Reporting of immaterial amounts NGERs FY14/15

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 typeThreshold per instance of a sourceMeasurement Determination section
Petroleum-based oils and greases (other than used as fuel)5,000 LDivision 2.4.1, section 2.39(a)
Other liquid fuels (not mentioned in s2.39(a))1,000 LDivision 2.4.1, section 2.39(b)
Gaseous fuels1,000 m3Division 2.3.1, section 2.18
Solid Fuels1 tonneDivision 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.”

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. This is because the class of equipment used to perform the activities are different.

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.

About The Author

Matt established Ndevr’s Environmental Consulting division in May 2010 after a career with the Australian Government working on high profile carbon and energy policy reform and implementation. Since 2010, the Melbourne based Environmental Consulting team has grown to a strong national team of policy, legal, engineering and IT professionals specialising in the carbon and energy space. As a professional consultant Matt has provided strategic carbon emissions and energy advice for some of Australia’s largest and most well-respected corporations. Matt also works closely with industry associations and government to analyse and advise on the impacts of carbon and energy legislation. He is one of Australia’s most experienced and highly accredited Registered Greenhouse and Energy Auditors (RGEAs), with Category 1 (Technical and Non-technical), CFI (Technical), Category 2 and Category 3 accreditation from the Australian Government. Matt's RGEA accreditation can be found here. Matt holds a degree in Commerce, a Diploma in Government and is currently completing a Graduate Diploma in Environment, Resource and Energy Law at Melbourne University and guest lectures for Monash University (Carbon Management programs). m: 0406 757 289

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