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 After considering the comments received, this change proposal has been withdrawn and the change has not been made in the 2014-2015 NPRI Canada Gazette notice.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 (February 2013)

B) Summary of Stakeholder Comments and Environment Canada’s Response (July 2014)

A) Proposal (Febuary 2013)

1. Background

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).

Table 1. Reporting Thresholds for Particulate Matter Fractions
Particulate Matter FractionAir 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 μm0.5
PM2.5 – particulate matter with a diameter less than 2.5 μm0.3

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:

  1. The facility reports PM10 and PM2.5, but does not report TPM
  2. The facility reports TPM and PM2.5, but does not report PM10
  3. The facility reports TPM and PM10, but does not report PM2.5
  4. The facility reports PM2.5, but does not report TPM and PM10
  5. The facility reports PM10, but does not report TPM and PM2.5
  6. 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.

Table 2. Number of Facilities with Unreported Particulate Matter Fractions, 2008-2010
PM Fraction(s) Not ReportedNumber of Facilities That Did Not Report PMFraction(s)
200820092010
TPM2,3112,2062,080
PM10313
PM2.5423023
TPM and PM10667641712
TPM and PM2.5332298227
PM10 and PM2.5866953
TOTAL3,4413,2453,098

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.

Table 3. Particulate Matter Release Quantities, Reported and Adjusted, 2010
 TPM (tonnes)PM10 (tonnes)PM2.5 (tonnes)
Total of release quantities as reported by facilities345,406144,56854,469
Total release quantities after unreported quantities are approximated353,748148,17356,579
Difference8,3433,6042,110

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.

Table 4. Number of Facilities Reporting Particulate Matter Fractions by North American Industrial Classification System (NAICS) Code, 2010
3-Digit NAICS CodeNAICS Sub-Sector NameNumber of Facilities that reported 1 PM fractionNumber of Facilities that reported 2 PM fractionsNumber of Facilities that reported 3 PM PMfractionsNumber of Facilities that reported one or more PM fractions
111Crop Production0303
113Forestry and Logging1001
115Support Activities for Agriculture and Forestry362332
211Oil and Gas Extraction6081,029461,683
212Mining and Quarrying (except Oil and Gas)532200237
213Support Activities for Mining and Oil and Gas Extraction410216
221Utilities2017455249
237Heavy and Civil Engineering Construction251118
311Food Manufacturing4512257224
312Beverage and Tobacco Product Manufacturing112316
313Textile Mills1102
314Textile Product Mills0224
315Clothing Manufacturing0112
321Wood Product Manufacturing2170168259
322Paper Manufacturing62573104
323Printing and Related Support Activities5027
324Petroleum and Coal Product Manufacturing204950119
325Chemical Manufacturing245674154
326Plastics and Rubber Products Manufacturing15281154
327Non-Metallic Mineral Product Manufacturing699058217
331Primary Metal Manufacturing145168133
332Fabricated Metal Product Manufacturing19311161
333Machinery Manufacturing1719
334Computer and Electronic Product Manufacturing1001
335Electrical Equipment, Appliance and Component Manufacturing3306
336Transportation Equipment Manufacturing21571795
337Furniture and Related Product Manufacturing514221
339Miscellaneous Manufacturing612725
411Farm Product Wholesaler-Distributors113418
412Petroleum Product Wholesaler-Distributors0145
416Building Material and Supplies Wholesaler-Distributors0101
418Miscellaneous Wholesaler-Distributors11231347
481Air Transportation1001
482Rail Transportation0011
484Truck Transportation1001
486Pipeline Transportation16561486
488Support Activities for Transportation45211
493Warehousing and Storage7233161
531Real Estate328031
541Professional, Scientific and Technical Services1023
561Administrative and Support Services0101
562Waste Management and Remediation Services13363887
611Educational Services016521
622Hospitals0628
811Repair and Maintenance0268
812Personal and Laundry Services1102
911Federal Government Public Administration314320
TOTAL9922,1061,0674,165

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
Table 5. Summary of Stakeholder Comments and Environment Canada's Response
No./TopicStakeholder CommentEnvironment Canada Response
1. SupportThe 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 RationaleEC 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 PMEC should also consider reporting requirements for PM that include more sources of PM than are presently captured.
4. Data QualityThe 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 QualityThe 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 BurdenAdditional 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 BurdenWhile 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. TimingThe 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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