TranslateFilename
7 What sector are you in?
Other: "No sector."
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?: Thresholds are too high
Are the current facility reporting thresholds under the NGER scheme appropriate?:
Thresholds are too high
14 Are there any sectors not currently part of the scheme that should be
added?
Yes
15 If so, what?
Other: "The trigger should be set based on volumes of fossil fuels produced, processed or
used, regardless of the type of corporate entity that does the producing, processing or
use. "
2 of 8
Collec , manage and analyse surveys and consul a ion da a converlens.com
16 If you responded yes, please provide reasoning why the NGER scheme
should be expanded to include additional sectors.
Fossil fuels have caused the climate emergency, so regulation, including reporting, needs
to be inclusive of all large fossil fuel users, processors and producers, regardless of what
sectors they are in.
17 Currently only constitutional corporations can have obligations under
the NGER scheme. Should the NGER scheme be expanded to other
entities?
All not-for-profit
All government
Government managed waste facilities
Charities
Other: "All users (producers & processors) of fossil fuels above trigger thresholds should
be included."
18 Please list any potential benefits or drawbacks you believe may arise
from expanding the NGER scheme to include additional entities.
We will know who the largest users (& producers etc) of fossil fuels are. We can't develop
policies for a just transition away from fossil fuels if we don't know who the largest users
are.
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?
The inclusion of Scope 3 emissions needs to be limited to entities which sell fossil fuels
and to the scope 3 emissions from their sales. The requirement should be to individually
list purchasers above a threshold and to then list the rest as sector and geographical
totals. The purpose of this reporting is for compliance certainty, so that all larger fossil
fuel users will be discovered.
21 Why shouldn't the NGER scheme be expanded to include scope 3
emissions?
3 of 8
Collec , manage and analyse surveys and consul a ion da a converlens.com
Not answered
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?
Not answered
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: Very easy to 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?
Not answered
29 Does your organisation intend to join the United Nations Environment
Programme (UNEP) Metcoal Methane Partnership (MMP) when it
4 of 8
Collec , manage and analyse surveys and consul a ion da a converlens.com
launches?
Not answered
30 Does your organisation face any of the following barriers in moving
from Method 1 to higher order methods for measuring fugitive
emissions?
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?
There is too much estimation in the scheme methods! A program of moving towards a
fully measured system needs to be in place. There are numerous reports of
measurements of fugitive methane emissions that found much higher emissions than
previously estimated, and I do not recall a single example where the measured emissions
were lower than the reported ones. Measurements need to be periodically independently
verified, and perhaps this is role for the State EPAs.
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:
I am focussed on who the largest users of fossil fuels are, broken down by fuel, and the
current data does not provide that information.
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?
The publication threshold should be decreased
5 of 8
Collec , manage and analyse surveys and consul a ion da a converlens.com
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 estimation methods
Publish emissions by greenhouse gas
Publish time series data
Other: "Publish emissions from fossil fuels by fuels as well. Methane emissions should be
published using the GWP20 value for methane as well as the GWP100 value."
37 What would be an appropriate publication threshold for emissions data
at the facility level?
This is hard to answer in the absence of data on the statistical distribution of emissions!
My suggestion is to start by halving all the reporting thresholds and to review the
thresholds in a few years. Because it is imperative that we phase out fossil fuel use,
reporting thresholds for fossil fuel use need to reduce towards zero over time as the fuel
use is reduced. Publishing the future time course of reporting threshold reductions will
provide an incentive for emissions reduction.
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)?
Other: "Only reporters who have their own atmosphere to pollute - not shared with any
other life - can be allowed to have their emissions confidential."
39 On what basis should NGER reporters be able to have data excluded
from publication?
See above for one way of expressing this very important matter. Put simply, emitting
greenhouse gases does harm, and the current arrangements allow those entities who do
that harm to hide behind the commercial value/trade secret provisions. It is a matter of
simple ethics that all entities who pollute our shared atmosphere should be able to be
held publicly accountable for their pollution. Therefore, no entities whose emissions
exceed the thresholds should be able to have their data excluded. If they don't want to
report their emissions, they should have to reduce them to below the current thresholds
to escape public scrutiny.
6 of 8
Collec , manage and analyse surveys and consul a ion da a converlens.com
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?
I worry about the potential for the Clean Energy Regulator to be captured by the entities
it regulates. I would like to see the CCA - with help of the NACC - review governance
arrangements for the CER to make it as immune from regulatory capture as possible.
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?
If possible, the costs should scale with emissions, so the higher the emissions, the more it
costs to report them. One option would be to have a much simpler scheme for smaller
entities. For example, if the thresholds for the full scheme are halved - as recommended
7 of 8
Collec , manage and analyse surveys and consul a ion da a converlens.com
above - the simpler scheme could start under those new thresholds and continue down to
another half. The simpler scheme could consist of just reporting fossil fuel use in the units
used for trade - no formulae or conversions required. However, this data must also be
public, no exceptions.
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?: I'm not sure
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?
See above comments about the need to minimise the possibility of regulatory capture.
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
