{"data":{"id":"sbm3c9b2bf13ebff5712526b","short_id":13,"created":"2026-05-08T00:53:38.750Z","space_id":"spc3b9aaeac473f68dfbbe14","project_id":"prj3b9a86ba78d82ca6d5958","org_id":"org20ee740c8b3c21feb3566","content":{"23zvek0s":"fil3c9b2b98cc9d77665102a","f22e9n0y":"yes","zovp5q48":"Woodside Energy","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":{"fil3c9b2b98cc9d77665102a":{"id":"fil3c9b2b98cc9d77665102a","bucket":"files-au-climate","remote_path":"climate-au/p/prj3b9a86ba78d82ca6d5958/submission/spc3b9aaeac473f68dfbbe14/Woodside_submission_National_Greenhouse_and_Energy_Reporting_NGER_Scheme_2026_Public_Consultation_8_May_2026.02f3167a.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj3b9a86ba78d82ca6d5958/submission/spc3b9aaeac473f68dfbbe14/Woodside_submission_National_Greenhouse_and_Energy_Reporting_NGER_Scheme_2026_Public_Consultation_8_May_2026.02f3167a.pdf","filename":"Woodside submission - National Greenhouse and Energy Reporting (NGER) Scheme - 2026 Public Consultation - 8 May 2026.pdf","transcribed":"Please direct all responses/queries to:\nPeter Metcalfe\nVice President Climate, Sustainability & Energy Policy\nE: peter.metcalfe@woodside.com\n\nWoodside Energy Group Ltd\nACN 004 898 962\nMia Yellagonga\n11 Mount Street\nPerth WA 6000\n8 May 2026 Australia\nT: +61 8 9348 4000\nNational Greenhouse Accounts www.woodside.com\nDepartment of Climate Change, Energy, the\nEnvironment and Water\nGPO Box 3090\nCanberra ACT 2601\n\nSubmission via DCCEEW’s Consultation Hub\n\nTo Whom It May Concern\n\nNational Greenhouse and Energy Reporting Scheme (NGER Scheme) - 2026 Public Consultation\n\nWoodside Energy (Woodside) welcomes the opportunity to comment on the proposed amendments to the\nNational Greenhouse and Energy Reporting (Measurement) Amendment (2026 Update) Determination 2026\n(the Update Determination) and National Greenhouse and Energy Reporting Amendment (2026 Measures No.\n1) Regulations 2026 (the Update Regulations).\n\nWoodside acknowledges and appreciates the Department of Climate Change, Energy, the Environment and\nWater’s (DCCEEW) ongoing efforts to ensure the National Greenhouse and Energy Reporting Act 2007 (Cth)\n(NGER Act) and associated legislation remain fit for purpose.\n\nWoodside supports clear, stable and pragmatic emissions reporting frameworks and recognises the important role the NGER Scheme makes to the integrity and confidence in Australia's greenhouse gas emissions inventories. Central to this integrity and confidence are the review processes that enhance the accuracy and reliability of data reported under the NGER Scheme. Woodside appreciates DCCEEW’s responsiveness to industry feedback.\n\nExamples of reforms that could further enhance the Scheme’s operation include:\n• Strengthening integrity and confidence by allowing reporters to use the methods prescribed by OGMP\n2.0, a global methane measurement management reporting and verification framework, as the basis\nfor reporting directly for NGERS compliance (see Section F).\n• Refining the application of Australia-wide residual mix factors for electricity associated with large -scale\ngeneration certificates so that they deliver more accurate state- or grid-based factors (see Section E).\n\nWoodside’s detailed consultation responses are provided in Table 1 – Woodside’s Recommendations\n(attached). We value ongoing collaboration with DCCEEW and would welcome the opportunity to discuss this submission further.\n\nYours sincerely,\n\nPeter Metcalfe\nVice President, Climate, Sustainability, and Energy Policy\nTable 1: Woodside’s Recommendations\nConsultation Question (selection) Woodside Response\nSection A: Renewable fuels\nGeneral feedback Aligning the renewable liquid fuel framework more closely with a market-based approach, including allowing contractual\n(book-and-claim) claims with appropriate safeguards, rather than requiring exclusive reliance on physical delivery and\nfacility-specific consumption would offer greater flexibility and support growth of the renewable liquid fuels market.\n\nThere is an opportunity to align feedstock emission factors with EU Renewable Energy Directive Annex VI that allows for\nnegative emissions (rather than just zero) for certain production pathways (e.g. biogas from wet manure feedstocks for\nelectricity) in recognition of displacement due to biomethane production and methane conversion to CO2. This would also\nimprove the commerciality of biogas projects and facilitate greater scale and pace of the industry. 1\n\nThe amendments proposed in this consultation relating to co‑processed liquid fuels and bioLPG are welcome; however this\ncould be further enhanced by extending co-processing to biomethane as an enabler of potential bioLNG developments.