Streamlining Reporting under the National Greenhouse and Energy Reporting Scheme

The department has also released a position paper outlining their proposed changes to streamline reporting under the NGERs scheme. The proposed changes aim to cut requirements for reporting uncertainty, create new materiality thresholds for reporting certain types of fuel combustion, facilitate and encourage an increased use of existing streamlining provisions and clarify where reporters under NGERs are able to move between methods of measuring emissions.

The position paper, additionally, seeks to address issues raised in the public consultations of the consultation paper Efficiency of Reporting under the NGER scheme. Submissions for this process closed the 1st of February 2013. Table 1 details the most important issues raised in the consultation process and the Department’s proposals to address these issues.

Issue	Proposed approach
1. Reporting of statistical uncertainty Reporters do not see the value in their statistical uncertainty calculations and consider that the calculations are time consuming and that audit of those calculations is expensive.	Changes to the NGER Regulations will require only reporters with the largest sources of emissions (25,000 tonnes of CO2-e or over) to calculate and report the statistical uncertainty associated with emissions reporting.
2. Reporting of immaterial amounts Reporters consider that a disproportionate amount of their reporting expense is incurred in calculating and reporting data that is immaterial to reported totals.	The Measurement Determination will include new materiality thresholds for certain types of fuel combustion. This will remove the need to report on very minor amounts of emissions and energy consumption from these sources.
3. Reporting by percentage or by estimate Less than 10 per cent of reporters use existing streamlining provisions. Many reporters are not familiar with the provisions, are unsure of how to use them in practice, or the practical constraints placed around their use make them less attractive.	Changes to regulations 4.26 and 4.27of the NGER Regulations – which are designed to reduce reporting costs for very minor amounts of emissions or energy – will make them more readily available to reporters through amended thresholds.
4. Availability of methods Reporters would like greater freedom to move between measurement methods, particularly when a method has been applied incorrectly or the measuring equipment is unavailable because of mechanical or technical difficulties.	Amendments to the Measurement Determination will allow more flexibility when choosing the method that can be used when a reporter’s previous measurement method has been unintentionally applied incorrectly. The rules regarding the allowed period of down time when measuring equipment is unavailable will be clarified.
5: Reporting by facility aggregate Reporters would like greater flexibility to aggregate information by removing the requirement that only data for facilities in the same State/Territory and same industry can be reported in aggregate.	The ‘same State, same industry’ rule will be retained. The data is needed to meet the legislated objectives of the NGER Scheme, for example the Clean Energy Regulator must share with state and territory governments NGER information within their jurisdictions. However, in certain circumstances reporters will be provided with the option of reporting single small facilities by reference to a business unit.
6: Reporting about contractors Many reporters find it difficult and costly to collect data from contractors responsible for emissions or energy use at the reporters’ facilities. Collecting information from small contractors can be particularly difficult.	The obligation to collect and report data from all contractors whose activities form part of the emissions or energy from a facility will be retained. However, the threshold changes in response to issues 2 and 3 above will assist with more efficient reporting of contractor activity.

By releasing the draft amendments, the Department is hoping for feedback on the practical operation and application on the amendments and whether they will achieve the Department’s proposed aims of streamlining of the NGER reporting process. Additionally, the Department is hoping to determine the consistency of the amendments with the current requirements of the NGER Scheme.

This is the last consultation before the finalisation of the draft NGER Amendment Regulation which is expected to be in made in June 2013. The Department will accept feedback submissions until 7 June 2013.

References

Department of Industry, Innovation, Climate Change, Science, Research and Tertiary Education, 2013, NGER Reporting Efficiency Streamlining – Reporting under the National Greenhouse and Energy Reporting Scheme, Commonwealth of Australia