Second report of the National Pollutant Release Inventory working group 2001 to 2002: chapter 5


5. Parameters for Adding Greenhouse Gases to the NPRI

Notwithstanding differing views on the underlying merits of the undertaking, the WG, with substantial input from the GHG SG, worked towards defining the parameters for addition of GHGs to the NPRI in the event that the decision to do so is confirmed by EC. The views and recommendations of the WG related to the parameters are summarized in sections 5.1 (exemptions), 5.2 (facility definition) and 5.3 (thresholds). In addition, there was general agreement that attention should be paid to opportunities to facilitate and streamline reporting. In this vein, the WG specifically explored potential relationships with the VCR. Section 5.4 addresses this issue, and other outstanding issues and work.

5.1 Exemptions

The WG considered the possible need to drop or modify existing exemptions, should GHGs be added to the NPRI. WG members agreed that most NPRI exemptions can continue to stand for GHGs (i.e., most exemptions would not significantly affect coverage from GHG emissions reporting), with the exception of those discussed below.

5.1.1 Upstream Oil and Gas Industry

Assuming GHGs are added to the NPRI, members agree in principle that the requirement to report GHGs should apply to the UOG industry. As noted in subsection 3.1.2, the fact that emissions from many upstream oil and gas activities are currently not reported to the NPRI relates partly to the fact that oil and gas well drilling and operation are specifically exempt from reporting; although the employee threshold may be a more significant factor. The UOG SG will bear the issue of GHG reporting in mind in the context of their ongoing examination of the implications of removing the current oil and gas well exemption.

5.1.2 Distribution, Storage or Retail Sale of Fuels

The current exemption from reporting for the distribution, storage or retail sale of fuels (with the exception of terminal operations), means that reporting is not currently required for emissions associated with the operation of fuel pipelines. Assuming that GHGs are integrated into the NPRI, members agree that significant GHG emissions from fuel pipeline systems should be captured in the reporting. Natural gas pipelines are a significant source of GHG emissions; but GHG emissions from other fuel pipeline systems are negligible. Thus, if the current NPRI exemption was completely removed for purposes of GHG emissions reporting, reporting would only be triggered from natural gas transmission and distribution systems. However, due-diligence in determining whether reporting requirements are applicable would be a potential burden on operators of other types of fuel pipeline systems.

Industry members of the WG support an alternative approach that would meet the objective of activating reporting on GHG emissions from the target (natural gas) pipeline systems, without adding complexity and needless work for non-target systems. This approach involves maintaining the exemption, but specifying that it does not apply to GHG emissions from natural gas transmission and distribution.

As a related point, since fugitive emissions can occur along the length of a pipeline system, the WG recommends that GHG emissions from transmission pipelines and distribution systems be reported on a systems-basis. A recommended approach to accomplishing this is described in subsection 5.2.2.

It is worth noting that the focus in this subsection on potential reporting gaps in fuel transmission and distribution pipeline systems reflects the fact that upstream gathering systems (i.e., the infrastructure linking wells to each other and to batteries or processing plants) are addressed under section 3 of this Report.

5.1.3 Mining

Mining operations associated with the production of fossil fuels were briefly discussed in relation to both the UOG industry, and the addition of GHGs. Specifically, questions were raised regarding the status of reporting for coal and oil sands mining. All mining is currently exempt from NPRI reporting. Thus, it is difficult to rationally address gaps in GHG emissions reporting from coal and oil sands mines in isolation from the broader question of whether the current exemption of mining activities from NPRI reporting requirements should continue to stand. WG members therefore agree that the exemption of mining from NPRI reporting needs to be examined in a systematic manner, and for all NPRI substances, not just GHGs. A path forward is outlined in subsection 7.1.3 of this report.

5.2 Facility Definition

5.2.1 Basic "contiguous facility" Definition

The "contiguous facility" definition is familiar to reporters, and extending its application to cover GHG emissions will support consistent multi-pollutant tracking. The WG therefore recommends that for the majority of reporting sectors, NPRI’s current "contiguous facility" definition continue to apply in the context of GHG reporting. As further outlined below, however, a unique approach is needed for pipeline transportation systems.

Notwithstanding general agreement to maintain the "contiguous facility" definition, the WG also recommends that:

  • EC explore with Statistics Canada (Stats Can) how this NPRI definition links with the SC definition of "establishment" (used as the basis for defining reporting entities in the ICE survey), for purposes of reconciling data reported through the two systems; and
  • EC track how "facility" is being defined in international protocols that have been or are being developed for purposes of GHG data collection, to maximize potential linkages.

