landfills. Taking these points into account and in order not to underestimated environmental pressures related to wastes, we would prefer to include landfilled wastes among the flows of residuals into nature. Para 66. The content of this para is directly linked to para 64. We would suggest exchanging the order of paras 65 and 66. Para 68. Distinction between domestic and other countries'' environment does not make sense for emissions contributed to global climate change as they are directly released into "global" environment. It means that place of release of these emissions does not matter, because they contribute to global environmental problems. Table 3.2.5. The examples of solid waste include some rather minor solid waste categories, but exclude some very important ones such as municipal waste and demolition waste. Chapter 3.3.2. The distinction between gross and net recording of physical flows is so specific for various flows categories that it would make sense to define this distinction in Chapters devoted to particular accounts. The separate Chapters in Chapter 3.3 should contain only the most important points, which are treated similarly for majority of accounts. Para 131. What does it mean that all losses can be recorded in the physical supply and use tables? Is this point up to the person who constructs the tables? Maybe "should" would be more appropriate here, as all following sentences in this para also use "should". Paras 136 and 138. The definition of energy resources in para 136 seems the same as the definition of primary energy products in para 138. Could it be clarified what is the difference between these two items? Table 3.4.1, para 159. The use part of the Table excludes some important final energy consumption such as government energy consumption and energy accumulation in terms of gross capital formation. These items are not further mentioned in para 159. On the other hand the general physical supply and use table (Table 3.2.1) rightly includes these items. The Chapter on energy accounts should be amended to include these items as well! Para 168. What does it mean "percolation"? Para 168. It would be helpful to add a short explanation why, contrary to other accounts, water accounts include flows within the environment such as water exchange between water resources and natural water flows between countries. Table 3.5.1. Similarly to energy accounts, the Table 3.5.1 excludes the water consumption by government. Para 181. It should be noted in this para that if a subject sells water for use to another subject in the same sector, this transaction is recorded in physical supply and use table. Para 202. This para mentions input-output modelling as a way for calculating materials embodied in products. Life cycle assessment method (LCA) deserves to be mentioned in this context as well. Table 3.6.1. This Table again does not contain emissions from government consumption activities. Para 219. The release of other air emissions is related to capturing of methane or to combustion of methane when producing energy? A short explanation would be useful. Table 3.6.2. Production of waste by government is again missing. Para 231. It is not quite clear what is meant by natural resource residuals related to cultivated biological resources. Does it mean remnants from harvest which are left on fields?
26/07/2011Sweden/Statistics SwedenPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
Due to the timing of the revision, we will have to be brief in this reply. It occurs in holiday season, and so we do not have the time to consult with the experts during this time. We will send you a more detailed reply (on part II and III of the questionnaire) on the 19th of August when we have had the time to discuss your questions. The physical flows of air emissions and of energy use are one of the most important parts of the environmental accounts as we see it. The most important thing is to be able to combine this information with the rest of the economic information in the systems of the national accounts and also with the economic instruments that are related to environmental issues. The tables sometimes have very crude classifications like ‘mineral and energy resources’, which are difficult to add together in a meaningful way. We suggest that you also add units in the tables and that way see if meaningful aggregations can be made. On the other hand the text sometimes seems to be on a product or substance (mercury) level, that is unlikely to be captured in the accounts. Here there are other environmental systems management tools, like LCA:s or SFA:s that are better suited to capture the problems and solutions that are of interest. We are unsure of what type of assessment that would give meaningful figures on ‘soil resources’ in an accounting framework. The areas of soil quality and of water quality are local and often better served with more of a modelling approach than the accounts can normally achieve. The system boundary between natural and cultivated biological resources is difficult to find, in particular for the forests. We suggest that the text stick to the classifications that FAO use in their data collections, if there are not very strong reasons for departing from it.
