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ENVIRONMENTAL INDICATORSENVIRONMENTAL INDICATORSConsumption of Consumption of
Ozone-Depleting SubstancesOzone-Depleting Substances
UNECE Joint Task Force on Environmental Indicators UNECE Joint Task Force on Environmental Indicators Eastern Europe, the Caucasus, Central Asia & South-Eastern EuropeEastern Europe, the Caucasus, Central Asia & South-Eastern Europe
Geneva, 11-13 July 2011Geneva, 11-13 July 2011
Ozone SecretariatOzone SecretariatSophia MylonaSophia Mylona
Monitoring and Compliance OfficerMonitoring and Compliance Officer
Presentation outlinePresentation outline
Background information on the Montreal Protocol Background information on the Montreal Protocol Key features, Institutional frameworkKey features, Institutional framework Key obligations Key obligations
Data reporting Data reporting Status of reporting Status of reporting Reporting proceduresReporting procedures Issues related to the quality of reported data Issues related to the quality of reported data Major challengesMajor challenges
Concluding remarksConcluding remarks
1985 VIENNA CONVENTION FOR THE PROTECTION OF THE OZONE LAYER1985 VIENNA CONVENTION FOR THE PROTECTION OF THE OZONE LAYER
Montreal Protocol Montreal Protocol on Substances that Deplete the Ozone Layer (ODS)on Substances that Deplete the Ozone Layer (ODS)
Adopted 16 September 1987Adopted 16 September 1987
196 Parties – Universal Ratification196 Parties – Universal Ratification
Contains mandatory timetables for the phase out of ODS Contains mandatory timetables for the phase out of ODS
- Original Protocol: 5 CFCs & 3 halons; - Original Protocol: 5 CFCs & 3 halons;
- Current: 96 ODS- Current: 96 ODS
Amended 4 times (1990, 1992, 1997, 1999)Amended 4 times (1990, 1992, 1997, 1999)
Adjusted 6 times (1990, 1992, 1995, 1997, 1999, 2007)Adjusted 6 times (1990, 1992, 1995, 1997, 1999, 2007)
As Parties ratify the various Amendments they assume As Parties ratify the various Amendments they assume
new data reporting responsibilitiesnew data reporting responsibilities
Development of Parties’ Ratification StatusDevelopment of Parties’ Ratification Status
Institutional Framework under the Montreal ProtocolInstitutional Framework under the Montreal ProtocolInnovative features:Innovative features: Assessment Panels,Assessment Panels,
Non-Compliance MechanismNon-Compliance Mechanism andand Financial MechanismFinancial Mechanism
Meeting of Meeting of the Parties the Parties
ImplementationImplementation
CommitteeCommittee
ExCom/ExCom/Multilateral Multilateral
FundFund
UNEP/DTIEUNEP/DTIE
Ozone Ozone Secretariat Secretariat
UNEPUNEP
UNDPUNDP UNIDOUNIDO World BankWorld Bank
Assessment Assessment PanelsPanels
Bureau of Bureau of the the
Meeting of Meeting of PartiesParties
ScientificScientific Environmental Environmental EffectsEffects
Technology Technology & &
EconomicsEconomics
Multilateral Multilateral Fund Fund
SecretariatSecretariat
Other MEAsOther MEAs
Party classification under the Montreal ProtocolParty classification under the Montreal Protocol EECCA/SEE RegionEECCA/SEE Region
Developing countries (Article 5 Parties) Developing countries (Article 5 Parties)
- eligible for MLF funding- eligible for MLF funding
Albania, Armenia, Bosnia and Herzegovina,
Georgia, Kyrgyzstan, Montenegro,
Republic of Moldova, Serbia,
The former Yugoslav Republic of Macedonia, Turkmenistan
Developed countries (non-Article 5 Parties) - CEIT, funded by Global Environment Facility (GEF)- CEIT, funded by Global Environment Facility (GEF)
Azerbaijan, Belarus, Kazakhstan, Russian Federation,
Tajikistan, Ukraine and Uzbekistan
Regional Networks of National Ozone Units (NOUs)Regional Networks of National Ozone Units (NOUs)
Set up under the Multilateral Fund to build the National Ozone Set up under the Multilateral Fund to build the National Ozone Officers’ (NOOs) skills to implement and manage national ODS Officers’ (NOOs) skills to implement and manage national ODS phase-out activitiesphase-out activities
Networking activitiesNetworking activities- Annual and follow-up workshops- Annual and follow-up workshops- Regular communication between UNEP and NOOs- Regular communication between UNEP and NOOs- Thematic and contact group meetings - Thematic and contact group meetings - Country-to-country cooperation- Country-to-country cooperation
