Monday, 10 July 2017 17:10

All about refrigerants


Reporting refrigerants under the National Greenhouse and Energy Reporting (NGER) Scheme is a quirky and sometimes confusing process. Not sure if you should be reporting your refrigerants? Not sure how to report refrigerants?

Keep reading to find out what you need to know.


Who needs to report

Reporting of refrigerants is only required for facilities which falls under specific ANZIC codes – these are:

  • Food product manufacturing services (ANZIC classification, Subdivision 11)
  • Beverage and tobacco product manufacturing (ANZIC classification, Subdivision 12)
  • Retail trade (ANZIC classification, Division G)
  • Warehousing and storage services (ANZIC classification, number 530)
  • Wholesale trade (ANZIC classification, Division F)
  • Rental, hiring and real estate services (ANZIC classification, Division L)


What to report

Refrigerant plant needs to be reported if it meets the following criteria:

  • Has a gas charge of greater than 100 kg
  • Includes a hydroflurocarbon gas listed in subsection 7A(2) of the NGER Act, and that gas has a global warming potential greater than 1000.


How to report

You can report on emissions from refrigerants either as incidental emissions, or using the methods described in the NGER Measurement Determination 2008 (the NGER Determination).

If you would like to report your refrigerants as incidentals, both the facility and the refrigerant plant, will need to meet threshold criteria for reporting incidentals. Reporting of incidentals also needs to adhere to the general principles for measuring emissions laid out in section 1.13 of the NGER Determination. This means that if you choose to report refrigerants as incidentals, the emissions report still need to be transparent, comparable, accurate and complete. Furthermore you cannot report refrigerants as incidentals if you are required to collect the information for other legislative purposes.

To report using methods 1 listed in the NGER Determination you will need to collect information about your refrigerant plant. Specifically, you will need to know:

  • The type of cooling the plant is used for (air conditioning, commercial refrigeration, or industrial refrigeration),
  • The type of refrigerant gas is sued in the plant, and
  • The gas charge of the plant.

This information can usually be found either on the plant name plate, or in maintenance records.

Figure 1 below, shows a flow chart for identifying when and how to report your refrigerants.




The traps

There are a few catches to refrigerant reporting which may trip-up the unwary.

Firstly refrigerants may be made up of a mix of gases. In such cases it may not be immediately apparent that the refrigerant needs to be reported. It is important to check the refrigerant specifications to confirm whether it contains a reportable gas.

The requirement to report plant that uses a mix of gases is based on the entire gas charge of the plant, not just the reportable component. If the gas charge of the plant is above 100 kg you must report - it doesn’t matter if the reportable component of the gas mixture is only a small portion of the total.

However, if reporting using method 1, the calculation of emissions does account for the proportion of the gas mix which is reportable. The total quantity of emissions or as known in the NGER Determinations as the Stock value, reflect the proportion of the total gas that is made up of reportable gas(es) by the individual global warming potential of those gas(es).   To calculate the volume of emissions that is reportable, the stock value is multiplied by a leakage factor as per 4.102 of the NGERs Determinations.

Lastly, it is important to note that the refrigerant gases used in your plant may change over time. Under the Montreal Protocol some types of refrigerant gases are being gradually phased out, and new ones introduced. The gas used in your refrigerant plant may be changed during servicing or maintenance, and this change will result in a change in to your emissions.  Hence, what was reported last year, may not be true this year.


Contact us

For help on reporting your refrigerants, or assistance in complying with your NGER requirements, contact Claire Bright or Ndevr Environmental on (03) 9865-1400.


Published in Blog
Wednesday, 20 August 2014 14:00

EERS Up and About

The Emissions and Energy Reporting System (EERS) for the 2014 NGERs reporting season is now up and running after an extended upgrade period. Users are now able to enter data, generate drafts and submit reports as required under NGER Section 19 and Section 22 (liable entities) for the 2013/14 reporting period.

We have noted there are still some issues plaguing the system. Some users have found that generating drafts can take longer than usual (up to a few days). This, coupled with a feature in EERS which now prevents data entry when a draft report has been generated means users may find themselves unable to modify EERS data for an extended period of time after generating a draft report. Once the report is generated, users can go in to ‘unlock’ the report and continue data entry.

