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NGER Measurement Methods Guide 2023-24

The document provides guidelines for organizations to comply with their reporting obligations under the National Greenhouse and Energy Reporting Act 2007 (NGER Act) for the 2023-24 reporting year. It outlines various methods for measuring greenhouse gas emissions and energy consumption, including default methods and more complex sampling techniques, while emphasizing the importance of accurate data for regulatory compliance. Additionally, it includes updates on new methods for estimating scope 2 emissions and clarifications on reporting contractor activities.

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0% found this document useful (0 votes)
12 views17 pages

NGER Measurement Methods Guide 2023-24

The document provides guidelines for organizations to comply with their reporting obligations under the National Greenhouse and Energy Reporting Act 2007 (NGER Act) for the 2023-24 reporting year. It outlines various methods for measuring greenhouse gas emissions and energy consumption, including default methods and more complex sampling techniques, while emphasizing the importance of accurate data for regulatory compliance. Additionally, it includes updates on new methods for estimating scope 2 emissions and clarifications on reporting contractor activities.

Uploaded by

darrenkwok242
Copyright
© All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

Methods and

measurement
criteria guideline
August 2024
OFFICIAL

Contents
Contents .................................................................................................................................................. 1
Definitions and abbreviations................................................................................................................... 3
Disclaimer................................................................................................................................................ 4
2023–24 updates ..................................................................................................................................... 5
1. Purpose of this guideline .................................................................................................................. 5
1.1. Focus of this guideline ......................................................................................................................... 5
2. Methods for measurement - overview .............................................................................................. 6
2.1. Method 1 ............................................................................................................................................. 7
2.2. Method 2 ............................................................................................................................................. 7
2.3. Method 3 ............................................................................................................................................. 7
2.4. Method 4 ............................................................................................................................................. 7
2.5. Scope 2 emissions estimation methods - overview ............................................................................ 8
Compulsory location-based methods for estimating scope 2 emissions .................................................... 8
Voluntary market-based method for estimating scope 2 emissions .......................................................... 8
2.6. Energy estimation methods - overview............................................................................................... 8
2.7. Temporary unavailability of Method................................................................................................... 8
2.8. Constraints on Methods ...................................................................................................................... 9
3. What are measurement criteria?..................................................................................................... 10
3.1. General definitions ............................................................................................................................ 10
3.2. Constraints on measurement criterion ............................................................................................. 12
4. Measurement criteria for carbon capture and storage ..................................................................... 12
5. Measurement criteria for solid fuels................................................................................................ 13
6. Measurement criteria for gaseous fuels .......................................................................................... 13
7. Measurement criteria for liquid fuels .............................................................................................. 14
8. Measurement criteria for carbonates .............................................................................................. 15
9. Measurement criteria for solid waste .............................................................................................. 16
10. Measurement criteria where data relates to a contractor’s activities ........................................... 16
11. More information ....................................................................................................................... 17

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Definitions and abbreviations


Term Meaning

Department Department of Climate Change, Energy, the Environment and Water. Federal
department who is the policy agency for the NGER Legislation.

Facility Has the meaning given by section 9 of the NGER Act. For more information on
defining a facility under the NGER scheme, see What is a Facility 1.

GJ Gigajoules

L Litres

NGER National Greenhouse and Energy Reporting

NGER Act National Greenhouse and Energy Reporting Act 2007

NGER Legislation The NGER Act, the NGER Regulations and the NGER Measurement
Determination

NGER Measurement National Greenhouse and Energy Reporting (Measurement) Determination


Determination 2008

NGER Regulations National Greenhouse and Energy Reporting Regulations 2008

Safeguard Mechanism The Australian Government’s mechanism to contribute to the achievement of


Australia’s greenhouse gas emissions reduction targets. See the Safeguard
Mechanism2 for more information.

Scope 1 emissions Means the release of greenhouse gas into the atmosphere as a direct result of
an activity or series of activities (including ancillary activities) that constitute
the facility.

Scope 2 emissions Means the release of greenhouse gas into the atmosphere as a direct result of
one or more activities that generate electricity, heating, cooling or steam that
is consumed by the facility but that do not form part of the facility.

t CO2-e Tonnes carbon dioxide equivalence

Please refer to Division 2 of the NGER Act, 1.03 of the NGER Regulations and Division 1.1.2 of the NGER
Measurement Determination for defined terms in NGER legislation.

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Disclaimer
This guideline has been developed by the Clean Energy Regulator (CER) to assist entities to comply with their
reporting obligations under the National Greenhouse and Energy Reporting Act 2007 3 (NGER Act) and
associated legislation.