25/07/2011African Development BankPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
Chapter 3 is well written for the reader to understand, however the statistics and indicators paragraphs are outliers in Chapter 3, and I would propose a creation of own chapter covering the different areas covered in SEEA.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. Paragraph 23 states that TUNI= TSNI, TSR =TUR. We would need explanations for these equalities I would suggest that both TUNI and TUR should include households
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
The boundary of the economy and environment need more explanation though the reduction of natural resources as a result of economic activities is clearly explained. Paragraph 113: How is the exploitation of natural resources by non-residents going to be captured in their accounts, when exports are not recorded by resident economy or imports by non-residents.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
The residuals and wastes from cultivated biological resources to the environment should be recorded in environment account. In paragraph 230; recording of harvest rather than flows, this assumes EW-MFA accounts for all different natural inputs. This may be true for harvests that are with short period. However, for harvests whose maturity is 10 years or more for timber resources. The prince of work-in-progress should be applied.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
  Part III: Any additional comments including those of a more technical nature
Create a Chapter for statistics and indicators to cover the different areas of SEEA
22/07/2011International Monetary FundPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
As a whole, this chapter is well structured and presented, and complete in terms of contents.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. We agree with the presentation of general physical supply and use table 3.2.1. In addition, we suggest the following: It would be beneficial to include a chart similar to the figure 3.3 in SEEA 2003 on the scope of physical accounting.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. Following issues need to be addressed: Non-fuel energy inputs (table 3.2.2): We agree with the inclusion of non-fuel energy inputs as a sub-category of natural inputs. However, clarification on its inclusion may be provided, as the same was not there in 2003 SEEA classification of natural inputs. Paragraph 49: It is mentioned that ‘non-fuel energy inputs represent the energy captured by the capture technology''. What is capture technology? Capture technology is generally used in the context of catching fish and using the same terminology for non-fuel energy could be avoided. It is mentioned that (paragraph 88) the flows of natural resource residuals are defined in the context of the extraction of natural resources. However, no definition is provided. Therefore, providing a specific definition of natural resource residuals would be necessary. In addition to this, in table 3.2.3, natural resource residual for fish resources is shown as ‘by-catch''. This needs further explanation.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes. As the focus and scope of EW-MFAs is much broader than physical flow accounts for biological resources in SEEA, we agree with this approach. What we should ensure is the consistency of physical flow accounts of biological resources with asset accounts presented in chapter 5 and that SEEA is consistent with 2008 SNA.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes. It is suggested to address the following issues: If the disposer receives payment for solid waste, then it would be treated as product and not as a residual. As practices with regard to disposal of solid waste differ from country to country, a particular solid waste may not have any monetary value in one country whereas in another country it may have. Therefore, an alternative treatment may be necessary to bring in more consistency in the treatment of solid waste. Typical components for groups of residuals (table 3.2.5): One of the important components of solid waste, electronic waste including cyber-waste is missing from the list. It may be included.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes. We understand the need for physical flow accounts to be on a gross basis in SEEA. As the monetary flows in SEEA are recorded in accordance with the 2008 SNA treatment, we would suggest more explanation on the reconciliation of physical flows and monetary flows accounts.
  Part III: Any additional comments including those of a more technical nature
Air emission account (table 3.6.1): What about air emissions by other sectors? For example, transport vehicles of government also produce air emissions. An additional column for government sector may be included for this purpose. Air emissions (paragraph 204, 216 and 217): It is mentioned in 216 that ‘air emissions are released due to economic activity by industries and households''; whereas, paragraph 214 defines emissions as a particular form of residual that are releases of materials into the air, water or soil as a result of production or consumption purposes. If we go by this (paragraph 214), emissions released from transportation services for own consumption by households are part of air emissions account. However, if we follow the logic of 216, as the transport activity by households for own consumption is not included in production boundary, air emissions from this activity should not be taken into account in the compilation of air emissions account. Therefore, further clarification on this issue would be necessary. It is suggested to modify 216 as ‘ …economic activity by industries and consumption by households''. Solid waste account (3.6.2): Government sector also generates a lot of solid waste like paper, plastics, used furniture, construction debris, electronic waste, etc. This may not be very large in terms of overall supply of solid waste. Nevertheless, it may be useful to know the nature and magnitude of solid waste generated by this sector. For this purpose, it is suggested to include a separate column in the table 3.6.2.
22/07/2011Slovak Republic/Statistical Office of the Slovak RepublicPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
The chapter is well presented and appropriately covers the issue of physical flow accounts. The structure of the chapter is good and the balance of material is adequate. The chapter is well written and comprehensible for readers.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. Structure and concept of the Table 3.2.1 is good. The table shows all main types of physical flows in clear and comprehensible form.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. The descriptions of types of natural inputs and the definition of natural resource residuals are sufficient in general however it would be helpful to have a more detailed classification of natural inputs in Table 3.2.2 (with Level 3 at least).
