Submission on NGER Technical Guidelines for Reporting

AEBN responded to the Federal Government’s Technical Guidelines For The Estimation Of Emissions And Energy At Facility Level Discussion Paper which, details the measurement and estimation techniques for greenhouse gases that can be used for reporting under the NGER Act. 4 increasingly accurate levels of measurement approaches are proposed in the paper which AEBN considered conceptually useful.

 AEBN considers there is a need to more formally approve appropriate alternative measurement and estimation techniques than the standard set provided. A similar and useful process for dealing with alterntaive measurement and estimation has been used under the NSW Load Based Licensing scheme. Consequently, AEBN recommends the National Greenhouse and Energy Reporting (NGER) scheme adopt a similar approach for greenhouse gas reporting. AEBN consequently, recommends that an independent scientific panel be formed under NGER. This will enable emitters to approach the panel with alternative measurement and estimation techniques. It will have the advantage of letting industry use alternative approaches which will cut their costs of measurement and or provide more accurate measurements of greenhouse emissions.


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