Second report of the National Pollutant Release Inventory working group 2001 to 2002: chapter 4


4.1 Background

The GHGs that are under consideration for addition to the NPRI are the gases covered under the UNFCCC, that is:

  • Carbon Dioxide (CO2)
  • Methane (CH4)
  • Nitrous Oxide (N2O)
  • Hydrofluorocarbons (HFCs)
  • Perfluorocarbons (PFCs)

A sixth GHG, sulphur hexafluoride (SF6), is also included under the United Nations Framework Convention on Climate Change (UNFCCC). However, it is already on the NPRI due to its toxic properties. The WG did not therefore consider whether it should be added to the NPRI, but only whether its current listing should be altered, assuming the other GHGs are added.

The following two-phase approach was applied in considering the potential addition of GHGs to the NPRI:

  • Phase 1: Assess, through analysis of the decision-factors, whether GHGs should be added to the NPRI.
  • Phase 2: Define the boundaries (substances, facilities and exemptions) and reporting parameters (thresholds) for reporting of GHGs to the NPRI.

In keeping with this general approach, this section of the report contains a summary of the outcomes of the WG’s discussions on whether GHGs should be added to the NPRI, given that disagreement on the merits of adding GHGs to the NPRI remained a constant throughout the WG’s discussions. In the case that EC decides to add GHGs to the NPRI, Section 5 of the report addresses the question of how this can be best accomplished.

4.2 Overview of Key Positions

ENGO members of the WG argue strongly in favour of the addition of GHGs to the NPRI and hold that there is no further cause for debate, given that the Phase 1 report concluded that the decision factors are satisfied for each of the GHGs. In the view of the ENGO members, the development of a publicly available, facility-level, annual database on GHG emissions is strongly justified; the addition of GHGs to the NPRI is in keeping with all the objectives of the NPRI; and the NPRI is a ready-made and logical vehicle for facility-level reporting. The ENGO members note that the possibility of adding GHGs to the NPRI has already been on the table for several years, and should not be delayed any longer. They point out that the requests for facility-specific GHG emissions data that are already arising from various sources -- such as local and regional governments and ENGOs -- are likely to increase with availability of information. They also note the importance of linked reporting of CACs and GHGs, in part to support co-benefits assessment. In addition, they argue that given probable thresholds for triggering reporting of GHGs to the NPRI, almost all facilities that will be required to report GHGs would already be reporting CACs. Since in many instances the information needed to estimate GHGs and CACs is the same, additional burden should not be great.

Conversely, industry representatives on the WG are generally not in agreement with the findings of the Phase 1 assessment report; and that in any case, the decision factors are not a sufficient basis for determining whether GHGs should be added to the NPRI, because GHGs are different in nature from other substances on the NPRI. Most fundamentally, industry members maintain that the issue is not whether to add GHGs to the NPRI, but rather what is Canada's national GHG inventory, what are the requirements that it must fulfill, and subsequently, what role does NPRI play. They note that industry has stated its support for a single national GHG inventory that allows for informed policy decisions regarding climate change, advances Canada's National Climate Change Business Plan, and supports Canada's international reporting obligations. The industry members of the WG hold that a clear understanding of the requirements of the inventory and the climate change business plan are essential to an evaluation of whether and how NPRI GHG reporting would meet these needs. Moreover, they argue that a lack of clear alignment with the data that would be collected through NPRI exists not only in relation to the national inventory, but also in relation to other current and future initiatives involving GHG data (e.g., domestic emissions trading, corporate-level emissions reduction strategies, reporting requirements in other jurisdictions). Industry members are also concerned that GHGs from NPRI reporting facilities are only one part of the national picture, and providing a partial picture could lead to confusion and misinterpretation. Finally, industry representatives hold that regardless of whether a facility is already reporting CACs to the NPRI, there are not insubstantial additional costs involved to assess and implement GHG reporting requirements.

4.3 Additional Detail on Specific Issues

4.3.1 Relationship to the National Inventory and Other Federal Requirements for GHG Data

As noted, industry members of the WG fundamentally believe that the question of whether GHGs should be added to the NPRI must be considered in the context of how this would relate to the national GHG inventory, and also to a future domestic emissions trading (DET) program, and to other federal requirements for GHG data. They question whether the necessary institutional connections are being made to ensure efficient linkages between initiatives. (They note, for example, that the Second National Business Plan addresses issues related to data needs, but does not mention the NPRI.) They note that implementation of another data-gathering initiative that does not adequately meet the range of legitimate data needs will increase fragmentation and frustration.

Industry members hold that there should be a single national inventory of emissions (versus two or more separate inventory initiatives that may or may not be linked), and that the only way to accomplish this, should GHGs be added to the NPRI, would be to incorporate the NPRI data in the national inventory. They note, however, that the current national inventory is developed in a top-down manner and the future linkages of the NPRI and the national inventory are unclear. Industry members are also concerned that without addressing the issues of what additional data requirements are needed to serve Canada’s climate change plans and the national inventory, the result may be two or more inventory systems which do not fully meet the federal government needs.

Industry is also concerned that the NPRI is not an appropriate vehicle to inform Canadians on GHG emissions because it does not provide the proper context for this issue. The NPRI by nature is not a comprehensive inventory (excludes diffuse sources such as transportation) so it does not give the complete picture. There is also concern about whether NPRI data would be compatible with UNFCCC inventory guidelines.