This guideline only applies to the 2023–24 NGER reporting year and should be read in conjunction with the
NGER Act, National Greenhouse and Energy Regulations 2008 4 (NGER Regulations), and National
Greenhouse and Energy Reporting (Measurement) Determination 2008 5 (NGER Measurement
Determination), as in force for this reporting period. These laws and their interpretation are subject to
change, which may affect the accuracy of the information contained in the guideline.

The guidance provided in this document is not exhaustive, nor does it consider all circumstances applicable
to all entities. This guidance is not intended to comprehensively deal with its subject area, and it is not a
substitute for independent legal advice. Although entities are not bound to follow the guidance provided in
this document, they must ensure they meet their obligations under the National Greenhouse and Energy
Reporting (NGER) scheme 6 at all times. CER encourages all users of this guidance to seek independent legal
advice before taking any action or decision based on this guidance.

CER and the Australian Government will not be liable for any loss or damage from any cause (including
negligence) whether arising directly, incidentally, or as consequential loss, out of or in connection with, any
use of this guideline or reliance on it, for any purpose.

If an entity chooses to meet their obligations under the NGER scheme in a manner that is inconsistent with
the guidance provided in this document, CER, or an independent auditor, may require the entity to
demonstrate that they are compliant with requirements of the NGER Act, NGER Regulations, and/or the
NGER Measurement Determination. Entities are responsible for determining their obligations under the law
and for applying the law to their individual circumstances.

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2023–24 updates
Changes in this document for the 2023–24 reporting year:

• Minor stylistic and formatting changes have been made to this document
• Chapter 2.5: added information about the new voluntary market-based scope 2 emissions method
• Chapter 10: clarified requirements for reporting contractor activities

Read about the changes to the NGER Legislation for the 2023–24 reporting period 7.

1. Purpose of this guideline


Certain organisations have reporting obligations under the NGER Legislation, comprising the NGER Act, the
NGER Regulations and the NGER Measurement Determination.

It is important that data relating to greenhouse gas emissions, energy consumption and energy production
of corporations, provided under the NGER scheme, is accurate and complies with the requirements of the
legislation. The information is used to:

• inform government policy formulation and the Australian public


• meet Australia’s international reporting obligations
• assist Commonwealth, State and Territory government programs and activities
• ensure, under the Safeguard Mechanism, that net covered emissions of greenhouse gases from the
operation of a designated large facility do not exceed the baseline applicable to the facility.
The following information has been compiled to provide stakeholders with an understanding of how we will
apply legislation with regards to method and measurement criterion selection and application through
worked examples and elaborations. It is intended to assist stakeholders (reporters, auditors, and those who
prepare NGER reports) with demonstrating compliance by providing practical examples of the application of
the legislation.

This compilation is an extension of the Department of Climate Change, Energy, the Environment and Water’s
(DCCEEW) discontinued technical guidelines and is intended to provide industry stakeholders with an
understanding of how the regulator interprets and applies the legislation. It is intended for educational
purposes only.

Reporters are responsible for ensuring they meet the legislative requirements.

1.1. Focus of this guideline


The objective of this guideline is to promote an understanding of the methods used for estimating emissions
and energy, the general requirements for measurement of emissions and energy and the compliant
reporting of measurement criteria for a facility under the NGER Act. See NGER Defining facilities 8 for
guidance on what constitutes a facility.

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2. Methods for measurement - overview


Emissions are rarely measured through direct observation. They are most often estimated by reference to
readily observable variables that are closely related to greenhouse gas emissions such as the quantity of
fossil fuels consumed.

This guideline outlines the methods that allow for both direct emissions monitoring and the estimation of
emissions through the of tracking of related variables. The methods reflect the approaches taken globally,
for example for the estimation of national greenhouse gas inventories, the EU guidelines, and the United
States Environmental Protection Agency’s Mandatory Greenhouse Gas Reporting Rule 9.

At its simplest, emissions may be estimated by reference to reportable data such as fossil fuel consumption
and the use of specified emission factors provided in this guideline. For example, emissions from fuel
combustion data on consumption of a fuel would be multiplied by a specific emission factor for that fuel to
generate an emissions estimate.

Greater levels of complexity, technical equipment and expertise may in some circumstances produce more
accurate estimates of emissions at the facility level. For example, sampling and direct analysis of the carbon
content and other characteristics will lead to a more accurate estimate of actual emissions generated by its
use at a facility. In Australia, this approach to estimation of emissions has been used for several years in the
electricity industry.

Direct monitoring of emissions is also an approach that reporters may find useful in accurately estimating
their emissions. While not common, direct monitoring already occurs in the coal industry, where state
legislation requires the monitoring of methane levels for health and safety reasons.

The 4 methods are described in general terms in chapters 2.1 to 2.4 of this guideline. These 4 general types
of method are used for estimating emissions in the NGER Measurement Determination for a range of
sources. Reporters are given a choice of methods they may use for estimating emissions, however not all
methods are available for estimating emissions from all sources.