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes. Just a remark on Table 3.2.4: Some terms used in the table are unclear. For example what is meant by "Product-not solid waste" (no waste but product or waste in liquid state)?
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
No opinion.
22/07/2011BPS-Statistics IndonesiaPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
Structure of the chapter: OK; however it needs something like footnotes to link from one discussion/chapter/subchapter to the others in order that readers may get more clarifications or understanding about the discussed subjects. Balance of materials: OK; however it needs more comprehensive examples for some discussions/chapters/subchapters. Coverage: OK
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. Table 3.2.1 already presents the main flows of physical supply and use of the SEEA; however, it is suggested that every terminologies used in the table should be clearly defined, for example: what it means by natural inputs, residuals, etc; or at least there is a note/footnote in the volume which links to what chapter or sub-chapter readers should go forwards to understand clearly about it.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. No. Descriptions of the types of natural inputs: OK Descriptions of natural resource residuals: needs more elaboration, especially if it is related to whether the residuals have economic/monetary values (Chapter 4), and then the residuals are not considered as residuals anymore.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes. As long as cultivated biological resources are used as natural inputs, then it should be included in the central framework of the SEEA. Cultivated biological resources should be excluded from the EW-MFA because cultivated biological resources are actually parts of production.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes. No more comment.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes. Yes, goods sent abroad for processing should be recorded in the central framework because processing goods in imported countries creates flows of residuals and therefore it should be included in the central framework.
  Part III: Any additional comments including those of a more technical nature
No more comment.
20/07/2011Netherlands/Statistics NetherlandsPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
• Bridge tables, very important explaining for example air emission accounts and energy accounts, seem to be missing. We suggest that these are added to this chapter and discussed. • We deplore that no strict classification for residuals is recommended. At least for part of the residual classes, classifications can be recommended, for example for air emissions etc.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. For clarity reasons it might be helpful to add to "A. Flows from environment" that they include natural resource residuals.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. Can we assume that dredgings (soil removed from waterways in order to keep them accessible for shipping trade) are considered natural inputs? If so, for clarity sake, can dredgings be added to table 3.2.3. Paragraph 34: Maybe change non-fuel energy inputs into non-physical energy inputs. Table 3.2.3. The term unextracted harvest seems a contradiction in terms.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes. The issue of the production boundary is very important with regard to physical flow accounting and thus should also be described in detail here (and not just as a reference to chapter 5).
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
No. Paragraph 75 and table 3.2.4. To us "Processing/treatment required by receiving unit" is irrelevant for estimating if a material is solid waste or not. It only depends on the intentions of the producer (materials that are not longer desired by the owner). When a material, on the basis of this criteria, is considered solid waste, this material can be considered a product if the producing unit receives payment from the receiving unit. Actually, one can argue that there are products that need treatment by the receiving unit but should not be considered solid waste (for example metal sheets that need treatment to become useful for a car producer). This kind of treatment is not different from food waste products that are processed into animal feed by the receiving industry. We would suggest to leave table 3.2.4 out and remove point II in paragraph 75. Paragraph 3.6.4, table 3.6.2: We would like to propose some changes to table 3.6.2. Considering the generation of solid waste, the waste collection industry (like any other industry) produces waste residuals (for example food residues from their canteen). Also, the process of waste incineration produces slags that are being reused or landfilled. In order to incorporate these kind of wastes, the rows in supply table regarding the generation of waste should not be shaded in grey. Also the import of waste products should not be shaded grey. Considering the use table. Other industries can also use waste residuals (for example biomass waste by power plants), therefore the collum "other industries" should not be shaded grey.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
  Part III: Any additional comments including those of a more technical nature
