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Proposal to Modify the National Pollutant Release Inventory Reporting Requirements for Particulate Matter
Environment Canada (EC) proposed to change the National Pollutant Release Inventory (NPRI) reporting requirements for the three listed particulate matter (PM) size fractions commencing with the 2014 reporting year. The revised requirements would mean that if the reporting threshold for any one of the three PM fractions is met, then all three PM fractions would have to be reported, regardless of release quantities. Consultations on this issue were conducted with the NPRI Multi-Stakeholder Work Group (WG) in February 2013. After considering the comments received, this change proposal has been withdrawn and the change has not been made in the 2014-2015 NPRI Canada Gazette notice.
A) Proposal (Febuary 2013)
Beginning with the 2002 reporting year, seven criteria air contaminants (CACs) were added to the list of NPRI substances, including three PM size fractions, which are shown in Table 1. Each of the three PM fractions has a mass threshold for releases to air that must be met before reporting is required (see Table 1).
|Particulate Matter Fraction||Air Release Threshold (tonnes)|
|Total particulate matter (TPM) – particulate matter with a diameter less than 100 micrometres (μm)||20|
|PM10 – particulate matter with a diameter less than 10 μm||0.5|
|PM2.5 – particulate matter with a diameter less than 2.5 μm||0.3|
The TPM fraction includes PM10and PM2.5, while PM10 includes PM2.5. It is therefore impossible for PM2.5 or PM10 releases to exceed TPM releases. It is also impossible for PM2.5 releases to exceed PM10releases.
2. Particulate Matter Data Issues
Since each PM fraction has its own release threshold, a facility may be required to report any combination of one, two or three PM fractions. For example, a facility that releases 0.3 tonnes of PM2.5, but no PM larger than this size, would have to report for PM2.5, but not for PM10 and TPM. Because TPM and PM10 include PM2.5, we know that at least 0.3 tonnes of PM10 and TPM were released, but these releases are not required to be reported since the PM10 and TPM thresholds were not met. This results in information gaps in the NPRI database. There are six scenarios that occur when facilities report for PM:
- The facility reports PM10 and PM2.5, but does not report TPM
- The facility reports TPM and PM2.5, but does not report PM10
- The facility reports TPM and PM10, but does not report PM2.5
- The facility reports PM2.5, but does not report TPM and PM10
- The facility reports PM10, but does not report TPM and PM2.5
- The facility reports TPM, but does not report PM10 and PM2.5
The information may not be reported by a facility for two possible reasons – either because reporting requirements for certain fractions were not met, in which case the facility is not required to report for those fractions; or a facility fails to report for one or more PMfractions even though the reporting requirements were met.
Table 2 summarizes the number of facilities that reported for one or more PM fraction, but did not report for other PM fractions (the scenarios described above) for the 2008 through 2010 reporting years. From 2008 to 2010, the number of facilities that did not report for one or two PM fractions ranged from 3,098 to 3,441.
|PM Fraction(s) Not Reported||Number of Facilities That Did Not Report PMFraction(s)|
|TPM and PM10||667||641||712|
|TPM and PM2.5||332||298||227|
|PM10 and PM2.5||86||69||53|
When data is not reported on all three PM fractions, it causes significant issues during the annual preparation of the comprehensive air pollutant inventories. Where the data is not reported, it must be allocated using ratios based on sector PM profiles by facility subclass. These allocations are not as accurate as facility-reported data would be.
As shown in Table 3, quantities of PM are allocated and added to the facility-reported release values to adjust the amounts for the comprehensive inventory. While the quantities that are added to the facility-reported values are not large when compared to the total amounts reported, the adjustment could be quite large for any specific facility. Information at the facility level is important, since emissions have impacts on local air quality. If facility-reported data was available, it is unknown what impact it may have on the totals for these substances.
|TPM (tonnes)||PM10 (tonnes)||PM2.5 (tonnes)|
|Total of release quantities as reported by facilities||345,406||144,568||54,469|
|Total release quantities after unreported quantities are approximated||353,748||148,173||56,579|
3. Proposed Change
Currently, a report is required to be submitted for a listed PM fraction if the threshold for that fraction is met. Environment Canada proposes to modify the existing reporting requirements for TPM, PM10 and PM2.5 starting with the 2014 reporting year. A clause would be added to the Canada Gazette Notice indicating that if the reporting threshold for any one of the three PM fractions is met, then all three PM fractions would have to be reported, regardless of release quantities. No changes will be made to the air release thresholds for the individual PM fractions – the air release thresholds will remain at 20, 0.5 and 0.3 tonnes for TPM, PM10 and PM2.5, respectively.
