What did you have to say about the NPI Review?

In June 2018, the NPI Review Steering Committee released a discussion paper inviting public comment to inform the review of the National Pollutant Inventory (NPI), with submissions closing August 2018. Recently, the NPI published all the public submissions and we were interested in what people had to say, and thought you might be too. Let us run through some of the emerging trends we noticed amongst respondents.

 

Background

The Australian National Pollutant Inventory (NPI) has been collecting annual emissions estimates for 93 toxic substances since 1998. Although this has been a positive step towards enhancing environmental quality through public awareness and industry accountability, the NPI scheme has been almost unchanged since its inception.

On 25 November 2016, the national Environment Protection Council agreed to terms of reference (TOR) for a review of the NPI, and in June 2018 the review was opened for public consultation.

 

So, what did you think?

The review received 374 submissions in response to the discussion paper:

• 60 direct submissions, 6 of which were confidential
• 314 submissions from people who used a campaign form on the Environmental Justice Australia website – all were treated as confidential.

The resulting 54 submissions were published online on the 7 December 2018. The key stakeholder groups that provided feedback were large councils and associations, environmental consultants, individuals, and NPI reporters. Feedback varied in length from a brief email through to detailed reports providing answers to every question posed in the discussion papers’ TOR.

A summary that identifies the key trends in submissions is provided below.

 

Please note: If you would like to read the recommendations in greater detail, please visit the NPI Website for the list of submissions.

 

Emerging Recommendations from Questions raised in the NPI Review Discussion Paper

 

1. Environmental Outcomes

Appropriateness of Environmental Outcomes

Most respondents found the NPI objectives and outcomes are relevant to the goals of:

1. Maintaining and improving ambient air quality and ambient marine, estuarine and fresh water quality
2. Minimising environmental impacts associated with hazardous wastes
3. Improving sustainable use of resources

Whilst some respondents felt these objectives were achieved indirectly, most felt these goals should be maintained. The common recommendations for improvement included the addition of public health and environmental quality in the stated outcomes, and the ultimate aim to minimise harmful emissions.

 

Increasing Public and Industry understanding of substance emissions and transfers

Overall, most respondents felt greater public awareness and understanding were required moving forward, particularly, that there is a need to provide greater context when communicating NPI data. Mixed responses were provided regarding the NPI’s role in interpreting data, with respondents concerned that interpretation of data would detract from the NPI’s stated outcomes to:

• Collect a broad base of information on emissions and transfers of substances on the reporting list
• Disseminate the information collected to all sectors of the community in a useful, accessible and understandable form.

Whilst guidelines on how to interpret the NPI data were supported by respondents, an outright analysis of the data was considered the responsibility of third parties.

 

Encouraging industry to use cleaner production techniques to reduce emissions and waste

Although NPI data may indirectly encourage the minimisation of environmental impacts, most respondents to the review who report emissions to the NPI felt it did not encourage industry to use cleaner productions techniques. Instead, these respondents felt internal industry, license, or state requirements were more likely to spur techniques to reduce emissions and waste.

 

2. Performance

Substance List

Respondents were divided on whether more substances should be added to the NPI substance list. While public associations were often in favour of increasing and harmonising the list to align with international lists, such as the US Toxic Release Inventory, reporters often posited that only the minimum required substances should be mandatory to reduce the reporting burden on industry. This is not to say that reporters were against additional substances but that any additions should not result in greater burden for reporters or duplication between platforms.

Nearly all submitters agreed that a Technical Advisory Panel (TAP) should be established to review the substance list, and several submitters were in support of aligning the substance list and reporting requirements to those of others, such as state government requirements or the NGER reporting scheme.

The most frequent substance requests included:

• Diffuse emission sources (e.g. bushfires, windblown dust, aviation, marine, and fireworks)
• Greenhouse Gas Emissions
• PFAS (Per- and Poly-Fluoroalkyl Substances – fire retardants)
• PM_2.5 from fugitive sources.

Other substances mentioned in submissions included:

• The addition of black carbon, UFP (Ultra Fine Particles), various herbicides and fungicides, and TSP (Total Suspended Particles)
• The removal of ethanol.