3.2.2 Definition and classification of natural inputs: This paragraph describes the definitions, but not much is said about classifications. This should be added here. Paragraph 87: Residual heat losses needs a clear definition. Paragraph 98: This is not correct. Net energy use equals energy end use plus transformation losses (i.e. losses that occur when one energy product is transformed into another) plus other losses. Paragraph 115: please add reference to SNA2008 Paragraph 141: Residual heat losses should be added here. Table 3.4.1 (physical supply and use table for energy). To be fully consistent with the SEEA philosophy of the classification of natural inputs, products and residuals, residual heat losses should be added to the residuals in the supply table. Accordingly the energy end use of products (use table) matches the supply of residual heat (supply table). Accordingly also an energy balance is created for industries and households (column supply equals column use), one of the principle accounting identities for physical supply and use tables. See also the recent work by the Eurostat taskforce on energy accounts here. In addition, a column for stock changes seems to be missing in the table. Paragraph 164: The net energy use may be mentioned explicitly here, and also how this can be directly derived from table 3.4.1 (see also Eurostat taskforce energy accounts for this). Paragraph 207: For clarity, it still is useful to construct the table for air emission within the general supply use framework: The upper part of the table is the supply table (generation of the emissions), the lower part the use table. If a column with the environment is added, a separate heading for capture and transfer and storage is no longer needed. Paragraph 207: Maybe an exception here has to be made for greenhouse gasses that may be produced after decomposition of for example NMVOS in the atmosphere. These are part of the Kyoto figures. Leaving them out may create another bridge item that is not really necessary. Paragraph 231: "One consequence of applying a "harvest" boundary in the EW-MFA is that flows of water for irrigation and fertiliser etc, are treated as flows from the economy to the environment whereas in the PSUTs only the amount not absorbed by cultivated plants is considered to flow to the environment." Leave irrigation water out of this example as it is not part of the EW-MFA.
18/07/2011Lebanon/Central Administration of StatisticsPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
• The structure of the chapter is clear and coherent • Material is balanced among chapters • Clear synthetic tables • Good mathematical approach especially on page 7 • Chapter very easy to read
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. Very clear and well distributed table for supply and use for the economic agents and for the environment. The environment column is very useful.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. Increases the organized knowledge about the treatment of natural resource inputs.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes. • Good to show the differences in treatment between EW – MFA and PUST on page 48. • Will consult the reference in paragraph 228 on the web.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes. Will there be more elaborate definitions and wider discussions about waste in the future?
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
  Part III: Any additional comments including those of a more technical nature
• Liked so much section 3.3.4, 3.3.5, 3.4.4, and 3.4.5 related to energy and section 3.3.3 about treatment of international flows • Will have also to read chapter 6 for a better understanding of sections 3.3.4, 3.4.5, and 3.5.4
14/07/2011Mexico/INEGIPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
In general the structure of the chapter is adequate and exhaustive, the content covers all the issues related to physical environmental flows to the economy, within the economy and from the economy to the environment.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes, because it generally includes all possible recording flows through environmental accounting, moreover, the identities that are explained in paragraph 26 are aligned within the 2008 SNA framework. Additionally, it takes into consideration the availability of basic information about the recording way and timing of the flows, as well its specific nature in order to be considered as waste, natural supplies or affordable products. On the other hand, in specific accounting of natural resources such as water (SEEA Water), flows can be observed with a higher level of detail, such as water transfer or reuse between the different economic units.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes, because all natural inputs are directly incorporated into the process of economic production. In addition, part of the value of natural inputs is modified in its transit between the environment and the economy; when this value is lost and can’t be recovered through an economic transaction it becomes a waste, otherwise it would be a product. We agree with the definition of waste, because they are considered a type of flows that can be thrown, discharged or emitted to the air, water or soil resulting from the processes of production, consumption and accumulation.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes. We agree to consider cultivated biological resources as products formed within the economic system and not as natural inputs because cultivated resources incorporate into their development production costs such as labor and capital.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes. We agree to consider the physical and monetary flows within the economy and the economy to the environment, including the table it seems that 3.2.4 is essential to fully explain the concept refers to the treatment of solid waste and that are not subjected to any treatment and therefore returned to the environment.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes, because considering the residence principle in the interaction of the domestic economy with the rest of the world, allows accurately measure the flows of products and waste in the international bunkers.
  Part III: Any additional comments including those of a more technical nature
Not at the moment.
14/07/2011European Commission/EurostatPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
The structure of the chapter is good. In general, the balance of material is fine. For better understanding the concept of Physical Supply and Use Tables (PSUT framework) it is necessary to also explain the columns of the tables. Hence, in section 3.2 one may consider to add some paragraphs (or even a sub-section) on the columns of the general PSUT (definition, structure, classification etc.). Moreover the headers in the use table seem to be a mix of industries, final demand categories, stocks (accumulation) and a sector (RoW).
