PlanetNL45: NL Has Terrible Per Capita Pollutant Emissions

Plenty of Room For Improvement

The last PlanetNL post served a narrow purpose of demonstrating that the Holyrood generating station has consistently met provincial air quality regulations since 2006 and that Government and Nalcor claims that the plant needed expensive pollution control equipment was a lie.  

The evidence provided should not be interpreted as meaning that all is fine with industrial emissions, however.  There is considerable evidence pointing to the opposite.

By many measures, Canada is one of the absolute worst emitters among advanced industrialized countries and this province is among the worst in Canada.  Time for an honest look in the mirror.

Per Capita Pollutant Emissions Tell the Real Story

The Conference Board of Canada has done great work preparing charts that need to be seen.  They compared the pollutant emissions of all provinces along with a basket of peer OECD nations.   The Board provides both a qualitative grade (A, B, C, D, D-) for each plus they rank the group in order.

Canada grades out as a D overall while NL and four other provinces earn a D-.  Only Australia scores worse.

Below are the Conference Board charts for three key pollutants: NOx, PM10, and SOx.  Accompanying each is a summary of who the key NL emitters are for that pollutant using data sourced from the Government of Canada’s National Pollutant Release Information (NPRI) database.

Canada emits nearly triple the level of NOx as most countries in the group.  NL emits more than double the Canadian average.

NPRI data shows that this province’s industrial emitters totalled 19,885 Tonnes of NOx in 2017 (the latest year available).  The big three onshore emitters are clearly the Iron Ore Company (IOC), NL Hydro’s Holyrood station, and North Atlantic Refining LP (NARL).

Much the same pattern is repeated for Particulate Matter emissions smaller than 10 microns except this time NL is distinctly the worst jurisdiction.  Of the total 5182 Tonnes of PM10 emitted in the province, NPRI data shows that IOC accounts for 60%.

More than with other air pollutants, many countries have gone to great lengths to nearly eliminate sulphur oxide emissions.  Canada has improved over time but has much further to go.  NL SOx emissions are triple the US average but are astonishingly exceeded by four other provinces and Australia.

NPRI data identifies total NL industrial SO2 emissions of 21,584 Tonnes in 2017 with the familiar big three accounting for 99.6% of it.

Canada’s Refineries A Pollutant Emissions Nightmare

A 2018 report (Ecojustice) compared all 15 refineries in Canada to the average level of performance of US refineries.  Canadian refineries fared extremely poorly in the comparison.  The entire US refining industry produces 30% less SO2 than the entire and far smaller Canadian industry.  That an average US refinery was found to release 98% less SO2 than NARL is beyond reason.  The report indicates the US Clean Air Act (last amended in 1990, so not exactly up to date) is far more comprehensive and effective than Canadian regulations.

Consumers may be aware that advances in automotive technology and tightening of fuel quality regulations – including a sulphur limit of barely 0.001% – have tremendously cleaned up tailpipe emissions.  However, regulating only the end users of the transport sector misleads the public as to the true emissions of their demand for crude oil.  Canada needs to follow the lead of the US and close the loopholes that allow existing refineries to seemingly pollute at will.

As NARL ceased operations in 2020 and the facility is being reconfigured to process non-fossil fuel renewable feedstock under a new owner, the province can presumably look forward to the refinery moving well down the list of in-province polluters.  This should be a very good thing, though it remains to be seen what the emission profile will eventually be.  There will still likely be considerable room for improvement relative to refining in other nations.

IOC and Holyrood – Two of Canada’s Largest Heavy Fuel Oil Users

Both IOC and Holyrood burn large amounts of sulphur-laden Heavy Fuel Oil (HFO) and together represent nearly 20% of national HFO consumption. Industrial use of HFO has been largely displaced by much cheaper and cleaner burning natural gas.  As the only province in which natural gas is completely unavailable, HFO remains the industrial fuel of choice and its buyers will get away with as much sulphur content as they can as without violating regulations. 

Hydro’s Holyrood plant is the very last HFO-fired generating station in North America (aside from Hawaii) still operating as a steady baseload plant.  As noted in last week’s post, substantially lower SO2 emissions could be obtained with readily available lower-sulphur fuels but they cost more.  As current air quality standards are being comfortably met and the cleaner fuels cost more, Hydro sticks to a mid-level sulphur HFO.

At IOC, HFO is used mainly to bake 12.5 Million Tonnes annually of iron ore pellets at temperatures up to 1300 deg C as well as to fire their process hot water and steam requirements.  Like Holyrood, IOC’s SO2 emission could likely be much lower but the company is unlikely to choose to do so without decisive regulatory change forcing its hand.  Incidentally, IOC’s own Sustainable Development Report for 2020 fails entirely to mention SO2 or any emissions besides GHGs.

