Journal of Environmental Planning and Management

ISSN: 0964-0568 (Print) 1360-0559 (Online) Journal homepage: https://www.tandfonline.com/loi/cjep20

An overview of Canada’s National Pollutant

Release Inventory program as a pollution control
policy tool

Stuart Johnston Edwards & Tony R. Walker

To cite this article: Stuart Johnston Edwards & Tony R. Walker (2019): An overview of Canada’s
National Pollutant Release Inventory program as a pollution control policy tool, Journal of
Environmental Planning and Management, DOI: 10.1080/09640568.2019.1634525

To link to this article: https://doi.org/10.1080/09640568.2019.1634525

Published online: 29 Jul 2019.

Submit your article to this journal

Article views: 13

View Crossmark data

Full Terms & Conditions of access and use can be found at

https://www.tandfonline.com/action/journalInformation?journalCode=cjep20
Journal of Environmental Planning and Management, 2019
https://doi.org/10.1080/09640568.2019.1634525

An overview of Canada’s National Pollutant Release Inventory

program as a pollution control policy tool
Stuart Johnston Edwards and Tony R. Walker

School for Resource and Environmental Studies, Dalhousie University, Halifax, NS, Canada

(Received 4 July 2018; final version received 13 June 2019)

Formed under ‘right-to-know’ legislation and public disclosure principles, Pollutant

Release and Transfer Registers (PRTRs) are a key policy tool for pollution control.
PRTRs affect both social and environmental policy outcomes by making facility
pollutant release quantities available to stakeholders. While PRTRs operate under
similar principles, they are designed to reflect national priorities. This study
investigates and critically discusses the stated policy goals of Canada’s National
Pollutant Release Inventory (NPRI) to other PRTRs. Notably, there are issues
involving data completeness and accuracy, creating gaps in inventory emissions,
thereby not reflecting actual emissions. While relative pollutant release levels have
decreased, overall toxicity has increased. Coupled with the omission of toxicity
factors and pollutant thresholds from the NPRI, this creates a false sense of
progress for stakeholders. Making pollutant release data more comprehensive
would improve stakeholder engagement and better inform the decision-making
process which can be applied to policies across geopolitical scales.
Keywords: National Pollutant Release Inventory; Pollutant Release and Transfer
Register; pollution control; environmental regulation; data reliability

1. History of pollution control policy in Canada

Modern pollution control policies are designed to address both environmental issues
and social issues. In Canada, the first iteration of pollution control regulations followed
a command-and-control framework starting in the 1970s. Being tightly centralized and
controlled at the federal level, they were often criticized for being too forceful
(Simmons 2013). The main grievances against command-and-control techniques are
rigidity and overreach: inflexibility regarding how facilities can achieve reductions hin-
ders innovation, and the centralized nature of regulations led to government largess in
terms of both expenditure and intervention (Rabe 1999; Swaney 1992). When applied
to pollution control, command-and-control regulations involve: setting emission inten-
sity standards; prescribing must-adopt technologies; or outright banning of certain
chemicals (Delgado-Ceballos and Rueda-Manzanares 2010; Henriques and Sadorsky
2008). From industry’s perspective, environmental regulation has historically been
viewed as industries needing to increase expenditure to meet compliance requirements
(Horvathova 2012).

Corresponding author. Email: trwalker@dal.ca

ß 2019 Newcastle University

2 S. Johnston Edwards and T. R. Walker

In response to the stringency of command-and-control regulations, and mirroring

small government mechanisms elsewhere, deregulation gained traction in the 1990s as
governments backed away from large-scale pollution control programs. Instead, gov-
ernments resorted to limited monitoring programs rather than establishing emission
reduction targets (Bennett 2012). Cuts were made to existing program budgets and
infrastructure, leaving government agencies without the capacity to implement pro-
grams effectively. Further, regulations had inherent gaps in their original designs, lead-
ing to limited program success (Blackman 2010; DeMarco and Vigod 2007). Flawed
programs combined with undersized governance capacity consequently caused com-
mand-and-control techniques to become increasingly ineffective and inefficient
(Tietenberg 1998).
Governments and industry then turned to market-based approaches and voluntary
mechanisms to tackle pollution levels (Harrison and Antweiler 2003; Tietenberg 1998).
Voluntary programs (VPs) were developed to offer industry the flexibility to find
lower cost options for improving environmental performance, which command-and-
control regulation lacked (Miyamoto 2016). VPs had limited participation and there-
fore limited results in Canada, although, reasons remain unclear (Henriques and
Sadorsky 2008). Some authors claim that VPs in Canada would have been effective if
more market-based instruments were available (Henriques and Sadorsky 2008).
Meanwhile, others argue that the threat of regulation is necessary to prompt industry
action when voluntary actions are limited (Harrison and Antweiler 2003) and that
regulatory threats in Canada were too weak or poorly enforced (Miyamoto 2016);
thereby passively allowing inaction from industry. In either case, the role of govern-
ment in environmental regulation has been widely debated (Rabe 1999). When regula-
tions are imposed by government, they are often incentivised to promote participation
and offset their unpopularity, which stems from undesirable intervention and from
potential costs of meeting requirements (Anh et al. 2010; Anton, Deltas, and Khanna
2004). However, these incentives, can result in cost-inefficient outcomes (Anh
et al. 2010).
National and regional jurisdictions have developed public disclosure programs tar-
geting industrial releases as a major form of pollution control (Delgado-Ceballos and
Rueda-Manzanares 2010; DeMarco and Vigod 2007; Harrison and Antweiler 2003;
Simmons 2013; Tietenberg 1998). These public disclosure programs operate in tandem
with other forms of regulation by informing the public and policymakers on trends in
pollutant releases, thereby facilitating formation of strong environmental policy and
effective results (Cooper, Green, and Meissner 2017; Foulon, Lanoie, and Laplante
2002; Rabe 1999). These tools are called Pollutant Release and Transfer Registers
(PRTRs). The US Environmental Protection Agency (USEPA) launched the first
PRTR, the Toxic Release Inventory (TRI), in 1987 (EPA 2017). Canada followed suit
with the National Pollutant Release Inventory (NPRI) in 1993 (ECCC 2017). Other
PRTR programs include Australia’s National Pollutant Inventory (NPI) and the
European Union’s European-PRTR (E-PRTR). Each program has similar processes,
structures and desired outcomes, but they are ultimately designed to reflect priorities
and resources of individual countries (Sullivan and Gouldson 2007).
As countries implement their own PRTRs, each has developed their own methods
and desired policy outcomes. This paper examines policy objectives and outcomes of
public disclosure-based pollution control, with a focus on the Canadian context.
Canada’s NPRI policies will be critically discussed and compared to those in the
 Journal of Environmental Planning and Management 3

Figure 1. National Pollution Release Inventory analysis flow diagram.

United States, Australia and the EU. This study focuses on how the NPRI addresses
the government’s desired policy outcomes by: (i) Reviewing theory behind public dis-
closure methods of pollution control; (ii) Identifying issues that PRTRs are meant to
address and comparing NPRI’s stated policy objectives to other jurisdictions (e.g. the
United States, Australia and the EU); and (iii) Discussing ideal PRTR policy goals and
examining NPRI’s effectiveness at addressing its stated policy outcomes, which will
include an overview of theoretical underpinnings and associated contemporary issues
with PRTRs (Figure 1).

