Who needs to report?
Reporting refrigerants under the National Greenhouse and Energy Reporting (NGER) Scheme is a quirky and sometimes confusing process. Not sure if you should be reporting your refrigerants? Not sure how to report refrigerants?
Keep reading to find out what you need to know. Reporting of refrigerants is only required for facilities which falls under specific ANZIC codes – these are:
- Food product manufacturing services (ANZIC classification, Subdivision 11)
- Beverage and tobacco product manufacturing (ANZIC classification, Subdivision 12)
- Retail trade (ANZIC classification, Division G)
- Warehousing and storage services (ANZIC classification, number 530)
- Wholesale trade (ANZIC classification, Division F)
- Rental, hiring and real estate services (ANZIC classification, Division L)
What to report
Refrigerant plant needs to be reported if it meets the following criteria:
- Has a gas charge of greater than 100 kg
- Includes a hydroflurocarbon gas listed in subsection 7A(2) of the NGER Act, and that gas has a global warming potential greater than 1000.
How to report
You can report on emissions from refrigerants either as incidental emissions, or using the methods described in the NGER Measurement Determination 2008 (the NGER Determination).
If you would like to report your refrigerants as incidentals, both the facility and the refrigerant plant, will need to meet threshold criteria for reporting incidentals. Reporting of incidentals also needs to adhere to the general principles for measuring emissions laid out in section 1.13 of the NGER Determination. This means that if you choose to report refrigerants as incidentals, the emissions report still need to be transparent, comparable, accurate and complete. Furthermore you cannot report refrigerants as incidentals if you are required to collect the information for other legislative purposes.
To report using methods 1 listed in the NGER Determination you will need to collect information about your refrigerant plant. Specifically, you will need to know:
- The type of cooling the plant is used for (air conditioning, commercial refrigeration, or industrial refrigeration),
- The type of refrigerant gas is used in the plant, and
- The gas charge of the plant.
This information can usually be found either on the plant name plate, or in maintenance records.
Figure 1 below, shows a flow chart for identifying when and how to report your refrigerants.
There are a few catches to refrigerant reporting which may trip-up the unwary.
Firstly refrigerants may be made up of a mix of gases. In such cases it may not be immediately apparent that the refrigerant needs to be reported. It is important to check the refrigerant specifications to confirm whether it contains a reportable gas.
The requirement to report plant that uses a mix of gases is based on the entire gas charge of the plant, not just the reportable component. If the gas charge of the plant is above 100 kg you must report – it doesn’t matter if the reportable component of the gas mixture is only a small portion of the total.
However, if reporting using method 1, the calculation of emissions does account for the proportion of the gas mix which is reportable. The total quantity of emissions or as known in the NGER Determinations as the Stock value, reflect the proportion of the total gas that is made up of reportable gas(es) by the individual global warming potential of those gas(es). To calculate the volume of emissions that is reportable, the stock value is multiplied by a leakage factor as per 4.102 of the NGERs Determinations.
Lastly, it is important to note that the refrigerant gases used in your plant may change over time. Under the Montreal Protocol some types of refrigerant gases are being gradually phased out, and new ones introduced. The gas used in your refrigerant plant may be changed during servicing or maintenance, and this change will result in a change in to your emissions. Hence, what was reported last year, may not be true this year.
For help on reporting your refrigerants, or assistance in complying with your NGER requirements, contact Claire Bright or Ndevr Environmental on (03) 9865-1400.
Matt is the Managing Director and provides strategic carbon emissions and energy advice for some of Australia’s largest and most well-respected corporations.