Methods for estimating emissions have been developed to be compatible with existing emission estimation
practices where possible. The guidance documents published by CER are intended to assist reporters to
meet their NGER obligations by drawing on existing processes particularly for higher order methods (2, 3 and
4 set out below).

The provision for reporters to select methods for the estimation of emissions also allows reporters to make
their own judgements to balance the costs of using the higher methods with the benefits of potentially more
accurate emission estimates.

It is intended that the reporter indicate the method used for reporting each source. For example, the
reporter can apply different methods for different fuels and different methods for individual gases. Where
appropriate, the reporter can use different methods to estimate emissions from ‘separate instances of a
source’ (section 1.9A of the NGER Measurement Determination) and ‘separate occurrences of a source’
(section 1.9B of the NGER Measurement Determination). Not all methods are available for all sources or for
all gases. For example, for solid fuels only Method 1 is available for methane and nitrous oxide, reflecting the
minor nature of the emission sources, whereas 4 methods are available for carbon dioxide.

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2.1. Method 1
Method 1 within the NGER is the default method for determining emissions, and it:

• Provides estimation procedures derived directly from the methodologies used by the Department of
Climate Change, Energy, the Environment and Water for the preparation of Australia’s National
Greenhouse Accounts. The use of methodologies from the National Greenhouse Accounts anchors
Method 1 within the international guidelines adopted by the United Nations Framework Convention on
Climate Change (UNFCCC) for the estimation of greenhouse emissions.
• Specifies the use of default emission factors in the estimation of emissions. These emission factors are
national average factors determined by the Department of Climate Change, Energy, the Environment
and Water using the Australian Greenhouse Emissions Information System (AGEIS).
• Is likely to be most useful for emission sources where the source is relatively homogenous, such as from
the combustion of standard liquid fossil fuels and where the emissions resulting from combustion will be
very similar across most facilities.

2.2. Method 2
Method 2 employs industry-based sampling and applies Australian or international standards, or their
equivalent, to analysis of fuels and raw materials. Method 2:

• Enables corporations to undertake additional measurements, for example, the qualities of fuels
consumed at a facility, to gain more accurate estimates for emissions for a particular facility.
• Draws on the large body of Australian and international documentary standards prepared by standards
organisations to provide the benchmarks for procedures for the analysis of, typically, the critical
chemical properties of the fuels being combusted.
• Is likely to be most useful for fuels which exhibit some variability in key qualities, such as carbon content,
from source to source. This is the case for coal in Australia.
• Is based on technical guidelines that were used by reporters under the Generator Efficiency Standards
program. The option to report using this higher order approach is extended by the NGER Measurement
Determination from the electricity industry to all major consumers of fossil fuels.

2.3. Method 3
Method 3 requires sampling and analysis based on Australian or international standards or their equivalent
standards for fuels and raw materials. These methods are very similar to Method 2, except that they require
reporters to comply with Australian or international documentary standards for sampling (of fuels or raw
materials) or equivalent as well as for the analysis of fuels.

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
Methods 2 and 3.

2.4. Method 4
Method 4 requires direct monitoring of emission systems on either a continuous or a periodic basis.

Rather than analysing the chemical properties of inputs (or in some cases, products), Method 4 provides
approaches based on direct monitoring of greenhouse gas emissions arising from an activity. This approach
can provide a higher level of accuracy compared to Methods 1 to 3. Although it is more data intensive than
other approaches. Direct monitoring already occurs, for example, in underground coal mines reflecting the

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nature of the emission process and the importance of relatively accurate data to support health and safety
objectives.

2.5. Scope 2 emissions estimation methods - overview


Scope 2 emissions arise from the consumption of an energy commodity which was produced outside of the
facility. Scope 2 emission account for the scope 1 emissions which were required to produce the energy
commodity.

In NGER, scope 2 emissions arise from the consumption of electricity which was produced at another facility.
By reporting scope 2 emissions, the electricity consumer is accounting for the scope 1 emissions which were
required to produce the electricity. The location-based and market-based methods for the estimation of
scope 2 emissions are given in chapter 7 of the NGER Measurement Determination.

Compulsory location-based methods for estimating scope 2 emissions


Location-based scope 2 emissions must be reported as per section 7.2 and 7.3 of the NGER Measurement
Determination, provided facilities meet the relevant thresholds.

These methods employ an emission factor of tonnes of scope 1 emissions per kilowatt hour of electricity
consumed. Scope 2 emission factors for the consumption of purchased electricity from Australia’s major
electricity grids are updated annually to reflect the latest data on the mix of electricity generation sources,
which is a major determinant of the emission factors. Chapter 7 of the NGER Measurement Determination
also covers how to estimate scope 2 emissions from the purchase and loss of other sources (sources other
than the purchase and loss of electricity from a State or Territory’s main electricity grid).

