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A National Pollutant Release Inventory for Canada: The Final Report of the Multi-stakeholder Advisory Committee (December 1992)

RECOMMENDATIONS FOR FURTHER WORK

The Committee recommends that additional work be undertaken on the following issues. Discussions should be pursued through the consultative mechanism described in chapter 8 of this report.

6.1. EVALUATING THE COSTS OF NPRI REPORTING

U.S. experience with the TRI showed that, on average, each reporting facility requires about 50 hours annually to report on the release of each particular substance. No equivalent data exist for the proposed NPRI, but it is expected to impose less of a burden on most reporting facilities because of its design.

The Committee therefore recommends that the cost for Canadian facilities reporting to the NPRI be estimated during the trial run6 based on the information gathered then. It should be made available to stakeholders and senior Environment Canada officials beginning in June 1993, and again after the first reporting year is completed. As well, an analysis of costs and benefits should accompany any changes to NPRI considered for the reporting years beyond 1994.

6.2. ISSUES RELATED TO THE NPRI LIST OF SUBSTANCES

6.2.1. Characterizing the substances on the 1993 list

The Committee believes that the list of 178 substances is acceptable for launching the NPRI, but it recommends that available data on the substances be examined to characterize their related health and environmental concerns. This information will help to determine whether the substances on the list really belong there. It will also be useful for informing stakeholders and the public about the properties and potential effects of NPRI substances. Environment Canada representatives have agreed to undertake this work.

6.2.2. Candidate substances for addition to the NPRI list

A candidate list of 78 substances has been prepared for possible addition to the NPRI (please see appendices). This list was derived from the 10 lists of hazardous substances below. It includes substances that were (a) on two or more of the lists, (b) on the Domestic Substances List in quantities greater than one tonne, and (c) were not on the NPRI list of substances.

The Committee recommends that the health and environmental concerns posed by these substances should be assessed to determine whether they merit inclusion on the NPRI substances list in future years.

The candidate list was derived from:

  • The CEPA Priority Substances List, 1988

  • The Federal-Provincial Advisory Committee on Air Quality List, 1989

  • The Great Lakes Water Quality Agreement (GLWQA), Annex 1, 1988

  • The Great Lakes Water Quality Agreement (GLWQA), Annex 10, 1988

  • The Ontario Ministry of the Environment MISA List (EMPPL), 1988

  • The CCME Interim Assessment Criteria for Contaminated Sites List, 1991

  • The Ontario Ministry of the Environment Clean Air Program List, 1987

  • The IJC Working List of Chemicals in the Great Lakes Basin, 1986

  • The Mayor Industrial Accidents Council of Canada Interim List, 1991

  • The U.S. EPA Superfund Chemicals List, 1991

There are many other lists of substances, prepared for different purposes. They use different criteria in different media and geographical areas. However, the above ten lists are believed to encompass many of the substances in the Canadian environment that are of concern.

6.2.3. Greenhouse gases

The Committee recommends that greenhouse gases (carbon dioxide, methane, and nitrous oxide) be considered for inclusion on the NPRI list.

Environment Canada proposed that greenhouse gases be on the NPRI list. The proposal suggested requesting information on either (a) the amount and type of fossil fuels consumed by the reporting facilities; or (b) the amount of greenhouse gases released, calculated using conversion factors supplied with the NPRI form; or (c) the amount released based on other methods of estimation.

This proposal would require a reporting condition developed specifically for greenhouse gases, since the 10-tonne condition used for other NPRI substances could include sources such as shopping centres, whose releases are better captured by other means. Another approach would be to ask only facilities that already report to include releases of greenhouse gases.

In keeping with its desire for a comprehensive inventory, the Committee agrees with the Environment Canada proposal in principle. However, it is divided on the time and manner of implementation.

Including greenhouse gases in the 1993, reporting year would establish the NPRI as the primary reporting mechanism for these releases; no institutionalized greenhouse gas inventories now exist. On the other hand, delaying the inclusion of greenhouse gases until the reporting details are ironed out would allow the time for considering all the issues involved.

One such issue, for example, is whether data on greenhouse gas releases should be categorized as a by-product of energy use or fossil fuel use. Under Environment Canada's proposal, a facility's shift from oil to electricity would result in that facility's reporting reduced greenhouse gas releases to the NPRI. If the electricity was generated hydraulically, the reduction would be real; if it was generated by coal, there would be little or no actual reduction.