2. Pollution control public disclosure theory

Public disclosure methods are the third generation of pollution control policies, follow-
ing command-and-control policies, and market-based instruments and voluntary pro-
grams. The enabling theory behind public disclosure methods is that by publishing
facility-level performance records, various stakeholders (such as consumers, commu-
nity and environmental groups, industry groups and shareholders) can exert socioeco-
nomic pressures on facilities to improve their environmental performance (OECD
1999; Simmons 2013). Facilities will then act to reduce their release levels to maintain
a positive brand image. In essence, public awareness of pollution levels fosters societal
pressures that modify a facility’s behaviour, lest the facility (or company) develop a
poor reputation and lose market share (Delgado-Ceballos and Rueda-Manzanares
2010). Empirical studies support theories that public disclosure of environmental per-
formance creates strong pressures and incentives for adoption of internal pollution con-
trol mechanisms (Anton, Deltas, and Khanna 2004; Foulon, Lanoie, and
Laplante 2002).
The environmental regulation decision-making process reflects stakeholder values
and experience (Blake 2001). Industrial accidents increase the social profile of
4 S. Johnston Edwards and T. R. Walker

environmental standards and public pressure for transparency related to pollutant

releases (Kwon, Bae, and Park 2014). Reflecting in part how pollution control policy
has become more comprehensive, adoption of PRTRs and other public disclosure tools
has been driven by more than environmental grounds (DeMarco and Vigod 2007;
Rabe 1999). While a healthy environment is a necessity for a healthy society (Resnik
2007), PRTR-enabling legislation is meant to directly address both social (e.g. public
health, social justice) and environmental concerns. In fact, social causes have been the
main drivers in backing legislation for PRTRs on the grounds of human rights and
right-to-know ethics (Sullivan and Gouldson 2007). The formation of PRTRs is justi-
fied for community right-to-know grounds, so that stakeholders (consumers, workers,
investors, etc.) will be aware of risks posed by a facility and thereby be motivated to
address the situation (Harrison and Antweiler 2003). Thus, more voices will be
reflected in decision-making processes.
Public disclosure instruments, such as PRTRs, were developed as non-regulatory,
non-coercive tools to incentivize facilities to voluntarily improve their environmental
performance by flexible means while still maximizing revenue and maintaining a posi-
tive brand image (Blackman 2010; Kwon, Bae, and Park 2014). Given that markets
are influenced by information, companies that have strong social licence receive
greater investments (Wanxin 2011). Policymakers and politicians alike support PRTRs
because they can increase market efficiency by allowing market pressures (via stake-
holder actions) to dictate facility-level decisions on whether to implement changes,
whilst absolving the government of responsibility (Ashcroft and Smith 2008; Simmons
2013). At the same time, PRTRs eliminate informational asymmetries to allow for the
creation of ‘scientifically valid’ environmental regulation (Ashcroft and Smith 2008).
As such, two key themes are embedded in the theory behind public disclosure meth-
ods: reducing overall pollutant release quantities; and acting as a right-to-know tool by
providing accessible data to inform stakeholders, which allows them to participate in
the development of public policy.

3. Canada’s NPRI policy objectives

As NPRI deals with toxic substances, it falls under the purview of the Minister of the
Environment and the Minister of Health (Government of Canada [GoC] 2004).
Administered by Environment and Climate Change Canada (ECCC), this joint scope is
reflected in the NPRI’s stated policy goals which are both environmentally and
socially focused, signifying the government hopes that NPRI can facilitate outcomes in
more than one policy area. Stated policy objectives for Canada’s NPRI are:

1. Identifying pollution prevention priorities;

2. Supporting the assessment and risk management of chemicals and air
quality modelling;
3. Helping develop targeted regulations for reducing releases of toxic substances
and air pollutants;
4. Encouraging actions to reduce the release of pollutants into the environment; and
5. Improving public understanding (from ECCC 2016a).

Three policy goals (1, 3, 4) directly relate to reducing pollution levels and formu-
lating environmental policy. The first goal addresses pollution prevention priorities, the
 Journal of Environmental Planning and Management 5

primary governing philosophy shared by all PRTRs. Importantly, pollution prevention

differs from pollution control. Pollution prevention targets the efficiency of a process,
whereas pollution control aims to treat waste at the source (i.e. end-of-pipe solutions),
both of which use technology (Gavronski et al. 2012). For example, Australia’s NPI
mentions improving sustainable use of resources and minimising environmental
impacts associated with hazardous waste (ADEE 2017). The wording of Australia’s
policy outcomes suggest that the goal is to improve the efficiency of their process,
thereby aligning it with pollution prevention. The use of the word ‘minimize’ suggests
a move to diminish pollutant releases without fully eliminating them. Likewise,
Canada’s third and fourth policy goals use the term ‘reduce’ with respect to pollutant
release levels. Despite using different keywords (reduce vs. minimize) Canadian and
Australian programs have similar desired environmental outcomes: decreasing pollutant
release levels. As such, by focusing on pollution prevention, the Canadian government
can claim that it is focusing on incrementally reducing its environmental impact, rather
than encouraging industry to clean up pollutants that have already been released.
However, this belies the fact that pollution prevention and pollution control are, ultim-
ately, forms of weak sustainability due to their focus on technological fixes (Gavronski
et al. 2012; Huesemann 2003).
While the NPRI is geared towards pollution prevention, increasing the efficiency
of a process is not enough to achieve sustainability (Huesemann 2003). Decreasing
releases is often an indicator of efficiency as less material is wasted, thereby providing
an overall economic advantage (Fujii, Managi, and Kawahara 2011; Gavronski et al.
2012). Yet, economic growth can increase pollutant releases due to the rebound effect
(Fujii, Managi, and Kawahara 2011; Korhonen and Seager 2008). Reducing pollutant
releases via efficiency is assuredly a good first step but requires follow-through. Many
firms are striving to eliminate their emissions altogether via concepts, such as cradle-
to-cradle and through eco-industrial parks (Bocken et al. 2014). Thus, by advocating
for pollution prevention, Canada is investing in sustainable methods, but not necessar-
ily in sustainability.
To determine whether release levels are decreasing, reliable data is a key factor.
The EU’s E-PRTR cites data quality and accessibility is a primary guiding principle to
the program’s development, stating that data should be of high quality with respect to
its completeness, consistency and credibility. Data should also be publicly accessible
to non-governmental organizations (NGOs), industry, the public and academics (ECCC
2016a). Elsewhere, the US TRI program also emphasises data accessibility and user-
friendliness. The TRI program has three goals specifically related to data contained in
their reports: (a) TRI covers chemicals and sectors of concern to data users; (b) TRI
data are credible with quality suitable for TRI data uses; and (c) TRI information is
accessible, understandable and is used to promote environmentally beneficial dialogue
and decision making (EPA 2017).
In emphasizing data pertinence, quality and the data’s usefulness to stakeholders
for promoting dialogue and decision making, the stated TRI policies go beyond those
of NPRI. The TRI places data at the centre of the discussion. The NPRI goals use key
terms: support (environmental assessment); encourage (actions); and improve (under-
standing) (ECCC 2016a). From this, it is clear that Canada’s NPRI is meant to be a
support tool for stakeholders, but there is no stated NPRI policy goal dealing with the
quality of the information collection, nor on how it is displayed. Meanwhile, the TRI
program is designed to be more than just a support tool, but to be a platform for
6 S. Johnston Edwards and T. R. Walker

