Environmental Reporting Requirements NGERS

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Environmental Legislation

Environmental Legislation

National Greenhouse and Energy Reporting Act & Carbon Pollution Reduction Scheme

Introduction

It is apparent there is a varying degree of awareness and knowledge of the various legislative environmental requirements. Are you familiar with the registration and reporting thresholds? Do you know how to calculate your environmental emissions? Are you aware of the penalties for non-compliance. Are you aware of the implications of the Carbon Pollution Reduction Scheme (CPRS) should it pass through Senate.

All corporations exceeding the greenhouse gas (GHG) emissions, and energy consumption and production thresholds contained in the National Greenhouse and Energy Reporting Act 2007 (Cth) (NGERS) will be required to register with the Department of Climate Change (DCC) by 31 August and report by 31 October. This report shall outline the corporation’s level of GHG emissions and energy consumption and production.

Objective

Registration and reporting under NGERS must be self-assessed. Whilst you or your clients may guess you are below the thresholds, the consequences for not registering or reporting if required could be substantial. It is therefore important that you are at least aware of these legislative requirements.

This article aims to provide a brief overview of the main requirements of NGERS and the impact for you or your clients. This article intends to provide guidance to assist in understanding:

NGERS registration and reporting requirements;
NGERS thresholds in relation to various sized organisations;
How to calculate emissions; and
The impact of a CPRS.

NGERS registration and reporting requirements

A corporation must register with the DCC if they meet one or more of the following thresholds:

GHG emissions with a carbon dioxide equivalence of 25 kilotonnes or more; or
Energy consumption of 100 terajoules or more; or
Energy production of 100 terajoules or more.

The penalty for failing to register is $220,000 for the corporation and potentially the same for the corporation’s Chief Executive Officer.

GHG emissions include direct emissions (Scope 1) and emissions attributable to purchased energy (Scope 2).

NGERS thresholds in relation to various sized organisations

These figures included below are intended for guidance purposes only. No reliance should be placed on such for decision making purposes.

Fuel Consumption – Tonnes of GHG emissions from Fuel Consumption*

Transport Company	20 Vehicles Each Travelling		100 Vehicles Each Travelling		1,000 Vehicles Each Travelling
Type of Vehicle	50,000 km/yr	100,000 km/yr	50,000 km/yr	100,000 km/yr	50,000 km/yr	100,000 km/yr
Light Commercial	378	756	1,890	3,780	18,900	37,800
Rigid Truck	756	1,512	3,780	7,560	37,800	75,600
Articulated Truck	1,480	2,960	7,400	14,800	74,000	148,000

* The above GHG emissions figures are ESTIMATES ONLY based on National Greenhouse Accounts (NGA) Factors and fuel consumption provided by the Australian Bureau of Statistics. These figures are for information and indicative purposes only. No reliance is to be placed on these figures for decision making purposes.

Electricity Consumption – Tonnes of GHG emissions from Electricity Usage

Electricity Use – Annual Kilowatt Hours	Approximate Size of Building or Corporation	Terajoules TJ of electricity or Tonnes of GHG emissions
60,000 kWh	500 square metres	0.2 TJ or 53 Tonnes
600,000 kWh	10 shops in a retail chain	2 TJ or 530 Tonnes
20,000,000 kWh	Large shopping centre	80 TJ or 18,000 Tonnes

These are approximate figures for information and indicative purposes only based on a selected sample size. No reliance is to be placed on these figures for decision making purposes.

The above are approximate figures for two common sources of emissions prevalent in most organisations. Another material source of emissions comes from waste, including food, paper and cardboard, concrete, metals, plastic and glass. The calculation tools referred below provide guidance on calculating emissions for these sources.

Calculating emissions

There are four methods for calculating GHG emissions for NGERS purposes. The scope of emissions to be included in your calculations also requires consideration. The nature of these is quite complex. You should take time to familiarise yourself with the National Greenhouse and Energy Reporting Regulations 2008 and the National Greenhouse and Energy (Measurement) Determination 2008.

To assist, the DCC has published calculation tools which can be found on the following website:

http://www.climatechange.gov.au/reporting/calculator/index.html

Implications of a Carbon Pollution Reduction Scheme

The implications of a CPRS may be significant for those required to register and report. A CPRS will apply to those registered under NGERS. Therefore, in addition to NGERS reporting requirements, under a CPRS, organisations will also be required to surrender to the regulator a requisite number of Eligible Emissions Units (these include Australian Emissions Units (AEUs) and International Units) based upon their GHG emissions. It is envisaged an AEU will cost around $20 - $25. Therefore, if you emit 25,000 tonnes of GHG, at a price of $25 per AEU you will be required to acquit $625,000 worth of AEUs.

With both NGERS and a CPRS, a corporation is either all in or all out. What this means is that should you emit 25,000 tonnes or more of GHG you must register and report. Those emitting less than this are not caught under either. Because, this is a strong incentive for those at or near the threshold to implement methods for reducing their GHG emissions to remain under the threshold, there are anti-avoidance rules in CPRS which allow the regulator to cancel the benefit of the threshold.

Conclusion

Environmental legislation is complex and vast. It is important that you understand and familiarise yourself with these new rules. The consequence for your organisation or for clients of not doing so could be significant. Corporations that meet or exceed these thresholds should be collecting GHG and emissions data now, and preparing for registration (if not already registered). Establishment of GHG and energy accounting and reporting systems should be well advanced.

Next Edition

Next article we will discuss the environmental reporting requirements for the voluntary market and those not caught under NGERS or the CPRS but are interested in reducing their emissions regardless.

Ashley Course
Director
WPIAS Training Academy Pty Ltd