The NGER Act is now in its third reporting year and the threshold levels triggering the obligation on companies to report their greenhouse gas emissions, energy consumption or energy production levels have dropped again.
The threshold levels that trigger the reporting requirement this year are emissions by a facility of 25kt CO2 equivalence (CO2-e) of greenhouse gases or 100 TJ of energy consumption or production. A controlling corporation has to report when the total CO2-e emissions of its corporate group reach 50 kt or the energy consumed or generated by the group is 200TJ.
What is a facility?
The following four criteria can be used in determining if an activity or series of activities forms a facility under the Act:
1. Activities must produce greenhouse gas emissions or produce or consume energy.
2. Activities are part of a production process.
3. Activities occur at a ‘single site’.
4. Activities are attributable to a single industry sector.
What emissions are counted?
Scope 1
These are emissions of greenhouse gases over which entities have a high level of control, which occur as a direct result of activities at a facility. Examples are emissions from fuel combustion in facility boilers, furnaces, flares or vehicles.
Scope 2
Scope 2 emissions cover greenhouse gas emissions from the generation of purchased electricity, steam, heating or cooling consumed by a facility brought in from outside the facility boundary. They are indirect emissions but are easily measured and influenced through adopting efficiency measures.
The greenhouse gases that must be recorded and reported are CO2, SF6, CH4, N2O, HFCs and PFCs.
The NGERS threshold tester calculator at www.oscar.gov.au can be used for an indication of whether or not your company may need to register.
Penalties for non-compliance
If your company meets these threshold values for last year, it must register with the Department of Climate Change by 31 August 2011. Failure to report could result a penalty of $220,000.
For more information see the NGER Reporting Guidelines in the Government’s climate change website http://www.climatechange.gov.au
Checklist to reduce the risk of non-compliance and reduce the costs if audited
The following list of documents and records should be collated and kept to ensure that emissions and energy audits, both within the company and by external auditors are complete, accurate, consistent and transparent. Having well maintained and complete records should also reduce the costs of an audit.
- Details of emissions sources, types of gases generated, types and amounts of fuels and materials used
- Details of processes generating greenhouse gas emissions
- Detailed calculations of emissions generated, energy used or generated
- Details of methods, data, processes, systems, assumptions, estimates used to prepare an inventory of GHG emissions and energy consumption and generation
- Documentary evidence including invoices, energy statements
- Documents that support the monitoring method selected if appropriate
- Documentary evidence supporting the activity data collection for the facility
- Calibration results of any equipment used to measure emissions and equipment certification
- Copies of cited references justifying methods, assumptions made, best data available at the time of making the report etc