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29 April 2022
Department of Industry, Science and Resources
National Greenhouse and Energy Reporting
Emissions Reduction
Industry House, 10 Binara St
CANBERRA ACT 2601
via online submission portal
ARA SUBMISSION ON PROPOSED CHANGES TO THE
NATIONAL GREENHOUSE AND ENERGY REPORTING
(NGER) SCHEME
The Australian Retailers Association (ARA) welcomes the opportunity to comment on proposed
updates to the National Greenhouse and Energy Reporting (NGER) scheme.
The ARA is Australia’s oldest, largest, and most diverse peak retail body, representing a $360 billion
sector that employs 1.3 million Australians. We represent the full spectrum of Australian retail, from
our largest national and international retailers to our small and medium sized members, who make up
95% of our membership.
The ARA is committed to play a leading role in the development and implementation of a meaningful
sectorial response to climate action, as demonstrated by the launch of our Net-zero Roadmap for the
Australian retail sector and our support of the UN-backed Race to Zero campaign in partnership with
the World Business Council for Sustainable Development.
Our members are equally committed to making an efficient transition to the low-carbon economy of
the future and many of our largest members have been reporting under the NGER framework for
more than a decade.
Following consultation with members of our Sustainability Advisory Committee, the ARA is supportive
of the proposed changes to the methodology for measuring Scope 2 emissions, which we understand
will be reflected in amendments to the Measurement Determination and NGER regulations.
We also understand the proposed changes to the methodology will enable more timely and accurate
collection of information about electricity consumption, which will be broadly welcomed by our
members with a reporting obligation under the NGER scheme.
Thank you again for the opportunity to comment on these proposed updates to the NGER scheme.
Any queries in relation to this submission can be directed to our policy team at policy@retail.org.au.
Yours sincerely,
Paul Zahra
Chief Executive Officer
Australian Retailers Association Level 1, 112 Wellington Parade
ABN 99 064 713 718 East Melbourne VIC 3002