creating change by empowering non-governmental stakeholders. The empowerment of

non-governmental stakeholders is a shared outcome amongst PRTRs. The NPRI cites
the improvement of public understanding and supporting risk assessment as desired
outcomes (ECCC 2016a). Australia’s NPI cites data as being essential for increasing
public understanding of toxic substances and for meeting community right-to-know
obligations (ADEE 2017). Environment and Climate Change Canada (ECCC) wants E-
PRTR data to create greater awareness and participation of the public for effective
decision-making processes (ECCC 2016a, 2016b).
PRTRs were formed on the basis of the ‘right-to-know’ principles (Pulles 2008;
Simmons 2013) and are therefore justified on ethical grounds (Tietenberg 1998). As such,
data provided to stakeholders needs to be transparent, accessible and easily interpretable
(Pulles 2008; Tietenberg 1998; Wanxin 2011). All three of these factors are essential to
promoting engaged civic action and to forming strong and accepted public policy by creat-
ing informed stakeholders (Morriss and Meiners 2009). To be informed, data has to be
both accessible and easy to understand (i.e. interpretable), and without transparency there
is insufficient knowledge to motivate and enhance public participation in decision-making
processes. This can ultimately reflect poorly on industry (Ishizaka and Tanaka 2003), who
should, therefore, be in favour of engaged stakeholders.
Data accessibility is linked to two of the NPRI’s stated policy goals: encouraging
actions to reduce release of pollutants into the environment and improving public
understanding (ECCC 2016a). This involves encouraging actions of stakeholders (other
industrial firms) which requires ensuring they are properly informed. Simmons (2013)
argues that, public access to understandable information links to the goal of encourag-
ing voluntary action on the part of industry. Understanding data and being able to use
available data empowers otherwise disenfranchised stakeholders such as community
groups and, in theory, allows them to play a role in decision-making processes from
which they would otherwise be excluded (Henriques and Sadorsky 2008; Simmons
2013). Sullivan and Gouldson (2007) stress that previous research found that public
access to information can significantly improve the environmental performance of
facilities. As societal pressures mount, firms must choose whether to comply or risk
developing a negative reputation (Delgado-Ceballos and Rueda-Manzanares 2010).

4. Evaluating NPRI as an effective pollution reduction policy tool

To accomplish the key themes of reducing release quantities and acting as a right-to-
know that is embedded in the practice of public disclosure policy goals, the provision of
interpretable and accessible data is necessary to inform stakeholders as it allows them to
participate in development of public policy. Extrapolating from these key themes and
stated policy goals of Canada and other jurisdictions, a series of three idealized policy
goals for PRTRs have been established. The policy goals listed reflect a combination of
shared policy goals of the PRTRs examined. They are also formed with the understand-
ing that PRTRs mature over time to reflect changes to jurisdictional priorities and
capacities (Sullivan and Gouldson 2007). The intention of these policy statements is to
promote changes to a PRTR system that would create an effective policy tool that
addresses its underlying tenets. Therefore, an effective PRTR program should:

1. Reduce overall negative environmental and social outcomes of toxic or

hazardous substances;
 Journal of Environmental Planning and Management 7

2. Provide high quality data in a user-friendly manner to stakeholders; and

3. Act as a right-to-know tool to inform stakeholders thereby serving as a vector
for development and formation of strong public policy.

While Canada’s NPRI may not perfectly embody or fully reflect all these idealized
policy outcomes, it does partially share these goals and is qualitatively assessed against
these policy statements.

5. Is NPRI effective at pollution reduction?

The NPRI is meant to be a pollution reduction tool. There were early successes fol-
lowing the adoption of NPRI in 1993. Harrison and Antweiler (2003) found a 27%
reduction in pollutant releases by 1999 and Kerret and Gray (2007) found a 15%
decrease in pollutant releases over the first decade from facilities that had been tracked
since the NPRI’s inception. However, this perceived progress may be masking larger
issues. First, a study by Walker (2018) found that overall NPRI releases are stable or
increasing, meaning the NPRI may be failing to complete its primary policy goal.
Second, NPRI displays pollutant releases by mass, but this metric represents only a
‘coarse indicator’ of its environmental and health effects (Rabe 1999; Setton et al.
2015). This is reflected in that NPRI is governed by a pollution prevention mentality
rather than a pollution outcome mentality. Tietenberg (1998) speculated that if the pub-
lic ‘naïvely’ focused solely on total discharges, firms would respond by switching to
processes that result in pollutant releases of lesser quantity but higher toxicity. This
would give stakeholders a false impression of progress on environmental and social
issues. For example, though a substance may not be toxic it can still carry sublethal
environment effects leading to poor outcomes (Jørgensen 2000). More concerningly,
policymakers may adopt the same impressions (Blackman 2010) leading to a period of
inaction or stagnant policy development, increasing social and economic costs
(Tietenberg 1998).
Kerret and Gray (2007) found that while the overall mass of pollutant releases was
decreasing in Canada, the toxicity level of pollutants released had increased. Harrison
and Antweiler (2003) found the same, concluding ‘while the total weight of releases
has declined, the average toxicity of those releases has increased’. This is cause of
concern. Some PRTRs release annual trend reports and rank pollutants based on the
sum of their emissions in a given year (Delgado-Ceballos and Rueda-Manzanares
2010). But based on their findings Kerret and Gray (2007) determined that release
trends do not properly represent risk trends. This trend of facilities switching to lower-
volume, higher-toxicity substances ultimately contravenes the NPRI’s larger policy
goal of reducing releases of toxic substances and runs counter to the NPRI’s fifth and
second stated policy outcomes of improving public understanding and supporting
risk assessment.
Programs like NPRI and TRI report releases by mass to increase public engage-
ment and understanding (Rosenberger 2014). However, toxicity of chemical releases is
not assessed, as quantities are easier to convey (Lim, Lam, and Schoenung 2010).
Public perceive that larger releases are worse, especially when thresholds are exceeded.
In the United States it has been shown that highly toxic chemicals were not identified
as a significant issue in the TRI’s quantity-based assessment (Zhou and Schoenung
2009). The USEPA identifies high priority chemicals based on each year’s numbers.
8 S. Johnston Edwards and T. R. Walker

None of the chemicals identified as high priority by the quantity-based analysis made
the USEPA list (Lim, Lam, and Schoenung 2010). Potentially detrimental emissions
are overlooked because attention is focused on quantities rather than toxicity. In
Canada, the NPRI also uses quantity-based assessments, therefore, similar issues apply
(Olewiler and Dawson 1998). However, to address these issues, using programs like
USEtoxV R (United Nations) or TRACI (USEPA), the toxicity of chemicals released can

be incorporated into PRTR databases and potential environmental and human health
effects can be better understood.
Toxicity considerations do figure into determining what substances are covered by
the NPRI. Specifically, the NPRI targets ‘toxic substances released in significant quan-
tities’ – thereby excluding high-volume substances and low-toxicity conventional pol-
lutants (Harrison and Antweiler 2003). But these considerations have limited influence
on end-users as toxicity data is not communicated by NPRI. Incorporating toxicity-
weighted emission indicators in NPRI, instead of solely relying on release quantity,
would have far-reaching advantages for all stakeholders including industry, policy-
makers and external analysts (Bennett 2012; Muhammad et al. 2016; Toffel and
Marshall 2008). This addition would reflect a larger shift in NPRI’s governing philoso-
phy from pollution prevention to pollution reduction outcomes.

