Consultation Draft
National Greenhouse and Energy
Reporting (Measurement) Amendment
Determination 2015 (No 1)
Departmental Commentary
December 2014
1
© Commonwealth of Australia, 2014.
National Greenhouse and Energy Reporting (Measurement) Amendment
Determination 2015 (No 1) Departmental Commentary is licensed by the
Commonwealth of Australia for use under a Creative Commons By Attribution 3.0
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This report should be attributed as ‘National Greenhouse and Energy Reporting
(Measurement) Amendment Determination 2015 (No 1) Departmental Commentary.
The Commonwealth of Australia has made all reasonable efforts to identify content
supplied by third parties using the following format ‘© Copyright, [name of third party].
Disclaimer The views and opinions expressed in this publication are those of the
authors and do not necessarily reflect those of the Australian Government or the
Minister for the Environment.
2
CONTENTS
Purpose.................................................................................................................... 4
Information for respondents - NGER (Measurement) Amendment Determination
2015 (No.1) (Attachment A) ..................................................................................... 5
Submissions .......................................................................................................... 5
Overview of the NGER (Measurement) Determination 2008 ................................. 6
Attachment A: Explanation of the NGER (Measurement) Amendment
Determination 2015 (No. 1) ..................................................................................... 8
Schedule 1— Amendments relating to adoption of IPCC 2006 Global Warming
Potential Values and Oxidation Factors ................................................................ 9
Chapter 1: General ............................................................................................. 10
Part 1.1A Potential greenhouse gas emission embodied in an amount of
natural gas ...................................................................................................... 10
Part 1.1B Potential greenhouse gas emission embodied in an amount of
gaseous designated fuel................................................................................ 10
Part 1.1A Potential greenhouse gas emission embodied in an amount of
liquid designated fuel .................................................................................... 10
Part 2.2 Emissions released from the combustion of solid fuels ............... 10
Part 2.3 Emissions released from the combustion of gaseous fuels ......... 10
Part 2.4 Emissions released from the combustion of liquid fuels .............. 11
Chapter 3: Fugitive Emissions.......................................................................... 11
Part 3.2 Coal mining – fugitive emissions .................................................... 11
Part 3.3 Oil and natural gas – fugitive emissions......................................... 12
Chapter 4: Industrial Processes emissions ..................................................... 13
Part 4.3 Industrial processes – chemical industry ....................................... 13
Part 4.4 Industrial processes – metal industry ............................................. 13
Chapter 5: Waste ............................................................................................... 14
Part 5.2 Solid waste disposal in land ............................................................ 14
Part 5.3 Wastewater handling (domestic and commercial) ......................... 14
Part 5.4 Wastewater handling (Industrial) .................................................... 15
Schedule 2 Energy content factors and emission factors .......................... 16
Schedule 3 Carbon conent factors ............................................................... 16
Schedule 2— Amendments relating to carbon capture and storage ................. 17
Part 3.4 – Carbon Capture and Storage – Fugitive Emissions .................... 17
3
PURPOSE
The National Greenhouse and Energy Reporting (NGER) system is a national
system for reporting greenhouse gas emissions, energy consumption and energy
production by Australian corporations.
The NGER Measurement Determination 2008 was made under subsection 10(3) of
the National Greenhouse and Energy Reporting Act 2007, which provides for the
Minister to determine methods for the measurement and estimation of these data.
This document has been prepared by the Department of the Environment and
outlines proposed amendments to the NGER Measurement Determination 2008.
They are designed to align NGERS reporting with Australia’s international reporting
obligation, provide additional flexibility for reporters and to improve the consistency,
cost effectiveness and accuracy of the methods available to estimate emissions.
The draft amendments contained in the NGER Measurement Amendment
Determination 2015 (No.1) are restricted in scope.