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. The general set-up of table 3.2.1 is appreciated. However, the following issues may require some further reflections and a final clarification. : 1. How to record the scrapping of buildings, machinery etc?: The current text does not seem to describe how to deal with demolition waste and scrapped equipment. We see three options: a. The supply of old buildings, machinery etc. is shown in the accumulation-column of the SUPPLY table. This option seems close to the physical reality. However, this option does not assign the flow to the owner, i.e. the economic agent responsible for the residual supply. This disadvantage could be met by booking a respective counter residual input at the owning industry (i.e. a residual input in the USE table, industry column). The very same flow would be booked a third time as a residual output (supply) of the respective industry. The advantage of this way of recording: inputs and outputs for each industry-column are physically balanced. b. The supplies of residuals resulting from stocks (e.g. demolition waste, old equipment) could be recorded as originating directly in the industry-column of the owning industry. This approach seems consistent with the treatment of controlled landfills. The disadvantage of this option is that the physical input and output is not balanced for each industry-column. A certain part of the residual-output of an industry is coming from nowhere, i.e. is not counter-balanced by the actual input of natural resources and intermediate products. c. The demolition materials originate from the construction industry and are sent to the waste industry, who sort them and send them on to recycling or landfills. 2. Government consumption (G.): In this column, monetary use tables record the final use of the government''s own non-market output. Any goods used (and resulting pollution, etc) would be found in the intermediate consumption matrix, while government consumption expenditure is only services output 3. Emissions to water. In section 3.6 water is briefly mentioned in para 204, but an elaboration of accounting for emissions to water (e.g. nutrients, toxic substances) is missing.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. The definition of natural inputs and the treatment of natural resource residuals are appreciated in general. Maybe, it could be made clearer that the amounts of natural resource residuals need to be recorded first as natural inputs and that their classifications are not trivial. Often, the natural inputs may be differently classified than the natural resource residuals. E.g. the overburden associated to a metal ore may be constituted of ordinary soil and hence it is not classified as natural input of metal. Another example is flaring of natural gas during extraction: the natural input is natural gas but the natural resource residual is CO2.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes. Could we clarify the definition of residuals? Table 3.2.4 delimits residuals by their zero value, but Table 3.2.5 shows (all/some?) recovered materials and discarded materials among residuals.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes. The alternative approach proposed in section 3.3.4 is appreciated as it better reflects the technological structures of production processes.
  Part III: Any additional comments including those of a more technical nature
[comments attached]
 Chapter3-Eurostat.pdf;   
14/07/2011Norway/Statistics NorwayPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
(a) It is very unclear how the different accounts (such as air, water, energy) relate to the general PSUT shown in Table 3.2.1. The terminology differs in each of the tables in the chapter so it is impossible to figure out the connections back to the general PSUT or what you are actually doing. It is imperative that the reader can easily understand which portions of the general PSUT are to be developed in each of the different types of accounts. For example, the energy PSUT has two sections under products in the use table, in the water PSUT you do not find the terms natural inputs, products or residuals at all and no explanation is provided for the use of other terms and then the air emission accounts are not in a SUT at all but are basically expanding in more detail the information that is found in cells “J” (including J1 and J2) and “K” in a detailed way. (b) In our opinion, there is a lack of standard English punctuation and some phrases are too colloquial to appear in a statistics manual. These stylistic components of the manual need to be corrected before the global consultation for the whole SEEA planned takes place later this year. The short writers’ guide by Skrunk and White, “Elements of Style,” although ‘old’, has some simple, clear advice which, in our opinion, would be useful to follow. (c) In addition, throughout the document there are missing spaces between words. Although this may be the result of converting the document between one program and another, this needs to be corrected before the next version is released for global consultation. We have not taken the time to comment on each of these errors but they were annoying when reading the text.