International Requirements on Pollutant Emissions Reporting and Implications for Greenhouse Gas Emissions

In an effort to understand the quantity of pollutants entering the environment, several countries have implemented pollutant emissions reporting programs. Under the typical pollutant emissions reporting program, an affected facility is required to report to its respective government or government agency information concerning the quantity of pollutants emitted into the air, water and land as well as the amount of waste transported for disposal, recycling or reclamation.

Criteria that determine whether a facility is required to report pollutant emissions often includes the types of pollutants released, the quantity of pollutants released and, in some cases, the number of individuals employed or the total number of hours that employees work at a facility releasing pollutants. The pollutant emissions information collected by the government or the government agency is then disseminated to the public.

A facility can to use a number of tools to estimate the quantity of pollutants released into the environment, tools commonly used to estimate the quantity of pollutants released into the environment include:

  • Direct Measurement: Direct measurement is based on measured concentrations of the substance in a waste stream and volume/ flow rate of that stream. This method can involve periodic sampling or continuous monitoring.
  • Mass Balance: A mass balance involves applying the law of conservation of mass to a facility, process or piece of equipment. Releases are determined from the differences in input, output, accumulation and depletion of a substance.
  • Engineering Calculations: Releases can be estimated from engineering principles and judgment, by using knowledge of the chemical and physical processes involved, the design features of the source and an understanding of the applicable physical and chemical laws.
  • Emissions Factors: Emission factors relate to the quantity of substances emitted from a source to some common activity associated with those emissions. Emission factors are generally based on the results of source sampling tests performed at one or more facilities within a specific industry.

Countries implementing pollutant emissions reporting programs include the United States, Canada, Australia and Member States of the European Union.  The following pollutant emission reporting programs are just a few examples of programs currently implemented:

Australia:  National Pollutant Inventory (NPI)

  • Canada:  National Pollutant Release Inventory (NPRI)
  • Europe:  European Pollutant Release and Transfer Register (European PRTR)
  • United States:  Toxic Release Inventory (TRI)

While these pollutant emissions reporting programs are similar, there are also key differences such as the method to verify pollutant emissions reported by a facility, the types of facilities required to report, pollutant emissions thresholds triggering reporting requirements and the types of pollutants that an affected facility is required to report. Pollutant emissions reporting requirements can vary depending on what country a facility is located in. For example, while there are no explicit provisions in the United States’ TRI program regarding verification procedures for emissions information, there are verification procedures for pollutant emissions reporting programs for Member States of the European Union, Australia and Canada.  Given that pollutant emission eligibility and reporting requirements can vary depending upon a facility’s location, it is critical for a company to know what pollutant emissions reporting requirements apply to a facility based on the facility’s location.

Climate change concerns are leading to expanded reporting requirements

Over the years concerns over climate change have increased.  In response, countries are exploring how to efficiently obtain information about the quantity of greenhouse gases (GHGs) released into the environment and implement policies that address climate change. Many countries, trying to determine how to implement a GHG emissions reporting program, are faced with the decision of whether to include GHG emissions within existing pollutant emissions reporting programs or whether GHG emissions will require a separate reporting program. Despite the implementation issues surrounding GHG emissions reporting programs, countries have decided that knowing the quantity of GHGs emitted by a facility into the environment is a critical step in addressing climate change.

Some countries, namely Member States in the European Union, already require the reporting of GHGs, which include carbon dioxide (CO2), nitrous oxide, methane, chloroflourocarbons (CFCs), hydrofluorocarbons (HFCs), hydrochlorofluorocarbons (HCFCs) and perfluorocarbon (PFCs). In Australia, while the reporting of GHG was originally incorporated into the NPI, the National Greenhouse and Energy Reporting Act 2007 (NGER) established requirements for a facility to report GHG emissions. As NGER is implemented, GHG reporting requirements have been removed from the NPI. Under NGER, a facility is required to report CO2, nitrous oxide and methane.  The reporting of PFCs is voluntary. In the United States, under the TRI program, facilities are required to report certain GHG emissions excluding CO2, methane, and nitrous oxide.  Canada is phasing in requirements to report GHG emissions into the NPRI and continues to develop a single harmonized system for reporting of all air pollutant emissions, including GHGs. On 22 September 2009, the U.S. Environmental Protection Agency (EPA) finalized a GHG reporting rule that requires fossil fuel and industrial GHG suppliers, motor vehicle and engine manufacturers, and facilities that emit 25,000 metric tons or more of CO2 equivalent per year to annually report GHG emissions data to the EPA. Under the finalized rule, annual reports, covering the calendar year 2010, are required to be submitted in 2011. Additionally, several states, such as Massachusetts, require reporting of GHG emissions.

Emissions reporting might have broader impacts on a company

As countries explore how to address climate change, information submitted under a GHG emission reporting program may impact a company by serving as a baseline for further regulation. The quantity of GHGs emitted may serve as a basis of a GHG tax. Various countries, including member states of the European Union and Canada have explored the possibility of implementing a tax based on the quantity of GHGs emitted by a facility. Notably, France, Sweden and Finland have adopted legislation levying a tax on the amount of carbon emitted. Additionally, some states, provinces, and municipalities have also taken steps to implement a tax on GHGs emitted by a facility. In November 2006, Boulder, Colorado became the first municipality to charge a carbon tax on residents and businesses based on electricity usage. On 1 July 2008, the Canadian province of British Columbia was the first in North America to institute a comprehensive tax on carbon emitted by fuels such as gasoline, diesel, natural gas, coal, propane, and home heating fuel.

The quantity of reported GHGs emissions may also affect the allocation of emission credits under a GHG trading program such as the European Union Greenhouse Gas Emission Trading System, the U.S. cap-and-trade program proposed in the American Clean Energy and Security Act passed in the House of Representatives on 26 June 2009, or the proposed Australian Carbon Pollution Reduction Scheme. The GHG emissions information submitted may also impact the public perception of a facility, potentially affecting the ability of the facility to operate. For example, a company that is perceived as a major polluter may find itself under more scrutiny from environmental agencies as the company attempts to acquire or renew operating permits or licenses for its facilities.

Jonathan Nwagbaraocha
Enhesa Consultant


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