June 2009 Newsletter - NGER Update
June 30 2009 is the National Greenhouse and Energy Reporting (NGER) scheme's 1st year reporting deadline for the period 2008/09.
Are you Ready?
The first NGER data collection period is coming to a close and companies should now be focusing on finalising and submitting their 2008/09 NGER dataset.
It is important that effective planning is carried out so that reporters (and CEOs) can ensure that complete and accurate reports are submitted by the due date.
Unlike previous reporting programs, companies should be viewing this dataset in the same context as their financials, ensuring that appropriate data checking, and risk management is applied. Companies should also keep in mind that NGER data will be made publicly available.
This may include:
- Planning your key dates between now and 31st October 2009
- Engaging with your CEO on the sign off process
- Finalising your strategy for reviewing your readiness to report, including correct application of the legislation, ability to meet audit requirements and the completeness and accuracy of the dataset
- Determining the process for entering and verifying data within OSCAR
It is important to note that each of these activities takes time and the reporting deadline is at the end of the financial year. Energetics' team of NGER experts can provide the support your business needs to address each of these issues.
Readiness Review for NGER Submission
Corporations and facilities that exceed the NGER thresholds in 2008/09, must register by August 31st 2009 and report by October 31st 2009. Are you confident that your NGER data is complete and compliant with the Regulations?
Energetics provides a tailored service to assess your readiness to report, including reviews of:
- Site boundary definitions and corporate reporting structure
- Emission source definitions and decisions
- Information management system documentation
- Data collection and handling practices
- Technical review of site-specific calculation methodologies
- Desktop review of inventory datasets, including sanity checking against history and industry
- Primary source records and verifiable audit trail
In addition, Energetics can assist with:
- Checking entered OSCAR data against checked and verified inventory data to ensure no clerical errors in a submission or to highlight potential issues with OSCAR
- Identifying issues that require clarification at government level in relation to any aspect of the review, and seek response on these issues.
Feedback can be tailored to the scope and depth of the review, including:
- Prepare dataset-specific feedback reports to highlight issues identified in the data review, including recommended actions to address these issues and ensure compliance with NGER
- Hold on-site, web-delivered, video or teleconferences with dataset owners to discuss findings and recommended actions following the data review
For more information about perparing to report, please contact your Energetics account manager or Robert Sims, Principal Consultant on 02 9929 3911.
Learnings From Recent NGER Online Reporting Workshops
The Federal Department of Climate Change (DCC) recently held a series of workshops on the Online System for Comprehensive Activity Reporting (OSCAR) for NGER.
The workshops introduced the newly developed NGER functionality component of OSCAR to be used by liable entities for NGER reporting by the 31st October 2009. The workshops were hands–on, practical sessions, focusing on the use of OSCAR, with several department staff available for discussing technical and legislative issues.
From attending the workshops we understand that reporting entities will be required to:
- Define a corporate entity structure (group members, facilities, etc)
- Set up users for managing the data and nominate the controlling corporation’s Chief Executive Officer (CEO)
- Set up the list of sources and data streams for each facility, specifying the method and measurement criterion used
- Enter the annual energy consumption and production quantities and emissions where required for each facility, or aggregated facility.
Once data entry is completed, reporting entities must gain CEO sign off of the data within OSCAR by printing out the OSCAR report for signature. Companies need to submit their inventory as a signed hard copy by 31st October 2009.
Key Takeouts From The Session
1) Companies reporting this year should note that reporters will need to prepare their inventory offline prior to transfer into OSCAR
In Energetics' view, OSCAR is structured as a data submission tool, not an ongoing data management tool. The tool is set up to accept final annual figures, and requests only the essential information required under the legislation.
This means that, apart from the simplest organisations with only a handful of sites, reporting entities will need to prepare their inventory using in-house tools, and translate the data into OSCAR at reporting time.
Where higher order methods are being used to calculate emissions, companies must pre-calculate their emissions. OSCAR is configured to accept the final values only (tonnes CO2-e).
Other data management elements that need to be managed internally and not through OSCAR are:
- Evaluating which sites break the facility thresholds and need to be reported individually; as well as aggregating data at state / territory level for multiple facilities that do not meet facility thresholds
- Data entry, checking, error control and storage of the raw data set.
- Linking datasets to primary source records, and establishing and managing an effective audit trail
- Aggregating invoice data (e.g. monthly, quarterly) into annual totals
- Managing and tracking changes to sites and corporate structures, including periods over which operational control applies.
- Tracking and actioning missing data to maintain a complete inventory
- Developing and maintaining routines for estimating incidental sources and higher order methods
- Managing complex calculations that involve a variety of inputs
2) For the first reporting year, all data must be entered manually
The DCC has stated that there is no provision made for submitting or uploading datasets electronically for the 2008/09 reporting year. This will significantly impact reporters in relation to timing, resourcing, and verification of data entered.
Reporters must prepare and enter a range of data, including:
- Corporate entity structure that includes all sites for which they are reporting. For aggregated facilities (e.g. state level aggregation of small facilities), a full list of all included facilities must also be submitted.
- Facility details required include ABN, address, latitude and longitude, and the period for which operational control is being reported.