Voluntary market-based method for estimating scope 2 emissions


From the 2023–24 NGER reporting year, NGER reporters may choose to additionally report using the
market-based method for estimating scope 2 emissions. The method allows NGER reporters to reflect
actions they take that incentivise renewable electricity generation. These actions include voluntary
surrenders of large-scale generation certificates (LGCs) and purchases of GreenPower electricity. The
method is described in section 7.4 of the NGER Measurement Determination. Read more in the voluntary
market-based scope 2 emissions guideline 10.

2.6. Energy estimation methods - overview


Methods for the estimation of the energy content of fuels produced and fuels consumed are set out in
chapter 6 of the NGER Measurement Determination.

Information used for the estimation of emissions from fuel combustion as set out in chapter 2 of the NGER
Measurement Determination will also be used as the data for estimating energy from the consumption of
fuels. Separate collection of data is required for the quantities of energy produced and in some cases where
energy is consumed and not combusted.

2.7. Temporary unavailability of Method


Reporters must observe the requirements in section 1.19 of the NGER Measurement Determination relating
to down time of equipment or failure of measurement systems to monitor emissions:

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• If the down time in a year is 6 weeks (42 days) or less (this down time does not include down time taken
for calibration of measurement systems), emissions for each day of the down time must be estimated
consistently with the principles of section 1.13 of the NGER Measurement Determination.
Note: when estimating emissions by continuous emissions monitoring (CEM), the down time cannot
exceed 10% of the year (36.5 or 36.6 days) – that is, maximum 5 weeks and one day (excluding down
time for calibration), as per subsection 1.26(4) of the NGER Measurement Determination.
• If the down time exceeds 6 weeks in a reporting period, within 6 weeks after the day when down time
first exceeds 6 weeks, the registered controlling corporation or responsible emitter must inform CER in
writing of the following:
» the reason why down time is more than 6 weeks
» how the reporter plans to minimise down time
» how emissions have been estimated during the down time.
Whilst this ‘down time’ requirement in practice may be of most relevance for CEM using Method 4, it is a
requirement for all methods for all emissions sources. Periodic Emissions Monitoring (PEM) using Method 4
can also be affected, noting that if monthly emissions monitoring is applied, only one measurement period
can be missed. It also applies to all other emissions sources – for example, failure of a meter to measure flow
of gas to a combustion source, even when using Method 1, 2 or 3.
CER may direct Method 1 be used to estimate emissions during the down time if Method 2, 3 or 4 has been
used to estimate emissions for the source and if the down time exceeds 6 weeks in a reporting period.

2.8. Constraints on Methods


The consistent use of reporting methods over multiple reporting periods is an important principle for
measuring emissions and energy. To promote consistency, restrictions have been placed on when methods
may be applied. Method restrictions for a source of emissions are provided in Division 1.2.2 of the NGER
Measurement Determination. With respect to any separate occurrence of a source, a reporter must
continue to use the same estimation method for at least 4 consecutive reporting years. A reporter may
switch to a higher method at any time but must use the higher method for at least 4 years before changing
to a lower method.
This principle is consistent with the approach that applies to the preparation of national inventories. Chapter
5 of Volume 1 of the 2006 Intergovernmental Panel on Climate Change (IPCC) Guidelines 11 for National
Greenhouse Gas Inventories provides a detailed discussion of the issue.

Commencing in the 2021–22 reporting year, constraints were also applied when estimating fugitive
emissions from the following natural gas sources:

• Subdivision 3.3.6A.1—Onshore natural gas production, other than emissions that are vented or flared—
wellheads
• Subdivision 3.3.6B.1—Offshore natural gas production, other than emissions that are vented or flared—
offshore platforms
• Division 3.3.6C—Natural gas gathering and boosting (other than emissions that are vented or flared)
• Division 3.3.6E—Natural gas processing (other than emissions that are vented or flared)

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• Division 3.3.7A—Natural gas storage (other than emissions that are vented or flared)
• Division 3.3.7B—Natural gas liquefaction, storage and transfer (other than emissions that are vented or
flared).
For the sources listed above, if Method 2 or 3 is used for a particular source then all applicable gases and
other sources that apply to the facility must also be estimated using the same method. For example, the use
of Method 2 under section 3.73B for a given facility, means that all other available Methods 2 must be used
in Divisions 3.3.6B, 3.3.6C, 3.3.6E, 3.3.7A and 3.3.7B of the NGER Measurement Determination if those
Divisions are applicable to the facility.

