{"data":{"id":"sbm3c9bdce845b89a4e51bd0","short_id":16,"created":"2026-05-08T04:06:56.325Z","space_id":"spc3b9aaeac473f68dfbbe14","project_id":"prj3b9a86ba78d82ca6d5958","org_id":"org20ee740c8b3c21feb3566","content":{"23zvek0s":"fil3c9bdcd57104f3d267bbd","f22e9n0y":"yes","zovp5q48":"Origin 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":{"fil3c9bdcd57104f3d267bbd":{"id":"fil3c9bdcd57104f3d267bbd","bucket":"files-au-climate","remote_path":"climate-au/p/prj3b9a86ba78d82ca6d5958/submission/spc3b9aaeac473f68dfbbe14/ORG_2026_NGERS_update_sub.0ef4f900.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj3b9a86ba78d82ca6d5958/submission/spc3b9aaeac473f68dfbbe14/ORG_2026_NGERS_update_sub.0ef4f900.pdf","filename":"ORG 2026 NGERS update sub.pdf","transcribed":"8 May 2026\n\nNational Greenhouse Accounts\n\nSubmitted online: www.consult.dcceew.gov.au\n\n2026 National Greenhouse and Energy Reporting (NGER) Scheme Updates – Consultation Paper\n\nOrigin Energy Limited (Origin) welcomes the opportunity to provide comments on the Department of\nClimate Change, Energy, the Environment and Water’s (DCCEEW) 2026 National Greenhouse and\nEnergy Reporting (NGER) Scheme Updates Consultation Paper.\n\nIn principle we support DCCEEW's proposed amendments to refine the NGER Scheme, including to recognise additional energy fuels. But these proposed amendments need to be refined further to support efficient, effective and equitable implementation which achieves these aims.\n\nBioLPG and co-processed fuels should be recognised within the NGER Scheme\n\nAs we noted in our 2025 submission on proposed amendments to the NGER Scheme, it is important that all low carbon and renewable energy sources are recognised to support further investment in these fuels which are not yet commercially competitive. This will help support delivery of the Commonwealth’s\nNet Zero Plan which states emerging alternative energy products must be established by 2030 to enable greater uptake of opportunities for fuel-switching by 2035.1 Greater uptake and use of these energy products can be encouraged if they are recognised in emissions reporting methodologies, particularly as there are currently no alternative incentives including through tradeable certificate schemes.\n\nWe support the proposed approach to integrating BioLPG. But there are limitations to mandating product guarantee of origin (PGO) certificates for co-processed liquid fuels under the NGER Scheme which are likely to impede the ability of this approach to facilitate development and uptake of this nascent sector.\nFor example, this approach would effectively mandate the use of voluntary PGO certificates, which carry a relatively significant administrative burden to create. Use of these non-tradeable voluntary PGO certificates for Scope 1, 2 and 3 emissions will also be delayed until DCCEEW has specified methodologies for each process to produce, deliver and use each product.\n\nTo overcome this, and to ensure consistency in how credible unique claims are treated for different fuels under the NGER Scheme, we suggest it would be appropriate to also allow for the emergence of tradeable certificates administered by GreenPower for this mandatory reporting of Scope 1 emissions.\nAlternatively, there is precedent for established international standards to be used until effective, efficient and equitable domestic methods can be developed. For example, the International Sustainability and\nCarbon Certification (ISCC) can be used in the national framework for recycled content traceability2 and the GHG Protocol can be used in mandatory climate-related financial disclosures.3\n\nConsistent with this need to manage the regulatory burden for nascent industries to avoid unnecessary costs and delays, we do not support requiring different allocation of attributed carbon for different products. A more proportionate and practical approach would be to start with a standard mass balance approach for all co-processed products. A transition to more complex arrangements could occur after practical limitations, such as limited volumes and the lack of physical segregation, have been resolved.