Amendments are designed to improve the methods available for particular emission
processes, with:

Updates to emissions factors for the combustion of fuel, by incorporating the
updated Global Warming Potentials (GWPs) adopted by the Parties to the UN
Framework Convention on Climate Change and its Kyoto Protocol, and
reflecting GWP values contained in the Fourth Assessment Report of the
Intergovernmental Panel on Climate Change (IPCC);

Provision of additional methods for the estimation of emissions from Carbon
Capture and Storage operations;

Removal of guidance for the estimation of potential emissions from natural
gas, and legacy waste for landfills - reflecting the repeal of the Clean Energy
Act 2011;

Support for the Government’s introduction of the Emissions Reduction Fund;
and

Responses to feedback from stakeholders.
In addition, there have been some minor corrections of previous drafting errors.
Details of the proposed amendments to the Determination are set out in
Attachment A.
In making these draft amendments publicly available the Department seeks views on
their practical operation and application.
4
This consultation will inform the finalisation of a National Greenhouse and Energy
Reporting Measurement Amendment Determination 2015 (No.1) which will be a
legislative instrument for the purposes of the Legislative Instruments Act 2003
(Cwlth).
Schedule 1 and 2 of this Amendment Determination are intended to commence on
1 July 2015 and apply to the 2015-2016 financial year. The amendments would affect
NGER reports to be submitted by corporations in October 2016.
INFORMATION FOR RESPONDENTS - NGER (MEASUREMENT) AMENDMENT
DETERMINATION 2015 (NO.1) (ATTACHMENT A)
17 December 2014
Consultation draft available on the Department of the
Environment’s website
30 January 2015
Submissions on the consultation draft close (Attachment A)
13 Febuary 2015
NGER Measurement Amendment Determination 2015 (No.1)
scheduled for lodgement
Submissions
Submissions are invited from all interested stakeholders. Where possible,
submissions should be lodged electronically to the email address below.
Submissions will not be treated as confidential and may be made publicly
available. If a stakeholder wishes their submission (or extracts of a submission) to be
kept confidential, this should be indicated in the submission.
Submissions should be sent to:
Email: nationalgreenhouseaccounts@environment.gov.au
Copies of this paper are available on the Department’s website at:
http://www.environment.gov.au/en/government/submissions.
5
OVERVIEW OF THE NGER (MEASUREMENT) DETERMINATION 2008
The legislative framework for the National Greenhouse and Energy Reporting system
is established by the National Greenhouse and Energy Reporting Act 2007.
The Act makes reporting mandatory for corporations whose energy production,
energy use, or greenhouse gas emissions meet certain specified thresholds.
The NGER Measurement Determination 2008 provides the methods for the
estimation of greenhouse gas emissions and for the production and consumption of
energy.
The scope of the Determination follows international classification systems including:

fuel combustion – emissions from the combustion of fuel for energy
(chapter 2);

fugitive emissions from the extraction, production, flaring, processing and
distribution of fossil fuels and carbon capture and storage (chapter 3);

industrial process emissions where a mineral, chemical or metal product is
formed using a chemical reaction that generates greenhouse gases as a
by-product and emissions of hydrofluorocarbons and sulphur hexafluoride
resulting from their use by certain industries (chapter 4); and

emissions from waste disposal – either in landfill, as management of
wastewater or from waste incineration (chapter 5).
The most significant source of emissions in Australia is from fuel combustion, which
accounts for over 60 per cent of the emissions reported in the national greenhouse
gas inventory.
The scope of the Determination does not include land based emissions covered by
the IPCC categories ‘Agriculture’ and ‘Land Use, Land Use Change and Forestry’.
Emissions from fuel combustion by land based industries are, nonetheless, covered
by this Determination.
Methods of measurement
The framework supporting the emissions estimation methods specified in the
Determination reflects the approaches of the IPCC guidelines governing the
estimation of national greenhouse gas inventories.
The Determination provides four different classes of methods for the estimation of
emissions for most emissions sources.
6
NGER Method 1: is the National Greenhouse Accounts default method and specifies
the use of default emission factors in the estimation of emissions. This is the
simplest method available and, in general, emissions may be estimated by reference
to activity data such as fossil fuel consumption, evidenced by invoices, and the use of
specified emission factors provided in the Determination.
NGER Method 2: is a facility-specific method using industry sampling and Australian
or international standards to provide more accurate estimates of emissions at facility
level. Method 2 enables corporations to undertake additional measurements – for
example, the qualities of fuels consumed at a particular facility – in order to gain
more accurate estimates for emissions for that particular facility.