6. Does NPRI yield high-quality data?

Due to PRTRs being developed as a right-to-know tool, data quality and data reliabil-
ity are extremely important (Kryzanowski 2009; Pulles 2008). This is best summarized
by Tietenberg (1998): ‘Inaccurate or partial information could be worse than no infor-
mation at all to the extent that it promotes a false sense of security or it promotes
unjustified fears’. Data reliability encompasses the completeness of a dataset (com-
pleteness vs. incompleteness) and the data accuracy refers to the data points within a
set (accuracy vs. inaccuracy). The manner in which data is currently reported and con-
tained within the NPRI is rife with data reliability issues (Henriques and Sadorsky
2013; Kryzanowski 2009; Setton et al. 2015; Sullivan and Gouldson 2007).
There have been gaps in the data collected by the NPRI for many years. The
NPRI’s original design covered less than 25% of the facilities it covers now. Over
time, the program has expanded – covering more industrial sectors, encompassing
more pollutants and lowering some reporting thresholds (Henriques and Sadorsky
2013; Rabe 1999). Expansion of coverage requirements increases the completeness of
the NPRI data. This is important as, otherwise, we risk underestimating emissions.
Prior to 2003, the oil and gas industry were exempt from reporting emissions (GoC
2016a; Walker 2018). Because of this exemption, Kryzanowski (2009) found that
reported air quality emissions from upstream oil and gas development in Northern
British Columbia were only half of actual emissions for NOx, SOx and VOCs for the
entire province. In other words, actual emissions were double what had been recorded
by the NPRI. Though the Kryzanowski (2009) study may be an extreme example, the
implications of exempting these emissions are serious. Data incompleteness in a PRTR
means it can underestimate potential health and environmental effects of pollutant
releases (Kryzanowski 2009).
The most notable expansions to NPRI data coverage occurred in 2002 and 2007.
The addition of Criteria Air Contaminants (CAC) in 2002 (GoC 2016a, 2016b) was an
important step in addressing the NPRI’s goal of helping to support risk assessment and
 Journal of Environmental Planning and Management 9

air quality monitoring, as many have used CAC data to model and simulate health
effects (e.g. Ayala et al. 2012; Hoffman et al. 2015; Setton et al. 2015). The removal
of oil and gas well exemptions in 2003 resulted in close to 4,000 oil and gas extraction
facilities being added to the NPRI database, representing 40% of total facilities cov-
ered in 2011 (ECCC 2017; GoC 2016a). Yet there remain other heavily polluting
industries exempt from reporting to NPRI. Mining used to be fully exempt but became
partially covered in 2006 after two environmental NGOs successfully sued the govern-
ment to change their interpretation of language within NPRI’s governing legislation
(Simmons 2013).
Sullivan and Gouldson (2007) discuss that as PRTR systems mature, the range and
breadth of chemicals and facilities covered increase and reporting thresholds are low-
ered. NPRI’s coverage has stagnated with only two new chemicals added since 2007
(GoC 2016b), possibly suggesting that the NPRI has reached a mature stage. But that
would be overlooking the biggest cause of data incompleteness – the exemptions of
small and medium-sized enterprise (SMEs). With a few exceptions for specialized
industry (e.g. burning of biomedical supplies), NPRI’s reporting requirements state that
only facilities where employees work a minimum of 20,000 employee-hours during the
calendar year are required to report (ECCC 2016b). This severely limits the number of
firms that are required to participate in the NPRI program. Harrison and Antweiler
(2003) estimated that only 7% of about 32,000 manufacturing facilities in Canada
reported to NPRI. By exempting these businesses, larger gaps in data completeness are
realized, as unreported emissions create a larger discrepancy between inventory emis-
sions and actual emissions.
Why the reporting exemption for SMEs? First, wide-scale reporting requirements
present a proportionately greater burden for SMEs in comparison to large firms
(Simmons 2013). Second, reporting to PRTRs is seen as a burden for which SMEs do
not have the time nor the expertise (Fujii, Managi, and Kawahara 2011). Blanket
environmental regulations have been shown to increase costs and negatively impact
SME profit margins (Anh et al. 2010). Third, the argument exists that larger firms
simply pollute more due to their size and, thus, are of higher concern (Simmons
2013). However, this overlooks the ability of large firms to develop pollution control
strategies (Fujii, Managi, and Kawahara 2011). Although, smaller firms may have
lower levels of pollution, by omitting them in the NPRI there is uncertainty regarding
their pollution intensity. Large facilities are more likely to develop proper environmen-
tal management systems through experience and knowledge diffusion, though it can
take time (Gavronski et al. 2012). Also, PRTRs were developed as non-regulatory
tools, meant to lower the cost of pollution control and increase market efficiencies
(Ashcroft and Smith 2008; Blackman 2010) meaning they pose little burden. To guar-
antee high quality data that can be used in a meaningful way, it needs to be accurate
and complete. Inclusion of SMEs presents an opportunity to grow and mature
Canada’s NPRI; their inclusion would represent an important step in addressing the
gaps in data breadth (Simmons 2013). To offset possible burdens of reporting, the gov-
ernment could provide incentives and/or training materials to ease the transition (Anh
et al. 2010; Blackman 2010; Henriques and Sadorsky 2013).
NPRI depends on self-reported, facility-level pollutant release data. For jurisdic-
tions to properly use self-reported data, reporting methods must be standardized
(Horvathova 2012). However, estimation methods are not fully standardized in Canada
(Kryzanowski 2009; Simmons 2013). Instead, facilities are instructed to use the ‘best
10 S. Johnston Edwards and T. R. Walker