Results:Results: Improved data reporting, policy making, Improved data reporting, policy making,
Refrigerant Management plans and development of peer Refrigerant Management plans and development of peer pressure among ODS Officers to take early steps to implement pressure among ODS Officers to take early steps to implement
the Protocolthe Protocol
Key players:Key players: NOOs, Implementing Agencies, NOOs, Implementing Agencies, Regional Coordinators Regional Coordinators (based at (based at UNEP’s Regional Offices)UNEP’s Regional Offices)
Compliance Assistance Programme - Regional Networks
Key Obligations under the Montreal ProtocolKey Obligations under the Montreal Protocol
Control Measures: phase out schedulesControl Measures: phase out schedules Common but differentiated approach: Developing Common but differentiated approach: Developing countries given 10 years’ grace periodcountries given 10 years’ grace period
Regulatory measures:Regulatory measures: - Establishment of Licensing systems- Establishment of Licensing systems- Trade controls- Trade controls
Data ReportingData Reporting - Imports, Exports, Production, Destruction of ODS, - Imports, Exports, Production, Destruction of ODS, Trade with non-Parties Trade with non-Parties - Exempted uses (if relevant): Feedstocks, Essential - Exempted uses (if relevant): Feedstocks, Essential
uses, uses, Critical or Quarantine and Preshipment applications of Critical or Quarantine and Preshipment applications of methyl bromide, Emergency uses methyl bromide, Emergency uses
Non-Article 5 Party Control Measures 2010-2030Non-Article 5 Party Control Measures 2010-2030 (Consumption)(Consumption)
SubstanceSubstance BaselineBaseline 20102010 20152015 20202020 20302030
CFCsCFCs, , HalonsHalons 19861986 100%100%
Other CFCs,Other CFCs,
Carbon Carbon tetrachloride,tetrachloride,
Methyl chloroformMethyl chloroform
19891989 100%100%
HCFCsHCFCs 19891989** 75%75% 90%90% 99.5%99.5% 100%100%
HBFCHBFC NoneNone 100%100%
BCMBCM NoneNone 100%100%
Methyl BromideMethyl Bromide 19911991 100%100%
* 1989 HCFC Consumption + 2.8 CFC Consumption
Article 5 Party Control Measures 2010-2040Article 5 Party Control Measures 2010-2040 (Consumption)(Consumption)
SubstanceSubstance BaselineBaseline 20102010 20152015 20202020 20252025 20302030 20402040
CFC, CFC,
HalonsHalons
Average ofAverage of
1995-19971995-1997
100%100%
Other CFCsOther CFCs, ,
Carbon Carbon tetrachloridetetrachloride
Average of Average of 1998-20001998-2000 100%100%
Methyl Methyl chloroformchloroform
Average of Average of 1998-20001998-2000
70%70% 100%100%
HCFCsHCFCs Average of Average of 2009-20102009-2010
10%10% 35%35% 67.5%67.5% 100%100%** 100%100%
HBFC, BCMHBFC, BCM NoneNone 100%100%
Methyl Methyl BromideBromide
Average of Average of
1995-19981995-1998
20%20% 100%100%
* Allowing for servicing an annual average of 2.5% during 2030-40
Regulatory measures: Licensing systemsRegulatory measures: Licensing systems
Within 6 months of ratifying the 1997 Montreal Within 6 months of ratifying the 1997 Montreal Amendment Parties must establish and implement a Amendment Parties must establish and implement a system for licensing the import and export of all new, system for licensing the import and export of all new, used, recycled and reclaimed ODSused, recycled and reclaimed ODS
All parties in the EECCA/SEE region have reported to All parties in the EECCA/SEE region have reported to the Secretariat that they have established and operate the Secretariat that they have established and operate licensing systemslicensing systems
However, more than cursory compliance is essential toHowever, more than cursory compliance is essential to
ensure ODS phase-out – The efficiency of operation and ensure ODS phase-out – The efficiency of operation and
enforcement of licensing systems remains a challengeenforcement of licensing systems remains a challenge
Data Reporting obligations Data Reporting obligations (Article 7)(Article 7)
Each Party must report its ODS data annualyEach Party must report its ODS data annualy