3. What are measurement criteria?


Measurement criteria categories indicate the quality of data that is obtained when reporters use different
types of information or through application of methods of measurement. The measurement criteria set out
how the following are to be estimated:

• the amount of fuel consumed or combusted for a source 12


• the amount of fuel related to fugitive emissions from the extraction, production, processing and
distribution of fossil fuels
• the amount of carbonates consumed, synthetic gas emitted, and fuel used as a feedstock or as carbon
reductant related to industrial process emissions
• the amount of waste for a source.

3.1. General definitions


There are 4 different measurement criteria that can broadly be defined as follows:

• Criterion A - quantity verified by invoices 13

• Criterion AA - quantity verified by stockpile change estimation and invoices

• Criterion AAA - quantity measured at point of sale, consumption or production using


measuring equipment calibrated to a measurement requirement as specified
in the NGER Measurement Determination

• Criterion BBB - quantity measured or estimated in accordance with industry practice if the
equipment used to measure combustion of the fuel is not calibrated to a
measurement requirement.
Note: An estimate obtained using industry practice must be consistent with
the principles in section 1.13

12
A 'source' is defined in section 1.10 of the NGER Measurement Determination.
13
To use criterion A, the invoice(s) must refer to a particular amount of a particular fuel delivered to a particular facility.
An 'invoice' includes delivery records.

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• If the acquisition involves a commercial transaction, one of criterion A, AA or AAA may be used.
• If you are estimating fuels using only invoices issued by a vendor, then you must use Criterion A.
• If the acquisition does not involve a commercial transaction, criterion AAA or BBB must be used.
• Criterion AAA is only to be used where measuring equipment is calibrated to a measurement
requirement as specified in the NGER Measurement Determination. Point-of-sale measurement
can only be used if stockpile requirements are met in accordance with the NGER Measurement
Determination.
• Criterion BBB is not to be used where a commercial transaction has taken place, that is, where
invoices exist.
• Please read sections 4 - 9 below for further details.

Please note that measurement criteria can have different requirements for each source type and some
criteria are not available for some types of sources. Moreover, there may be multiple options or sub-criteria
to choose from within each criterion. For example, criterion AAA can be applied in several ways depending
on whether there is a commercial transaction involved in the acquisition of the fuel.

Table 1 below summarises the measurement criteria that are available for different fuels and emissions
sources. The number of check marks in each cell represent the number of sub-criteria within each criterion.
For instance, criterion AAA for solid fuels has 3 check marks because it is comprised of the following sub-
criteria:

• Fuel consumed involves a commercial transaction and is measured at the point of sale 14
• Fuel consumed involves a commercial transaction and is measured at the point of consumption. If used
for a facility during a reporting year, an alternative sub-criterion or criterion cannot be used in
subsequent years for that facility.
• Fuel consumed does NOT involve a commercial transaction and is measured at the point of
consumption.
Table 1 – Available measurement criteria.

NGER Criterion A Criterion AA Criterion Criterion BBB


Measurement AAA
Determination

Carbon capture and Section 1.19E  -  


storage

Solid fuels Division 2.2.5    

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This represents a simplification of the subcategories. Please see the 'Solid fuels' divisions of the NGER Measurement
Determination for more details.

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Gaseous fuels Division 2.3.6    

Liquid fuels Division 2.4.6    

Carbonates Division 4.2.5    

Solid waste Section 5.5  -  


Note: The number of check marks in each cell represent the number of sub-criteria within each criterion.

3.2. Constraints on measurement criterion


The consistent use of criteria for measurement over multiple reporting periods is an important principle for
measuring emissions and energy. To promote consistency, restrictions have been placed on the how
measurement criteria can be used. Restrictions on criteria for measurement are provided in Part 1.3, and
Divisions 2.2.5, 2.3.6, 2.4.6 and 4.2.5 of the NGER Measurement Determination.

In general, for solid, gaseous, and liquid fuel and consumption of carbonates, once criterion AA is used (and
in some circumstances, once AAA is used) to estimate a quantity of fuel during a year, then in each year
following, only that criterion is to be used.

This principle is consistent with the approach that applies to the preparation of national inventories. Chapter
5 of Volume 1 of the 2006 IPCC Guidelines 15 for National Greenhouse Gas Inventories provides a detailed
discussion of the issue.

4. Measurement criteria for carbon capture and storage


The volume of the greenhouse gas stream containing the captured greenhouse gas must be estimated:

• if the greenhouse gas stream is transferred to a relevant person 16, using:

− criterion A - as evidenced by invoices issued by the relevant person


− criterion AAA - by undertaking volumetric measurement in accordance with sections 1.19H
or 1.19I of the NGER Measurement Determination and gas measuring
equipment that complies with section 1.19J. The gas measuring equipment
must, for a given flow, also comply with transmitter and accuracy
requirements detailed in section 1.19G(4).