Photo: IOC Pellet Plant in foreground – largest section at right contains 6 oil-fired indurating furnaces

If burning any fossil fuel bothers you, then you will be especially upset if you read up on HFO.  It is the residual leftover crud that cannot be refined into better fuel types (diesel, gasoline, kerosene, propane).  It is a thick tar at normal temperatures and a major spill poses risk of environmental damage and difficulty to clean up that exceeds crude oil.  But it’s the cheapest oil product money can buy and in market segments with no better economic substitute and lax pollution regulations, like this province, HFO is king.

Regulatory Absurdity

The global shipping industry is the last place one ordinarily expects to find environmental progress.  They fly their flags of convenience and avail of the very limited legal obligations in non-territorial waters to economize costs in every way possible.  The shipping industry has historically treated oceans as a free dump.  Large ships have burned the cheapest high-sulphur HFO, also known as Bunker C, without emission controls ever since oil replaced coal-fired boilers. 

One key problem is that fuel combustion emissions of all types are acidifying oceans, depleting the organisms that produce half of the world’s oxygen are putting at risk all ecosystems in oceans and elsewhere.  2020 shipping regulations now limit HFO-fired ships without emission controls to no longer use fuel with more than 0.5% sulphur.  Furthermore, when they enter the more sensitive coastal territorial waters (the 200-mile limit) of Canada and many other countries, they must switch to fuels below 0.1% sulphur.  For this, they have an extra tank holding marine diesel which isn’t quite as clean as road diesel but is a substantial improvement over HFO and therefore quite a bit more expensive.

These are steps in the right direction for the shipping industry.  Yet, policymakers allow onshore industries to absurdly carry on burning HFO, including the higher than 0.5% sulphur type.  If it makes sense to improve protection of coastal territorial waters with less than 0.1% sulphur fuel, shouldn’t the onshore industries be required to use 0.1 sulphur fuels or better as well?  Apparently not.  Our legislators are just fine with industries polluting onshore ecosystem and at a seaside site such as Holyrood, there is no doubt much of the emissions go directly into the ocean.

Scale of The Problem

Few people can understand the scale of Holyrood’s fuel consumption and its air pollution potential.  To help visualize it, a comparison to Marine Atlantic’s ferry fleet may be useful.  Marine Atlantic annual reports indicate about 30 million litres of marine diesel consumption in their three primary ferries.  Their ships used to burn HFO but, as explained above, they were compelled by regulations to switch to lower-sulphur marine diesel ahead of 2020.

By comparison, Holyrood has frequently used more than 300 million litres of HFO annually.  We can reason then that the Holyrood plant has the equivalent fuel consumption and greenhouse gas (GHG) intensity as roughly 30 Marine Atlantic ferries.  As Holyrood is a seasonal plant, the true level of intensity would be upward of 60 ferries in the winter months when the plant is at full power.  As Holyrood uses a midlevel HFO with at least 5 times higher sulphur than marine diesel, Holyrood at full power emits the SO2 equivalent of 300 Marine Atlantic ferries.  It’s quite possible that the Holyrood plant by itself is now emitting as much SO2 as all the annual heavy shipping industry working in or passing through the entire Atlantic Canada area.

Another comparable involves road diesel fuel.  The entire provincial market for road diesel is about the same as Holyrood: 300 million litres annually.  Holyrood burns the same amount of fuel (and has about the same GHG emissions) as every diesel pickup, heavy duty van and truck, construction equipment, municipal and government heavy vehicles, and long-haul transport vehicles in the province but it does so in one stationary location.  Just imagine all those vehicles assembled tightly in one town and steadily roaring away, never leaving.  As road diesel contains over 300 times less sulphur than Holyrood’s HFO, it takes less than half a day of winter operations to equal the entire year’s worth of the province’s road diesel sulphur content.  Just one winter month of Holyrood operations equals all the sulphur content of an entire year’s worth of road diesel consumption across Canada.

While those emissions at ground level would surely poison many people, or worse, the Holyrood plant’s 100m tall smokestacks allow emissions to be very broadly dispersed and mixed with ambient air to ensure that ground level concentrations in the immediate area are safe.  That doesn’t mean there isn’t a lot of harmful pollution being produced though.

Deducing from IOC’s GHG emission data, they use about half as much HFO as Holyrood: still a very large amount. Knowing their approximate HFO usage, the NPRI emissions data for NOx and SO2 suggest that IOC likely uses a much dirtier HFO.  An IOC consultant report filed with the Dept of Environment indicates 1.5% has been the maximum allowable for Canadian industry since 2012 and the emissions data align with that number.  IOC is notable for other air pollutants as well: NPRI data reveal IOC as Canada’s 6th largest leading air emitter of arsenic and lead.

