This document assists in measuring and reporting consumption of petroleum based oils and greases under
the National Greenhouse and Energy Reporting Act 2007 (NGER Act).
Petroleum based oils (PBOs) and petroleum based greases (PBGs) used for all purposes, including transport,
should be reported under the NGER legislation. Amendments to the National Greenhouse and Energy
Reporting (Measurement) Determination 2008 (NGER (Measurement) Determination) will be implemented
to reflect this.
Note: In this supplementary guideline references to petroleum based oils (PBOs) mean PBOs (other than
those used as a fuel).
What are petroleum based oils and petroleum based
greases?
PBOs and PBGs are identified as energy commodities under the NGER Regulations and NGER (Measurement)
Determination (Schedule 1). The quantity of PBOs and PBGs consumed at a facility must be measured and,
providing thresholds are met, included in reports submitted under the NGER legislation. Measuring the
quantity of PBOs and PBGs allows the emissions released from the consumption of the fuel to be
determined.
Petroleum based oils are:
a) oils (including lubricants or fluids but not greases) derived from petroleum and their synthetic
equivalents; or
b) oils (including lubricants, fluids and greases) derived from petroleum and their synthetic
equivalents, if recycled for use as oils.
Petroleum based greases are:
a) petroleum based greases and their synthetic equivalents; or
b) oils (including lubricants, fluids and greases) derived from petroleum and their synthetic
equivalents, if recycled for use as greases.
(r 1.03 NGER Regulations)
When are they consumed?
PBOs and PBGs are generally considered consumed when the oil or grease is applied to equipment. Under
regulation 2.23(4), ‘use’ of an energy commodity has occurred, and PBOs and PBGs applied to equipment
must therefore be reported as energy consumed.
Consumption of energy, in relation to a facility, means the use or disposal of energy from the
operation of the facility including own-use and losses in extraction, production and transmission.
(r 2.23 (4) NGER Regulations)
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Reporting PBOs and PBGS consumed without combustion
Under regulation 4.22 energy consumption must be reported where energy is consumed:

by combustion (r 4.22(1)(a));

by a means other than combustion (r 4.22(1)(b); and

to produce a chemical or metal product (r 4.22(2) and (3)).
Fuels consumed by means other than combustion must be included in NGER Report, if the amount;
(i) exceeds the reporting thresholds mentioned in the Measurement Determination for this paragraph;
and,
(ii) is not reported under paragraph (a) or subregulation (2) or (3).
(r 4.22(1)(b) NGER Regulations)
If any energy commodity listed in the NGER (Measurement) Determination or the Regulations is consumed
without combustion, then the thresholds and methodology in section 2.68 of the NGER (Measurement)
Determination apply. It is important to note that this section is only applicable where no combustion of the
fuel takes place.
PBOs or PBGs that are consumed without combustion are to be reported if any of the following reporting
thresholds are met:
(i)
For solid fuels – 20 tonnes; or,
(ii)
For gaseous fuel – 13,000 cubic meters; or,
(iii)
For liquid fuel – 15 kilolitres.
(s 2.68 NGER (Measurement) Determination)
Note: this threshold must be met for every energy commodity (either PBO or PBG) at a single facility.
Reporting PBOS AND PBGS consumed with combustions as
lubricants
Corporations must also include the amount of fuel consumed by means of combustion as lubricants in their
NGER Reports, in accordance with Division 2.4.5A of the NGER (Measurement) Determination. The
methodology provides for adoption of a default oxidation factor of approximately 40 per cent (Method 1
only), or calculation of a specific emission factor (Methods 1, 2, and 3) through amendment of the
Determination for 2009-10.
Combustion, under the NGER legislation, covers both partial and full combustion. Therefore, anything from
slight combustion to full combustion should be reported under Division 2.4.5A of the NGER
(Measurement) Determination. There are no thresholds for reporting combustion of PBOs or PBGs.
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How to determine if combustions has occured
The NGER (Measurement) Determination and the National Greenhouse and Energy Reporting
(Measurement) Technical Guidelines (Technical guidelines) do not specify a methodology for determining
whether combustion of a PBO or PBG occurs during consumption. In determining whether combustion has
occurred, corporations should develop their own methodology consistent with section 1.13 of the NGER
(Measurement) Determination.
Estimates of PBO and PBG combustion must be prepared in accordance with the following principles:
a) transparency – emission estimates must be documented and verifiable;
b) comparability – emission estimates using a particular method and produced by a registered
corporation in an industry sector must be comparable with emission estimates produced by
similar corporations in that industry sector using the same method and consistent with the
emission estimates published by the Department in the National Greenhouse Accounts;
c) accuracy – having regard to the availability of reasonable resources by a registered
corporation and the requirements of this Determination, uncertainties in emission estimates
must be minimised and any estimates must neither be over nor under estimates of the true
values at a 95 per cent confidence level;
d) completeness – all identifiable emission sources within the energy, industrial process and
waste sectors as identified by the National Inventory Report must be accounted for.
(s 1.13 NGER (Measurement) Determination)
Set out below is some general guidance on possible methods for determining whether a PBO or PBG is
consumed with or without combustion. This is provided as an example of methods which may be suitable;
however, it is not intended to be legal advice. Corporations may need to obtain advice (including use of
expert opinion) on the best way to proceed to ensure that the principles of section 1.13 are met in their
particular circumstance.
Reporting based on intended use
In order to determine whether combustion of a PBO or PBG occurs, a corporation may begin by considering
their intended use within a facility. The following four scenarios provide examples of how the intended use
may inform the way in which PBOs and PBGs are reported under the NGER legislation;
Considered to be combusted:

