TranslateFilename
7 What sector are you in?
Other: "Not for profit"
8 Electricity, gas, water and waste services
Not answered
9 Mining
Not answered
10 Manufactuing
Not answered
11 Transport, postal and warehousing
Not answered
12 What do you use to help your organisation or corporation understand
and comply with its reporting requirements under the scheme?
Not answered
13 [Blank question text]
Are the current corporate group reporting thresholds under the NGER scheme
appropriate?: I'm not sure
Are the current facility reporting thresholds under the NGER scheme appropriate?: I'm
not sure
14 Are there any sectors not currently part of the scheme that should be
added?
I'm not sure
15 If so, what?
Not answered
16 If you responded yes, please provide reasoning why the NGER scheme
2 of 8
Collec , manage and analyse surveys and consul a ion da a converlens.com
should be expanded to include additional sectors.
Not answered
17 Currently only constitutional corporations can have obligations under
the NGER scheme. Should the NGER scheme be expanded to other
entities?
I'm not sure
18 Please list any potential benefits or drawbacks you believe may arise
from expanding the NGER scheme to include additional entities.
Not answered
19 Should the NGER scheme be expanded to include scope 3 emissions?
Yes
20 Why should the NGER scheme be expanded to include scope 3
emissions?
For many industrial facilities in Australia, scope 3 emissions represent the majority of
their emissions. However, there is currently very little information available on those
emissions. This greatly limits the ability of investors for example to correctly assess the
risks and opportunities associated with different facilities and companies, and
understand how they vary from one to the other. While a comprehensive reporting of
scope 3 emissions would not make sense, a requirement to report on the most material
sources of scope 3 emissions, especially when they are larger than scope 1 and 2
emissions, would be a good first step. This could be aligned with the mandatory climate-
related financial disclosure guidelines.
21 Why shouldn't the NGER scheme be expanded to include scope 3
emissions?
Not answered
22 Is there anything else you would like to tell us about the NGER scheme
thresholds or coverage?
Not answered
3 of 8
Collec , manage and analyse surveys and consul a ion da a converlens.com
23 Does your organisation or corporation report fugitive emissions to the
NGER scheme?
No
24 How does your organisation rate the current NGER methods for
reporting fugitive emissions in terms of:
Accuracy: Very inaccurate
25 [Blank question text]
Ease of use: Somewhat hardto use
26 Is your organisation currently using top-down measurements for
reconciliation or verification of the fugitive emissions you report under
the NGER scheme?
Not answered
27 Does your organisation intend to use top-down measurements for
reconciliation or verification of source-based measurements in the
future?
Not answered
28 Has your organisation joined the United Nations Environment
Programme (UNEP) Oil and Gas Methane Partnership (OGMP) 2.0?
No
29 Does your organisation intend to join the United Nations Environment
Programme (UNEP) Metcoal Methane Partnership (MMP) when it
launches?
No
30 Does your organisation face any of the following barriers in moving
from Method 1 to higher order methods for measuring fugitive
emissions?
4 of 8
Collec , manage and analyse surveys and consul a ion da a converlens.com
Not answered
31 What changes to the NGER scheme would you suggest to make it easier
or less costly to move from Method 1 to higher order methods?
Not answered
32 Is there anything else you would like to tell us about methane
measurement, reporting or verification within the NGER scheme?
Australia currently relies heavily on emissions intensity factors. The system needs to
move towards a greater use of direct emissions measurements. Several independent
studies estimate that Australia's methane emissions have been greatly underestimated.
The IEA estimates that our coal fugitive emissions are underestimated by about 80% and
our oil and gas emissions by 90%. This is extremely material to Australia's overall
emissions levels (more than 6% of national emissions) and our existing policies - if true it
would double the required rate of emissions reductions for facilities covered by the
safeguard mechanism to stay within agreed limits. Independent studies also suggested
that emissions at particular sites could be orders of magnitude higher than reported.
Uncertainties of this magnitude are problematic for investors who are currently unable to
properly assess the financial risks associated with methane emissions. Direct emissions
measurement would help get more accurate estimates for each site, and would also
support greater mitigation of those emissions. We support the recommendations put
forward by Ember and the Environmental Defense Fund on this issue.
