Clause 15 of the NPI NEPM requires the occupier to document any alternative estimation technique it uses and to keep the data needed to verify its estimates for as long as the jurisdiction requires. State and territory agencies must take reasonable steps to check the accuracy of reported data, so these records are what a facility relies on if its report is audited.
Key points
- Clause 15 of the NPI NEPM requires verification data to be kept
- Retention periods are set by state and territory law
- WA requires 3 years, NSW 4 years
- Records support audits of reported data
- Keep threshold calculations and approvals
Retention periods
| Jurisdiction | Requirement |
|---|---|
| Western Australia | Verification data kept for 3 years and produced on request. Failure is an offence with a maximum penalty of $5,000 |
| New South Wales | Data used to assess thresholds and make estimates kept for 4 years |
| Victoria | The Environment Protection Regulations 2021 include record-keeping obligations |
What to keep
- Threshold calculations, including substance use, fuel and waste burnt, and electricity consumed.
- The estimation technique and EET manual used for each substance.
- Source data such as monitoring results, fuel records, safety data sheets and production figures.
- Any written approval for an alternative estimation technique.
Why records matter
Information provided solely for the NPI will not be used as evidence in proceedings about other obligations, under clause 26 of the NEPM. False or misleading NPI information can, however, be an offence in its own right under state law, as it is in Western Australia.
A practical approach
Keep records by facility and reporting year, and retain them for the longest period required in any jurisdiction where you report. Store the calculation workbook with the emission factors and manual editions used, so each estimate can be reproduced if the agency asks.
What regulators check
Under clauses 16 and 17 of the NEPM, state and territory agencies must take reasonable steps to confirm the accuracy of reported data and assess its integrity. EPA South Australia describes desktop audits, scheduled site visits and on-site audits. Keep evidence of how the facility boundary was decided, and keep the version of any safety data sheet used, because DCCEEW advises using the midpoint where a sheet gives a range.
References & sources
Primary regulatory documents and authoritative references underpinning this answer.