{"data":{"id":"sbm3c9b161b878f22030662b","short_id":12,"created":"2026-05-08T00:29:47.783Z","space_id":"spc3b9aaeac473f68dfbbe14","project_id":"prj3b9a86ba78d82ca6d5958","org_id":"org20ee740c8b3c21feb3566","content":{"23zvek0s":"fil3c9b15e8f63f837545510","f22e9n0y":"yes","zovp5q48":"BHP","would-you-like-t_08a393":"yes"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3c9b15e8f63f837545510":{"id":"fil3c9b15e8f63f837545510","bucket":"files-au-climate","remote_path":"climate-au/p/prj3b9a86ba78d82ca6d5958/submission/spc3b9aaeac473f68dfbbe14/BHP_comments_2026_NGER_Scheme_updates_Final.37c40846.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj3b9a86ba78d82ca6d5958/submission/spc3b9aaeac473f68dfbbe14/BHP_comments_2026_NGER_Scheme_updates_Final.37c40846.pdf","filename":"BHP_comments_2026_NGER_Scheme_updates_Final.pdf","transcribed":"171 Collins Street\nMelbourne, Victoria 3000\nAustralia\n\nT +61 3 9606 3333\n7 May 2026 F +61 3 9609 3015\nbhp.com\nDepartment of Climate Change, Energy, the Environment and Water\n\nRe: 2026 National Greenhouse and Energy Reporting (NGER) Scheme Updates\nBHP (hereinafter “we,” and “our”) appreciates the opportunity to provide comments in response to the\n2026 National Greenhouse and Energy Reporting (NGER) Scheme Updates consultation paper (2026\nNGER update consultation) published by the Department of Climate Change, Energy, the\nEnvironment and Water (DCCEEW).\nBHP is a global resources company. Our purpose is to bring people and resources together to build a better world. We produce some of the critical resources used in infrastructure, items essential to everyday life, and the global energy transition, and strive to do so responsibly and efficiently.\nWe support the ongoing evolution of the NGER Scheme to ensure it remains fit-for-purpose, internationally credible, and aligned with Australia’s climate reporting and policy objectives. BHP recognises the importance of maintaining a robust, transparent and consistently applied framework for corporate greenhouse gas and energy reporting.\nWe have no specific feedback on the practical operation and application for the proposed amendments outlined in section 1 of the 2026 NGER update consultation.\nWe look forward to the review of Method 2 for estimating fugitive emissions from open-cut coal extraction outlined in section 2 of the 2026 NGER update consultation. We recognise that Method 2 plays a critical role in providing a more site-specific approach to estimating fugitive emissions. A review of Method 2 presents an important opportunity to ensure the method remains scientifically robust, transparent, and aligned with evolving measurement techniques and international best practice.\nWe appreciate DCCEEW’s commitment to continuous improvement with annual reviews as outlined on page 5 of the 2026 NGER update consultation. We have the following feedback on the current practical operation and application that we request the DCCEEW address in the next annual review:\n1. Double-counting of emissions for electricity generated, transferred and consumed within\nan entity or controlling corporation’s group\nThe National Greenhouse and Energy Reporting (Measurement) Amendment (2023 Update)\nDetermination 2023 amended chapter 7 of the National Greenhouse and Energy Reporting\n(Measurement) Determination 2008 (Determination) to introduce a requirement for facilities to\nreport Scope 2 emissions associated with electricity “acquired”.\n“Acquired” is not defined in the Determination and its ordinary meaning results in double-counting\nwhere electricity is generated, transferred and consumed within the same entity or within the\ncontrolling corporation’s group.\nAs a result:\n Scope 2 emissions are required to be counted and reported for electricity transferred between\nfacilities within the same entity or corporate group; and\n when facility-level emissions are aggregated at the NGER registered entity level (or the level\nof the responsible member for section 22X reporting), emissions may be counted more than\nonce, particularly where electricity is self-generated (counted as Scope 1) and consumed\nwithin the same entity or corporate group (counted as Scope 2).\nThis issue is particularly relevant for vertically integrated companies, where electricity is\ngenerated, transferred and consumed within the same NGER reporting boundary.\nAlthough the National Greenhouse and Energy Reporting (Measurement) Amendment (2024\nUpdate) Determination 2024 and its associated Explanatory Statement acknowledge and enable\nidentification of overlap between Scope 1 and Scope 2 emissions for this issue, we consider this\noutcome inconsistent with the intent of emissions accounting and encourage the DCCEEW to:\n clarify the treatment of internally generated, transferred and consumed electricity; and\n amend the framework to remove unintended double-counting at aggregated reporting levels\n(whether for single entities, controlling corporations or section 22X members).\n2. Clarity on national residual mix factor (RMF) application in Western Australia and Off-Grid\nContexts\nUnder Schedule 1, Part 6 of the Determination, the RMF for Western Australia is limited to the\nSouth West Interconnected System (SWIS) only, which is inconsistent with all other States and\nTerritories. This creates uncertainty for entities that consume electricity from sources other than\nthe SWIS, in Western Australia. Under current requirements:\n if one facility within a controlling corporation adopts the market-based method for Scope 2,\nall facilities within that corporation must report using the same method;\n yet the Determination does not clearly specify which RMF applies to:\no the North West Interconnected System (NWIS); or\no off-grid electricity networks, such as the BHP Newman network.\nThis creates ambiguity, and potential inconsistency in reporting outcomes. We encourage the\nDCCEEW to:\n clarify RMF applicability for all Western Australia electricity systems; and\n provide guidance for market-based reporting in off-grid and isolated networks.\n3. Development of State and Territory-Based RMFs\nWe continue to encourage the DCCEEW to introduce state-based RMFs that more accurately\nreflect state-specific grid characteristics. State and Territory-specific RMFs developed specifically\nfor the different electricity systems in which electricity is consumed would:\n improve the accuracy of market-based Scope 2 reporting; and\n better reflect differences in generation mix, grid structure, and renewable penetration.\n\nThank you for the opportunity to provide feedback.\n\nAshley Preston Vice President Climate Change,\nBHP","size":28928,"redacted":[],"meta":{"name":"BHP_comments_2026_NGER_Scheme_updates_Final.37c40846.pdf","mime_type":"application/pdf","transcribe_error":null,"transcribe_status":null,"transcribe_queued_at":null,"transcribe_started_at":null},"config":{}}}}}