available’ method to prepare release estimates which include: monitoring data; mass
balance calculations; emission factor estimates; and engineering estimates amongst
others (ECCC 2016c). This is where concerns over data accuracy arise. Companies are
permitted to change estimation methods over both temporal and spatial scales provided
that they include a reason (ECCC 2016c). When release estimation techniques differ, it
limits potential for direct comparisons to be made across facilities in different regions
and across different industries (Hoffman et al. 2015; Horvathova 2012; Sullivan and
Gouldson 2007). Recent studies show the same for reports from the same facility
(Cooper, Green, and Meissner 2017).
Cooper, Green, and Meissner (2017) examined self-reported lead (Pb) release data
from a facility in Australia and verified it with surrounding ambient air quality moni-
toring data. They found that the self-reported releases to Australia’s NPI correlated
poorly with ambient air quality measurements, suggesting that reported data were
inaccurate. Further, they found that the facility had changed estimation methods seven
times over 14 years. Cooper, Green, and Meissner (2017) concluded that the changes
in estimation methodology rendered comparison of results across sources and years
impossible. These findings are important for two reasons. First, data collected via dif-
ferent methods has limited usefulness in forming evidence-based policy due to an
overarching inability to properly compare performance numbers. Second, concerns
around the accuracy of self-reported data brings up questions of how to deal with the
issue of uncertainty associated with reported data.
When assuring data accuracy, it is important to distinguish between validation and
verification. ‘Validation and verification are complementary and together they can
guarantee the environmental integrity of emissions control policies’ (Swart et al.
2007). Validation examines whether self-reported facility data matches relevant guide-
lines, while verification means scientifically reviewing the reported data (Pulles 2008).
Put another way, constant checks for validation assure that regulations are working as
designed (Kryzanowski 2009) and verification assures the regulations are properly
designed (Pulles 2008). In Canada, while NPRI data is occasionally validated against
procedural requirements, the procedures are almost never verified (Pulles 2008); only
3% of NPRI-reporting facilities are certified on a yearly basis (Simmons 2013), mean-
ing the potential for errors is high. For example, Anh et al. (2010) measured reported
emissions from construction sites using on-site monitors and found that actual emis-
sions were double those of reported values. As such, while the issue of data accuracy
can be attributed to the facility level, there is a role for governments to improve this
process through policy design and regulation.
Due to inaccuracy and inconsistency in pollutant release estimation techniques,
care must be taken when drawing conclusions (Sullivan and Gouldson 2007).
Uncertainties around data reliability and comparability show the importance of data
verification, as inconsistencies in data collection impede users’ ability to verify
whether self-reported data reflects actual emissions. One solution is to be aware of
uncertainty that exists within reported values and include uncertainty when reporting
values. The scientific validity of data can then be assessed (Pulles 2008). Fortunately,
policymakers do not always have to wait for scientists to resolve all uncertainties
(Swart et al. 2007). If uncertainties are included in the NPRI; appropriate policy and
decision making can occur (Kryzanowski 2009). For example, (Gottlieb 1995) reported
uncertainties in emission estimates for the TRI that can arise from under-reporting of
quantities due to data inaccuracies, and omission of substances from reporting.
 Journal of Environmental Planning and Management 11

Another study identified under-reporting in the TRI after comparing self-reported data
to air quality surveillance monitoring stations around point source emitters (De Marchi
and Hamilton 2006). Cooper, Green, and Meissner (2017) highlighted uncertainties in
self-reported release data to Australia’s NPI, which correlated poorly with ambient air
quality measurements. Cooper, Green, and Meissner (2017) also reported that nonpoint
source (diffuse) emissions from paved road and other sources of fugitive dust were not
incorporated. However, uncertainty is not a metric currently included in publicly avail-
able NPRI data.
As data is reported in line with requirements, it is the requirements that need to be
addressed. Specifically, this means a greater focus on verification, and thereby on
monitoring and enforcement. Lack of stringent monitoring means that NPRI currently
shares similar flaws to Canada’s failed VPs due to the absence of credible verification
by third parties (Henriques and Sadorsky 2008). If data contained within a PRTR lacks
credible verification, then the tool needs strengthening to improve overall effective-
ness. Inaccurate data can give stakeholders a false sense of security/progression or fear
(Blackman 2010; Tietenberg 1998). Scaling back exemptions coupled with an
increased focus on data verification would combine to create a program with high
quality data that would be more effective at fulfilling the NPRI’s stated policy out-
comes, including identifying pollution prevention priorities, addressing risk assessment
and informing the public.

7. Does NPRI inform stakeholders?

PRTRs are designed to promote the public right-to-know and encourage stakeholders
to exert pressures on industry so as to achieve reductions in release and in the risk
from releases (OECD 1999) meaning, at its basic level, the NPRI should inform citi-
zens (Rabe 1999). This extends to informing and empowering stakeholders, so they
participate in decision-making processes. When governments set stringent pollutant
release standards, facilities act to improve environmental performance, due to a higher
probability of being caught in non-compliance (DeMarco and Vigod 2007). Harrison
and Antweiler (2003) found that disclosure of release data can be as effective as coer-
cive discharge regulations, as they prompt voluntary actions by industry; although
Blackman (2010) highlights that it is unclear whether public disclosure spurs abate-
ment by improving a facility’s internal information or by enhancing external pressures.
For NPRI to be effective, multiple stakeholders need to be included in the policy for-
mation and development. However, NPRI is poorly known and certain aspects of the
data are difficult to use, meaning it is failing to inform stakeholders in its current state.
Environmentally conscious citizens are the most likely to exert pressure on facili-
ties and to advocate for rigorous regulation (Rae 2003). While these citizens may use
NPRI data, broad knowledge of the program amongst the general public is restricted.
Research into awareness of the EPA’s TRI system found that while environmental and
public interest groups used TRI data to affect social and regulatory change, citizens
who were unfamiliar with the issues had little knowledge of the program or data
(Atlas 2007; Hamilton 2005). The same patterns exist, more pronouncedly in Canada.
Setton et al. (2015) found no published literature evaluating the NPRI in terms of its
utility in increasing Canadians’ awareness of potentially harmful pollutants. Other
studies have found that while multiple stakeholders can physically access the informa-
tion, not all are able to effectively use it (Dance 2015; Pulles 2008). Henriques and
12 S. Johnston Edwards and T. R. Walker

Sadorsky (2013) conclude that NRPI data in not as easily accessible as the EPA’s TRI
data. The lack of accessibility limits NPRI’s overall effectiveness and fails to fulfil to
NPRI’s fifth policy outcome of improving public understanding. Environmental deci-
sion-making processes reflect stakeholder values and experiences (Blake 2001), but
participation in these processes is limited, meaning not all are being heard. To promote
a greater degree of public involvement in decision-making processes, greater ease of
access to data is important to help inform and to help encourage actions to reduce pol-
lutant releases, as stipulated in NPRI policies 5 and 4.
Empirical studies back the theory that information release provides information to
stakeholders who exert pressures for stronger environmental performance (Anton,
Deltas, and Khanna 2004; Foulon, Lanoie, and Laplante 2002). However, Blackman
(2010) mentions that it is unclear which stakeholders exert the greatest pressures on
industry. Henriques and Sadorsky (2013) found that consumers and directives from
corporate headquarters were the two main forces responsible for facilities adopting
stronger performance practices, although, a previous study by Antweiler and Harrison
(2003) disagreed on the impact of environmentally conscious consumers. Either way it
shows that these pressures can be both bottom-up and top-down. Notably, despite
those who may be environmentally conscious and the NPRI’s basis as a social and
environmental policy tool, it seems that economic factors are the main motive behind
facilities adopting higher environmental performance standards (Antweiler and
Harrison 2003).
NPRI is touted as a new governance policy style as it relies on communication
between various stakeholder groups (Simmons 2013). Changes to NPRI are made on a
case-by-case basis and are overseen by multistakeholder working groups including rep-
resentatives from government, industry, environmental groups and First Nations
(ECCC 2016c). This governance structure can empower otherwise marginalized stake-
holders and, hopefully, can be effective at building public support for environmental
policy (Blackman 2010; Blake 2001; Sullivan and Gouldson 2007). Currently, changes
only pass when all stakeholders agree to them, meaning industry can delay or prevent
changes it deems undesirable. Mining operations were only partially added to the
scope of the NPRI in 2007 because two NGOs went through the court system to chal-
lenge the government’s interpretation of its own legislation (Simmons 2013).
Ultimately, this comes back to collecting and publishing high quality data. For the
NPRI, policy formation focuses on developing targeted policy for pollution prevention
(ECCC 2016a). Beyond government and industry, academics are some of the most fre-
quent users of NPRI data. In line with NPRI’s policy goal two, data from the NPRI is
used by academics to model air quality and perform risk assessment from pollution
(e.g. Ayala et al. 2012). This can be done by estimating the relative contributions of
various sources of pollutants in a geographic area (Setton et al. 2015). Academics and
think tanks have become hotbeds of policy development recommendations. Scientists
have identified issues with the data pertaining to data reliability and usability. Due to
the policy-orientated nature of NPRI data, its quality might not always be at the level
that hard scientists would expect (Pulles 2008); because of this, NPRI data cannot be
treated as 'model-ready' input (Kryzanowski 2009).
To properly develop strong public policy and to fulfill NPRI’s stated goals of iden-
tifying pollution prevention priorities and developing targeted regulations, it is neces-
sary to understand the patterns of pollutant release which depends on the types of
pollutants, the sources of pollutants and the geographic positions of their release
 Journal of Environmental Planning and Management 13