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. (a) It would be helpful to briefly state what are the main structural differences between the SEEA and SNA SUTs. For example, in the SEEA the environment has been added as a column and that two rows are added, namely natural inputs and residuals. By doing it this way the environment becomes a passive ‘actor’ within the supply and use system by providing natural inputs and receiving residuals. (b) It is unclear from table 3.2.1 what the purpose is of the totals of the columns in the supply and in the use table. These are neither given a letter designation nor are they shaded indicating invalid entries. Should the totals of the columns be the same as the total of the rows? Also is the value found in the cell ‘Total, TOTAL SUPPLY’ equal to the cell ‘Total, TOTAL USE’? Are the figures obtained in those cells the sum of the figures in the column (TSNI+TSP+TSR) = (TUNI+TUP+TUR) or of the figures in the row? Or both are true? (c) One problem we find is that there is no guidance regarding the ‘totals’ and ‘sub-totals’ shown in the tables. In the theoretical table it would appear that total use must equal total supply – and this is purely a mathematical relationship. Those totals have no real meaning since you are adding residuals together with products. This topic of ‘which totals’ are you talking about especially comes into the picture with the water and energy tables (Tables 3.4.1 and 3.5.1). Here you find numerous rows called ‘total’ with no indication of what this total is used for – just a mathematical check of the entries or are these to be used in indicators, or are these supposed to equal the corresponding ‘total’ on the opposite table (supply or use). For example, which ‘total’ in the energy accounts table would be used to compare with or be adjusted or ‘bridged’ to other energy statistics? (d) Related to the problem with the totals is the question of units. The units for the tables need to be clearly described so that the different calculations and totals can be made correctly. The numbers cannot simply be added up if the units are not the same. This may seem like a trivial point – but deciding what the common unit should be is not a trivial exercise. When you are adding across the different categories (natural inputs, products and residuals) what would this mean? What is the common unit? (e) Own Account Production: In Table 3.2.1, “Household production on own account” is shown in the column heading together with the supply from industries. This does not seem to be totally consistent with the description of “own account production” as described in §53 – although it only states that the physical flows “should be recorded to ensure consistency…” and no guidance is given as to how these should be recorded. In the water table 3.5.1, nothing is indicated regarding own account production from households. Own account production needs to be consistently presented in chapter 3 (for households and industries) and it needs to be the same as is described in chapter 4, §36-39, §49 and §53.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
No. [comments attached]
 Chapter3-Norway1.pdf;   
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
No. The SEEA system boundary cannot and should not be changed – we agree with the treatment of cultivated biological resources for the SEEA central framework as described in Section 3.2. We strongly disagree with the proposed exception for EW-MFA. Since EW-MFA clearly has a different system boundary then these should not be part of the SEEA. No exceptions should be allowed – if another system boundary is chosen then those statistics cannot be considered SEEA accounts. Since EW-MFA has crop production as part of the environment and not as part of the economy then these are clearly not compliant with the SEEA and should not be considered SEEA-accounts or included in the SEEA statistical manual.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
No. The description of waste is not very clear so we cannot “generally agree” since it is difficult to identify the nuances which may make this definition problematic. “Waste” is typically defined by the legal system in a country – as are the different requirements for the treatment and disposal of waste. Therefore there are no universally applicable definitions of waste. Waste in one context may be the starting point in another context. Why is “solid waste” discussed under section 3.2.4 “Definition and classification of residuals”? Solid waste should be discussed separate from products and residuals since waste can be a product and/or a residual (even at the same time) so waste needs to not be discussed as a portion of either of these topics but have its own separate discussion. In Table 3.2.4 it is not clear what is meant by “Product – not solid waste.” Does this mean it is liquid waste or does it mean that it is not waste at all or does it mean that this is only a product. Are liquid wastes not part of the definition of waste since only ‘solid waste’ is being discussed.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes. We agree that the actual physical flows are important to follow – but this may result in the physical flows deviating from the national accounts supply and use data. The extent of this deviation has not yet been evaluated here in Norway but the size and implications of this will be examined in the next year as Statistics Norway implements the changes in SNA 2008. In some cases it may not be so critical if the flows into the country match the flows out. The problem comes when the type of processing results in non-negligible amounts of residuals or by-products/waste/waste-products that remain in the country of processing. There will be a physical flow that has no associated economic transactions. More importantly, however, it is our opinion that the description of “goods sent abroad for processing” is consistently misrepresented in the chapter. It appears from the treatment and description in the text that ALL goods sent abroad for processing should be treated in the manor described. It is our understanding that the described situation only arises when there is no change in ownership, i.e. when the flow of goods is, for example, between establishments within the same enterprise. This criterion of not changing ownership needs to be clearly stated whenever this topic is discussed.
