We recommend that industry participants undertake the following:
- Review the proposed amendments;
- Ensure their measurement and reporting processes will comply with the proposed new methods; and
- Consider making submissions on the proposed amendments before 21 May 2021.
Should an industry participant require further information on the proposed amendments or submissions process please do not hesitate to contact our team.
In more detail
On 5 May 2021, the federal government announced its intention to make amendments to the National Greenhouse and Energy Reporting Regulations 2008 (the NGER Regulations) and National Greenhouse and Energy Reporting (Measurement) Determination 2008 (the Measurement Determination).1 The NGER Regulations outline the requirements for reporting entities under the NGER scheme and the Measurement Determination provides methods for estimating GHG emissions and the production and consumption of energy.
The proposed amendments are expected to commence on 1 July 2021 and will apply to NGER reports that are due to be submitted by 31 October 2022.
New method for hydrogen production facilities
The 2021 NGER Amendments propose to introduce a new method which provides explicit reporting guidance for hydrogen production facilities that rely on fossil fuel feedstocks (e.g. coal, natural gas) to produce hydrogen. The method will apply to facilities with a primary product of hydrogen for use outside the facility (e.g. for use in transport, or international export).
Specifically, the method provides guidance for estimating Scope 1 emissions from steam reforming processes used to produce 'blue' or 'brown' hydrogen. Facilities will be required to report on production volumes by type of production method. The method allows for the deduction of carbon dioxide that is captured and transferred for permanent storage or for use in another facility.
If no fuel Is used as a feedstock in the production of hydrogen (e.g. hydrogen is produced by electrolysis instead), the emissions from the production of hydrogen from the facility will be zero, although we note that other emissions from the facility may need to be reported.
Importantly, this emissions data will provide critical data to hydrogen certification schemes, which the Australian Government is currently pursuing both domestically and internationally in collaboration with the International Partnership on Hydrogen and Fuel Cells in the Economy. The purpose of these schemes is to certify the carbon footprint of hydrogen produced by different facilities.
Inclusion of enhanced oil recovery
The 2021 NGER Amendments propose to require that EOR facilities report on fugitive emissions from the transport of captured carbon dioxide to injection site, and also from the injection of carbon dioxide for the purpose of EOR. This builds on existing methods in Divisions 3.4.2 and 3.4.3 of the Measurement Determination, which provide guidance on estimating fugitive emissions from the transport and injection of carbon dioxide for the purpose of permanent storage (i.e. carbon capture and storage (CCS) operations).
EOR technologies inject compressed carbon dioxide into depleted oil or gas reservoirs to extract more hydrocarbons. A significant proportion of the carbon dioxide injected as part of the EOR process is recovered during the production of hydrocarbon and recycled. Although not currently used commercially in Australia, the amendments aim to allow for EOR to be accurately reflected in Australia's national greenhouse gas inventory should EOR be implemented in the future.2
The 2021 NGER Amendments propose to amend the NGER Regulations by introducing a requirement that the annual reports of EOR facilities include the amount of GHGs captured and imported for EOR, as well as the amount of GHGs injected at EOR sites. More specifically, reports are to include the following information:
- the amount of emissions that occurred during the transportation of greenhouse gases to the enhanced oil recovery site;
- the amount of emissions that occurred when greenhouse gases were being injected into the enhanced oil recovery site;
- the type of the source of the emissions;
- the methods in the Measurement Determination used to estimate the emissions from the source;
- the total amount of greenhouse gases emitted from the source, in CO2-e.
The amendments to the Measurement Determination propose to define EOR as "a greenhouse gas is captured for enhanced oil recovery if it is captured and transferred to the holder of an enhanced oil recovery authority for injection into a geological formation, such as a natural reservoir, to further oil or gas production activities and is not captured for permanent storage (emphasis added)". An "enhanced oil recovery authority" is defined to include a licence, lease or approval under Commonwealth, State or Territory legislation which authorises the injection of greenhouse gases into geological formations to further oil or gas production.
Importantly, the discussion paper expressly states that the proposed amendment "does not imply EOR is a form of permanent geological storage, and does not provide methods for losses of any injected CO2 via leaks in the geological formation, as there are no provisions under existing oil and gas production licencing regimes for such monitoring activities (emphasis added)".3 Accordingly, the amendments do not allow for the deduction of any carbon dioxide that may be permanently stored as a result of EOR activities.
Update for oil and gas fugitive emissions methods
Finally, the 2021 NGER Amendments propose to update existing methods for estimating and reporting on fugitive oil and gas emissions.
The proposed amendments will bring existing oil and gas reporting provisions in line with estimation methods applied in Australia's National Inventory Report submitted under the United Nations Framework Convention on Climate Change and its Kyoto Protocol. They also reflect the latest available research and developments in empirical evidence.4
The proposed amendments will allow reporters to apply per-component ‘leak’ and ‘no-leak’ emissions factors based on the results of Leak Detection and Repair (LDAR) programs applied at specified types of facilities.5 This will allow active leak management efforts to be accurately accounted for.
The specified facilities that may take the results of LDAR programs into account are onshore and offshore natural gas production, natural gas gathering and boosting, natural gas processing, natural gas storage, and natural gas liquefaction, storage and transfer facilities.
The proposed amendments also delineate the different types of emissions sources that may occur within the existing emissions source of "natural gas production or processing". This will enable companies reporting on such facilities to be more specific as to whether leakage or venting/flaring occurred from onshore natural gas production, offshore natural gas production, natural gas gathering and boosting, natural gas processing, natural gas storage, natural gas liquefaction, storage and transfer, or produced water.
The Department of Industry, Science, Energy and Resources are seeking submissions from all interested stakeholders on the proposed amendments. Submissions opened on 4 May 2021 and will close on 21 May 2021.
Any submissions should be lodged electronically via the consultation website (here
) or sent by email to email@example.com
1 Microsoft Word - 2021 NGER amendments- Departmental commentary (industry.gov.au)
2 New NGER guidance proposed for CO2 injection with oil recovery (footprintnews.com.au)
3 Microsoft Word - 2021 NGER amendments- Departmental commentary (industry.gov.au)
4 Microsoft Word - 2021 NGER amendments- Departmental commentary (industry.gov.au)
5 Microsoft Word - 2021 NGER amendments- Departmental commentary (industry.gov.au)