If you are experiencing any difficulties you can contact the Clean Energy Regulator support team on 1300 553 542

Published in Blog
Thursday, 17 July 2014 14:28

Reporting Materiality - NGERS 2014

Materiality thresholds for 2013/14 reporting year have changed. From July 2013 Reporters have been required to apply updated thresholds to their data capture and management strategies. The purpose of the changes is to reduce the reporting burden for key materials, namely petroleum based oils and greases, liquid, gaseous and solid fuels.


Table 1. New Materiality Thresholds for 2013/14

Fuel type

Threshold per instance of a source

Measurement Determination section

Petroleum-based oils and greases (other than used as fuel)5,000 LDivision 2.4.1, section 2.39(a)
Other liquid fuels (not mentioned in s2.39(a))1,000 LDivision 2.4.1, section 2.39(b)
Gaseous fuels1,000 m3Division 2.3.1, section 2.18
Solid Fuels1 tonneDivision 2.2.1, section 2.2


Implications for reporters

These changes to the materiality thresholds will see a more streamlined NGERs 13/14 reporting process as reporters will be able to exclude reporting certain materials if they fall under the specified thresholds.

For example, reporters who consume less than the 5000L of oils and greases per instance of a source will no longer have to mandatorily report the consumption of these substances. Nevertheless, it is recommended that estimates for the quantities of substances consumed be quantified to ensure whether thresholds are tripped or not.

Reporting of immaterial amounts

Reporting fuel combustion and the associated energy consumption related to a separate instance of a source are optional if the amount combusted is less than the reporting thresholds set out in Table 1.

'Separate instance of a source' is defined in section 1.9A of the Measurement Determination as:

"If two or more different activities of a facility have the same source of emissions, each activity is taken to be a separate instance of the source if the activity is performed by a class of equipment is different from that used by another activity."

For example:

The combustion of liquid petroleum gas (LPG) in the engines of distribution vehicles and the combustion of LPG in the engines of forklifts at any given facility are taken to be a separate instance of a source as the class of equipment used to the perform the activities are different. This is so even though the activities have the same source of emissions, namely the combustion of LPG fuel.

Discerning Materiality

Determining whether or not a particular NGERs reportable substance will trip thresholds can be undertaken in a variety of ways. Consulting historic datasets and NGER reports will show reporters if substances have met or exceeded thresholds in previous reporting periods. Undertaking representative-sampling and applying the results across similar operations can also provide robust estimates to reporters as to whether particular substances will breach thresholds. Finally, reporters may choose to directly measure the consumption for the reportable items in question and report remissions regardless of whether thresholds have been breached.

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The department has also released a position paper outlining their proposed changes to streamline reporting under the NGERs scheme. The proposed changes aim to cut requirements for reporting uncertainty, create new materiality thresholds for reporting certain types of fuel combustion, facilitate and encourage an increased use of existing streamlining provisions and clarify where reporters under NGERs are able to move between methods of measuring emissions.

The position paper, additionally, seeks to address issues raised in the public consultations of the consultation paper Efficiency of Reporting under the NGER scheme. Submissions for this process closed the 1st of February 2013. Table 1 details the most important issues raised in the consultation process and the Department’s proposals to address these issues.

Table 1. The Government’s proposed approach to key issues raised in the consultation process (Department of Industry, Innovation, Climate Change, Science, Research and Tertiary Education, 2013)


Proposed approach

1. Reporting of statistical uncertainty
Reporters do not see the value in their statistical uncertainty calculations and consider that the calculations are time consuming and that audit of those calculations is expensive.

Changes to the NGER Regulations will require only reporters with the largest sources of emissions (25,000 tonnes of CO2-e or over) to calculate and report the statistical uncertainty associated with emissions reporting.

2. Reporting of immaterial amounts
Reporters consider that a disproportionate amount of their reporting expense is incurred in calculating and reporting data that is immaterial to reported totals.

The Measurement Determination will include new materiality thresholds for certain types of fuel combustion. This will remove the need to report on very minor amounts of emissions and energy consumption from these sources.

3. Reporting by percentage or by estimate
Less than 10 per cent of reporters use existing streamlining provisions. Many reporters are not familiar with the provisions, are unsure of how to use them in practice, or the practical constraints placed around their use make them less attractive.

