In April 2026, the Department of Climate Change, Energy, the Environment and Water (DCCEEW) opened public consultation on proposed amendments to the National Greenhouse and Energy Reporting (NGER) scheme, scheduled to take effect from 1 July 2026. The consultation forms part of the annual continuous improvement process for the NGER framework, which underpins greenhouse gas (GHG) reporting obligations and the operation of the Safeguard Mechanism for facilities across the mining, oil and gas, industrial, energy, waste and infrastructure sectors.

SLR works extensively with NGER reporters and Safeguard Mechanism facilities, supporting clients with emissions estimation, reporting, audit readiness, method development, GHG assurance and decarbonisation strategy. We were pleased to provide a submission drawing on this experience.

SLR supports the overall direction of the proposed amendments. Together, they improve alignment with contemporary science, strengthen emissions integrity, support low-carbon fuel pathways, and resolve several long-standing methodological and clarity issues, while keeping continuity with existing regulatory objectives. Some changes, however, would benefit from additional guidance, worked examples and transitional support to help implementation across facilities.

To help ensure the amendments are workable in practice, our submission included several key recommendations and observations, drawing on our experience supporting clients across NGER-covered sectors:

  • Publish detailed implementation guidance and worked examples for certificate-backed reporting of co-processed liquid fuels, including how to handle mixed fuel inventories, fuel blending, partial certificate coverage and chain-of-custody issues.
  • Support the expansion of Method 2B for flaring across additional gas chain segments, while keeping flexibility for facilities to apply alternative higher-order methods where site-specific constraints make Method 2B impractical.
  • Provide practical guidance and worked examples for the revised landfill gas Method 2, including the updated flux box and chamber measurement framework and the replacement approach for the collection efficiency limit.
  • Ensure tighter method unavailability and continuous emissions monitoring requirements do not place a disproportionate compliance burden on facilities with intermittent, seasonal or highly variable operating profiles.
  • Allow sufficient lead time for facilities to update systems, metering, data collection and assurance processes before the amendments take effect, and consider an initial compliance period in which reporting errors can be corrected without enforcement consequences.
  • Maintain flexibility within higher-order methods, including Method 2 for open-cut coal mines, where coal basins, geological settings and mine designs differ materially.

SLR is pleased to have contributed to this consultation and looks forward to continued engagement with DCCEEW as the proposed amendments are finalised. We also welcome ongoing involvement as the broader NGER forward work program develops, including the review of Method 2 for open-cut coal mines, the Expert Panel on Atmospheric Measurement of Fugitive Methane Emissions, and the Controlled Methane Release Study.

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