 

User Experience

Unanimous feedback from respondents suggest that the Online Reporting System (ORS) requires immediate updating to improve user experience, especially during the reporting season. Frequently requested updates included the addition of:

• Temporal profiles and time series data
• An upload/download tool to reduce manual data entry errors
• Contextual information linked to data to increase understanding – including, for example, the measurement method
• An autosave function
• Online calculators.

Generally the ORS was encouraged to reflect the EERS system, with smarter year-to-year functionality to reduce instances of duplication during validation. Greater capacity during peak periods was also commonly requested, with several respondents citing sluggish and unreliable systems during the reporting season.

Similarly, the NPI website requires substantial modernisation based on respondent recommendation, and should be updated with the following:

• Easy comparison of pollution year to year, facility to facility;
• A link with the ambient concentrations data for each state to help explain differences between emissions and exposure, and an explanation of the role State and Territory regulators play
• Publications of all collected advisory information when a specified difference in substance reporting is triggered.

Due to the substantial updates required on both the NPI website and ORS platform, nearly all respondents who commented on the topic were not in favour of an App development prior to the modernisation of the website.

The following comments were also significant:

• While increased public awareness was supported, respondents frequently stated that a focus on increased understanding should be prioritised
• Those who commented on transfer data often found it to hold little to no value, and proposed it be shifted from NPI reporting to National Waste Policy legislation
• Most NPI reporters recommended pursuit of any initiative that reduced duplication between platforms – most commonly, people suggested that NPI should be combined with the NGER scheme and that both are aligned with state government requirements.

 

Reporters and Thresholds

Reporters

Submissions sourced from the agricultural sector were most frequently in favour of changing the industry sectors that are required to report where the cost to report exceeds the benefit to the public. Meanwhile, associations representing health research were more likely to request an increase in reporting industries to produce more comprehensive emission inventories.

Thresholds

While most respondents were divided on whether thresholds should be increased or decreased, most agreed that thresholds should be streamlined to reflect reporting conducted for NGERs and other state government requirements. Two common suggestions were to move from usage-threshold reporting to emissions threshold, and to factor uncertainty into thresholds (like that of the Methods identified in NGERs). Other alternative thresholds included:

• Exposure based emissions (to highlight its impact on health)
• Source specific thresholds as opposed to substance specific thresholds.

 

Accuracy of reporting/ compliance and validation

One item that all respondents agreed upon was the need for regular updates to the Emission Estimation Technique manuals (EETM). All submissions that covered this topic stated that the EETMs need to be less ambiguous, and should remain current with changes in each industry. Urgent consultations are required with each industry to update the manuals to ensure they align with current methodologies and share a nationally consistent structure and format. The following additions to the manuals were deemed desirable:

• More industry specific manuals to reduce the reporting burden
• Summary page outlining where to find specific estimation techniques
• NPI guide outlining common materials
• Guide of key NPI Substance concentrations.

Some respondents felt that reduced frequency of reporting could improve the accuracy and overall quality of the data produced, while maintaining the objectives of the NPI. These responders suggested the frequency of every 2-5 years; however, other respondents favoured continuous monitoring so the public could review more up-to-date data.

 

3. Resourcing

Current Funding Model and Sustainable Resourcing Models

All respondents who covered this question agreed that more funding needed to be directed to the NPI to catch-up with funding received by comparable NPI programs internationally.

Most felt that a cost recovery scheme where, for example, reporters or users pay, was not beneficial to the objectives of the NPI and would ultimately hinder the program and burden reporters further. Instead, the majority felt funding should continue to stem from the federal and state governments.

Overall, respondents did believe that the NPI has the potential to play a major role nationally to help reduce harmful emissions in Australia; however, until greater funding becomes available to improve upon the existing system, the NPI will continue to burden reporters without the desired benefits.

 

 

Want to learn more? Here are some helpful links about the NPI:

• Katestone’s Submission to the NPI Review
• The original NPI discussion paper
• The full list of public NPI Submissions.
• Other NPI Articles by Katestone

For more information about the NPI review, contact your local state or territory NPI office.