NGER Method 3: is a facility-specific method using Australian or international
standards for both sampling and analysis of fuels and raw materials. Method 3 is very
similar to Method 2, except that reporters must use Australian or equivalent
documentary standards for sampling (of fuels or raw materials) as well as for the
analysis of fuels.
NGER Method 4: direct monitoring of emission systems, either on a continuous or
periodic basis. Rather than providing for the analysis of the chemical properties of
inputs (or in some case, products), Method 4 aims to directly monitor greenhouse
gas emissions arising from an activity. This approach can provide a higher level of
accuracy in certain circumstances, depending on the type of emissions process;
however, it is more likely to be more data intensive than other approaches.
As for Methods 2 and 3, there is a substantial body of documented procedures on
monitoring practices and state and territory government regulatory experience that
provide the principal sources of guidance for the establishment of such systems.
More generally, the NGER Measurement Determination draws on existing estimation
practices wherever possible, including the use of data collected for commercial,
taxation or other regulatory purposes, with the aim of maximising the use of readily
validated data and minimising administrative burdens on reporters.
7
ATTACHMENT A: EXPLANATION OF THE NGER (MEASUREMENT)
AMENDMENT DETERMINATION 2015 (NO. 1)
The draft National Greenhouse and Energy Reporting Measurement Amendment
Determination 2015 (No.1) would amend the National Greenhouse and Energy
Reporting Measurement Determination 2008.
The following pages set out the amendment items and provide additional information
to assist stakeholders in understanding them and to provide their views.
Item 1 – Name of Determination
This item provides that the title of the Instrument is the National Greenhouse and
Energy Reporting (Measurement) Amendment Determination 2015 (No.1).
Item 2 – Commencement
This item provides for the amendments in Schedule 1 to commence on 1 July 2015.
Item 3 – Authority
This item outlines that the Determination falls under the National Greenhouse and
Energy Reporting Act 2007.
Item 4 – Schedule(s)
The draft amendments to the Determination are outlined at Schedule 1.
Schedule 1 Amendments
The explanations of amendments provided below are grouped by division within the
Determination. Individual amendment items are referenced to the amendment
number as stated in the draft NGER (Measurement) Amendment Determination 2015
(No.1).
8
SCHEDULE 1— AMENDMENTS RELATING TO ADOPTION OF IPCC 2006
GLOBAL WARMING POTENTIAL VALUES AND OXIDATION FACTORS
COMMENCING 1 JULY 2015
The explanations of amendments provided below are grouped by part and division
within the Instrument. Individual amendment items are referenced to the amendment
number as stated in the Instrument.
Schedule 1 provides amendments to update the National Greenhouse and Energy
Reporting (Measurement) Amendment Determination to reflect the use of updated
Global Warming Potentials (GWPs) from the IPCC Fourth Assessment Report,
adopted by the Parties to the UN Framework Convention on Climate Change
(UNFCCC) and its Kyoto Protocol.
Internationally, the Australian Government will report on emissions utilising the
updated GWPs for the first time in the submission of the National Inventory Report
due in April 2015. For that submission, the 2006 IPCC Guidelines for the preparation
of national greenhouse gas inventories (IPCC 2006) will become mandatory for
Annex 1 countries and, in accordance with these rules, updated GWPs will be used.
The GWPs used to convert raw gases into carbon dioxide equivalent values have
been revised. The GWP for methane increases from 21 to 25, and the GWP for
nitrous oxide decreases from 310 to 298.
Additionally, IPCC 2006 mandates the application of 100% Oxidation Factors.
NGERS will be updated to reflect this requirement, which will result in minor
increases in CO2 emission factors.
These updates ensure NGERS is consistent with the IPCC 2006 and will adequately
support Australia’s international reporting obligations.
The proposed amendments will support the implementation of the Emissions
Reduction Fund, providing the latest internationally agreed GWP for the calculation
and verification of emissions reduction from different activities. The amendment will
also support the Government’s deregulation agenda - reducing administrative
burdens and enhancing flexibility for company reporters.