• if the greenhouse gas stream is captured by the relevant person and is neither transferred to the
relevant person nor transferred by the relevant person to another person, using:

− criterion AAA - as detailed in the previous point


− criterion BBB -

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A 'relevant person' means a person mentioned in section 1.19A(a), (b), (c), (d), (e) or (f) of the NGER Measurement
Determination. It broadly refers to holders of federal or state licenses, leases or approvals for carbon capture and
storage.

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by undertaking volumetric measurement in accordance with industry


practice, providing the measuring equipment does not meet the
requirements of criterion AAA.

5. Measurement criteria for solid fuels


The quantity of solid fuel consumed must be estimated:

• if the solid fuel acquired involves a commercial transaction, using:

− criterion A - as evidenced by invoices issued by the vendor of the fuel.

− criterion AA - by estimating the change in the quantity of the stockpile of the fuel using the
survey approach (subsection 2.15(2C) of the NGER Measurement
Determination) or the error allowance approach (subsection 2.15(2D)).
Once an approach has been selected for a facility for a reporting year, that
same approach must be used for each subsequent year unless there is a
significant change in stockpile management, and this results in the current
approach being less accurate than the alternative approach.
The quantity of fuel added to the fuel stockpile must be evidenced by
invoices issued by the vendor of the fuel.
If criterion AA is used for a facility in a year, then, in each subsequent year,
only criterion AA can be used for that facility.

− criterion AAA - by measuring at the point of consumption or at the point of sale using
measuring equipment calibrated to a measurement requirement.
The point-of-sale measurement can only be used if the change in stockpile of
the fuel is less than 1% of the total average combustion or consumption for
the year and, at the beginning of the year, the stockpile quantity is less than
5% of total combustion or consumption for the year.
If criterion AAA’s point of combustion or consumption measurement is used
for a facility in a year, then, in each subsequent year, only this point of
combustion or consumption measurement can be used for the facility.

• if the solid fuel acquired does not involve a commercial transaction, using:

− criterion AAA - by measuring at the point of combustion or consumption using measuring


equipment calibrated to a measurement requirement.
Note that a different criterion can still be used in subsequent years.

− criterion BBB - by measuring combustion/consumption in accordance with industry practice


providing measurement equipment is not calibrated to a measurement
requirement.

6. Measurement criteria for gaseous fuels


The quantity of gaseous fuel combusted or consumed must be estimated:

• if the gaseous fuel acquired involves a commercial transaction, using:

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− criterion A - as evidenced by invoices issued by the vendor of the fuel.

− criterion AA - by estimating the change in the quantity of the stockpile of the fuel as
evidenced by invoices issued by the vendor of the fuel.
If criterion AA is used for a facility in a year, then, in each subsequent year,
only criterion AA can be used for that facility.

− criterion AAA - by measuring at the point of combustion/consumption or the point of sale in


accordance with sections 2.32 or 2.33 of the NGER Measurement
Determination using gas measuring equipment that complies with section
2.34. The gas measuring equipment must, for a given flow, also comply with
transmitter and accuracy requirements detailed in section 2.31(4).
The point-of-sale measurement can only be used if the change in stockpile of
the fuel is less than 1% of the total average combustion/consumption for the
year and, at the beginning of the year, the stockpile quantity is less than 5%
of total combustion/consumption for the year.
If criterion AAA's point of combustion or consumption measurement is used
for a facility in a year, then, in each subsequent year, only this point of
combustion or consumption measurement can be used for the facility.

• if the gaseous fuel acquired does not involve a commercial transaction, using:

− criterion AAA - by measuring at the point of combustion or consumption using measuring


equipment calibrated to a measurement requirement.
Note that a different criterion can still be used in subsequent years.

− criterion BBB - by measuring combustion or consumption in accordance with industry


practice providing measurement equipment does not meet the requirements
of criterion AAA.
For sources of landfill gas captured for production of electricity, the energy
content may be estimated using the electrical efficiency factor specified by
the manufacturer of the internal combustion engine used to generate
electricity. If no electrical efficiency factor is specified, then a 36% fuel to
electricity conversion factor is to be used.

7. Measurement criteria for liquid fuels


The quantity of liquid fuel combusted or consumed must be estimated:

• if the liquid fuel acquired involves a commercial transaction, using:

− criterion A - as evidenced by invoices issued by the vendor of the fuel.

− criterion AA - by estimating the change in the quantity of the stockpile of the fuel as
evidenced by invoices issued by the vendor of the fuel.
If criterion AA is used for a facility in a year, then, in each subsequent year,
only criterion AA can be used for that facility.

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− criterion AAA - by measuring at the point of combustion or consumption or at the point of


sale at ambient temperatures and converted to standard temperatures using
measuring equipment calibrated to a measurement requirement.
The point-of-sale measurement can only be used if the change in stockpile of
the fuel is less than 1% of the total average combustion or consumption for
the year and, at the beginning of the year, the stockpile quantity is less than
5% of total combustion or consumption for the year.
If criterion AAA's point of combustion or consumption measurement is used
for a facility in a year, then, in each subsequent year, only this point of
combustion or consumption measurement can be used for the facility.