  Part III: Any additional comments including those of a more technical nature
[comments attached]
 Chapter3-Norway2.pdf;   
13/07/2011Finland/Geological Survey of Finland & Statistics FinlandPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
The order of sub-chapters could be 3.4. materials, 3.5. water, and 3.6. energy. I thank for having an opportunity to take part in this important procedure. My comments represent an individual expert’s opinion and do not thus have any official or organisational status. 1. Would it help to lighten standardisation efforts if standardised concepts, logical frameworks or formats (like flow sheets) of definition methods and procedures used in information (technology) systems development processes were applied to define and describe SEEA? 2. In global SEEA context, universal (standardised) definitions should be found and understood unambiguously, so that they can be reflected on more regional or other global domain-bound conventions, like materials and energy information gathering for regional (e.g. EU) legislation purposes, for scientific raw materials base accounting, for life cycle considerations (like LCA/LCI) or for Geographic Information Systems (GIS) and so on. E.g. in EU countries SEEA and EU INSPIRE data definitions and classifications concerning materials should negotiate with each other properly to avoid overlapping work. 3. It would be good to introduce the principles of physical flow accounting together with the framework and sub-systems concept in chapter 3.1. 4. I would like to swap the places of chapters 3.4 and 3.6 in order, because every human action at first needs some kind of material use, like commodities or water, as means of using other materials in producing products or energy for consumption.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes. The table seems ok, but I cannot be quite sure, if all relevant classes are included or the logical concept of the table is flowing ok. A process flow sheet might help to piece together the possible gaps in the described flow process and classification.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes. Recording of natural resource residuals as changes of relevant environmental assets should be clearly explained in the asset accounts chapter. 1. Table 3.2.2: In some materials classifications the mineral resources and energy resources are being separated. 2. A general comment to Natural resource inputs (p. 9, 35. text under the table 3.2.2): The entering of minerals or other geological material and energy resources from nature to the economy or geological or mineral residuals back to the economy may take a very long time when compared to many other natural resources or residuals. The reason is the very time-consuming character of finding suitable resources and developing them economical. Also developing and building of mineral-based production infrastructure and units as natural inputs may constitute of a noticeable amount of economic activities. Do e.g. these kinds of factors have effect on the balance of the SEEA in any way?
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes. The discussion in section 3.2. is very clarifying, but still leaves some boundaries unclear. For example, the scrap metal can be firstly recorded as generated solid waste in the store of the producer, but it turns into product if it is later collected by a unit that pays for it. The term by-product: this term and other terms concerning material or energy usage or production need to be defined universally, consistently and objectively. E.g. by-product may mean a profitable by-product besides products from main production line in an industrial production unit context and not just unwanted by-product (residual, waste) etc. 2. Residuals produced besides and from exploitation of mineral natural resources may have economical interest in the long run as raw material resource base. Various environmental mineral waste classifications seem to be underdeveloped and waste/product interfacing and conceptualisation of these materials vague from the economic-geological raw material point of view. Several economic-geological resource classifications and reporting systems exist in use of mineral exploitation industries, but the standardisation of these is under development. These systems may be of help in defining and classifying mineral residuals or their economic status. Resource classifications themselves may need further consideration from the residuals definition point of view. These systems may also need to be integrated to mineral residual resource base outside mining and quarrying industries for getting a big economic-geological picture of the mineral originated resource base.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes. These physical flows can be very remarkable, as well as the flows related to the processing (e.g. energy, residuals). How is the export of resource base consisting or goods made of residuals classified in this context?
  Part III: Any additional comments including those of a more technical nature
Chapter 3.4.5. A short description and a clarifying picture of the EW_MFA framework should be presented in this chapter, and not only a reference to the OECD 2008.
12/07/2011Republic of Croatia/Central Bureau of StatisticsPart II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes.
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
  Part III: Any additional comments including those of a more technical nature
CBS didn’t develop environmental accounts. For the time beings we collect only data on environmental protection expenditure, material flow, environmental taxes and charges and the next steps will be work on water accounts and NAMEA AIR.
11/07/2011Switzerland/Federal Statistical OfficePart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
This chapter is well presented and the major topics are included. However, we think that the classification of natural input should be more detailed with at least a third level (like the proposition made for the consultation last year). This will avoid that every country develops its own classification.