being publically accessible (Ayala et al. 2012; Moghadam and Kayahan 2017). Data
contained within the NPRI is also important for policy at the international scale, such
as international agreements or trade deals (Know 2001; McAusland and Millimet
2013; Pulles 2008). The effects of pollution are not constrained by geographic or
domestic boundaries, yet environmental policies tend to stop there (Morriss and
Meiners 2009). In trade deals, adopting strong environmental policy is becoming
important for exporting products to other countries, as firms have to assure that their
production processes comply with jurisdictional standards. As international environ-
mental standards become more stringent, firms are wise to meet these standards in
order to best maintain access to the global market (Fujii, Managi, and Kawahara.
2011). As such, the extent to which Canada’s NPRI system can inform policy goes
beyond just developing pollution prevention targets.

8. Conclusion
Although, PRTRs are meant to be standalone programs, PRTRs work best when paired
with some form of command-and-control regulation. Use of public disclosure helps to
craft targeted command-and-control regulations which, when enforced, positively influ-
ence patterns of pollution reduction. The importance of Canada’s NPRI program as a
public policy tool extends beyond simply addressing environmental policy. It directly
addresses social policy issues such as public health and governance issues around
stakeholder engagement. Further, NPRI informs policies at local and national levels
and can extend to policies at the international level through agreements and trade pol-
icy. At present, NPRI is plagued with issues that hinder the effectiveness of its policy
goals. Specifically, in the literature discussing improvements to Canada’s NPRI pro-
gram, concerns with data reliability within the NPRI need to be addressed. This
encompasses the type of data included in, and excluded from, the NPRI database, com-
pleteness of data and data accuracy. Regulated reporting exemptions create gaps in
inventory emissions, and when tabulated they create a mismatch, often underestimating
actual emissions. By not accounting for emissions from exempt industries or small and
medium businesses, these can lead to serious flaws in designing emission reduction
targets, both on national and international scales. Further, differences in emission esti-
mation and reporting methods make data comparison difficult across jurisdictions,
across industry and even from the same facility. If data contained within a PRTR lacks
credible verification, then the tool needs strengthening to improve overall effectiveness
of its policy outcomes.
Pollution control through use of PRTRs offers insight into the actions taken by
industry and government in reducing pollutant release levels. In Canada, as changes
are made to NPRI reporting requirements, patterns and trends in these levels emerge.
Actual pollution reduction has occurred in concert with stringent command-and-control
regulation wherein the publishing of data online allows stakeholders to advocate for
targeting certain areas for improvement, alongside the government proposing or actu-
ally implementing updated compliance targets. To achieve emissions reductions, threats
of monitoring and actual enforcement have proven to be most effective. In order to
develop social actions, increased public understanding and engagement in decision
making beyond just dedicated stakeholders will be important. For this, increased acces-
sibility and data completeness will be key. Conclusively, we see that it is economic
14 S. Johnston Edwards and T. R. Walker

factors that push individual firms to adopt higher environmental performance stand-
ards, although consumers themselves may be environmentally motivated.
While pollutant release quantities have decreased overall, at least in terms of facili-
ties that have reported since the start, the toxicity of pollutants released in Canada has
increased over the same time period. By focusing the mass of releases, pollution con-
trol policy misses out on effecting real change as it ignores other, arguably more
important, considerations in toxicity levels and exposure times. A focus on developing
methods of grading substances by toxicity should be the prime criterion for setting
chemical reduction and elimination priorities. NPRI and other PRTRs are ultimately
designed as pollution prevention policy tools, with the goal of reducing pollutant
releases for both environmental and social reasons. But simply reducing pollutants is
not enough anymore. A switch from pollution prevention to pollution outcome-based
decision making as the governing philosophy is encouraged. As environmental mind-
fulness increases, proactive firms are moving away from simply relying on techno-
logical fixes, to eliminating pollutant releases altogether to move towards true
sustainability. Canada’s NPRI has the capacity to be a tool to facilitate this transition
if issues around data completeness, accuracy and accessibility are addressed.

Disclosure statement
No potential conflict of interest was reported by the authors.

References
ADEE (Australian Department of Environment and Energy). 2017. “About the NPI.” Australian
Government. Accessed June 28, 2018. http://www.npi.gov.au/about-npi.
Anh, C., S. H. Lee, F. Pena-Mera, and S. Abourizk. 2010. “Toward Environmentally
Sustainable Construction Processes: The US and Canada’s Perspective on Energy
Consumption and GHG/CAP Emissions.” Sustainability 2: 354–370. doi:10.3390/su2010354.
Anton, W. R. Q., G. Deltas, and M. Khanna. 2004. “Incentives for Environmental Self-
Regulation and Implications for Environmental Performance.” Journal of Environmental
Economics and Management 48 (1): 632–654. doi:10.1016/j.jeem.2003.06.003.
Antweiler, W., and K. Harrison. 2003. “Toxic Release Inventories and Green Consumerism:
Empirical Evidence from Canada.” Canadian Journal of Economics/Revue Canadienne
dEconomique 36 (2): 495–520. doi:10.1111/1540-5982.t01-1-00011.
Ashcroft, P., and L. M. Smith. 2008. “Impact of Environmental Regulation on Financial
Reporting of Pollution Activity: A Comparative Study of US and Canadian Firms.”
Research in Accounting Regulation 20: 127–153.
Atlas, M. 2007. “TRI to Communicate: Public Knowledge of the Federal Toxics Release
Inventory.” Social Science Quarterly 88 (2): 555–572. (doi:10.1111/j.1540-6237.2007.00471.x.
Ayala, A., J. Brauer, J. L. Mauderly, and J. M. Samet. 2012. “Air Pollutants and Sources
Associated with Health Effects.” Air Quality, Atmosphere and Health 5 (2): 151–163. doi:
10.1007/s11869-011-0155-2.
Bennett, D. 2012. “Labour and Pollution Prevention in Canada.” New Solutions: A Journal of
Environmental and Occupational Health Policy 22 (1): 19–35. doi:10.2190/NS.22.1.c.
Blackman, A. 2010. “Alternative Pollution Control Policies in Developing Countries.” Review of
Environmental Economics and Policy 4 (2): 234–253. doi:10.1093/reep/req005.
Blake, D. E. 2001. “Contextual Effects on Environmental Attitudes and Behavior.” Environment
and Behaviour 33 (5): 708–725. doi:10.1177/00139160121973205.
Bocken, N. M. P., S. W. Short, P. Rana, and S. Evans. 2014. “A Literature and Practice Review
to Develop Sustainable Business Model Archetypes.” Journal of Cleaner Production 65:
42–56. doi:10.1016/j.jclepro.2013.11.039.
 Journal of Environmental Planning and Management 15

