Reporting Materiality – NGERS 2014

Materiality thresholds for 2013/14 reporting year have changed. From July 2013 Reporters have been required to apply updated thresholds to their data capture and management strategies. The purpose of the changes is to reduce the reporting burden for key materials, namely petroleum based oils and greases, liquid, gaseous and solid fuels.

Fuel type	Threshold per instance of a source	Measurement Determination section
Petroleum-based oils and greases (other than used as fuel)	5,000 L	Division 2.4.1, section 2.39(a)
Other liquid fuels (not mentioned in s2.39(a))	1,000 L	Division 2.4.1, section 2.39(b)
Gaseous fuels	1,000 m3	Division 2.3.1, section 2.18
Solid Fuels	1 tonne	Division 2.2.1, section 2.2

Implications for reporters

These changes to the materiality thresholds will see a more streamlined NGERs 13/14 reporting process as reporters will be able to exclude reporting certain materials if they fall under the specified thresholds.

For example, reporters who consume less than the 5000L of oils and greases per instance of a source will no longer have to mandatorily report the consumption of these substances. Nevertheless, it is recommended that estimates for the quantities of substances consumed be quantified to ensure whether thresholds are tripped or not.

Reporting of immaterial amounts

Reporting fuel combustion and the associated energy consumption related to a separate instance of a source are optional if the amount combusted is less than the reporting thresholds set out in Table 1.

‘Separate instance of a source’ is defined in section 1.9A of the Measurement Determination as:

“If two or more different activities of a facility have the same source of emissions, each activity is taken to be a separate instance of the source if the activity is performed by a class of equipment is different from that used by another activity.”

For example:

The combustion of liquid petroleum gas (LPG) in the engines of distribution vehicles and the combustion of LPG in the engines of forklifts at any given facility are taken to be a separate instance of a source as the class of equipment used to the perform the activities are different. This is so even though the activities have the same source of emissions, namely the combustion of LPG fuel.

Discerning Materiality

Determining whether or not a particular NGERs reportable substance will trip thresholds can be undertaken in a variety of ways. Consulting historic datasets and NGER reports will show reporters if substances have met or exceeded thresholds in previous reporting periods. Undertaking representative-sampling and applying the results across similar operations can also provide robust estimates to reporters as to whether particular substances will breach thresholds. Finally, reporters may choose to directly measure the consumption for the reportable items in question and report remissions regardless of whether thresholds have been breached.