Forcing Solutions – Not the Canadian Way

Canadian policymakers tend to be powderpuff soft on existing industrial operators.  They will tout the stronger regulations created for new industrial projects but existing operators – refineries, mines, and fossil fuel power plants among them – are exempted from such modern regulations.  With governments clamouring to develop green credentials, however, the public may have an opportunity to hold policymakers to a higher standard that includes real efforts to reduce pollutant levels from existing industries.

The matter of allowing dirty HFO to be used onshore when it cannot be used in the marine sector is an absurdity that should be dealt with promptly.  As Canada claims to be attempting to phase out coal burning by 2030, why not include HFO as an equally noxious substance.  The 2030 objective should be revised to eliminate combustion of all high pollutant fossil fuels across the country as well as throughout all territorial waters.  The Province, as a maritime jurisdiction, surely has both the moral obligation and the legislative opportunity to impose changes even faster.  This is what some call “low hanging fruit”.

IOC could easily and quickly switch to marine diesel and achieve high reductions in their pollutant emissions.  The extra cost would be a very small fraction of their substantial earnings.  The company should publicly table plans to innovate and modernize their process technology.  If they do nothing, the green economy may eventually squeeze them out.  IOC’s neighbour, ArcelorMittal, is starting an LNG conversion at their pellet plant to eliminate HFO and substantially lower fuel emissions by 2025.  In theory, IOC could eventually use green hydrogen technology if it ever becomes commercially viable but this likely entails doubling or more their electricity demand.  Government already gives IOC an enormous amount of virtually free electricity despite IOC’s original rights to the electricity having expired years ago – this is a major public subsidy of a highly profitable company.  Government must grow a backbone to deal with the company to both end HFO use and to raise Labrador electricity revenue to its market value.

As for Holyrood, declining demand for electricity has proven to be a wonderful emission reduction strategy all by itself.  If Muskrat power is ever properly and reliably delivered in full by the LIL, Holyrood emissions will be a thing of the past, not that this would ever justify Muskrat’s crippling cost.  However, if the LIL continues to be a critical problem, then serious efforts to reduce seasonal electricity demand must be considered with an aim toward ending baseload power supply.  This would be (and could have been) most economically achieved through pricing policy changes to stimulate a decrease in winter loads and with the promotion of energy efficient heating systems such as heat pumps or heat energy storage devices.  Best utility practice is always to mitigate seasonal peak loads rather than add new generation and transmission – adding Muskrat was the entirely wrong approach.  Drastic reduction and practical elimination of Holyrood pollution emissions would result just from applying simple levers of economics.

Pathways to success are best managed by tackling problems head-on.  The steps to improving our environmental grade of “D-“ are as obvious as our Government’s desire to avoid them. 

Key Sources and References:

Conference Board of Canada –  Environment Provincial Rankings – How Canada Performs (

Ecojustice – Inadequate Pollution Control in Canadian Refineries: Media Backgrounder – 2018-04-30-benchmarking-backgrounder-FINAL-1.pdf (

NPRI Search Tool for Pollutant Emissions in Canada – Environment and Climate Change Canada – NPRI Data Search

IOC Sustainable Development Report 2020 – ioc_rdd_2020_en-final-web.pdf (

AMEC Air Quality Study for IOC, November 2012 – env-assessment-projects-y2013-1711-1711-a4-w3-air-qual-clim.pdf (

Heavy Fuel Oil Consumption in Canada – Supply and use tables, detail level, provincial and territorial (

NL diesel fuel sales 2016-2020 – Sales of fuel used for road motor vehicles, annual (

Port Cartier pellet plant LNG upgrade – ArcelorMittal announces CAD$205 million decarbonisation (

Green Hydrogen for Iron Ore Mining – Global push for green steel could hit Australia’s $150bn iron ore exports if miners don’t adapt, report finds | Mining | The Guardian

Bonus reading on Canada’s inattention to Heavy Fuel Oil pollution and risks:

Air Pollution & Marine Shipping | Clear Seas

How Canada’s shipping industry can reduce its climate change impacts – WWF.CA

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Bill left public life shortly after the signing of the Atlantic Accord and became a member of the Court of Appeal until his retirement in 2003. During his time on the court he was involved in a number of successful appeals which overturned wrongful convictions, for which he was recognized by Innocence Canada. Bill had a special place in his heart for the underdog.

Churchill Falls Explainer (Coles Notes version)

If CFLCo is required to maximize its profit, then CFLCo should sell its electricity to the highest bidder(s) on the most advantageous terms available.


This is the most important set of negotiations we have engaged in since the Atlantic Accord and Hibernia. Despite being a small jurisdiction we proved to be smart and nimble enough to negotiate good deals on both. They have stood the test of time and have resulted in billions of dollars in royalties and created an industry which represents over a quarter of our economy. Will we prove to be smart and nimble enough to do the same with the Upper Churchill?