• if the liquid fuel acquired does not involve a commercial transaction, using:

− criterion AAA - by measuring at the point of combustion or consumption at ambient


temperatures and converted to standard temperatures using measuring
equipment calibrated to a measuring requirement.
Note that a different criterion can still be used in subsequent years.

− criterion BBB - by measuring combustion or consumption using an accepted industry


measuring device or in accordance with industry practice, if the measuring
equipment is not calibrated to a measurement requirement. Industry practice
may include use of logbooks, fuel cards or fleet management software.

8. Measurement criteria for carbonates


The measurement criteria for carbonates apply when estimating emissions from the following sources:

• cement clinker production


• lime production
• calcination of carbonates in an industrial process
• soda ash production.
The quantity of carbonates consumed, or the quantity of products derived from carbonates must be
estimated:

• if the acquisition of carbonates or the dispatch of products derived from carbonates involves a
commercial transaction, using:

− criterion A - as evidenced by invoices issued by the vendor of the carbonates or products.

− criterion AA - by estimating the change in the quantity of the stockpile of the carbonates or
products as evidenced by invoices issued by the vendor of the carbonates or
products.
If criterion AA is used for a facility in a year, then, in each subsequent year,
only criterion AA can be used for that facility.

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− criterion AAA - by measuring at the point of consumption of the carbonates or the point of
production of the products derived from carbonates, using measuring
equipment calibrated to a measurement requirement.
The quantity of the carbonates consumed can also be measured at the point
of sale but only if the change in stockpile of the carbonates is less than 1% of
the total consumption for the year and, at the beginning of the year, the
stockpile quantity is less than 5% of total consumption of carbonates for the
year.
If criterion AAA's point of consumption is used for a facility in a year, then, in
each subsequent year, only this point of consumption measurement can be
used for the facility.

• if the acquisition of carbonates or the dispatch of products derived from carbonates does not involve a
commercial transaction, using:

− criterion AAA - by measuring at the point of consumption of the carbonates or the point of
production of the products derived from carbonates, using measuring
equipment calibrated to a measurement requirement.
Note that a different criterion can still be used in subsequent years.

− criterion BBB - by measuring the consumption of carbonates or the products derived from
carbonates in accordance with industry practice, if the measuring equipment
is not calibrated to a measurement requirement.

9. Measurement criteria for solid waste


The tonnage of waste received at a landfill must be estimated using:

− criterion A - as evidenced by invoices or measured in accordance with State or Territory


legislation.

− criterion AAA - by measuring the quantities of solid waste received at the landfill using
measuring equipment calibrated to a measurement requirement.

− criterion BBB - by estimating the quantities of solid waste received at the landfill in
accordance with industry estimation practices. Industry practice includes
weighbridges, receipts, invoices, other documents or records, or population
and per-capita waste generation rates.

10. Measurement criteria where data relates to a


contractor’s activities
In many cases, activities that form part of a facility are undertaken by contractors. This means that reporters
are required to get data from their contractors to complete their NGER reports. It is common for a
combination of invoices, logbook or fuel card data to be used to estimate the amount of fuel used by
contractors while conducting activities at a facility.

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In some cases, the amount of fuel purchased by a contractor will be partially used at the facility, and partially
used for activities that take place outside of a facility. Where this is the case, the reporter or contractor
needs to determine and document a way to apportion the total amount invoiced between fuel consumed
for the purposes of the facility and fuel consumed for other purposes.

The reporter should take the following into account in assessing a contractor’s activities:

• For criteria A or AA, the quantities estimated from invoices will permit estimates made by the contractor
of the quantity of fuel consumed by the contractor within the facility. This estimate must be based on
the invoiced amounts and apportion of the quantity that has been consumed within the facility in a
manner which meets the requirements of section 1.13 of the NGER Measurement Determination.
• If stockpiles are involved, estimates must be undertaken under criterion AA and comply with the
requirements for estimating stockpiles.
• If fuels are estimated using measurement equipment capable of meeting the requirements for criterion
AAA for each fuel type, criterion AAA will continue to be acceptable.
Note: If the fuel is purchased by a contractor, the term ‘commercial transaction’ has a meaning broader than
invoices. It can include contracts with or without directly attributable renumeration for the services
provided.
When a contractor conducts an activity in the reporting year that meets the requirement of 4.30 of the
NGER Regulations, the reporter must report the additional information about the contractor listed in the
regulation.

