Submission: Proposed updates to the National Greenhouse and Energy Reporting (NGER) scheme

10 April 2025

To: Department of Climate Change, Energy, the Environment and Water
Re: Proposed updates to the National Greenhouse and Energy Reporting (NGER) scheme

The Institute for Energy Economics and Financial Analysis (IEEFA) is grateful for the opportunity to present its submission to the 2025 Public Consultation on the National Greenhouse and Energy Reporting (NGER) scheme. IEEFA is an energy finance think tank that examines issues related to energy markets, trends and policies. The Institute’s mission is to accelerate the transition to a diverse, sustainable and profitable energy economy.

IEEFA is generally supportive of the proposed 2025 amendments and encourages the urgent review of Method 2 in coal mining sector. On reviewing the proposed 2025 amendments and the NGER forward work plan, IEEFA recommends:

• Renewable fuels: IEEFA supports the adoption of market-based reporting of emissions from consumption of biomethane and hydrogen, if it is accompanied by a robust measurement, reporting and verification (MRV) process.
• Fugitive emissions from oil and natural gas operations: IEEFA supports the revised factors for carbon dioxide (CO2) and methane (CH4) emissions (in Method 2) and the proposal that Method 2B is made available for gas flared during natural gas production available to natural gas transmission and distribution facilities.
• Waste: IEEFA supports the proposal enabling reporters to account for biosolids diverted to biochar production and an update to the nitrous oxide (N2O) emission factor for effluent discharged to estuaries, and other minor technical updates to improve clarity and operation of the scheme. 
• Urgent review of Method 2 for open-cut coal mines: IEEFA recommends phasing out of Method 2, in favour of Method 3, with its improved sampling and independent verification requirements. This should be paired with a more rigorous approach to gas estimation modelling. In addition, top-down methods from aerial or satellite monitoring should be adopted to verify coal mine methane emissions.

Please do not hesitate to contact us for any further information.

Kind regards,

Andrew Gorringe – Energy Finance Analyst, Australian Coal 
Kevin Morrison – Energy Finance Analyst, Australian Gas