15 May 2007
Businesses will face increased future obligations to report greenhouse gas emissions if a proposal to change the National Pollutant Inventory ("NPI") is implemented. Public comment is being sought on the proposed changes.
Background
The economic, social and environmental challenges of climate change have been high on the agendas of both the Council of Australian Governments ("COAG") and the Council of the Australian Federation ("CAF"), with a prominent issue being the design of a national emissions trading scheme. COAG has agreed to establish a mandatory national greenhouse gas emissions and energy reporting system, with the detailed design to be settled after the Prime Minister's task group on emissions trading reports at the end of May 2007.
If however the Commonwealth does not introduce legislation in time for the national greenhouse and energy reporting system by 1 July 2008, the States and Territories will require reporting from this date through the NPI as an interim measure.
The proposed triggers that have been drafted for inclusion in the NPI NEPM state that a business entity will have to comply with the reporting threshold for Category 4 substances where the activities of the entity involve the emission of 25,000 tonnes or more of greenhouse gases expressed in carbon dioxide equivalents, or the production or consumption of 100 terajuoles or more of energy in the reporting period.
The business entity will need to assess whether or not it triggers the reporting requirement by amalgamating emissions from all of its facilities. Reporting however will be made on a facility basis to the State in which a facility is located. Low emission facilities can be aggregated with other facilities. Calculation of emissions will need to include emissions from a transport fleet and emissions from offsite electricity generation consumed by the facility.
As a consequence of these developments the NPI NEPM variation project team, in conjunction with the National Environment Protection Council, will include greenhouse gas emissions reporting in the proposed NPI NEPM variation as an option for consideration at the upcoming June 2007 meeting. In preparation for the June 2007 meeting, a series of forums have been scheduled this week to consider this proposal in further detail. The primary focus of the forums will be to explain how the NPI proposal will operate and to receive feedback in relation to the proposal.
Public comments are primarily being sought on the day of the forum - all written submissions must be in by next Monday, 21 May 2007. The tight timeframe is because the NEPC meeting is 1 June 2007.
We can assist if you would like further information in relation to the upcoming forums and more specifically, the proposal to implement mandatory greenhouse gas emissions reporting.
