Use of published emissions factors by facilities in National Pollutant Release Inventory

Petition: 368

Issue(s): Air quality, governance, human/environmental health, science and technology, toxic substances

Petitioner(s): Canadian organization

Petitioner Location(s): Toronto, Ontario

Date Received: 22 July 2014

Status: Completed—Response(s) to petition received

Summary: The petition concerns the accuracy of air emissions data published in Environment Canada’s National Pollutant Release Inventory (NPRI). The petition asserts that releases of toxic volatile organic compounds (VOCs) may be under-reported because Canadian facilities are permitted to estimate a key component of their emissions using emission factors despite mounting evidence that these factors are unreliable. The petition focuses on fugitive emissions—pollutants released into the environment from leaks in equipment, pipelines, seals, valves, etc.—rather than the usual sources such as chimneys, stacks, and vents. According to the petition, fugitive emissions are a major component of emissions from the petrochemical industry that may be inaccurately reported.

The petition asserts that the use of emission factors rather than actual measurements to measure fugitive emissions increases the potential for inaccurate emissions reporting. The petition notes that published emission factors are the most commonly used method for estimating fugitive VOC emissions in the oil and gas sector. The petition states that researchers and environmental groups in Canada and the United States have expressed doubts about the accuracy of published emission factors for several years. The petition cites a 2006 report prepared for Environment Canada and two provincial environment ministries that underscored three major risks of using emission factor estimates: undetected production inefficiencies, adverse effects on air quality, and critical inaccuracies in database information.

According to the petition, Environment Canada continues to direct NPRI reporting facilities to a US Environmental Protection Agency (EPA) document entitled Compilation of Air Pollutant Emission Factors, despite the fact that the EPA has officially acknowledged that it needs to investigate whether its published emission factors are accurate.

The petition concludes by emphasizing the need to ensure that the NPRI presents fair and accurate information. The petition asserts that this is a duty placed on the government under the Canadian Environmental Protection Act, 1999. According to the petition, the continued use of published emission factors creates a risk that the NPRI is not living up to its intended purpose and that it might be providing a false indicator—at least about toxic VOC emissions.

The petition asks whether the Minister of the Environment is aware of concerns raised about using published emission factors to estimate and report toxic VOC emissions, including recent actions taken by the EPA. It also asks whether the Minister will amend the NPRI guidelines by prohibiting the use of published emission factors until their accuracy can be improved. Alternatively, the petition asks if the Minister will review and amend the NPRI reporting requirements to include a condition that direct measurement techniques be used to verify that emission factors are reasonably accurate. Finally, the petition requests an explanation of any research or actions that have been taken or will be taken to address this issue including relevant timelines for these activities.

Federal departments responsible for reply: Environment Canada