These amendments are intended to commence on 1 July 2015 and apply to the
2015-2016 financial year. The amendments would affect NGER reports to be
submitted by corporations in October 2016.
9
Chapter 1: General
Part 1.1A Potential greenhouse gas emission embodied in an amount of natural
gas
Part 1.1B Potential greenhouse gas emission embodied in an amount of
gaseous designated fuel
Part 1.1A Potential greenhouse gas emission embodied in an amount of liquid
designated fuel
Item
NGER
Commentary
(Measurement)
Determination
Reference
1
1.4(3)
1.4(4)
1.4(5)
Removes guidance for determining the method of
measurement for estimating potential emissions,
complementing the repeal of the Clean Energy Act
2011.
2
Part 1.1A
Part 1.1B
Part 1.1C
Provisions for the derivation of potential emissions
under the Clean Energy Act 2011 are repealed.
Part 2.2 Emissions released from the combustion of solid fuels
Part 2.2 updates Oxidation Factors provided as part of methodologies.
Item
NGER
Commentary
(Measurement)
Determination
Reference
3
2.5 (3)
References to Oxidation Factor changed to 100%
oxidation, in accordance with IPCC 2006 inventory
guidelines.
Part 2.3 Emissions released from the combustion of gaseous fuels
Part 2.3 updates Global Warming Potential (GWP) values and adjusts non-CO2
emission factors provided as part of methodologies.
10
Item
NGER
Commentary
(Measurement)
Determination
Reference
4
2.22 (1)
References to Oxidation Factor changed to 100%
oxidation, in accordance with IPCC 2006 inventory
guidelines.
Part 2.4 Emissions released from the combustion of liquid fuels
Part 2.4 updates Oxidation Factors provided as part of methodologies.
Item
NGER
Commentary
(Measurement)
Determination
Reference
5
2.43 (1)
References to Oxidation Factor changed to 100%
oxidation, in accordance with IPCC 2006 inventory
guidelines.
Chapter 3: Fugitive Emissions
Part 3.2 Coal mining – fugitive emissions
Part 3.2 updates GWP values and adjusts non-CO2 emission factors provided as part
of methodologies.
Item
NGER
Commentary
(Measurement)
Determination
Reference
6, 7, 8
3.5
Methane emission factors for gassy and non-gassy
mines updated for IPCC Fourth Assessment Report
(AR4) GWPs.
9
3.6 (1)
GWP for methane provided for equation updated
from 21 to 25 for IPCC AR4 GWP.
10, 11
3.14
3.15
3.15A
Definition of OF changed from correction factor to a
destruction efficiency. This reflects the change to
100% oxidation factors under IPCC 2006 inventory
guidelines, and clarifies the use of the 0.98
11
Item
NGER
Commentary
(Measurement)
Determination
Reference
destruction efficiency factor.
12
3.17(2)
Methane emission factors for run-of-mine coal
extracted from the mine updated for IPCC AR4
GWPs.
13
3.20
State based methane emission factors for
run-of-mine coal extracted from the mine updated
for IPCC AR4 GWPs.
14
3.21(1)
GWP for methane provided for equation updated
from 21 to 25 for IPCC AR4 GWP.
Part 3.3 Oil and natural gas – fugitive emissions
Part 3.3 updates GWPs and adjusts non-CO2 emission factors provided as part of
methodologies.
Item
NGER
Commentary
(Measurement)
Determination
Reference
15, 16
3.44 (2)
Methane emission factors for emission factor for gas
type updated for IPCC AR4 GWPs.
17, 23, 27,
33
3.45 (1)
3.53 (1)
3.68
3.86
Definition of OF changed from correction factor to a
destruction efficiency. This reflects the change to
100% oxidation factors under IPCC 2006 inventory
guidelines, and clarifies the use of `the 0.98
destruction efficiency factor.
18
3.46B (1)
3.46B (4)
GWP for methane provided for equation updated
from 21 to 25 for IPCC AR4 GWP.
19, 20, 21,
22, 24, 25,
28, 29, 30,
31
3.49 (1)
3.49 (2)
3.52 (2)
3.59
3.63
Methane emission factors for emission factors
updated for IPCC AR4 GWPs.
