#9
Corporation submission - Anonymous

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Corporation submission - Anonymous

Automated Transcription

7 What sector are you in?
Other: "Energy and Convenience"

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?: Thresholds are about right
Are the current facility reporting thresholds under the NGER scheme appropriate?:
Thresholds are about right

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

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16 If you responded yes, please provide reasoning why the NGER scheme
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?
Not answered

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?
We believe the effort to collect and assure the data would be significant with limited
benefits.

22 Is there anything else you would like to tell us about the NGER scheme
thresholds or coverage?
Consider lowering the thresholds as carbon reduction takes place to ensure that visibility
remains on large emitters when their emissions reduce below current thresholds

23 Does your organisation or corporation report fugitive emissions to the
NGER scheme?
Not answered

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24 How does your organisation rate the current NGER methods for
reporting fugitive emissions in terms of:
Not answered

25 [Blank question text]
Not answered

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
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?

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Not answered

32 Is there anything else you would like to tell us about methane
measurement, reporting or verification within the NGER scheme?
Not answered

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:
We would like to see more project details/information about ACCUs

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 answered

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?
Not answered

37 What would be an appropriate publication threshold for emissions data
at the facility level?
Consideration should be given to lowering thresholds over time as a means to expand
NGER scheme as we track towards the climate targets.

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 answered

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39 On what basis should NGER reporters be able to have data excluded
from publication?
They should have this option. Facility level data may have commercial value but this
should be assessed on a case by case basis.

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]
Not answered

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? : 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?
The costs associated with auditing and assurance are not insignificant. Additionally, with

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limited auditor community, access to auditors is increasingly difficult. Consider widening
the NGER auditor field to reduce costs, increase knowledge base across community and
reduce risk to auditor community.

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.
Not answered

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?

51 If yes, what is your email address?

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