National Greenhouse and Energy Reporting (NGER) Scheme

9 April 2025
Department of Climate Change, Energy, the Environment and Water
Via: https://consult.dcceew.gov.au/

National Greenhouse and Energy Reporting (NGER) Scheme 2025 Public
Consultation

Energy Networks Australia (ENA) welcomes the opportunity to provide feedback on
DCCEEW’s National Greenhouse and Energy Reporting (NGER) scheme 2025
Public Consultation.
ENA represents Australia’s electricity transmission and distribution and gas distribution networks. Our members provide over 16 million electricity and gas connections to almost every home and business across Australia.
1. Proposed 2025 Amendments: Market-based reporting of emissions from
consumption of biomethane and hydrogen
Renewable gas is a low emissions substitute for natural gas. To enable the market for renewable gas to mature it is essential that these gases – biomethane and hydrogen – are certified and recognised for the emission reductions that are generated by their use. ENA applauds the Government’s commitment to developing market-based reporting for biomethane and hydrogen. Additionally, ENA commends the consultative process that has been undertaken by the Department.
ENA is generally supportive of the proposed amendments and considers that these changes will support the renewable fuels markets and assist Australia to reach its climate targets.
ENA and other stakeholders have advocated for more flexible ‘market-based’ accounting approaches. Such approaches will enable full and exclusive attribution of the scope 1 emissions from their renewable gas purchased, even if the gas purchased is distributed through the natural gas network and physically consumed by multiple entities.
ENA’s response to the Design of the proposed gas market-based arrangements is below. It is worth noting that ENA is identifying some issues with the proposed arrangements. However, it is considered that further discussion of these issues should not stall the implementation of the proposed arrangements.

Mandatory, certificate-backed approach
The completion or retirement of an eligible renewable gas certificate by an
NGER scheme reporter, or on their behalf, enables them to fully and
exclusively reflect the scope 1 emission attributes of the renewable gas
represented by the certificate in their scope 1 emissions reporting.

Energy Networks Australia Unit 5, Level 12, 385 Bourke Street, Energy Networks Association
energynetworks.com.au Melbourne VIC 3000 T/A Energy Networks Australia
info@energynetworks.com.au +61 3 9103 0400 ABN: 75 106 735 406
Two types of certificates will be recognised:
• Product Guarantee of Origin certificates; and
• Renewable Gas Guarantee of Origin certificates, issued under the
GreenPower Renewable Gas Certification.
ENA Supports this approach.

Temporal link requirement
Eligible renewable gas certificates must represent renewable gas that was
injected into the natural gas network during the reporting year in which its
attributes are being reported.
This timing is inconsistent with the GreenPower Renewable Gas Certificates
which have a lifetime of 39 months (as opposed to the 12 months in the
Discussion paper). This may cause a distortion in the market.
It is not representative of how the gas market works. Pipelines can store gas
for extended periods based on capacity, pressure and demand requirements.
Gas entering the network is not always immediately consumed.
Certificates will be worth less as the end of the NGERs reporting year
approaches. This may cause a distortion in the market as certificates
generated at the beginning of the reporting year may be worth more than
those generated at the end of the reporting year, when there is less time to
present them.
This policy proposal is inconsistent with other Government schemes, for
example the Safeguard Mechanism where credits can be stockpiled for an
indefinite amount of time. There is significant experience in certificate-based
schemes that showing that the ‘banking’ of certificates across compliance
years leads to stability in pricing, which is essential to underpin investments to
deliver on the ultimate policy goals of the scheme.
ENA suggests that NGERs align fully with the GreenPower Certificate
process, i.e. link the Renewable Gas Certificates with GreenPower’s 39
months vintage.

Reasonable physical link requirement
Eligible renewable gas certificates used for market-based reporting must
represent renewable gas that could reasonably pass from its injection point
into the natural gas network to the NGER facility reporting its attributes.
ENA supports this.

Energy Networks Australia Unit 5, Level 12, 385 Bourke Street, Energy Networks Association energynetworks.com.au Melbourne VIC 3000 T/A Energy Networks Australia info@energynetworks.com.au +61 3 9103 0400 ABN: 75 106 735 406
Biomethane displacement ACCU requirement
It is proposed that eligible renewable gas certificates used for market-based
reporting must not represent renewable gas in respect of which a biomethane
ACCU has been surrendered for the purposes of reducing the net emissions
number for a facility with obligations under the Safeguard Mechanism.
ENA supports this.

Accounting for pipeline loss
Renewable gas certificates represent an amount of renewable gas produced
and injected into the network, some of which will be lost as pipeline fugitives
as the gas moves through the network to a consumer.
The department intends to apply a loss factor to account for these pipeline
transport losses.
• The loss factor for biomethane is 1 per cent.
• The loss factor for hydrogen is 0.9 per cent.
Gas losses transported by a gas distribution network are treated differently
from the transport of electricity, where losses are accounted in the electricity
settlement process.
• Pipeline network operators have an obligation to replace lost gas,
through Unaccounted for Gas (UAFG), and customers are credited for
the full amount of gas purchased.
• NGER scheme reporting includes fugitive emissions in the form of
UAFG and therefore captures total emissions from the network.
• The allocation of renewable certificates incorporating a loss is not
consistent with the current approach, resulting in customers incurring a
loss in certificates as well as network operators replacing the loss in
their UAFG purchase (including biomethane).
There is the potential for fugitives to be double-counted or overestimated in
the proposed discussion paper.
ENA suggests that the Government remove the loss factor component and
align with the current reporting framework.

2. NGER forward work program
The priorities in the forward work program show a clear desire to improve understanding of fugitive emissions. ENA’s gas distribution businesses are interested in the same and have already undertaken steps to onboard technologies to better understand and report emissions from gas networks.

Energy Networks Australia Unit 5, Level 12, 385 Bourke Street, Energy Networks Association
energynetworks.com.au Melbourne VIC 3000 T/A Energy Networks Australia
info@energynetworks.com.au +61 3 9103 0400 ABN: 75 106 735 406
ENA proposes that Method 4 is developed and implemented for inclusion in the
NGER (Measurement) Legislation division 3.3.8. The goal for Method 4 would be to allow gas distribution networks to fully realise the emission reduction benefits of actively detecting and remediating sources of fugitive gas loss.
We acknowledge that Method 2 in the present iteration of the NGER (Measurement)
Determination allows for asset specific emission factors from the API Compendium, and that there is some scope to fine tune emissions reporting via increased granularity of asset classification and matching to favourable emission factors.
However, this process is ultimately limited in that it can only be progressed to the extent allowed for by the type and count of assets themselves. Once the process of matching asset to factor is complete (meaning the lowest emission factor that can be plausibly selected has been made), there is no further scope to reduce reported emissions. The Methods do not allow for the benefits of an operationally active Leak
Detect and Repair (LDAR) program or other active leak management program to be captured.
Given the limitation on reporting and receiving credit for the reduction of emissions for gas distribution facilities under their Safeguard Mechanism obligations we propose to learn from and adapt implementations of suitable methods from peer jurisdictions.
ENA and its members would welcome the opportunity to develop Method 4 with
DCCEEW.

If you would like to discuss the contents of this submission, please contact Terese
Weber, Renewable Gas Policy Manager at tweber@energynetworks.com.au .
Yours sincerely,

Dominic Adams
General Manager - Networks

Energy Networks Australia Unit 5, Level 12, 385 Bourke Street, Energy Networks Association
energynetworks.com.au Melbourne VIC 3000 T/A Energy Networks Australia
info@energynetworks.com.au +61 3 9103 0400 ABN: 75 106 735 406