Reported data must include (as appropriate):Reported data must include (as appropriate): Imports, Exports, Production, Destruction of ODS, Imports, Exports, Production, Destruction of ODS, Trade with non-Parties Trade with non-Parties Exempted uses (if relevant): Feedstocks, Exempted uses (if relevant): Feedstocks,
Essential uses, Critical or Quarantine and Essential uses, Critical or Quarantine and Preshipment applications of methyl bromide, Preshipment applications of methyl bromide, Emergency uses Emergency uses
Data reporting forms and reporting instructions are Data reporting forms and reporting instructions are available at the Ozone Secretariat’s website available at the Ozone Secretariat’s website http://ozone.unep.org/new_site/en/ozone_data_tools.phphttp://ozone.unep.org/new_site/en/ozone_data_tools.php
Data reporting….Data reporting….contcont
Annual Data Reporting:Annual Data Reporting:
Due 30 September each year, starting the year Due 30 September each year, starting the year
the Protocol or relevant Amendment enters into the Protocol or relevant Amendment enters into
force for the Party force for the Party
Parties are encouraged to report by 30 June Parties are encouraged to report by 30 June
each year (decision XV/17)each year (decision XV/17)
All reported (aggregated) figures to date can be All reported (aggregated) figures to date can be
accessed through the Secretariat’s web site: accessed through the Secretariat’s web site: http://ozone.unep.org/new_site/en/ozone_data_tools_access.phphttp://ozone.unep.org/new_site/en/ozone_data_tools_access.php
Annual data reportingAnnual data reporting Parties reporting data within 6 and 9 months
02040
6080
100120140
160180
Num
ber
of P
artie
s
Year
30-Jun 30-Sep
Global ODS ConsumptionGlobal ODS Consumption97.4 % reduction in all ODS by all Parties by 200997.4 % reduction in all ODS by all Parties by 2009
0
200,000
400,000
600,000
800,000
1,000,000
1,200,000
1,400,000
1,600,000
1,800,00019
8619
8719
8819
8919
9019
9119
9219
9319
9419
9519
9619
9719
9819
9920
0020
0120
0220
0320
0420
0520
0620
0720
0820
09
Year
Co
nsu
mp
tio
n (
OD
P t
on
nes
) Non-Article 5 Article 5
Consumption of ODS in the EECCA/SEE RegionConsumption of ODS in the EECCA/SEE Region
98.6% of the Parties’ baseline phased out by 200998.6% of the Parties’ baseline phased out by 2009
0
20,000
40,000
60,000
80,000
100,000
120,000
140,000
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
Year
Co
nsu
mp
tio
n (
OD
P t
on
nes
) Methyl Bromide
BCM
HBFCs
HCFCs
Methyl Chloroform
CCL4
Other Fully Halogenated CFCs
Halons
CFCs
Reporting procedureReporting procedure Parties report their ODS data to the Ozone Secretariat Parties report their ODS data to the Ozone Secretariat
through their designated Authorities which act as focal through their designated Authorities which act as focal pointspoints
The Secretariat reviews the submitted data to detect any The Secretariat reviews the submitted data to detect any apparent discrepancies and check compliance with the apparent discrepancies and check compliance with the Protocol provisionsProtocol provisions
Cases of Potential Non-Compliance are subject to the Cases of Potential Non-Compliance are subject to the established Non-Compliance Procedure and are established Non-Compliance Procedure and are eventually brought to the attention of the Implementation eventually brought to the attention of the Implementation Committee for its considerationCommittee for its consideration
However,However,
The Ozone Secretariat does not have the mandate to The Ozone Secretariat does not have the mandate to question/assess the quality of reported dataquestion/assess the quality of reported data
Reporting procedure…Reporting procedure…contcont
Countries that receive financial assistance from Countries that receive financial assistance from
the MLF/GEF to phase out their ODS must the MLF/GEF to phase out their ODS must
report their sectoral data to those institutionsreport their sectoral data to those institutions
Those reports are evaluated by the MLF/GEFThose reports are evaluated by the MLF/GEF
Are you aware of any such activities in your country?Are you aware of any such activities in your country?
