Clear Carbon - Enterprise Environmental Management Platform

When can NGER criterion AAA use point-of-sale measurement?

NGER criterion AAA can measure a fuel at two points: where it is combusted or consumed, or where it is sold to the facility. Either way, the measuring equipment must be calibrated to a measurement requirement. The NGER (Measurement) Determination 2008 limits when the point of sale can be used.

Key points

  1. Point of sale needs stockpile change under 1% and opening stock under 5%
  2. The conditions apply to solid, gaseous and liquid fuels and carbonates
  3. Point-of-combustion measurement locks in, point of sale does not
  4. Calibration must be traceable to the National Measurement Act 1960 or an equivalent standard

The stockpile conditions

Point-of-sale measurement is available only if both conditions are met for the facility:

  • the change in the stockpile of the fuel for the year is less than 1% of total combustion, and
  • the stockpile at the beginning of the year is less than 5% of total combustion for the year.

The same conditions apply to solid fuels (section 2.16), gaseous fuels (section 2.31), liquid fuels (section 2.52) and carbonates (section 4.37). Liquid fuels are measured at ambient temperature and converted to standard temperature.

Why the choice matters

Measurement at the point of combustion or consumption locks in: once used in a year, only that measurement can be used in later years. Measurement at the point of sale does not trigger the lock-in. A facility with small, stable stocks can therefore rely on calibrated sales meters without committing to on-site metering.

What calibrated means

Section 1.8 defines calibrated to a measurement requirement as calibrated to a specific characteristic, such as a unit of weight, that is traceable to a measurement requirement under the National Measurement Act 1960, or to an equivalent standard. Calibration records for the meter, whether it is on site or at the supplier, are part of the evidence behind the figure.

Practical checks

  • Confirm the opening stockpile and the year’s stockpile change against the 5% and 1% limits every year.
  • Keep the supplier’s calibration evidence when relying on point-of-sale meters.
  • Record where each quantity was measured, because it decides whether the lock-in applies.
  • Re-test the conditions whenever stock-holding practice changes, such as a new storage tank or stockpile.

References & sources

Primary regulatory documents and authoritative references underpinning this answer.

  1. NGER (Measurement) Determination 2008 (sections 1.8, 2.16, 2.31, 2.52 and 4.37)legislation.gov.au
  2. Clean Energy Regulator: Methods and measurement criteria guidelinecer.gov.au