11. More information


For more information, please contact CER:

Email: reporting@[Link]

Phone: 1300 553 542 within Australia

Website: [Link]

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Common questions

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When commercial transactions occur, criterion A is used, evidenced by vendor invoices, or criterion AA for stockpile changes also evidenced by invoices, ensuring verifiable accounting. Without commercial transactions, criterion AAA applies, involving calibrated measurement at the point of consumption, offering consistency over time, or criterion BBB could apply, measuring according to industry practice without needing calibrated equipment. This variance affects the rigor and accuracy of documentation and compliance efforts required by the facility, emphasizing the significance of commercial documentation in regulatory reporting .

The safeguard mechanism functions to ensure that large facilities do not exceed their designated baseline emissions, thus contributing to Australia's overall emissions reduction targets. It mandates facilities to keep emissions within the set baseline, providing a framework for monitoring and enforcement. Through compliance incentives and potential penalties, it encourages facilities to implement energy-efficient practices and emissions reductions measures, ensuring adherence to the national emissions strategy and contributing to international commitments .

The guideline offers stakeholders educational resources through detailed explanations of measurement criterion selection and application, as well as worked examples and elaborations. These resources are designed to enhance understanding and facilitate the accurate application of legislation. The guideline aims to clarify the processes involved in compliance, aiding reporters, auditors, and report preparers in demonstrating compliance through tailored examples. This approach enables stakeholders to better meet their legislative obligations and integrate the required methodologies into their reporting practices effectively .

The methods and measurement criteria ensure alignment with international reporting standards by incorporating practices similar to global approaches such as the EU guidelines and the US EPA’s Mandatory Greenhouse Gas Reporting Rule. The guideline includes detailed criteria for estimating emissions through direct monitoring and tracking related variables, reflecting a capacity to adapt and meet international expectations for accuracy and standardization. This alignment facilitates the comparability of Australia's reporting methods with other countries, fostering international data integration and supporting cooperative policy responses .

Constraints on measurement criteria affect reporting processes for carbon capture and storage (CCS) activities by requiring precise documentation and adherence to specified measurement standards. Entities must ensure that data and methodologies used are reliable and verifiable, maintaining consistency over time. The constraints emphasize the importance of accuracy in capturing the variations in storage and emissions capture performance. These constraints prevent discrepancies in reporting and ensure that the carbon capture is accurately represented in emissions reductions reported under the NGER scheme .

The voluntary market-based method for estimating scope 2 emissions allows entities to take into account the specific renewable energy sources they purchase, reflecting their contributions to emissions reduction beyond merely consuming grid energy. In contrast, compulsory location-based methods use a default emissions factor related to the electricity grid specific to the location of the energy consumption. An entity might choose the market-based method to highlight their investment in green energy initiatives and reduce their reported emissions footprint if they are actively participating in renewable energy markets. However, it requires detailed contractual evidence and can be more complex to implement than location-based methods, which are simpler and based on standardized regional factors .

The NGER scheme provides a structured framework for reporting and tracking greenhouse gas emissions and energy data, supporting national policy-making and fulfilling international reporting obligations. It facilitates transparency and accountability in emissions management, enabling comparison and analysis across sectors. The scheme provides reliable data that underpin Australia's emissions reduction strategies and commitments under global climate agreements, ensuring alignment with international goals such as those of the Paris Agreement. By standardizing reporting criteria and methods, the NGER scheme promotes consistency, potentially fostering collaborative emissions reduction efforts globally .

The guideline identifies four primary methods for estimating emissions: direct measurement, estimation through observable variables closely related to emissions such as fossil fuel consumption, the use of specified emission factors, and elaborate technical equipment and expertise for more accurate estimates. These methods contribute to compliance by providing systematic approaches for facilities to calculate and report emissions accurately, aligning with the requirements set by the National Greenhouse and Energy Reporting scheme. This ensures that emissions reporting is consistent and meets governmental and international standards .

Entities may face challenges such as needing to adapt their reporting to incorporate the new voluntary market-based method for scope 2 emissions, which requires detailed supporting documentation of renewable energy purchases. Collecting and maintaining this information can be resource-intensive and complex. Additionally, ensuring consistency and accuracy while transitioning from previous practices might pose challenges. These updates demand a thorough understanding of both market-based calculations and traditional methods, requiring investment in training and potentially new accounting systems to ensure compliance with the updated legislation .

Criterion AAA involves measuring at the point of combustion or consumption using calibrated measuring equipment, which provides precise and possibly more consistent data. Criterion BBB allows measurement according to industry practice without the necessity for calibrated equipment, which might reduce cost and effort but could lead to less precise data. Using criterion AAA emphasizes accuracy and is likely to meet more rigorous compliance standards. However, criterion BBB offers flexibility and reduced operational burden, albeit potentially sacrificing precision. The choice between the two would depend on the facility's operational needs and the compliance stringency it faces .

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