Close interaction with your National Ozone Officers is Close interaction with your National Ozone Officers is
important in this regardimportant in this regard
Definition of ODS Consumption under the ProtocolDefinition of ODS Consumption under the Protocol
Annual controlled consumption is defined as:Annual controlled consumption is defined as:
““ConsumptionConsumption” = “” = “Production”Production” + + ImportImport –– ExportExport
where:where:
““ProductionProduction”” = Production – Destruction – Feedstock use = Production – Destruction – Feedstock use
With the exemption of the Russian Federation which is an With the exemption of the Russian Federation which is an
ODS producer and exporter, all other countries in the region ODS producer and exporter, all other countries in the region
are predominantly ODS importers; Thus, data quality depends are predominantly ODS importers; Thus, data quality depends
primarily on the reliability of imported dataprimarily on the reliability of imported data
Reliability of reported data - Major challengesReliability of reported data - Major challenges
National ODS legislation may not be as comprehensive as it National ODS legislation may not be as comprehensive as it should or may not be implemented effectivelyshould or may not be implemented effectively
National licensing systems for ODS import/export may not be National licensing systems for ODS import/export may not be operating or enforced effectively, resulting to misreporting and operating or enforced effectively, resulting to misreporting and possibly illegal tradepossibly illegal trade
Countries with ODS destruction facilities may not be reporting Countries with ODS destruction facilities may not be reporting the ODS quantities destroyedthe ODS quantities destroyed
Co-operation between all relevant authorities and stakeholders Co-operation between all relevant authorities and stakeholders at the national level or regional/global level (in cases involving at the national level or regional/global level (in cases involving international trade) may be inadequate or even absentinternational trade) may be inadequate or even absent
Participation of countries in the informal Prior Consent (iPIC) Participation of countries in the informal Prior Consent (iPIC) Procedure has prevented several cases of illegal trade in ODSProcedure has prevented several cases of illegal trade in ODS
Informal Prior Informed Procedure (iPIC) on ODS Trade Informal Prior Informed Procedure (iPIC) on ODS Trade
A voluntary and informal mechanism of information exchange A voluntary and informal mechanism of information exchange on intended trade between the authorities in importing and on intended trade between the authorities in importing and exporting countries which are responsible for issuing ODS exporting countries which are responsible for issuing ODS
trade licenses (NOUs)trade licenses (NOUs)
Aims to assist member countries to implement licensing Aims to assist member countries to implement licensing systems effectively so that they do not exceed their maximum systems effectively so that they do not exceed their maximum allowable consumption levels under the Protocolallowable consumption levels under the Protocol
Key elements:Key elements: Exporting countries check the copy of import licenses Exporting countries check the copy of import licenses
voluntarily before issuing export licensesvoluntarily before issuing export licenses Importing countries inform exporting countries of their Importing countries inform exporting countries of their
registered importers and the ODS quantities allocated to registered importers and the ODS quantities allocated to them for a specific yearthem for a specific year
Informal Prior Informed Procedure (iPIC) on ODS Trade Informal Prior Informed Procedure (iPIC) on ODS Trade
Established in 2005/2006 in South East Asia on a pilot basis Established in 2005/2006 in South East Asia on a pilot basis involving NOUs and their customs counterpartsinvolving NOUs and their customs counterparts
In 2008 6 countries of the ECA Ozone Network (In 2008 6 countries of the ECA Ozone Network (Armenia, Armenia, Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan and Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan and UzbekistanUzbekistan) and one country from Latin America () and one country from Latin America (ColombiaColombia) ) joined the iPIC procedurejoined the iPIC procedure
In the first 2 months of 2009, 6 more countries from Latin In the first 2 months of 2009, 6 more countries from Latin America (America (Bahamas, Belize, Guyana, Jamaica, St. Lucia and Bahamas, Belize, Guyana, Jamaica, St. Lucia and Trinidad & TobagoTrinidad & Tobago) joined in) joined in
The The European UnionEuropean Union fully participates in the iPIC since 2007 fully participates in the iPIC since 2007
