NGER Scheme Survey

NGER Scheme Survey
NGER scheme survey
Climate Change Authority

Response received at:
14 September 2023, 12:55am

Response ID:

1 I have read and understood the Privacy Collection Statement and
Consent.
Yes

2 How do you want your survey response to be treated?
Public and anonymous

3 If the Climate Change Authority needs to contact you about your
survey response, please provide an email address that we can use to get
in touch:

4 Who are you participating on behalf of?
A corporation

5 What is the name of your organisation or corporation?

6 Is your organisation or corporation required to report under the NGER
scheme?
Yes

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7 What sector are you in?
Electricity, gas, water and waste services

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?
The National Greenhouse and Energy Reporting Act 2007
The National Greenhouse and Energy Reporting (Measurement) Determination 2008
The National Greenhouse and Energy Reporting Regulations 2008

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?
Yes

15 If so, what?
Agriculture

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16 If you responded yes, please provide reasoning why the NGER scheme
should be expanded to include additional sectors.
Australia has signed up to the Global Methane Pledge, agriculture is a significant source
of methane for Australia and therefore should be included as part of the sectoral
breakdown of achieving the GMP goal of a 30% reduction in methane emissions by 2030.

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?
No

20 Why should the NGER scheme be expanded to include scope 3
emissions?
Not answered

21 Why shouldn't the NGER scheme be expanded to include scope 3
emissions?
Valeu chain emissions reporting is not currently robust enough, also risk of double-
counting emissions as Scope 3 is another corporations Scope 1 or 2.

22 Is there anything else you would like to tell us about the NGER scheme
thresholds or coverage?
Not answered

23 Does your organisation or corporation report fugitive emissions to the
NGER scheme?

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Yes

24 How does your organisation rate the current NGER methods for
reporting fugitive emissions in terms of:
Accuracy: Somewhat inaccurate

25 [Blank question text]
Ease of use: Not relevant

26 Is your organisation currently using top-down measurements for
reconciliation or verification of the fugitive emissions you report under
the NGER scheme?
Intend on using these in the future

27 Does your organisation intend to use top-down measurements for
reconciliation or verification of source-based measurements in the
future?
Yes, in the next 1-2 years

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?
I'm not sure

30 Does your organisation face any of the following barriers in moving
from Method 1 to higher order methods for measuring fugitive
emissions?
Technology
High costs

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Lack of trained employees
Lack of access to measurement instrumentation or services

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?
NGER scheme should allow for reporting site-based methane measurements under
Method 3 for gas pipelines and distribution.

32 Is there anything else you would like to tell us about methane
measurement, reporting or verification within the NGER scheme?
Tax reduction or carbon credits should be made available to companies who reduce
methane emissions (using site-based measurements) ahead of the glide path to achieve
the Global Methane Pledge 30% reduction. And/or funding should be made available to
support methane reduction initiatives.

33 [Blank question text]
How well does the current publicly available data meet your data needs?: Partially meets
needs

34 Please tell us in a few words the reasons for your response:
Not answered

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?
Not relevant

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?
I have no changes to recommend

37 What would be an appropriate publication threshold for emissions data

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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)?
Not relevant

39 On what basis should NGER reporters be able to have data excluded
from publication?
Not answered

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?: Somewhat satisfied
How satisfied are you with the Clean Energy Regulator’s administration of the NGER
scheme?: Somewhat satisfied

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]
How helpful do you find the Clean Energy Regulator’s guidance provided on its website
and through other channels, such as by phone and email, in ensuring you correctly report
under the NGER scheme?: Somewhat helpful

44 Do you have any comments about the Clean Energy Regulator's online
guidance you wish to share?

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Not answered

45 [Blank question text]
How would you rate the costs associated with reporting under the scheme? : Somewhat
significant administrative burden for businesses

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

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?: Moderately effective

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?
Not answered

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?

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51 If yes, what is your email address?

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