To ensure that the reporting community is aware of the revised requirements, a quality control check would be added to the online reporting system. When at least one of the PM fractions was reported, but not all of them, the check would either warn users or result in an error.
4. Impacts of Proposed Change
As shown in Table 2, 3,098 facilities reported for at least one PM fraction, but not for all three fractions, in 2010. Therefore, about 3,100 facilities are expected to have to submit reports on additional PM fractions if the proposed change is implemented. These facilities are already reporting on at least one PM fraction and are likely to have done the calculations for the other fraction(s) to determine if they were required to report. This change would simply require them to report on those releases they have already calculated, resulting in limited additional reporting burden on facilities. About 2,100 of these facilities will have to submit a report for one additional fraction (since they are already reporting for two PM fractions) and about 1,000 of these facilities will have to submit reports for two additional fractions (since they have only reported for one PM fraction in previous years).
As shown in Table 4, 4,165 facilities reported for at least one PM fraction in 2010, 88% of which are in four industrial sectors or sub-sectors: oil and gas extraction sub-sector (46%); manufacturing sector (NAICS codes starting with 31-33) (36%); utilities sub-sector (6%); and mining and quarrying (except oil and gas) sub-sector (5.7%). Approximately the same number of facilities in each sector is expected to report in future years and facilities in these four sectors would be impacted the most by the proposed change.
The proposed change will help to fill in some of the gaps in NPRI data on air releases, making more complete information on air pollutant releases available to Canadians. It will also help improve air quality predictions, support for regulations (federal, provincial and territorial), and improve the quality of comprehensive inventory data, since the releases will be facility-reported instead of allocated.
|3-Digit NAICS Code||NAICS Sub-Sector Name||Number of Facilities that reported 1 PM fraction||Number of Facilities that reported 2 PM fractions||Number of Facilities that reported 3 PM PMfractions||Number of Facilities that reported one or more PM fractions|
|113||Forestry and Logging||1||0||0||1|
|115||Support Activities for Agriculture and Forestry||3||6||23||32|
|211||Oil and Gas Extraction||608||1,029||46||1,683|
|212||Mining and Quarrying (except Oil and Gas)||5||32||200||237|
|213||Support Activities for Mining and Oil and Gas Extraction||4||10||2||16|
|237||Heavy and Civil Engineering Construction||2||5||11||18|
|312||Beverage and Tobacco Product Manufacturing||1||12||3||16|
|314||Textile Product Mills||0||2||2||4|
|321||Wood Product Manufacturing||21||70||168||259|
|323||Printing and Related Support Activities||5||0||2||7|
|324||Petroleum and Coal Product Manufacturing||20||49||50||119|
|326||Plastics and Rubber Products Manufacturing||15||28||11||54|
|327||Non-Metallic Mineral Product Manufacturing||69||90||58||217|
|331||Primary Metal Manufacturing||14||51||68||133|
|332||Fabricated Metal Product Manufacturing||19||31||11||61|
|334||Computer and Electronic Product Manufacturing||1||0||0||1|
|335||Electrical Equipment, Appliance and Component Manufacturing||3||3||0||6|
|336||Transportation Equipment Manufacturing||21||57||17||95|
|337||Furniture and Related Product Manufacturing||5||14||2||21|
|411||Farm Product Wholesaler-Distributors||11||3||4||18|
|412||Petroleum Product Wholesaler-Distributors||0||1||4||5|
|416||Building Material and Supplies Wholesaler-Distributors||0||1||0||1|
|488||Support Activities for Transportation||4||5||2||11|
|493||Warehousing and Storage||7||23||31||61|
|541||Professional, Scientific and Technical Services||1||0||2||3|
|561||Administrative and Support Services||0||1||0||1|
|562||Waste Management and Remediation Services||13||36||38||87|
|811||Repair and Maintenance||0||2||6||8|
|812||Personal and Laundry Services||1||1||0||2|
|911||Federal Government Public Administration||3||14||3||20|
B) Summary of Stakeholder Comments and Environment Canada's Response (July 2014)
The NPRI Multi-Stakeholder WG provided input on Environment Canada’s proposal to change the reporting requirements for PM fractions. After considering stakeholder input, Environment Canada has decided not to implement this change for the 2014 reporting year. Additional analysis on the costs and benefits of the proposed change to thresholds for PM fractions, as well as other possible options to meet the objectives of the proposal, should be completed before moving ahead. Deferral of this change proposal will allow it to be considered in a coordinated manner with other possible changes to reporting requirements for PM, which are expected to be considered for the 2016 reporting year as a result of EC’s current work on the Air Quality Management System and inventories for black carbon.