Cooper, N., D. Green, and K. J. Meissner. 2017. “The Australian National Pollutant Inventory
Fails to Fulfil Its Legislated Goals.” International Journal of Environmental Research and
Public Health 14 (5): 478–496. doi:10.3390/ijerph14050478.
Dance, A. 2015. “Northern Reclamation in Canada: Contemporary Policy and Practice for New
and Legacy Mines.” Northern Review 41: 41–80.
De Marchi, S., and J. T. Hamilton. 2006. “Assessing the Accuracy of Self-Reported Data: An
Evaluation of the Toxics Release Inventory.” Journal of Risk and Uncertainty 32 (1):
57–76. doi:10.1007/s10797-006-6666-3.
Delgado-Ceballos, J., and A. Rueda-Manzanares. 2010. “Public Disclosure of Corporate
Environmental Performance: Pollutant Release and Transfer Registers (PRTRs).” In Global
Sustainability as a Business Imperative, edited by J. A. F. Stoner and C. Wankel, 111–125.
New York: Palgrave Macmillan.
DeMarco, J. V., and T. Vigod. 2007. “Smarter Regulation: The Case for Enforcement and
Transparency.” Journal of Environmental Law and Practice 17 (2): 85–113.
ECCC (Environment and Climate Change Canada). 2016a. “National Pollutant Release
Inventory.” Government of Canada. https://www.ec.gc.ca/inrp-npri/28C24172-53CB-4307-
8720-CB91EE2A6069/2016-17%20Guide%20for%20Reporting%20-%20EN.pdf
ECCC (Environment and Climate Change Canada). 2016b. “Guide for Reporting to the National
Pollutant Release Inventory (NPRI) 2016 and 2017 Canadian Environmental Protection Act,
1999 (CEPA).” Government of Canada. https://www.canada.ca/content/dam/eccc/migration/
main/inrp-npri/28c24172-53cb-4307-8720-cb91ee2a6069/2016-17-20guide-20for-20reporting-
20-20en.pdf
ECCC (Environment and Climate Change Canada). 2016c. “Guide for reporting to the National
Pollutant Release Inventory (NPRI) 2016 and 2017”. Government of Canada. https://www.
canada.ca/content/dam/eccc/migration/main/inrp-npri/afc98b81-a734-4e91-bd16-c5998f0dde6b/
2016-17-20guide-20for-20reporting-20-20en.pdf
ECCC (Environment and Climate Change Canada). 2017. “The National Pollutant Release
Inventory Oil and Gas Sector Review.” Archived ECCC, Government of Canada. https://
www.ec.gc.ca/inrp-npri/default.asp?lang ¼Enandn¼02C767B3-1
EPA. 2017. “About the TRI program.” United States Environmental Protection Agency. http://
www.epa.gov/toxics-release-inventory-tri-program
European Commission (EC). 2006. “Regulation (EC) No 166/2006 of the European Parliament
and of the Council of 18 January 2006 Concerning the Establishment of a European
Pollutant Release and Transfer Register and Amending Council Directives 91/689/EEC and
96/61/EC.” Official Journal of the European Union 49: 1–17.
Foulon, J., P. Lanoie, and B. Laplante. 2002. “Incentives for Pollution Control: Regulation or
Information?” Journal of Environmental Economics and Management 44 (1): 169–187. doi:
10.1006/jeem.2001.1196.
Fujii, H., S. Managi, and H. Kawahara. 2011. “The Pollution Release and Transfer Register
System in the US and Japan: An Analysis of Productivity.” Journal of Cleaner Production
19 (12): 1330–1338. doi:10.1016/j.jclepro.2011.01.010.
Gavronski, I., R. D. Klassen, S. Vachon, and L. F. Machado do Nascimento. 2012. “A Learning
and Knowledge Approach to Sustainable Operations.” International Journal of Production
Economics 140 (1): 183–192. doi:10.1016/j.ijpe.2012.01.037.
GoC (Government of Canada). 2004. “A Guide to Understanding the Canadian Environmental
Protection Act, 1999.” Government of Canada. http://publications.gc.ca/site/eng/267729/
publication.html
GoC (Government of Canada). 2016a. “History of Reporting Requirements: National Pollutant
Release Inventory.” Government of Canada. https://www.canada.ca/en/environment-climate-
change/services/national-pollutant-release-inventory/substances-list/history-reporting-require-
ments.html
GoC (Government of Canada). 2016b. “History of Changes to the Substance List.” Government
of Canada. https://www.canada.ca/en/environment-climate-change/services/national-pollutant-
release-inventory/substances-list/history-changes.html
Gottlieb, R. 1995. Reducing Toxics: A New Approach to Policy and Industrial Decision Making.
Washington, DC: Island Press.
Hamilton, J. T. 2005. Regulation Through Revelation: The Origin, Politics, and Impacts of the
Toxics Release Inventory Program. New York: Cambridge University Press.
16 S. Johnston Edwards and T. R. Walker