Changes to regulations 4.26 and 4.27of the NGER Regulations – which are designed to reduce reporting costs for very minor amounts of emissions or energy – will make them more readily available to reporters through amended thresholds.

4. Availability of methods
Reporters would like greater freedom to move between measurement methods, particularly when a method has been applied incorrectly or the measuring equipment is unavailable because of mechanical or technical difficulties.

Amendments to the Measurement Determination will allow more flexibility when choosing the method that can be used when a reporter’s previous measurement method has been unintentionally applied incorrectly. The rules regarding the allowed period of down time when measuring equipment is unavailable will be clarified.

5: Reporting by facility aggregate
Reporters would like greater flexibility to aggregate information by removing the requirement that only data for facilities in the same State/Territory and same industry can be reported in aggregate.

The ‘same State, same industry’ rule will be retained. The data is needed to meet the legislated objectives of the NGER Scheme, for example the Clean Energy Regulator must share with state and territory governments NGER information within their jurisdictions. However, in certain circumstances reporters will be provided with the option of reporting single small facilities by reference to a business unit.

6: Reporting about contractors
Many reporters find it difficult and costly to collect data from contractors responsible for emissions or energy use at the reporters’ facilities. Collecting information from small contractors can be particularly difficult.

The obligation to collect and report data from all contractors whose activities form part of the emissions or energy from a facility will be retained. However, the threshold changes in response to issues 2 and 3 above will assist with more efficient reporting of contractor activity.


By releasing the draft amendments, the Department is hoping for feedback on the practical operation and application on the amendments and whether they will achieve the Department’s proposed aims of streamlining of the NGER reporting process. Additionally, the Department is hoping to determine the consistency of the amendments with the current requirements of the NGER Scheme.

This is the last consultation before the finalisation of the draft NGER Amendment Regulation which is expected to be in made in June 2013. The Department will accept feedback submissions until 7 June 2013.


Department of Industry, Innovation, Climate Change, Science, Research and Tertiary Education, 2013, NGER Reporting Efficiency Streamlining – Reporting under the National Greenhouse and Energy Reporting Scheme, Commonwealth of Australia

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The Department of Industry, Innovation, Climate Change, Science, Research and Tertiary Education has developed a consultation draft to facilitate discussion and obtain feedback on the proposed National Greenhouse and Energy Reporting (Measurement) Amendment Determination 2013 (No. 1).

The draft Amendment Determination details updated methods and changes to calculation methods of Greenhouse Gas emissions associated with Coal Seam Gas exploitation, solid waste disposal on land and a revised emission factor for fugitive emission from brown coal mining. The Amendment Determination also seeks improvements for streamlining company reporting and incorporates responses from previous consultations.

Feedback will be received by the department until the 6h of June 2013.

Published in Blog

In some circumstances emissions from petroleum based oils and greases (PBOGs) may be considered ‘covered emissions’ under the Carbon Pricing Mechanism (CPM) attracting the $23 per tonne of carbon dioxide equivalents (tCO2-e) liability.

An example of where PBOGs may be covered emissions is at a ‘directly liable large gas consuming facility’ (covered emissions greater than 25,000 tCO2-e) that also has a vehicle fleet carrying out ancillary activities and consuming PBOGs in the process.

It is assumed that in many circumstances oils and greases used for lubrication purposes (particularly in internal combustion engines) will partially oxidise, or combust, and release CO2-e into the atmosphere. Subdivision 2.40A of the NGER (Measurement) Determination 2008 contains the methodologies for estimating emissions from PBOGs, and there are a couple ways to approach the task. The default method assumes ~40 per cent of the PBOGs will be combusted.

There may be instances where PBOGs are being utilised and do not produce emissions, for example hydraulics etc. Our advice (based on discussions with the Clean Energy Regulator – CER) is if you believe no oxidisation occurs in some or all applications, you should have some supporting evidence or documentation.

We thought it would be pertinent to advise our clients and friends of this issue well before the section 22A reports for covered emissions are due (31 October), as PBOGs are typically small emission sources and usage data can be difficult to obtain.

Remember, this direct ($23/ tCO2-e) liability only applies at facilities captured under the CPM. NGER reporters have always been required to report PBOGs in similar circumstances as described above under the normal section 19 reports, also due 31 October.