\n\nTo support consistent treatment across renewable fuels, we recommend aligning the temporal link requirement with\nexisting biomethane provisions, which allow Renewable Gas Guarantee of Origin certificates (RGGOs) to be used within 3\nyears and 3 months (1,185 days) rather than 24 months.2\n\nInvestment could be further encouraged through removal of the east coast/west coast constraint for RGGOs.\nSection C: Oil and gas fugitive\nemissions\nGeneral feedback Regarding the proposed amendments Section C. Oil and gas fugitives’ emissions we welcome:\n1) The change to the calculation of N2O emissions to exclude the oxidation factor.\n2) The extension of the Method 2B calculation method into the proposed natural gas supply chain segments as\ndiscussed during previous engagements.\n\nFurther to this we would like to highlight the following opportunities to improve their implementation in relation to the key\nprinciples of accuracy and comparability as well as enhancing the readability of the Determination.\n1) Extending the Application of Method 2B for Oil and gas fugitives’ emissions from flaring to Section 3.45 to allow\napplication of the method in oil and gas exploration and development, similar to the associated updates to the\nother natural gas segments (i.e via cross-reference to 3.87B). It is noted in the consultation document that this is\nintended however there is no reference to Method 2B in Section 3.45 in the Exposure Draft.\n2) Aligning the calculation of CO2 emissions detailed in Method 2 (section 3.87 which cross-references Division\n2.3.3) and Method 2B (section 3.87B (2) which are the same basis expressed in different ways: emissions per unit\nenergy/mass approach versus ‘carbon-weight fraction of the hydrocarbon component’ approach, respectively.\n\n1\nhttps://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02018L2001-20231120\n2\nhttps://www.greenpower.gov.au/sites/default/files/2025-07/Renewable%20Gas%20Certification%20Rules%20V3.0.pdf\n3) Aligning the calculation of CH4 emissions detailed in Method 2A (Section 3.87A, and exposure draft 3.45A) and\nMethod 2B (section 3.87B(1)) which for the same input data will result in different emissions. This is due to Method\n2B enables a methane-composition-focussed calculation using the weight fraction of methane in the hydrocarbon\nfuel flared, whereas Method 2A (e.g. Section 3.87A) assumes a standardised methane factor for total quantity of\nhydrocarbons as specified in table in subsection 3.86 (2).\n4) Amended nitrous oxide emissions section under 3.45A (3) needs to also recognise that total quantity of\nhydrocarbons (Qh) within fuel type [flared gas] can also be determined in accordance with Method 2B (which has\ndifferent measurement requirements compared to Method 2 prescriptive requirements under Division 2.3.3).\nAdditionally, the proposed Exposure Draft footnote should be slightly amended to allow that Subsection (2) does\nnot have to be used where methane emissions are calculated in accordance with Method 2B. Nitrous oxide\nemission calculation updates proposed in the Exposure Draft for Section 3.45A will also need to be replicated\nacross other segments within the Determination (e.g 3.87A)).\n5) 3.87B Method 2B; suggest adding footnote ‘Note 3’ to clarify: ‘If this method [Method 2B] is used to estimate\nmethane and CO2 emissions, then 3.45A subsection (3) must be used to estimate nitrous oxide emissions’ (i.e.\nwhere total quantity of hydrocarbons Qh is instead estimated in accordance with Method 2B).\n\nNote a simpler approach for consideration may be to detail one calculation set for all the gaseous fuel flare Method 2\ncalculations with a reference that for the alternative method a mass balance calculation may be used. For example:\n• For CO2 Method 2, (Section 3.87).\n• For CH4 Method 2A, (Section 3.87A), or Method 2B (Section 3.87B).\n• For N2O Method 2A (Section 3.87C) – by adding the updated N2O proposed calculation as detailed in Exposure\ndraft (section 3.45A(3)).\n\nIn this section, add the following note applicable for Method 2B (Mass balance approach). Note: “Method 2B is similar to\nMethod 2/2A, however Qh, QCO2 and Qmethane is calculated via mass balance approach as set out in the 2021 API\ncompendium.”\n\nThese updated sections could then be duly cross-referenced throughout the Determination for natural gas fuels segments\n(noting varying EF tables subsection references for N2O and CH4 if standard methane factors are to be used instead of\nQmethane informed by gas composition (see bullet 3)).