The table below summarizes comments received from the Multi-Stakeholder WG and provides EC’s responses.
Comments were received from these the following stakeholders:
- Assembly of First Nations
- Chemistry Industry Association of Canada and Canadian Fuels Association (joint comment)
- Great Lakes United
- Canadian Vehicle Manufacturers’ Association
- Canadian Association of Petroleum Producers
- International Institute of Concern for Public Heath
- Community Health Opposition to Known Emissions Dangers
|No./Topic||Stakeholder Comment||Environment Canada Response|
|1. Support||The proposed change to require the reporting of all three PM fractions if the threshold for any one of the fractions is met is warranted and is supported.||Support for the change proposed by Environment Canada (EC) is acknowledged. No response is required.|
|2. Insufficient Rationale||EC has not provided a strong enough rationale for the change. The current method that EC uses to estimate PM values that are not reported is adequate. Compliance promotion should instead be done for those facilities that are already required to report for more PM fractions but are not doing so.|
EC recognizes that there are several possible areas for improvements in PM reporting, and other options to meet the objectives of this proposal. EC is deferring consideration of this change based on the need for additional analysis on costs and benefits of the proposed approach, and to allow consideration of this change alongside other possible changes to PM reporting requirements that may result from current departmental activities related to criteria air contaminants (CACs).
The comments listed here, submitted by stakeholders in response to the February 2013 proposal, will be taken into account as these other possible changes are considered.
|3. Other Sources of PM||EC should also consider reporting requirements for PM that include more sources of PM than are presently captured.|
|4. Data Quality||The accuracy of reported PM data needs to be improved and the data that are presented reflect the appropriate number of significant digits so as not to imply a greater accuracy than exists.|
|5. Data Quality||The uncertainty associated with PM emission factors is significantly larger than the estimated increased coverage resulting from the proposed change and therefore the proposed change would not contribute to the quality of the data.|
|6. Additional Burden||Additional calculations and reporting by facilities will not represent significant extra burden on facilities; or any additional burden is minimal compared to the value of more comprehensive facility-reported PM data.|
|7. Additional Burden||While facilities may already be doing rough estimates to determine if they meet the reporting threshold for all three PM fractions, doing the more precise calculations in order to report on actual emissions would represent a more significant extra burden on industry than implied in the proposal. The additional burden outweighs any potential benefit of the additional PM data.|
|8. Timing||The timing for the implementation of the proposed changes does not provide facilities with sufficient lead time to collect the required information. The proposed changes should be implemented for the 2015 reporting year at the earliest. NPRI notices should be published no later than December of the year prior to which the notices apply.||This change is no longer being proposed for 2014 reporting. As such, the timing is not an issue since the PM reporting requirement for 2014 is the same as for the previous year. EC recognizes that the publication of Canada Gazette notices for the NPRI should occur as early as possible.|
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