We understand the CER is likely to release some explanatory material shortly, and if/when this is published we will notify our clients and friends and provide a link. In the meantime feel free to contact us directly if you would like any further information or clarification.

Disclaimer: this article should be considered general information only and not formal legal advice.

Published in Blog

Another NGERs Season Over! Highlights, Lowlights and What's Next...

With the 31 October NGERs deadline been and gone we thought it would be timely to congratulate all our clients and friends the successful submission of the 2012/13 reports!

From our perspective some of the highlights and ‘not-so-high – lights’ were:


  • The new Emissions and Energy Reporting System (EERS)
    • We found the system quite intuitive and for the most part functionality from its predecessor OSCAR, has improved
  • Expanded mandatory audit requirements for large liable emitters
    • The mandatory audit regime has expanded significantly under the Clean Energy Act
    • These audits are an important governance control and underpin the veracity of the reported liable emissions
    • Audits also provide for liable entities to continually improve their response to this complex program under both NGERs and the Clean Energy Act
  • Clean Energy Regulator (CER) Support
    • We found the CER was well resourced and officers had a strong working knowledge of the legislation
    • In the final weeks the CER was calling reporters yet to lodge to ensure they were on track to submit by 31 October. A great approach to engage the reporting community and encourage compliance
    • ‘CER Best and Fairest’ – we’d like to nominate Thomas Hodgson as the 2013 ‘CER Best and Fairest’. Thomas provided some invaluable advice to us and our clients on some complex issues efficiently and professionally during the final stages of the reporting period.
  • The NGER report submission process
    • We found the actual report submission process with regard to CEO equivalent sign-off and the ability to nominate others to submit on the CEO’s behalf was an improvement on past requirements
    • Also the flexibility and functionality with the EERS Client Portal was great
  • The Carbon Farming Initiative (CFI)
    • We have been quite busy on the CFI front, and the program is providing some fantastic Kyoto compliant offset opportunities – currently over 2.7M ACCU’s have been generated


  • EERS
    • Contained quite a few bugs and inexplicable error messages. It’s no fun watching a CEO get error after error as they try to submit a final report!
    • EERS was not ready until quite late in the reporting period, after an initial proposed launch date of April 2013 – adding pressure on reporters and advisors, especially those with large and complex inventories
    • Training could/should have been advertised and implemented further and wider
  • The imminent repeal of the Carbon Pricing Mechanism
    • In our opinion the current mechanism represents our best opportunity to meet 5% carbon reductions by 2020 at the lowest cost for our clients – particularly under an internationally linked ETS from 2014/15
    • The Direct Action Plan (DAP) is not looking quite so promising, and a lot of great work (from policy developers, Regulators and liable entities) will likely be lost post 2013/14.
  • The loss of one of our best and brightest public servants
    • Blair Comley former head of the former Department of Climate Change and Energy Efficiency, has been lost to the Australian Public Service (APS) under the change of government
    • Having worked under Blair as a policy advisor and regulator, Matt Drum found him to be one of the most intelligent and hard-working professionals you could ever hope to meet. His knowledge of the carbon and energy policy arena will be sorely missed.

What’s Next?

DAP consultation is now in full swing. The terms of reference for the ‘Emissions Reduction Fund (ERF)’ are out – with submissions due by 18 November.  The Green Paper is due in December 2013 with the White Paper following in early 2014.

We are heavily involved in the consultation process with the Department of Environment Taskforce (charged with the policy design) and the Carbon Market Institute. Some of the critical issues we want to see some clarity on include:

  • How will the proposed ‘baseline, credit and penalty’ approach work?
    • Who will be liable? i.e.
      • Will it be 100% voluntary opt-in?
      • Will all NGERs reporters be liable (approximately 750)?
      • Will only those liable under the carbon price (approximately 370) of NGER reporters be liable
    • How will baselines be set?
      • At the corporate, facility, sectoral or activity level?
    • How will penalties be applied where baselines are exceeded?
      • Will international offset units be available to meet penalties?
      • Will penalties be financial in nature?
    • How will the audit and verification regime be implemented?
  • How will the CFI operate and how will demand for ACCUs be maintained?
    • Will energy efficiency savings be incorporated and if so how will these be aligned to Kyoto requirements and how will ‘additionality’ be applied?
  • How will the ERF and reverse auction process operate?
    • Who will be eligible?
    • How will payments be made? Type and timing?