5.2.2 Additional Definition for Pipeline Transportation Systems

As noted in subsection 5.1.2 (under "Distribution, storage or retail sale of fuels"), the WG recommends a systems-level approach to the reporting of GHGs from pipelines. A systems-level approach would also be appropriate for GHG emissions reporting not only from natural gas pipelines, but also from non-fuel (e.g., CO2) pipeline systems, should they become NPRI reporters.

Given this, the "contiguous facility" definition is not appropriate for pipelines; and neither is the "pipeline installation" definition included in the December 29, 2001 Canada Gazette notice. A pipeline installation "is a collection of equipment situated at a single site, used in the operation of a fossil fuel pipeline". The need for this definition was driven by the addition of criteria air contaminants (CACs) to the NPRI for the 2002 reporting year, along with the associated requirement for reporting CAC emissions from stationary combustion equipment for all sectors, regardless of other exemptions or of number of employees. Thus, in keeping with modelling needs for location-specific emissions data, CAC emissions must now be reported individually for compressor stations and any other combustion-driven installations along pipelines.

The same conditions and needs do not apply to GHG reporting: fugitive emissions can occur all along the pipeline; and geographic specificity is of lower relative importance for GHG emissions reporting than for emissions reporting of other substances. Thus, there is no driver for location-specific data on GHG combustion-related emissions from pipelines. Given an intent to promote comprehensive reporting of GHGs from pipelines without undue burden, it makes sense to allow companies to report on aggregate pipeline emissions.

WG members therefore recommend that for purposes of GHG reporting, "pipeline transportation systems" be an additional component of the definition of "facility"; and that this term be defined to consist of all pipelines and associated installations -- including storage facilities but excluding straddle plants or other processing installations -- that are under single ownership within a given provincial boundary. Straddle plants and other processing installations that may occur along pipelines would be considered contiguous facilities for purposes of NPRI reporting, and would thus report individually if triggered. The wording "pipeline transportation systems" is sufficiently generic to cover pipelines for substances other than natural gas, should these become reporting facilities in the future.

5.3 Thresholds

5.3.1 General Points

Assuming GHGs are added to the NPRI, some industry members of the WG are opposed to including all six substances as GHGs. Specifically, they do not accept that there is a rationale for requiring that the three synthetic compound groupings be reported to the NPRI as GHGs, since these constitute only a very small proportion of Canadian GHG emissions. (There was also some questioning of the rationale for including N2O as a GHG on the NPRI, given that N2O is a small proportion of Canadian GHG emissions on a CO2 equivalent basis, and that industry sources in turn account for a very small proportion of N2O emissions.) Conversely, ENGO members of the WG believe that all these substances should be included as GHGs on the NPRI, given their high relative global warming potential (GWP) and Canada’s international obligations for them.

There was general agreement with the use of release-based thresholds, although some questions emerged as to whether and how the current MPO threshold for the reporting of SF6 should be altered. There was also general agreement in principle with considering CO2 equivalency as a factor in setting thresholds for the GHGs. Industry members of the WG are strongly in favour of direct linkage between thresholds on a GWP basis, and recommend a 100,000 tonne CO2 equivalent for all GHGs. ENGO members are less categorical, but also believe there should be a relationship, based on GWP, between the thresholds; at least for CO2, CH4 and N2O. EC representatives concur with the logic of GWP equivalency to the CO2 threshold, but hold that this should be one consideration in setting thresholds for the remaining substances, not the single determinant of these thresholds. They note that opportunities for emissions reductions may vary between the six gases; and thus, tracking some GHGs at a lower GWP threshold may make sense.

Little consensus emerged on the substance-specific thresholds that should apply in the event that GHGs are added to the NPRI. For reference, the following table indicates thresholds applied in emissions reporting programs in Ontario and Europe:

Table 5.1: GHG Facility Reporting Thresholds*
GHG Ontario MOEE**
O.Reg.127/01
(tonnes/year/facility)
EPER Draft
(tonnes/year/facility)
Carbon dioxide (CO2) 100,000 100,000
Methane (CH4) 5,000 100
Nitrous Oxide (N20) 2.7 100
Sulphur hexafluoride (SF6) 10*** 0.05

Perfluorocarbons (PFCs), Carbon tetrafluoride (CF4)

Carbon hexafluoride (C2F6)

None 0.1
Hydrofluorocarbons (HFCs 23,32,125,134a,143a,152a,227ea) (only HFC 134a) 0.01 0.1

* Thresholds are release-based unless otherwise noted

** MOEE set its thresholds with an intention to obtain 90% coverage of Ontario’s industrial facilities. (Data is not yet available to ascertain whether this coverage is being achieved.)