Network countries have proposed that major exporting Network countries have proposed that major exporting countries such as China, India and the Republic of Korea work countries such as China, India and the Republic of Korea work closely with importing countries in the region closely with importing countries in the region
The ECA Ozone NetworkThe ECA Ozone Network Includes 12 Article 5 countries from the Balkan, Caucasus and Includes 12 Article 5 countries from the Balkan, Caucasus and
Central Asia regionCentral Asia region
Trade partners including the EU, China and Russia are involved Trade partners including the EU, China and Russia are involved in a project in a project “ECA enforcement network of Customs & “ECA enforcement network of Customs & Enforcement Officers”Enforcement Officers” and cooperate closely on the prevention and cooperate closely on the prevention of illegal ODS tradeof illegal ODS trade
During the period 2007-2009, more than 1000 metric tonnes of During the period 2007-2009, more than 1000 metric tonnes of allegedly recycled CFCs were illegally traded and investigations allegedly recycled CFCs were illegally traded and investigations have been initiated. Such illegal trade could have been have been initiated. Such illegal trade could have been prevented through simple phone calls or email exchanges prevented through simple phone calls or email exchanges between importing and exporting countries applying the iPIC between importing and exporting countries applying the iPIC
procedureprocedure
Decision XVII/16Decision XVII/16 (Dakar, 2005)(Dakar, 2005)
Preventing illegal trade in controlled Preventing illegal trade in controlled ozone-depleting substancesozone-depleting substances
“…“…..
4. 4. To request the Ozone Secretariat to revise the reporting To request the Ozone Secretariat to revise the reporting format resulting from decision VII/9 to cover exports (including format resulting from decision VII/9 to cover exports (including re-exports) of all controlled ozone-depleting substances, re-exports) of all controlled ozone-depleting substances, including mixtures containing them, and to urge the Parties to including mixtures containing them, and to urge the Parties to implement the revised reporting format expeditiously. implement the revised reporting format expeditiously. The The Ozone Secretariat is also requested to report back Ozone Secretariat is also requested to report back aggregated information related to the controlled aggregated information related to the controlled substance in question received from the exporting/re-substance in question received from the exporting/re-exporting Party to the importing Party concernedexporting Party to the importing Party concerned;;
……” ……”
Import/Export data discrepancies in ECA/CEIT countries- 2009Import/Export data discrepancies in ECA/CEIT countries- 2009(Aggregated amounts in MT)(Aggregated amounts in MT)
Importing country Imported ODS(New)
Exported ODS(New)
Exporting country
Albania 97.37 36.5 China, EU, Turkey
Armenia 141.9
Azerbaijan 41.3
Belarus 179.36 1.9 A non-A5 Party
Bosnia & Herzegovina 82.76 45.8 Croatia, EU
Croatia 168.0185 86.5 China, EU, India
Georgia 83.2
Kazakhstan 1179.4 170.9China, EU, Rep. of Korea, Russian Fed.
Kyrgyzstan 75.66
Montenegro 17.14 15.7 India
Import – Export data discrepancies in 2009Import – Export data discrepancies in 2009…cont…cont (Aggregated amounts in MT)(Aggregated amounts in MT)
Importing country Imported ODS(New)
Exported ODS(New)
Exporting country
Republic of Moldova 21.1 0.7 A non-A5 Party
Russian Federation 9072.8 10377.6 USA, EU, China, India
Serbia 181.7 49.8 USA, EU, China, Croatia
Tajikistan 48.8
The FYR of Macedonia
57.3 45.7 Croatia, India, Turkey
Turkey 9072.9 8068.7 China, EU, India, Rep. of Korea
Turkmenistan 139.2
Ukraine 1015.6 1742.8 China, EU
Uzbekistan 32.6 15.7 Turkey
Import – Export data discrepanciesImport – Export data discrepancies ……contcont (Aggregated amounts of new and recovered substances in MT)(Aggregated amounts of new and recovered substances in MT)
ECA CEIT Total
Reported imports 10139.2 11893.1 22032.3
Discrepancies (MT) 1861.2 5097.0 6958.3
Discrepancies/trade volume (%)
18% 43% 32%
Import – Export data discrepanciesImport – Export data discrepancies ……contcont (per substance in MT)(per substance in MT)
SubstanceDiscrepancy
(MT)Discrepancy
(%)
CFC 348.4 5%
HCFC 6453.0 93%
Methyl bromide 142.2 2%
Methyl chloroform 0.0 0%
Halons 14.1 0%
Carbon tetrachloride 0.5 0%
Several reasons for detected discrepanciesSeveral reasons for detected discrepancies Imports greater that ExportsImports greater that Exports
- Some exporting countries may not be reporting their export - Some exporting countries may not be reporting their export destinations destinations - Exporting countries may be underestimating their exports- Exporting countries may be underestimating their exports- Importing countries may be overestimating their imports- Importing countries may be overestimating their imports