If you have any other items of interest, or key questions, please let us know and we can feed these into the consultation process and report back.

Materiality for 2014 NGERs

Materiality thresholds for 2013/14 reporting year have been included. Reporters need to apply these to their data capture and management strategies going forward in order to reduce the reporting burden. Please see below an overview of the amendments taken from the CER website:

Reporting of immaterial amounts

The following amendments have been incorporated into the Measurement Determination and they apply from 1 July 2013.

Reporting fuel combustion and the associated energy consumption related to a separate instance of a source are optional if the amount combusted is less than the reporting thresholds set out in Table 1.

‘Separate instance of a source’ is defined in section 1.9A of the Measurement Determination as:

“If 2 or more different activities of a facility have the same source of emission, each activity is taken to be a separate instance of the source if the activity is performed by a class of equipment different from that used by another activity.”

For example:

The combustion of liquefied petroleum gas in the engines of distribution vehicles of the facility operator and the combustion of liquid petroleum fuel in lawn mowers at the facility, although the activities have the same source of emissions, are taken to be a separate instance of the source as the activities are different and the class of equipment used to the perform the activities are different.

Reporting of electricity consumption at a facility is optional if the amount consumed is less than 20,000 kilowatt hours. The amount of 20,000 kilowatt hours was chosen because it is more than the average amount of electricity consumed by a 6 person household in Australia.

Table 1: Materiality Thresholds
Fuel typeThreshold per instance of a source
Petroleum-based oils and greases5,000 L
Other liquid fuels1,000 L
Gaseous fuels1,000 m3
Solid Fuels1 tonne


Australian Institute of Environmental Accountants (AIEA) 2013 Annual Conference – Registrations Closing Soon!

The AIEA conference will be held in Fremantle WA on 28 and 29 of November 2013. The Conference is a great event for those involved ‘on the ground’ in the carbon, energy, pollution and water reporting and management fields. Please click here for further information.

Published in Blog
Friday, 22 November 2013 11:57

EEO, CFI and NGER Latest News

EEO Updates

Highlights of November 2013 Newsletter

The latest Energy Efficiency Opportunities (EEO) newsletter can now be accessed from the EEO website. Some key information includes the achievements that Linfox, the largest trucking and logistics corporation in the Asia Pacific, has obtained by participating in the EEO Program. The corporation’s commitment to cut 50 of its 2006/07 emissions by 2015 is certainly admirable.

EEO participants are also encouraged to visit the findings of ClimateWorks Australia’s research project, Tracking Progress Towards a Low Carbon Economy, to gain a snapshot of most promising opportunities across different sectors and industries.

The Department of Industry is also seeking feedback with regards to the new reporting template (Excel Spreadsheet) and requesting participants to accompany a draft version of the spreadsheet along with other documentation before final submission. See our earlier post for further information.

The new online portal, EEO Net, is scheduled to be fully operational by the end of November. Participants will be notified of the date and activation instructions will be emailed to the EEO contact person.

The 2013 National Conference organised by the Energy Efficiency Council will be held on the 3rd and 4th of December in Melbourne. For further information and special offers for EEO participants, please visit the EEC website here.

The Commonwealth Government is also seeking input from the EEO participants with regards to design of the Emissions Reduction Fund (ERF) for inclusion of potential options of low-cost abatement.

CFI Updates

The Clean Energy Regulator is planning to hold a series of workshops in the first half of 2014 on the sequestration group of methodologies. For more information and registration, please visit the Regulator’s CFI events webpage.

The Regulator is also urging project proponents who are currently operating under the following schemes to request for transition into the Carbon Farming Initiative if they believe their project may be eligible:

  • Commonwealth Government’s Greenhouse Friendly TM initiative;
  • NSW Government’s Greenhouse Gas Reduction Scheme;
  • ACT Government’s Greenhouse Gas Abatement Scheme;
  • Verified Carbon Standard administered by the VCS Association

NGER Updates

The Regulator published emissions numbers reported by liable entities last week. Liable entities are required to purchase and surrender enough eligible emissions units to match the emissions number by 3 February 2014.

In addition, according to the Regulator, 10% of the reporters failed to fulfill their reporting obligation by 31st of October versus the 12% non-compliance rate in the last reporting year.

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