- Details about joint ventures and partnerships must also be provided.
- Companies can set up a number of users with varying permission levels to view and modify data across the corporate structure.
OSCAR applies Method 1 emissions calculations automatically. Reporters need only input the energy consumed for each source as applicable. However, we recommend that companies calculate their emissions separately, if for no other purpose than to validate OSCAR’s results.
The screens contain basic field validation, however it will be left to reporters to validate that the correct figures have been entered.
Given the limited validation features, users will have to pay careful attention that they are entering the right data against the correct sites and to save changes to data before moving on, as there is no prompting for unsaved data.
3) Continuing OSCAR software development
The DCC will continue to develop OSCAR in the lead up to the first reporting period. It is intended that the tool will be enhanced to include output reports for the data entered and have greater alignment with EEO reporting requirements.
Energetics understands that the inclusion of an automated upload will not occur until after the 2008/09 reporting year has completed, due to the complexity required to incorporate this functionality into OSCAR.
Future Workshops
The DCC is planning to conduct future workshops for registered companies to attend. If you have not registered, the DCC recommends that you do so, in order to be included in key communications and future invitations.
The DCC has drafted a 90-page manual to explain the functions contained within OSCAR. This is available to registered companies.
NGER 2nd Year Reporting 2009/10: New Participants
The 1st of July 2009 represents the commencement of the 2nd year of the NGER Act, in which the corporate reporting thresholds have been lowered. As a result, a new tier of organisations will be required to prepare and submit an inventory for the first time. The inventory will encompass the 2009/10 reporting year and must be submitted by 31st October 2010.
The NGER Act introduced staged process for introducing mandatory energy and greenhouse reporting into Australia. The three reporting years are defined by reducing corporate thresholds that, if triggered, require the corporation to comply with the requirements of the Act.
The corporate thresholds are:
TJ = Terajoule
The facility level threshold remains constant at 25,000 tonnes CO2-e and 100TJ of energy consumption or production.
What this means is that if you have operational control over a facility that triggers any of the facility thresholds, or if your aggregate corporate energy consumption or production or your total corporate emissions trigger any of these corporate thresholds you will need to report annual totals for:
- Energy consumption;
- Energy production; and
- Greenhouse gas emissions.
It is necessary to report all energy and emissions even if you only trigger one of the thresholds.
These lower thresholds will result in a significant increase in the number of organisations that are required to report to NGER. Organisations that that will report on a single facility in the first year, may now need to extend coverage to all sites.
While we expect that the current thresholds will result in total registrations of approximately 400 companies; the reduced threshold is likely to result in an order-of-magnitude more companies being required to register and report.
Companies that have not typically captured detailed energy and greenhouse information in the past will need to deliver robust, defensible and auditable inventories in the short term. This is not a trivial exercise as our experience with the first year reporters has demonstrated.
Getting Ready
Energetics has had extensive experience in assisting companies meet the requirements of NGER for the 2008/09 reporting year. Key lessons learnt from these experiences are:
Our experiences with Australia’s largest energy consumers and producers as well as the major greenhouse gas emitters have shown us that the most often observed gaps in energy and greenhouse reporting systems are:
- Incomplete / insufficient supporting documentation for higher order methods used to determine total emissions and measurement criteria for specific input information.
- NGER specifies strict standards that need to be adhered to e.g. standards for equipment metering and calibration.
- Incomplete coverage of emissions/energy sources and contractors, note that NGER requires that you report everything, not just those streams for which you have information.
- Material variance to other reporting information sets, for example, sustainability report.
- Incorrect use of NGER emission calculation methodologies and incomplete supporting documentation.
- Accidental omission or incorrect reporting of information.
We note that, if these are shortcoming in the systems of the largest companies, they are likely to represent significant gaps in the systems of smaller companies, presenting problems for those that need to report in current or future reporting years.
DCC releases Draft Amendments to the Measurement Determination
The Department of Climate Change recently released a series of draft changes to measurement determination. When finalised, these will apply for the 2009/10 reporting year. The amendments cover a range of topics, including:
- Introducing new definitions and refining others based on industry feedback
- Expanding the coverage of metals and minerals processing
- Revision of available methods, including:
- Treatment of petroleum based products used as lubricants
- Underground coal mines - must use method 4 (direct measurement) for fugitive methane emissions; method 1 to be deleted
- Updating of specific emissions and energy content factors
- Significant revision of the methods relating to onsite landfill and wastewater handling
- Further clarification of uncertainty
- Decoupling the legislation from the UNFCCC category numbering system
The revised Determination is due in June 2009. Energetics recommends that organisations review these changes with respect to their inventory, effects on calculation tools and the impacts on the proposed Carbon Pollution Reduction Scheme.
Further Information
For further information on how Energetics can help you, please contact your Energetics account manager, or:
WA: Brian Innes (08) 9429 6400 brian.innes@energetics.com.au
QLD: Adrian Abbott (07) 3230 8800 adrian.abbott@energetics.com.au
Vic: Roger Horwood (03) 9602 5511 roger.horwood@energetics.com.au
NSW: Robert Sims (02) 9929 3911 robert.sims@energetics.com.au