*** Threshold is based on the quantity manufactured, processed, and/or otherwise used.

5.3.2 Carbon Dioxide (CO2)

Industry members of the SG believe that 100 kilotonnes (kt) is the lowest reasonable threshold for CO2. They note that this threshold will trigger reporting from in the order of a few hundred facilities, and will yield coverage in the order of about 90% of industry emissions, based on available analysis for the manufacturing and electricity sector combined. They hold that the overall gains in emissions coverage associated with going to a 50 kt threshold are small when compared against the additional the number of facilities that would be triggered to report. In their view, the overall significance of industrial emissions in relation to the impact of global climate change does not warrant imposing a broader burden for relatively small incremental gains. They also note that the 100 kt reporting threshold is already used by the Ontario Ministry of Energy and the Environment (MOEE), and by the European Pollutant Emissions Register (EPER).

NGO members of the SG variously support a threshold of between 20 and 50 kt. They hold that the 8 megatonnes of emissions that would be captured from the manufacturing sector in going from a 100 to a 50 kt threshold is not insignificant. They also argue that since the estimate of 90% coverage at 100 kt is based on information from only two sectors, it is not a reliable indicator of coverage for industry emissions as a whole; and they believe that the capture of emissions from facilities in sectors other than manufacturing and electricity (e.g., the UOG sector and commercial and institutional buildings) will require a lower threshold. There was also a concern that with the 100 kt threshold, there would be little or no reporting from facilities in many provinces. This could undermine both community right-to-know about who are the major local/regional emitters, and the basis for comparisons between like facilities to improve understanding of emissions reduction opportunities. It was also noted that at a 100 kt threshold, many facilities reporting CACs would not be reporting GHGs; and this compromises the goal of multi-pollutant tracking.

5.3.3 Methane (CH4)

Members of the SG who represent the UOG, as well as representatives of other industry sectors, believe that a 5000 tonne threshold is reasonable, at least as a starting point. They argue that there is no rationale for imposing a lower threshold, in terms of CO2 equivalency, than for CO2 itself. (Rounding up, a 5000 tonne threshold for methane reflects reasonable GWP equivalency to the industry’s proposed 100 kt threshold for CO2.)

The ENGO position is that a 100 to 1000 tonne threshold is needed. They also suggest the need to relate the threshold for methane to the CO2 threshold, on an equivalency basis.

The UOG SG is developing an analysis for the sector of emissions coverage at different thresholds. This will be available to WG members prior to their September meeting, and may influence final positions on the threshold for methane.

5.3.4 Nitrous Oxide (N2O)

As a means of reducing reporting burden, the WG considered the option of linking N2O and NOx emissions reporting for combustion-related emissions. This would mean automatic reporting of N2O when NOx reporting is triggered. However, it was noted that this approach would not be consistent with existing practice, and that a linked approach for combustion emissions would need to be combined with another approach for covering process emissions. For these and other reasons, most members of the WG were in favour of a single threshold trigger for N2O reporting. (There could still be a software linkage between NOx and N2O combustion emissions to assist reporters, but N2O would only need to be reported if it met the threshold. Sectors likely to release process-related N2O could also be identified in guidance to reporters.)

In terms of recommending a specific threshold, some WG members noted that it would be useful to see what is reported to Ontario in the first reporting cycle under the new regulation; but the Ontario data will not be available in time to influence the threshold proposed by the WG for purposes of the current report to stakeholders.

Based on available information, EC indicated that a 500 tonne threshold would capture emissions associated with adipic acid production, but probably not nitric acid or fuel combustion. A lower threshold of 50 tonne would capture all process emissions, as well as the larger fuel combustion sources; and this is the threshold that EC proposed. (EC noted that there is significant uncertainty in estimating combustion emissions for this gas, so the capture of only the larger sources might be appropriate.)