12
Item
NGER
Commentary
(Measurement)
Determination
Reference
3.72 (2)
3.76
32
3.80 (3)
State based unaccounted for gas factors and natural
gas composition factor updated for IPCC AR4
GWPs.
Chapter 4: Industrial Processes emissions
Part 4.3 Industrial processes – chemical industry
Part 4.3 updates GWPs and adjusts non-CO2 emission factors provided as part of
methodologies.
Item
NGER
Commentary
(Measurement)
Determination
Reference
34, 35, 36
4.47 (2)
Nitrous oxide emission factor nitric acid production
updated for IPCC AR4 GWPs.
Part 4.4 Industrial processes – metal industry
Part 4.3 updates GWPs and adjusts non-CO2 emission factors provided as part of
methodologies.
Item
NGER
Commentary
(Measurement)
Determination
Reference
37
4.85
Tetrafluoromethane emission factor updated for
IPCC AR4 GWPs.
38
4.89
Hexafluoroethane emission factor updated for IPCC
AR4 GWPs.
13
Chapter 5: Waste
Part 5.2 Solid waste disposal in land
Part 5.2 updates GWPs and adjusts non-CO2 emission factors provided as part of
methodologies.
Item
NGER
Commentary
(Measurement)
Determination
Reference
39, 40, 41,
42, 43, 44,
45, 46
5.4(1)
5.4(3)
5.4B(3)
5.4D
5.13(2)(c)
5.15(1)
5.15(4)
5.15A(3)
GWP for methane provided for equation updated
from 21 to 25 for IPCC AR4 GWP.
47
5.15A (3) note
(c)
Collection efficiency calculation reference updated.
50
5.22(2)
Methane and nitrous oxide emission factors for
biological treatment updated for IPCC AR4 GWPs.
48, 49, 51
5.17AA (note 3)
5.17L (note)
5.22A – 5.22L
Provisions supporting the estimation of legacy waste
for supporting emissions estimation under the Clean
Energy Act 2011 repealed.
Part 5.3 Wastewater handling (domestic and commercial)
Part 5.3 updates GWPs and adjusts non-CO2 emission factors provided as part of
methodologies.
Item
NGER
Commentary
(Measurement)
Determination
Reference
52, 54
5.25 (1)
5.25 (3)
5.26 (1)
GWP for methane provided for equation updated
from 21 to 25 for IPCC AR4 GWP.
14
Item
NGER
Commentary
(Measurement)
Determination
Reference
53, 55
5.25 (5)
5.26 (2)
Default methane emission factors for wastewater
and sludge provided for equation updated for IPCC
AR4 GWP.
56
5.31(7)
Default nitrous oxide emission factors for
wastewater discharged into aquatic environments
provided for equation updated for IPCC AR4 GWP.
Part 5.4 Wastewater handling (Industrial)
Part 5.4 updates GWPs and adjusts non-CO2 emission factors provided as part of
methodologies.
Item
NGER
Commentary
(Measurement)
Determination
Reference
57
5.42 (1)
5.42 (3)
GWP for methane provided for equation updated
from 21 to 25 for IPCC AR4 GWP.
58
5.42 (6)
5.42 (7)
Default methane emission factors for the treatment
of sludge by the plant provided for equation updated
for IPCC AR4 GWP.
15
Schedule 2 Energy content factors and emission factors
Schedule 2 provides energy content factors and emission factors for the combustion
of fuels.
Item
NGER
Commentary
(Measurement)
Determination
Reference
59 – 64
Part 1, 2, 3,
and 4
Updates emissions factors for the combustion of
fuel.
Updates incorporate updated IPCC AR4 GWPs, and
updates based on most recent emissions estimates
contained in the National Greenhouse Accounts.
Schedule 3 Carbon conent factors
Schedule 3 provides the carbon content factors of fuels.
Item
NGER
Commentary
(Measurement)
Determination
Reference
65 - 68
Part 2 and 3
Updates are based on most recent emissions
estimates contained in the National Greenhouse
Accounts.