Other issues requiring consideration include 'the need to harmonize NPRI's approach with that of other departments (such as Energy, Mines and Resources Canada, which has a mandate to collect information on energy use under the authority of the Energy Efficiency Act); the sources from which release data should be gathered; and the reporting conditions under which greenhouse gases should be reported.

In summary, the representatives of federal and provincial governments, environmental groups, labour and the Canadian Chemical Producers Association (CCPA) are in favour of including greenhouse gases on the 1993 NPRI list of substances. Industry representatives (except CCPA) favour first working out how the data would be collected before putting greenhouse gases on the list. They do not believe this can be accomplished before the 1994 reporting year.

6.2.4. Processes for adding, deleting and qualifying substances on the NPRI list

The Committee recommends that a process be developed by which the NPRI substances list can be modified by addition, deletion or qualification. (Please see the NPRI substances list in the appendices for examples of qualified substances.)

Among other things, this process should take into account the health and environmental concerns associated with the substance; the likelihood of its use in sufficient quantity to be reported; and expert judgment on the interactions between toxicity, exposure, persistence and so on. The process should allow any person, stakeholder or government to request the addition, deletion or qualification of a substance; it should include an opportunity for public comment.

6.3. REVIEW OF FACILITY EXEMPTIONS

In section 4.3, the Committee recommended that several types of facilities be specifically exempted from NPRI reporting. The Committee recommends review of these exemptions after experience is gained during 1993. Additional information should be gathered from these sectors regarding their ability or difficulty in reporting.

6.4. ISSUES RELATED TO PUBLISHING NPRI INFORMATION

Making release data easily accessible to the public is a major NPRI objective. The Committee has proposed means by which NPRI data should be made available (please see the appendices). However, the Committee is also aware of the limitations on NPRI resources, and the importance of getting the inventory up and running. Therefore, the Committee is recommending the following topics for further discussion during 1993.

6.4.1. Methods of access and dissemination

There are various ways in which information gathered by the NPRI could be disseminated to the public, namely: an electronic data base accessible by modem; a CD-ROM; an annual report; and a telephone support service. The telephone service would provide user support for the electronic versions of the data base, and respond to requests for paper copies of specific information in the NPRI. The Committee recommends evaluation of these methods in terms of users' needs, and the cost of implementation.

6.4.2. The NPRI annual report

The Committee envisages an NPRI report composed of 13 volumes or sections: a national report, 10 provincial reports and two territorial reports. The national report would contain information from all parts of Canada, as well as inter-provincial comparisons. The provincial reports would detail the geographic distribution of releases within each province.

The NPRI report could present the data in figures and tables, accompanied by some discussion in the text. It should be structured to allow the tracking of trends. As a general rule, the quantities of substances released and those that are transferred should be listed separately, not added together.

The Committee recommends that these proposals be evaluated in terms of their cost and practicability.

6.5. A SPECIFIC LEGISLATIVE AUTHORITY FOR THE NPRI

The Committee (government members excepted) recommends investigation of an amendment to CEPA specifically tailored to the objectives and characteristics of the NPRI. The following reasons motivate the Committee's recommendation:

  1. Section 16 was not designed for use by an inventory with an annual reporting cycle.
  2. An explicit legislative authority would clarify rules governing the operation of the NPRI and give them a more permanent status.
  3. The use of Section 16 of CEPA limits what can be done to implement the NPRI. For example, under Section 16, suppliers cannot be required to notify customers of the presence of NPRI substances in the chemicals they sell, as is required by the U.S. TRI.

Government members of the Committee did not participate in the discussion of this recommendation because it is beyond their mandate to recommend changes to legislation.

The environmental groups would prefer the development and adoption of a specific legislative authority for the NPRI during the parliamentary review of CEPA in 1993.

6.6. A FIVE-YEAR REVIEW OF THE NPRI

The Committee recommends that a comprehensive review of the NPRI be undertaken after five years of operations. It should reconsider all aspects of the NPRI--reporting conditions, costs, the list of substances and so on--in the light of experience gained, and the current state-of-the-art of environmental protection.


6 The trial run is a test of the NPRI system that will be held in the first half of 1993. Sixty facilities have volunteered to complete and/or comment on the NPRI form and methodology manual.

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