\n\n1\nAustralian Government, Australia’s Net Zero Plan, 2025, p116\n2\nAustralian Government, National Framework for Recycled Content Traceability Third-Party Certification Scheme, June 2025\n3\nAustralian Government, Greenhouse Gas Emissions Disclosure requirements applying AASB S2, August 2025\n\nPage 1 of 2\n\nOrigin Energy Limited ABN 30 000 051 696 • Level 32, Tower 1, 100 Barangaroo Avenue, Barangaroo NSW 2000\nGPO Box 5376, Barangaroo NSW 2000 • Telephone (02) 8345 5000 • Facsimile (02) 9252 9244 • www.originenergy.com.au\nAmendments of oil and gas fugitive emissions methods must be considered holistically\n\nWe generally support the proposed amendments to refine and align methods for reporting fugitive emissions from the oil and gas sector, such as allowing the use of Method 2B for all activities across the gas supply chain. Additionally, we appreciate the clarification that incidental emissions can be reported using alternative emissions to enable a practical, flexible approach. While the proposed amendments for matters to be identified (MTBI) will increase the administrative burden for reporting entities, these amendments should contribute to a more accurate and consistent reporting framework.\n\nBut some of the broader proposed amendments risk undermining these efforts to improve accuracy and practicality in response to changes in technological, regulatory and market conditions. For example, the proposed amendments for managing temporary unavailability of continuous emissions monitoring\n(CEM) will be challenging to implement as at a given point in time it is not possible to fully assess the percentage of downtime for a source over the reporting year. This is especially the case for non-routine operations and is likely to lead to unnecessary notifications or create the potential for non-compliance with Subsection 1.19(5) at the end of the reporting year. Particularly as Subsection 1.19 obligations is not exclusive to measurements for Method 4 CEM devices or measurement systems.\n\nIt is worth noting that one of the benefits of the current obligation requiring the regulator to be notified after six weeks of downtime is that it is a simple trigger to implement and allows for timely guidance from the regulator on how to manage reporting during this period of downtime. In comparison, if the entity is required to assess their operations over the year, they must choose between notifying instances that may represent downtime periods that could become less than 10% of the relevant operations at the end of the reporting period, or only reporting at the end of the reporting year once operations have been finalised and risk being potentially non-compliant with Subsection 1.19(5). So, there is a trade-off between the regulator managing either an excessive number of incidents or a condensed period of reporting at the end of each year depending on the entity approach taken to implement this change.\n\nThe forward work program could consider opportunities for regulatory reform\n\nIt is helpful to signal topics likely to be considered in the next annual review of the NGER Scheme, including advice from the Expert Panel on Atmospheric Measurement of Fugitive Emissions. However,\nDCCEEW could also consider opportunities for additional reforms that could assist with improving the efficiency of the scheme. This would be consistent with the Commonwealth’s ambition to reduce red tape and ease burden on businesses4 and address the Productivity Commission’s advice it is harder than it should be to start and operate businesses in Australia. 5 For example, the Subsection 3.73J requirement to use the same methodology for all natural gas fugitive emissions other than venting or flaring could be perceived as red tape preventing entities from applying, higher order methods for a subset of natural gas emissions sources when they are unable to adopt similar approaches for all their activities. We would be happy to discuss this topic further if DCCEEW decides to address this issue.\n\nIf you wish to discuss any aspect of this submission further, please contact Clare Stark at clare.stark@originenergy.com.au or on 0458 286 194.\n\nYours Sincerely,\n\nShaun Cole\nGroup Manager, Regulatory Policy\n\n4\nDepartment of Finance, Regulatory reform to reduce red tape and ease burden on businesses website, accessed 1 May 2026\n5\nProductivity Commission, ‘Growth mindset: how to boost Australia’s productivity’, 2025\n\nPage 2 of 2","size":113517,"redacted":[],"meta":{"name":"ORG_2026_NGERS_update_sub.0ef4f900.pdf","mime_type":"application/pdf","transcribe_error":null,"transcribe_status":null,"transcribe_queued_at":null,"transcribe_started_at":null},"config":{}}}}}