Industry members of the WG believe a threshold of 300 tonnes is appropriate; and note that this is more or less equivalent to the proposed 100 kt thresholds for CO2 on a GWP basis. ENGO members support a threshold of between 10 and 100 tonnes. This range is in line, on a GWP basis, with their proposed CO2 threshold; and is also more in line with the Ontario and EPER thresholds.

5.3.5 PFCs, HFCs and SF6

The WG noted that these three synthetic gases are substantially different from the three main GHGs discussed earlier. As was already noted under the general points above, some industry members of the WG question whether these substances should be tracked as GHGs in the NPRI at all, given their small total contribution (in the order of 2%) to total GHG emissions on a CO2 equivalency basis. They also point out that data is already collected on the use patterns of PFCs and HFCs through CEPA 1999. Emissions of PFCs from aluminium production are a byproduct release and not collected in these use pattern surveys.

ENGO members point out that HFC emissions are expected to increase dramatically, and since HFCs and PFCs are not controlled by the Montreal Protocol, their use may increase. Therefore, they hold that given the high GWP of these substances, and Canada’s international obligations, emissions should be reported at the facility level.

WG members suggested that the EC confer with the industries that will be most affected by emissions reporting for these substances, to obtain their input on the ranges being discussed.

PFCs

PFCs are a family of gases with varying GWPs for each species. These gases, listed with the GWP in brackets, are: CF4(6500), C2F6(9200), C3F8(7000), C4F10(7000), C4F8(8700), C5F12(7500), and C6F14(7400).

Over 99% of emissions of PFCs (on a CO2 eq basis) are released as CF4 and C2F6 from aluminium production. EC proposes that the NPRI consider collecting release data for the major PFCs (CF4 and C2F6) because the releases of the other gases are small. (The sum of the releases of the other gases is less than 1 tonne.)

Following industry’s goal of setting thresholds at the 100 kt CO2 equivalency, the thresholds would be 15 tonnes for CF4 and 11 tonnes for C2F6. These thresholds would capture about 90% of CF4 and 20% of C2F6 emissions. ENGO member support a threshold similar to the EPER threshold of 0.1 to 1 tonne for each gas. A 1 tonne threshold would capture at least 99% of emissions of both substances.

Some members of the WG suggested that for simplicity, a single threshold be set for aggregate emissions of PFCs. The issue of how these gases should be reported (i.e., as a single number or by individual species) was not discussed by the WG.

HFC’s

HFCs are a family of gases with a range of GWPs for each species. These gases are generally being developed and used as replacements for ozone depleting substances. The gases which are used and released in Canada are listed with the GWP in brackets: HFC-23 (11700), HFC32(650), HFC-125(2800), HFC-134a(1300), HFC 152a(140) HFC 143a(3800). Other HFCs exist but currently are not being used in Canada.

Emissions of HFCs are associated primarily with their use in refrigeration, air conditioning and foam blowing. On a CO2 eq basis these emissions currently total 900 kt CO2 eq, but are projected to increase significantly in the future (e.g., up to 7000 kt by 2010, according to NRCan’s 1999 report Canada’s Emissions Outlook: An Update) as ozone depleting substances are phased out.

Following industry’s goal of setting thresholds on a 100 kt CO2 eq basis would result in a wide range of thresholds (9 to 714 tonnes). ENGOs would like to see a threshold of 0.1 tonne for each substance, in keeping with the EPER threshold. As with PFCs, some members of the WG suggested that a single threshold be set for aggregate release of PFCs. Again, the issue of how these gases should be reported (i.e., as a single number or by individual species) was not discussed by the WG.

Alternatively EC has suggested the possibility of paralleling the approach used for the ozone depleting substances (HCFC’s and CFC’s) that are already on the NPRI. These are reported on a 10 tonne MPO basis. This approach could be adopted for simplicity and comparability of reporting. Another alternative is the MOEE approach, which focuses on the HFC that accounts for the majority of emissions (HFC 134a), with a release-based threshold of 10 kg.

Further analysis of the options should be possible over the summer with the recent availability of the MOEE emission data.

SF6

Releases of SF6 are already reported to the NPRI on a 10 tonne MPO basis. Releases are primarily from the use of SF6 in processes such as magnesium smelting and to a lesser degree magnesium casting and insulating electric equipment. The WG discussed the possibility of altering the threshold to a release-based threshold, consistent with other GHGs.