ENGO members of the WG note that the purpose and value of a facility-level reporting initiative are distinct from those of a national inventory. EC indicated that the existing National Inventory, with its comprehensive estimates of greenhouse gases, will continue to be the means of reporting on Canadian sources and sinks of GHGs nationally and internationally. The reporting of facility level GHGs through the NPRI is being proposed because other domestic needs are not being met by the present inventory, which is at a sectoral level. However, there was agreement that linkages should be built to the extent possible, since facility-level information can help improve the accuracy of, and detail in, the National Inventory. Linkages can be considered in determining how to integrate GHGs into the NPRI (i.e., in defining reporting parameters). Some industry representatives are concerned, however, that meaningful reconciliation will require expenditures of unwarranted time and resources, and additional data (e.g., fuel consumption and process information) that industry considers to be sensitive.

With respect to DET, industry representatives pointed out that given that consultations on the need for and format of such an initiative are currently ongoing, data requirements cannot be ascertained with any certainty. Thus it is not possible at this point to establish NPRI design parameters that can reasonably be expected to satisfy future DET accounting needs. It was also noted that DET will require more robust information than that which is collected via the NPRI. Industry members feel that this raises important questions about the degree of modification to the NPRI that would be required to add GHGs in a way that would ensure a reasonable level of coverage of facility-specific emissions, and enable the data to be of use in other applications. It was suggested, for example, that the NPRI’s "single-entry" bookkeeping approach is not appropriate for GHGs: that a system to keep track of "debits and credits" (emissions and offsets) is necessary. This again raised the concern about multiple reporting requirements and reconciliation burdens.

ENGO members hold that facility-level reporting is likely to be integral to any DET scheme; and that there is value in implementing mandatory reporting in advance of DET in order to promote readiness to measure and report at the facility-level once trading begins. They also note that NPRI data on GHG emissions would be very useful in helping to determine appropriate allocation of permit requirements, which is acknowledged to be one of the most significant design challenges for DET. Moreover, they believe that regardless of the specific links with Canada’s broader climate policy, NPRI reporting of GHGs will provide a solid analytic basis, and an incentive, for improvements.

4.3.2 Relevance of the Decision Factors

Industry members of the WG hold that the decision factors are not well adapted to GHGs. In their view, GHGs are fundamentally different from other substances on the NPRI, in that their impacts are global, versus local/regional; and a significant and growing proportion of emissions are generated by area sources that are not captured in NPRI reporting. They feel that a more "systems-based", versus geographically specific, approach to GHG reporting is preferable. It was also observed that GHG emissions reduction strategies are not developed or implemented at the facility level, but at higher orders of management; and that corporate-level information (viz VCR reports) provides a platform to engage senior management and achieve the level of commitment and resources necessary to be effective. Thus, although they acknowledge that current data-gathering initiatives do not fully satisfy the conditions for NPRI reporting, industry members question the value of a reporting initiative that does not support a single national GHG inventory that meets all needs.

ENGO members hold that the decision factors can legitimately be applied to any substance of health and/or environmental concern; and that what is key is the concept of facilities taking responsibility for their emissions. Moreover, they are not convinced of the fundamental difference between GHGs and other NPRI substances. It was noted that there are other global-impact substances currently listed on the NPRI, for example some HCFCs; and that there are other substances on the NPRI for which emissions from non-facility sources are significant. ENGO members of the WG also pointed out that facility-level reporting does not preclude corporate-level planning and management; and that in fact, facility information is a required basis for corporate reporting.

4.3.3 Existing Reporting Initiatives

The availability of other databases on or related to GHG emissions led to some questioning by industry members about whether decision factor 4 has been applied and evaluated in the appropriate context. Regardless of views on this point, however, most industry members of the WG argue in favour of improving the comprehensiveness and consistency of existing data-gathering initiatives, rather than establishing a new one. There was a specific concern that a new mandatory reporting requirement could lower participation in the VCR, as many companies will not report to two different programs with different requirements.

ENGO members of the WG do not believe that the essentials of the NPRI -- a broad-based, consistent, legal obligation to report facility-level emissions on an annual basis, and public access to this data -- can be met through improvements to an existing initiative. They feel that the lack of comprehensiveness and consistency that remains following six years of voluntary reporting of GHG emissions through the VCR demonstrates the need for mandatory reporting. They also hold that since corporate-level GHG estimates have to be built up from data at the facility-level, reporting to the NPRI should not discourage current VCR reporters from continuing, and may even simplify participation.

4.3.4 Relationship to Initiatives by Other Levels of Government

ENGO members of the WG point out that facility-level reporting of GHGs is being, or soon will be, required by other jurisdictions. They suggest that early action to integrate GHGs into the NPRI can serve industry’s interest in having a single national window for mandatory facility-level reporting. This would be preferable to disparate regional systems that would create significant headaches for any organizations whose operations cross provincial/territorial borders. Industry representatives on the WG remain unconvinced that provinces will work with the federal government to eliminate duplication and overlap, and that a multiplicity of reporting requirements will likely result. It was suggested, however, that if EC could convince Ontario, Alberta and other jurisdictions to use the NPRI as a one-window reporting system for facility-level GHG data collection, it would have a good case.

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