Oil used in engines where oil combustion is intended by design would be reported under Division 2.4.5A
of the Determination as energy consumption by combustion. (e.g. oil used to lubricate internal
combustion engines)

Oil used in engines where oil combustion is not required but usually occurs due to unavoidable design
imperfections and machinery degradation would be reported under Division 2.4.5A of the NGER
(Measurement) Determination as energy consumption by combustion. (e.g. four-stroke engines)

Oil used in other applications for which oil combustion is not required but occurs because operating the
machinery heats the oil to its flashpoint temperature would be reported under Division 2.4.5A of the
NGER (Measurement) Determination as energy consumption by combustion.
Considered to be consumed without combustion:
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
Transmission oil, where oil is not intended for combustion may be reported under section 2.68 of the
NGER (Measurement) Determination, provided the reporting thresholds for PBO within the facility is
met.
Reporting based on flash point
Corporations could also use the concept of flash point to assist in determining if a PBO and PBG are likely to
be consumed without or with combustion. The flash point method assesses the likelihood that combustion
has occurred or not, it does not, however, provide a definitive answer as to whether combustion has
actually occurred. To do this, corporations would need to compare the flash point of a PBO and PBG to the
maximum operational temperature that the PBO and PBG are likely to be exposed to in use at a facility. This
comparison would need to be undertaken for each PBO and PBG product used within a facility and for each
activity that the PBO or PBG is involved in.
The flash point of a fuel or lubricant refers to the lowest temperature at which a product can form a
vapour/air mixture capable of combustion. This is a measureable and testable property of all PBO and PBG
product solids and should be available to all users of PBO and PBGs. The flash point is stated on the Material
Safety Data Sheet (MSDS) of every PBO and PBG product sold. Corporations could also contact the product
manufacturer for information on a fuel’s flash point.
Corporations should have the ability to use manufacturer’s specification or direct measurement to inform
their estimation of the maximum operational temperature that a PBO or PBG is exposed to during an
activity. Corporations may also consider how their particular operating environment may affect the specified
operational temperatures of machinery.
Reporting petroleum bases oil and greases in OSCAR
To report the consumption of PBO and PBG in the Online System for Comprehensive Activity Reporting
(OSCAR), follow the steps outlined below.
Please note, OSCAR only allows for PBO and PBG to be reported in kiloliters (kL), and the Clean Energy
Regulator does not provide conversion factors for PBO or PBG purchased by weight. To convert from weight
to volume, product manufacturers or retailers may be able to provide you with density information, which
can be multiplied by the mass of fuel to determine the volume consumed.
How to enter combusted PBO and PBG from stationary and transport sources
into OSCAR:
1. Select the data entry screen for the facility you wish to add data against. Under the GHG Emissions &
Energy Consumption tab, select Add Source / Activity Data.
2. For Parent Source, select Fuel Combustion/ Energy. For Source, select Other Stationary.
3. Under Available Activity Types select the correct activity type, either item 31 or item 32.
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4. In the GHG Emissions & Energy Consumption tab, select Add activity data next to the activity source. In
this screen you will be able to enter the quantity of PBO or PBG consumed for combustion, as well as the