33 [Blank question text]
How well does the current publicly available data meet your data needs?: Does not meet
needs at all
34 Please tell us in a few words the reasons for your response:
Greater transparency in the data reported would be very useful to support accurate
analysis on the financial risks and opportunities faced by different facilities and
organisations due to their emissions. This means both greater disaggregation of data,
better presentation of data and less protection of information for 'commercial in
confidence' reasons. The data should be by default made public, with companies having to
justify why something is commercial in confidence if they do not want it published. We do
not believe that a justification would exist in most cases. Also, a more disaggregated
presentation of the information - at a minimum disaggregating by types of scope 1
emissions (energy, fugitive, process) and if possible by source (emissions associated with
5 of 8
Collec , manage and analyse surveys and consul a ion da a converlens.com
gas use, oil use, coal use, etc) would greatly help understand how facilities compare to
each other and allow more transparent benchmarking between facilities. It would also
help support analysis around the opportunities for further emissions reductions.
Improved presentation, with consistent facility names (eg reference numbers) and
sectoral classification would also help make year to year comparisons and data analysis
easier. It would also be useful to have parent companies listed to help get a better view of
emissions at an organisational level - for large companies at the moment the responsible
emitter is often a department rather than the company/parent.
35 Thinking about the current publication threshold and the impacts of
publishing data on reporting corporations, data users and meeting our
climate targets, what changes would you recommend to government?
I'm not sure
36 Thinking about the current content of the publicly available data and
the impacts of publishing data on reporting corporations, data users
and meeting our climate targets, what changes would you recommend
to government?
Publish emissions data at the facility-level data
Publish emissions by greenhouse gas
Publish time series data
Other: "See comment above"
37 What would be an appropriate publication threshold for emissions data
at the facility level?
Not answered
38 What are your views on the current test for determining whether
NGER data has commercial value in section 25 of the National
Greenhouse and Energy Reporting Act (2007)?
The test needs to more clearly define the characteristics of data that has commercial
value
39 On what basis should NGER reporters be able to have data excluded
from publication?
6 of 8
Collec , manage and analyse surveys and consul a ion da a converlens.com
They should have a strong case that this information is commercial in confidence, which
we believe would be extremely rare.
40 Is there anything else you would like to tell us about publishing data
collected under the NGER legislation?
Not answered
41 [Blank question text]
How satisfied are you with the Department of Climate Change, Energy, the Environment
and Water’s role in maintaining and updating the NGER scheme?: I'm not sure
How satisfied are you with the Clean Energy Regulator’s administration of the NGER
scheme?: I'm not sure
42 Do you have any comments about the work of the Clean Energy
Regulator and the Department of Climate Change, Energy, the
Environment and Water on the NGER scheme?
Not answered
43 [Blank question text]
Not answered
44 Do you have any comments about the Clean Energy Regulator's online
guidance you wish to share?
Not answered
45 [Blank question text]
How would you rate the costs associated with reporting under the scheme? : I'm not sure
46 Do you have any comments you wish to share about the balance the
NGER scheme strikes between costs on businesses of reporting and
achieving the NGER scheme’s statutory duties around reporting
emissions and energy data?
Not answered
7 of 8
Collec , manage and analyse surveys and consul a ion da a converlens.com
47 The effectiveness of the NGER scheme depends on robust and reliable
compliance monitoring and enforcement activities. Auditing is a key
compliance monitoring measure under the National Greenhouse and
Energy Reporting Act 2007 (NGER Act). Information about the Clean
Energy Regulator's audit framework can be viewed here.
In your opinion, how effective is the NGER audit framework in ensuring that reporters are
reporting correctly, completely and are fully compliant with their reporting requirements
under the NGER Act?: Highly ineffective
48 Is there anything you would suggest changing about the audit
framework to make it more effective at ensuring compliance, reducing
the incidence of unnecessary audits or the experience of being audited
less difficult or costly?
In line with my previous comments, several independent analyses suggest that Australia is
currently vastly under-reporting on fugitive methane emissions, which is why we believe
that the verification process is likely highly ineffective at the moment. New technologies
like satellite measurements could for example be used to verify the data provided by
facilities, and identify any anomalities which could be caused by accidental leakages etc.
49 What are your views on the enforcement powers and activities of the
Clean Energy Regulator?
Not answered
50 Would you like to stay up to date on the Climate Change Authority’s
work?
51 If yes, what is your email address?
8 of 8
Collec , manage and analyse surveys and consul a ion da a converlens.com