Harrison, K., and W. Antweiler. 2003. “Incentives for Pollution Abatement: Regulation,
Regulatory Threats and Non-Governmental Pressures.” Journal of Policy Analysis and
Management 22 (3): 361–382. doi:10.1002/pam.10137.
Henriques, I., and P. Sadorsky. 2008. “Voluntary Environmental Programs: A Canadian
Perspective.” Policy Studies Journal 36 (1): 143–166. doi:10.1111/j.1541-0072.2007.00257.x.
Henriques, I., and P. Sadorsky. 2013. “Environmental Management Practices and Performance
in Canada.” Canadian Public Policy 39 (Supplement 2): S157–S175. doi:10.3138/CPP.39.
Supplement2.S157.
Hoffman, E., M. Bernier, B. Blotnicky, P. G. Golden, J. Janes, A. Kader, R. Kovacs-Da Costa,
S. Pettipas, S. Vermeulen, and T. R. Walker. 2015. “Assessment of Public Perception and
Environmental Compliance at a Pulp and Paper Facility: A Canadian Case Study.”
Environmental Monitoring and Assessment 187 (12): 113. doi:10.1007/s10661-015-4985-5.
Horvathova, E. 2012. “The Impact of Environmental Performance on Firm Performance: Short-
Term Costs and Long-Term Benefits?” Ecological Economics 84: 91–97. doi:10.1016/j.
ecolecon.2012.10.001.
Huesemann, M. H. 2003. “The Limits of Technological Solutions to Sustainable Development.”
Clean Technologies and Environmental Policy 5 (1): 21–34.
Ishizaka, K., and M. Tanaka. 2003. “Resolving Public Conflict in Site Selection Process: A Risk
Communication Approach.” Waste Management 23 (5): 385–396. doi:10.1016/S0956-
053X(03)00094-1.
Jørgensen, S. E. 2000. Principles of Pollution Abatement: Pollution Abatement for the 21st
Century. Oxford, UK: Elsevier.
Kerret, D., and G. M. Gray. 2007. “What Do We Learn from Emissions Reporting? Analytical
Considerations and Comparison of Pollutant Release and Transfer Registers in the United
States, Canada, England, and Australia.” Risk Analysis 27 (1): 203–223. doi:10.1111/j.1539-
6924.2006.00870.x.
Know, J. 2001. “Federal, State and Provincial Interplay regarding Cross-Border Environmental
Pollution.” Canada-United States Law Journal 27 (3): 199–204.
Korhonen, J., and T. P. Seager. 2008. “Beyond Eco-Efficiency: A Resilience Perspective.”
Business Strategy and the Environment 17 (7): 411–419. doi:10.1002/bse.635.
Kryzanowski, J. 2009. “The Importance of Policy in Emissions Inventory Accuracy.” Journal of
Air and Waste Management Issues 59: 430–439.
Kwon, Y.-S., M.-J. Bae, and Y.-S. Park. 2014. “Changes of Heavy Metals in Pollutant Release
and Transfer Registers (PRTRs) in Korea.” International Journal of Environmental
Research and Public Health 11 (3): 2381–2394. doi:10.3390/ijerph110302381.
Lim, S.-R., C. W. Lam, and J. M. Schoenung. 2010. “Quantity-Based and Toxicity-Based
Evaluation of the US Toxics Release Inventory.” Journal of Hazardous Materials 178
(1–3): 49–56. doi:10.1016/j.jhazmat.2010.01.041.
McAusland, C., and D. L. Millimet. 2013. “Do National Borders Matter? Intranational Trade,
International Trade, and the Environment.” Journal of Environmental Economics and
Management 65 (3): 411–437. doi:10.1016/j.jeem.2012.10.001.
Miyamoto, T. 2016. “Why Regulators Adopt Voluntary Programs: A Theoretical Analysis of
Voluntary Pollutant Reduction Programs.” Environmental Economics and Policy Studies 18
(4): 599–623. doi:10.1007/s10018-015-0133-2.
Moghadam, A. K., and B. Kayahan. 2017. “What Influences the Pattern of Pollutant Releases?
An Investigation of Firms’ Siting and Households’ Sorting Decisions in Ontario, Canada.”
Journal of Environmental Planning and Management 60 (4): 743–754. doi:10.1080/
09640568.2016.1178106.
Morriss, A. P., and R. E. Meiners. 2009. “Borders and the Environment.” Environmental Law
39: 141–192.
Muhammad, N., F. Scrimgeour, K. Reddy, and S. Abdin. 2016. “Emission Indices for
Hazardous Substances: An Alternative Measure of Corporate Environmental Performance.”
Corporate Social Responsibility and Environmental Management 23 (1): 15–26. doi:10.
1002/csr.1357.
OECD (Organisation for Economic Co-operation and Development). 1999. “Proceedings of the
OCED International Conference on Pollutant Release and Transfer Registers (PRTRs), Part 1.”
ENV/JM/MONO(99)16/PART1. Paris: OECD. http://www.oecd.org/officialdocuments/public
displaydocumentpdf/?doclanguage=en&cote=env/jm/mono(99)16/part1
 Journal of Environmental Planning and Management 17

Olewiler, N., and K. Dawson. 1998. Analysis of National Pollutant Release Inventory Data on
Toxic Emissions by Industry. Working Paper Burnaby, BC: Simon Fraser University. http://
epe.lacbac.gc.ca/100/200/301/finance/working_paper_tcbt-e/1997/1997-16/wp97-16e.pdf
Pulles, T. 2008. “Quality of Emission Data: Community Right to Know and National
Reporting.” Environmental Sciences 5 (3): 151–160. doi:10.1080/15693430802141357.
Rabe, G. B. 1999. “Federalism and Entrepreneurship: Explaining American and Canadian
Innovation in Pollution Prevention and Regulatory Integration.” Policy Studies Journal 2
(2): 288–306. doi:10.1111/j.1541-0072.1999.tb01969.x.
Rae, A. 2003. “Federalism in the Regulation of Chemical Pollutants in Australia.” Prometheus
21 (2): 247–264. doi:10.1080/08109020308128.
Resnik, D. B. 2007. “Responsibility for Health: Personal, Social, and Environmental.” Journal
of Medical Ethics 3 (8): 444–445. doi:10.1136/jme.2006.017574.
Rosenberger, J. 2014. “Canadian Experiences in Pollutant Reporting: The National Pollutant
Release Inventory.” https://www.epa.gov/sites/production/files/2014-10/documents/bk1_wed_
8_rosenberger_0.pdf
Setton, E. M., B. Veerman, A. Erickson, S. Deschenes, R. Cheasley, K. Poplawski, P. A.
Demers, and C. P. Keller. 2015. “Identifying Potential Exposure Reduction Priorities Using
Regional Rankings Based on Emissions of Known and Suspected Carcinogens to Outdoor
Air in Canada.” Environmental Health 14 (1): 69–84. doi:10.1186/s12940-015-0055-2.
Simmons, G. 2013. “Clearing the Air: Information Disclosure, Systems of Power, and the
National Pollution Release Inventory.” McGill Law Journal 59 (1): 9–48. doi:10.7202/
1018984ar.
Sullivan, R., and A. Gouldson. 2007. “Pollutant Release and Transfer Registers: Examining the
Value of Government-Led Reporting on Corporate Environmental Performance.” Corporate
Social Responsibility and Environmental Management 14 (5): 263–273. doi:10.1002/csr.148.
Swaney, J. A. 1992. “Market Versus Command and Control Environmental Policies.” Journal of
Economic Issues 26 (2): 623–633. doi:10.1080/00213624.1992.11505321.
Swart, R., P. Bergamaschi, T. Pulles, and F. Raes. 2007. “Are National Greenhouse Gas
Emissions Reports Scientifically Valid?” Climate Policy 7 (6): 535–538. doi:10.1080/
14693062.2007.9685675.
Tietenberg, T. 1998. “Disclosure Strategies for Pollution Control.” Environmental and Resource
Economics 11 (3/4): 587–602. doi:10.1023/A:1008291411492.
Toffel, M. W., and J. D. Marshall. 2008. “Improving Environmental Performance Assessment:
A Comparative Analysis of Weighting Methods Used to Evaluate Chemical Release
Inventories.” Journal of Industrial Ecology 8 (1–2): 143–172. doi:10.1162/1088198041269
445.
Walker, T. R. 2018. “Effectiveness of the National Pollutant Release Inventory as a Policy Tool
to Curb Atmospheric Industrial Emissions in Canada”. PeerJ Preprints 6: E 27372v1.
Wanxin, L. 2011. “Self-Motivated Versus Forced Disclosure of Environmental Information in
China: A Comparative Case Study of the Pilot Disclosure Programmes.” The China
Quarterly 206: 331–351.
Zhou, X., and J. M. Schoenung. 2009. “Combining US-Based Prioritization Tools to Improve
Screening Level Accountability for Environmental Impact: The Case of the Chemical
Manufacturing Industry.” Journal of Hazardous Materials 172 (1): 423–431. doi:10.1016/j.
jhazmat.2009.07.032.