criteria or measurement and method of calculation. Click Save.
Note: If you wish to delineate stationary and transport uses, use the Description field in OSCAR as per below.
In the GHG Emissions & Energy Consumption tab, select Add activity data. Under the Data Entry
Description input field enter Transport.
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Entering method 1 data when the default emission factor is not used (for
2010-11 onward only)
From the 2009-10 reporting year, corporations can choose to calculate an emission factor for PBO or PBG.
For 2010-11 OSCAR allows a corporation to enter their own emission factor for Method 1. This can be done
as follows:
1. Follow steps 1-3 above. When the activity data has been selected, in the greenhouse gas (GHG)
Emissions & Energy Consumption tab select Add Activity Type Information next to the activity source.
2. The default emission factor will be shown in the Method 1 box.
3. Replace this figure with the new emission factor determined under section 2.48A of the NGER
(Measurement) Determination and click Save. In the below example 20.0 has been entered.
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4. In the GHG Emissions & Energy Consumption tab, select Add activity data next to the activity source. In
this screen you will be able to enter the quantity of PBO or PBG consumed for combustion, as well as the
criteria or measurement and method of calculation. Click Calculate and the calculation will be displayed.
Click Save to save this data entered.
Entering method 1 data when the default emission factor is not used (for
2009-10 only)
From the 2009-10 reporting year, corporations can choose to calculate an emission factor for PBO or PBG,
but OSCAR does not allow a corporation to enter their own emission factor for Method 1 in the 2009-10
reporting functionality. This can be resolved by entering data as follows:
1. Follow steps 1-3 above. When the activity data has been selected, highlight Add Activity Data.
2. In the Data Entry Description input box, enter ‘Method 1 – (any other description you may wish to
add).
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3. After selecting criteria and quantity of fuel combusted, you will have the ability to select the method of
calculation.
4. Here, you will be required to select Method 2 and enter the direct emissions that have been calculated
outside OSCAR. Click Save.
5. Back in the GHG Emissions & Energy Consumption tab, select Add Activity Type Information next to the
activity source.
6. For the CO2 emission factor, add the emission factor calculated under section 2.48A (2) of the NGER
(Measurement) Determination. Click Save (see figure overleaf).
7. All relevant information has now been added into OSCAR.
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Entering PBO or PBG consumed without combustion into OSCAR
1. Select the data entry screen for the facility you wish to add data against. Under the GHG Emissions &
Energy Consumption tab, select Add Source / Activity Data.
2. For Parent Source, select Other Fuel Consumption. For Source, select Energy consumed (not
combusted).
3. Under Available Activity Types, select the correct activity type, either item 31 or item 32.
4. Click Add activity data. In this screen you will be able to enter the quantity of PBO or PBG consumed
without combustion, as well as the criteria or measurement.
Further information
Email: reporting@cleanenergyregulator.gov.au
Phone: 1300 553 542 within Australia
Web: www.cleanenergyregulator.gov.au
The information in this supplementary guideline is provided as guidance only. Controlling corporations are
responsible for applying the NGER legislation to their particular circumstances and organisational structure.
This guideline is not a substitute for independent professional advice.
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