Exports higher than ImportsExports higher than Imports- - Exporting countries may be overestimating their exportsExporting countries may be overestimating their exports- Importing countries may be underestimating their imports – - Importing countries may be underestimating their imports – this case may place the importing country into non-compliance this case may place the importing country into non-compliance under the Protocolunder the Protocol
Whatever the reason, understanding the cause(s) of such Whatever the reason, understanding the cause(s) of such discrepancies and taking measures to prevent them from discrepancies and taking measures to prevent them from reoccurring results in improving implementation of national reoccurring results in improving implementation of national licensing systems and combating illegal tradelicensing systems and combating illegal trade
Challenges related to HCFCsChallenges related to HCFCs HCFCs to be phased-out by 2030 in the developed/CEIT HCFCs to be phased-out by 2030 in the developed/CEIT
countries and by 2040 in the developing countriescountries and by 2040 in the developing countries
The MLF is currently assisting several developing countries to The MLF is currently assisting several developing countries to prepare their HCFC Management Plans (HPMPs) including prepare their HCFC Management Plans (HPMPs) including checking the reliability of national ODS inventories – This has checking the reliability of national ODS inventories – This has resulted in several developing countries requesting revision of resulted in several developing countries requesting revision of their ODS consumption figures for one or several years, their ODS consumption figures for one or several years, including those for 2009 (baseline year) including those for 2009 (baseline year)
From the countries in the EECCA/SEE region, Tajikistan has From the countries in the EECCA/SEE region, Tajikistan has requested revision of its HCFC baseline year (1989) so farrequested revision of its HCFC baseline year (1989) so far
Revisions of baseline data will be considered by the Protocol’s Revisions of baseline data will be considered by the Protocol’s Implementation Committee at its 46Implementation Committee at its 46thth meeting in Montreal, 7-8 meeting in Montreal, 7-8 August 2011August 2011
Concluding remarksConcluding remarks For the countries in the EECCA/SEE Region For the countries in the EECCA/SEE Region
consumption of ODS depends greatly on imported consumption of ODS depends greatly on imported (and to a lesser extent) exported figures(and to a lesser extent) exported figures
Good quality of import/export data requires efficiently Good quality of import/export data requires efficiently enforced licensing systems and excellent coordination enforced licensing systems and excellent coordination of relevant authorities at the national and international of relevant authorities at the national and international level, including participation in the iPIC Procedurelevel, including participation in the iPIC Procedure
For producing countries, reliable consumption data For producing countries, reliable consumption data depend additionally on reporting of ODS destroyed depend additionally on reporting of ODS destroyed and/or used as feedstocks (if relevant)and/or used as feedstocks (if relevant)
Concluding remarks…Concluding remarks…contcont.. Parties are advised to review and strengthen their Parties are advised to review and strengthen their
national data tracking procedures, to ensure proper national data tracking procedures, to ensure proper operation of their licensing systems and to cross-operation of their licensing systems and to cross-check their data with the sources of their importscheck their data with the sources of their imports
National representatives reporting to UNECE on ODS National representatives reporting to UNECE on ODS consumption as environmental indicators should co-consumption as environmental indicators should co-operate closely with their countries’ National Ozone operate closely with their countries’ National Ozone Officers to get a better understanding of the nature of Officers to get a better understanding of the nature of ODS data reported under the Montreal Protocol ODS data reported under the Montreal Protocol (including any activities undertaken by NOOs to (including any activities undertaken by NOOs to improve data quality and any phase-out projects those improve data quality and any phase-out projects those countries may have with the MLF/GEF) and resolve countries may have with the MLF/GEF) and resolve any inconsistencies involvedany inconsistencies involved
