Reporting fuel combustion and the associated energy consumption for certain fuel types is optional if the amount consumed is less than the reporting thresholds (See Table 1).
Table 1. Materiality Thresholds
|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|
‘Separate instance of a source’ is defined in section 1.9A of the Measurement Determination as:
“If 2 or more different activities of a facility have the same source of emission, 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.”
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. This is because the class of equipment used to perform the activities are different.
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.
Matt is the Managing Director and provides strategic carbon emissions and energy advice for some of Australia’s largest and most well-respected corporations.