16
SCHEDULE 2— AMENDMENTS RELATING TO CARBON CAPTURE AND
STORAGE
COMMENCING 1 JULY 2015
Schedule 2 provides amendments to complete NGERS guidance for the estimation
of fugitive emissions from Carbon Capture and Storage (CCS) operations.
Part 3.4 – Carbon Capture and Storage – Fugitive Emissions
Part 3.4 provides high level principles based approaches for the estimation of fugitive
emissions from CCS operations.
Due to the evolving nature of CCS in Australia, NGERS guidance for the estimation
of fugitive emissions from CCS operations methods is high level and generic.
It is recognised that industry best practice should be applied to estimating fugitive
emissions wherever possible, and that no additional regulatory burden be imposed.
Existing data produced for monitoring, reporting and verification (MRV) regimes and
approvals already in place under state and commonwealth CCS legislative
instruments should be utilised wherever possible to meet NGERS reporting
obligations, and applied to a high level “carbon accounting” approach. It is not, for
example, proposed that MRV activities be used to directly measure fugitive
emissions from storage formations.
Additional detailed guidance on the interpretation and application of CCS methods
will also be provided in an updated Technical Guidelines. This will include examples
and further assist reporters to understand how the NGERS methods are applied to
their unique CCS operations.
Stakeholder feedback in response to proposed amendments released in May 2014
(as part of the Exposure Draft process for the NGER (Measurement) Amendment
Determination 2014) has been incorporated where appropriate, with the department
proposing minor refinements to existing methods for estimating fugitive emissions
from the capture and transport components of CCS operations.
These include the adoption of the term “greenhouse gas substance”, aligning the
determination with existing commonwealth and state legislative instruments for
licensing CCS operations.
These amendments are intended to commence on 1 July 2015 and apply to the
2015-2016 financial year. The amendments would affect NGER reports to be
submitted by corporations in October 2016.
17
Item
NGER
Commentary
(Measurement)
Determination
Reference
1
1.8
Provides definition for “greenhouse gas substance”,
aligning the definition with the Offshore Petroleum
and Greenhouse Gas Storage Act 2006, and with
state based CCS legislative instruments.
2 – 44, 46 –
49, 51 - 66
1.11
1.19A
1.19B
1.19B(1)
1.19B(1)(a)
1.19B(1)(b)
1.19B(2)(a)
1.19(2)(a)(i)
1.19B(2)(a)(ii)
1.19B(2)(a)(iii)
1.19B(2)(b)
1.19B(2)(b)(i)
1.19B(2)(b)(ii)
1.19B(2)(b)(iii)
1.19B(3)
1.19C
1.19C(a)
1.19C(b)
1.19D
1.19E
1.19E(1)
1.19E(2)
1.19E(2)(a)
1.19E(2)(b)
1.19E(3)
1.19E(4)
1.19E(5)
1.19E(6)
1.19E(6)
1.19F
1.19F(1)
1.19G
1.19H
1.19H(1)
1.19H(2)
1.19I
1.19I(2)
1.19I(3)
Adoption of term “greenhouse gas substance” in
place of “carbon dioxide”. Recognises that the CCS
stream will routinely include trace amounts of other
greenhouse gases such as methane.
18
Item
NGER
Commentary
(Measurement)
Determination
Reference
Division 3.4.2
(heading)
3.89
3.90(1)
3.90(2)
3.90(3),
subdivision
3.4.2.2
(heading)
3.91
subdivision
3.4.2.2
(heading)
3.92
45, 50
1.19GA
1.19N
BBB provision for the use of industry best practice
moved.
67
3.93
3.94
Provides methods for the injection of “greenhouse
gas substances”.
3.95
Provides for the use of methods from Section 5.7.1
of the API Compendium for the estimation of fugitive
emissions from deliberate releases associated
during the injection component of CCS.
3.96
3.97
Provides methods based on for the estimation of
fugitive emissions (other than deliberate releases
from process vents, system upsets and accidents)
associated during the injection component of CCS.
Mirrors existing provisions for natural gas production
where carbon dioxide is often injected into reservoirs
as part of the normal operational practice of gas
extraction.
3.98
3.99
3.100
Provides additional high level principles based
approaches for the estimation of fugitive emissions
associated with the long term geological storage
components of CCS.
19