\nFurther to the proposed amendments we would recommend DCCEEW pursue greater alignment between the NGER\nDetermination methods and international best practice.\nThe Oil & Gas Methane Partnership 2.0 (OGMP 2.0) is the flagship oil and gas reporting and mitigation programme of the\nUnited Nations Environment Programme (UNEP).\n\nAlignment with international best practice such as the methods prescribed by the UNEPs OGMP2.0 reporting framework\ncould include provision of pathways for:\n• The compliant submission of OGMP2.0 Level 5 reports within the Determination, and\n• The adoption of alternative methods and measurement technologies by operators subject to alignment with the\ngeneral principles for measuring emission and energy.\n\nPage 3 of 4\nWe believe that providing options for NGER reporting aligned with OGMP 2.0 would be beneficial for the ongoing integrity\nand confidence in the scheme. We would welcome the opportunity to meet with DCCEEW to discuss how alignment may\nbe realised.\nSection E: Scope 2 emissions from\nconsumption of electricity\nGeneral feedback Refinement of residual mix factors (RMFs)\nWoodside notes that the application of an Australia-wide residual mix factor to electricity associated with large-scale\ngeneration certificates was raised during the NGER Scheme 2023 amendments process, with stakeholders highlighting\npotential misalignment with jurisdiction-specific grid emissions profiles. Since that time, differences in state and grid emission\nintensities have become more pronounced. Woodside therefore recommends that the Department further consider the\ndevelopment of state or grid-specific residual mix factors, particularly where renewable electricity procurement is\ndemonstrably linked to generation within a specific grid. Greater RMF granularity would improve the integrity of Scope 2\nreporting, strengthen alignment with location-based emission factors already used under NGER, and provide clearer\ninvestment signals without undermining overall scheme robustness.\n\nRecognition of variable renewable electricity under the Safeguard Mechanism\nWoodside encourages consideration of how the Safeguard Mechanism and NGER reporting framework can better recognise\nthe emissions value of variable renewable electricity imports, particularly where such imports directly displace\nhigher-emissions generation. In Woodside’s view, providing clearer recognition of variable renewable electricity — including\nwhere supported by storage or firming arrangements — would improve investment signals under the Safeguard Mechanism\nwhile remaining consistent with NGER’s integrity-based accounting principles. Such recognition would support least-cost\ndecarbonisation pathways by encouraging renewable deployment and system integration, rather than favouring specific\ntechnologies or fuels.\nSection F: Other changes\nGeneral feedback Having the option to report methane in line with OGMP 2.0 would allow methane inventories to be reported with a higher\nlevel of confidence where it is material and data is available. We would in principle support the department exploring\nongoing methodology alignment with emergent practices and technologies being developed via OGMP2.0\nAnnex 1. Assigned biogenic\ncarbon content on PGO certificates\nGeneral feedback Woodside considers the proposed methods to be, in principle, broadly suitable for Australia, but their effectiveness will\ndepend on proportionate and flexible application to avoid unnecessary cost or complexity. Higher-order analytical methods\ncan deliver greater precision. However, calculation of bio-fuel contribution on an energy balance (calorific value) basis,\nwhere each fuel is tested at some frequency and the portion estimated in accordance with the NGER Principles, may be\nsufficient for most compliance purposes. Flexibility to use an energy balance calculation where appropriate may better\nsupport timely deployment of biomethane and co-processing projects. Free allocation and flexible mass-balance\nmethodologies therefore have advantages over rigid product-by-product requirements, particularly for integrated facilities.\nClear system boundaries, alignment with NGER and ACCU frameworks, avoidance of duplicative regulation across GO,\nACCUs and the Safeguard Mechanism, and future-proofing for emerging renewable gas and bioLNG markets will enable\ninvestment certainty and regulatory efficiency\n\nPage 4 of 4","size":255532,"redacted":[],"meta":{"name":"Woodside_submission_National_Greenhouse_and_Energy_Reporting_NGER_Scheme_2026_Public_Consultation_8_May_2026.02f3167a.pdf","mime_type":"application/pdf","transcribe_error":null,"transcribe_status":null,"transcribe_queued_at":null,"transcribe_started_at":null},"config":{}}}}}