Following Industry’s goal of setting thresholds based on a 100 kt CO2 eq basis the threshold should be set at 4 tonnes. This threshold is expected to capture over 80% of total releases including all the major releases from magnesium smelting and some of the smaller releases from magnesium casting. It is not expected to capture releases from electric equipment.

ENGOs would like to see a threshold set at 0.1 to 1 tonne, to align more closely with EPER.

5.4 Additional Issues and Ongoing Work Requirements Related to GHGs

5.4.1 Alleviating Burdens Through One-Window Reporting

One of the key concerns for many WG members who are opposed to GHG emissions reporting in the NPRI relates to duplication of effort and burden. A "one-window" approach to the reporting of GHG emissions data could help alleviate this concern.

Several industry members of the WG back a specific proposal for one-window reporting, presented to the GHG SG by Bob Flemington of the Voluntary Challenge Registry (VCR) Inc. This proposal involves adapting the VCR to serve as a one window reporting service through which the GHG emissions data required by the NPRI and other emerging initiatives could be delivered, for those reporters who are participating in other aspects of the VCR. The VCR currently has a number of registries, and participating companies report to selected registries as appropriate. Rather than filing directly to the NPRI, those VCR reporters to whom NPRI reporting requirements for GHGs apply could choose to include NPRI reporting requirements as part of their VCR reporting, and the VCR would channel this data through to NPRI. (EC would remain responsible for data quality control and compliance.) This approach might enable the VCR to build linkages between reporting software and databases, thereby reducing reporting burden.

EC representatives noted that there may be legal impediments to reporting through the VCR to the NPRI. Research on legal implications would need to be undertaken in parallel with the exploration of different data-sharing options. ENGO members stress that the fundamentals of NPRI reporting must remain consistent for all reporters, regardless of other programs in which reporters participate. That is, the coverage, the conditions of reporting (facility definitions, threshold, etc.), the timing for receipt of data by the NPRI, and the public availability of NPRI data, must not be compromised. For this and other reasons, they maintain that whatever data-sharing arrangements are developed, the NPRI should be the window through which reporting occurs.

Bearing in mind the above, WG members generally support the goal of enabling reporters to use a single window to channel data and information required by different programs; and recommend further exploration of the various options by the VCR and EC, to determine whether and how the linkages should be pursued.

5.4.2 Geological Sequestration

Some industry members of the WG suggested that only releases to air should be tracked; and that reporting requirements should not apply to CO2 that is going into the ground. They pointed to a need for consistency with national and international inventory protocols in determining how to treat sequestration in the NPRI. EC representatives suggested that for consistency with NPRI reporting rules, emissions that are geologically sequestered should be reported; but that these emissions could be reported separately, to enable appropriate qualifications to be applied in analyzing the data and reporting out. ENGOs believe that reporting of sequestered emissions is essential, and that the nature of the sequestration must be clearly reported. However, they are open to the option of separate reporting for sequestered CO2.

5.4.3 Biomass Combustion

A similar set of issues arises with respect to CO2 from combustion of biomass. CO2 emissions from biomass are required to be reported separately in national inventories, but are not counted in national inventory emission totals, since biomass is defined as a zero net emission source in UNFCCC protocols. (The carbon released in burning is deemed to be offset by the carbon taken up in growing the biomass.) NPRI staff argued for separate reporting on biomass combustion emissions, and noted that tracking is an important means of gaining understanding of how much fuel switching to biomass is occurring. ENGO members of the WG hold that emissions from biomass should be reported as are emissions from other combustion sources, although again, they are open to the option of separate reporting. Some industry members hold that there is ample existing information on fuel switching, and that given that the UNFCCC deems this a zero net emission source, there is no rationale for reporting CO2 from biomass combustion to the NPRI.

5.4.4 Reporting Out

WG members note that proper context on GHG emissions must be provided when NPRI reports out to the public. This relates in part to a concern that data users may inappropriately lump GHG emissions in with emissions of other NPRI substances for purposes of analysis. Questions of reporting out may also need to be addressed in relation to the preceding two issues (sequestration and biomass combustion). Reporting out issues will be further explored by the WG at its September meeting.

5.4.5 Landfills (employee threshold)

The WG generally agrees that emissions of methane from landfills should be captured if GHGs are added to the NPRI. This probably requires removal of the employee threshold exemption for purposes of GHG reporting from landfills. It may be that a volume-based threshold would be a reasonable alternative to minimizing undue burden on small facilities. EC must undertake some additional analysis in order to present a proposal to the WG.

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