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
We globally agree with the description of natural inputs and the definition of residuals. However we have some comments: - Like already said under general comment: classification of natural Inputs should be more detailed. - It should be mentioned in the biological resources (39-44) that they also included bacteria and fungi. All discussions are about plants (crops) and/or animals (livestock) and there is a risk that cultivated bacteria and fungi will be forgotten altough they can have very specific ecosystem inputs and emissions. - The definition of Ecosystem input (45-47) could be more precise and detailed (what really means “not easily identifiable”). Furthermore, it should be explained that what is called Nitrogen and Oxygen are N2 and O2 from the air (at least it is what we understood). - In table 3.2.3 concerning soil resources, excavated soil should also be under residuals (it seems possible that no transportation happens). - In order to be complete and not to leave flows unexplained, in the description of the different output flows which are recorded in the 2008 SNA, the point 53 (or 56, or new point) should be completed as follows: "There are some products that are used as part of the production processes within an enterprise, intra-enterprise flows, that are recognized by monetary transactions in the SNA. For example, the flows of fodder grown within an agricultural holding which are directly consumed as intermediate consumption by the livestock of the same unit, in order to produce livestock (as stock or as own-account produced fixed capital goods) or animal products (e.g. milk, wool, honey, eggs)." - We propose to reformulate paragraph 54 as follows, in order to avoid misleading statements and interpretation: “Consistent with the discussion on natural resource inputs, cultivated biological resources, recorded in the SNA either as fixed assets or as work in progress, are considered to be products and hence growth in this resources is recorded as an increase in output of products. Cultivated fixed assets include livestock and plantations used repeatedly and continuously in production processes, and therefore reared or grown for the output they regularly provide. The cultivated fixed assets include e.g. breeding livestock, dairy livestock, draught animals, wool rearing animals, bees, orchards, vineyards, cork oak plantations, berry plantations. Work in progress on cultivated biological resources includes e.g. stock livestock (animals for slaughter), aquaculture products, crops and forests in the scope of wood production."
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
We agree with the treatment for the central network and the proposed exception for EW-MFA. However, a more systematic analysis of the implication of this exception should be done in section 3.6 (for example replace points 230-234 by a table)
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
  Part III: Any additional comments including those of a more technical nature
§89: Losses are also of particular interest for materials flows (e.g. food) §106: Example i) seems straightforward but identifying the country of residence of a ship can be very difficult considering the highly complicated structure of international shipping economy. Please specify how to define the residence country of a ship. §159: Please note that there may be a difference between energy products purchased and products consumed (e.g. in the case of heating oil). §229: This is true in the short term because of data availability but in the middle term full adjustment should be made also in EW-MFA.
11/07/2011ESCWAPart I: Any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content.
The structure and style are good. Proof reading is needed Refer to SEEAW and IRWS in section 3.5
  Part II: 1. Overall, do you agree that Table 3.2.1 correctly presents the main flows that need to be taken into account in physical flow accounting?
Yes.
  Part II: 2. Overall, do you agree with the descriptions of the types of natural inputs and, in particular, do you agree with the definition of natural resource residuals?
Yes.
  Part II: 3. Overall, do you agree with the proposed treatment of cultivated biological resources for the central framework as described in Section 3.2 and the proposed exception for EW-MFA purposes as described in Section 3.6?
Yes. Page 44 para 214. Clarification is needed on how to treat the recording of flaring and venting both in emissions accounts and natural resources residuals. (is it double counting??)
  Part II: 4. Overall, do you agree that the discussion on solid waste in section 3.2 reflects the relevant considerations for the definition of solid waste?
Yes. 1-More elaboration is needed on waste accounts since it is considered important by ESCWA member countries. 2-In page 46, para 223, ISIC 39 on remediation of solid waste activities can be added to ISIC 38. 3-In Table 3.6.2 Is Incineration to generate Energy part of Incineration?? It should be reported “of which Incineration to generate Energy..” -Also Add Remediation ISIC 39 separate from other industries. 4- UNSD /UNEP questionnaires on environment statistics o/waste should be harmonised with waste accounts like the Water statistics was harmonized with water accounts definitions.
  Part II: 5. Overall, do you agree that the actual physical flows of goods sent abroad for processing should be recorded in the central framework?
Yes.
  Part III: Any additional comments including those of a more technical nature
Page 29 first line: Examples include petroleum (Add products) from crude oil…..
 

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