A premises-focused gap review can help an existing reporter establish the remaining EPA work before commissioning another inventory.
How do NGER and NSW EPA CCMAP requirements differ?
| Question | Existing reporting may provide | What to check for the EPA |
|---|---|---|
| Reporting boundary | NGER facility and corporate reporting structure | How the reported facility relates to each EPL premises |
| Emissions and energy | Existing activity records, calculations and reported results | Source coverage, boundary explanations and additional required information |
| Operational performance | Production and energy management records | Premises-specific intensity information where required and explanations of significant changes |
| Future operations | Budgets, production plans and approved projects | Forward emissions estimates with documented assumptions |
| Public disclosure | Sustainability reports or existing climate plans | CCMAP content, premises detail, gaps and publication requirements |
This is a work-planning comparison, not a substitute for either scheme’s reporting rules. Start with the EPA reporting guidance, particularly its annual reporting, boundary and existing-plan provisions.[2]
What if the NGER facility and EPL boundaries differ?
EPA guidance does not automatically require an inventory to be rebuilt each time the boundaries differ. It allows the NGER report most closely related to the premises, accompanied by an explanation of the emissions differences arising from the boundaries or operations.[2]
Illustrative example: an NGER facility combines operations at locations A and B, while an EPL covers A. Review whether the combined report can be used with a clear explanation and the extra premises-specific information required, rather than immediately recalculating the entire inventory.
Record the NGER facility, EPL number, locations, sources and material differences in one reconciliation. Confirm how the EPA expects the data to be supplied or accessed for the sites.
What information might still be missing?
The EPA guidance addresses additional premises information even where an NGER report can be reused. Its boundary example includes premises-specific emissions and energy intensity information and explanations for significant reporting-period changes.[2]
Check the following against the actual existing report:
- All relevant sources and activities at the premises.
- Differences in locations, entities or operations covered.
- The reporting period, units and required disaggregation.
- Intensity measures and the basis for production data, where required.
- Reasons for significant emissions changes.
- Forward estimates and the status of mitigation commitments.
For an agricultural site, check whether livestock and manure sources are absent from the NGER inventory. See the agriculture and feedlot guide before treating the existing total as a complete EPA threshold assessment.[3]
Can an existing sustainability report serve as the CCMAP?
Existing disclosures or plans may be used where they satisfy the EPA requirements and are publicly available. Missing elements can be addressed in a published addendum. The information still needs to cover the relevant premises, emissions and mitigation measures.[2]
Assess the public report against a short content matrix: required information, existing reference, premises covered, evidence gap and proposed addition. A group target alone may not explain what is happening at a particular premises.
The initial EPA requirements focus on mitigation. Check the current adaptation position separately before expanding the work into a wider climate risk assessment.
Can one CCMAP cover multiple NSW licensed premises?
EPA guidance allows one CCMAP to cover multiple NSW premises within the same corporate entity. It also provides for joint approaches by local government entities. Premises-specific emissions sources, quantities and mitigation measures still need to be addressed.[2]
Start with one master list of licences and reporting boundaries. Decide which information can be managed centrally and which needs a site appendix. That can make internal review clearer without obscuring the individual premises.
Does an existing NGER report provide the forward estimates?
Do not assume a historical inventory supplies the required forecast. Forward estimates need planned operating activity and the treatment of implemented or committed measures, using an appropriate calculation basis.[2]
Ask operations and finance to agree the future activity assumptions. Link each committed change to an expected start date and a documented emissions effect. Keep unapproved opportunities distinguishable from committed measures.
The first reporting deadline is 31 March 2027. Check the deadline guide for how reporting and public CCMAP dates fit together.
What should a focused gap review deliver?
- A facility-to-EPL mapping with the key boundary differences.
- A list of usable existing reports and calculation evidence.
- The additional sources, records and explanations required.
- A forecast assumptions register and named data owners.
- A CCMAP content matrix showing what can be reused and what needs drafting.
- A scoped work programme, review responsibilities and fee basis.
For an established reporter, those outputs help define the remaining job. For a site with major data gaps, they provide the basis for a more detailed inventory engagement.
Sources and review date
- NSW EPA: climate change requirements for licensees. Reporting and publication timetable.
- EPA emissions reporting and CCMAP guidance (PDF). Applicability, methods, boundaries, estimates and existing-plan provisions.
- EPA: additional information for agricultural licensees. Agricultural sources and premises boundaries.
Sources checked . Apply the current requirements and any EPA directions to the particular premises. Examples describe an approach and are not client case studies.
Common Questions
Frequently Asked Questions
Does NGER reporting exempt a business from preparing a CCMAP?
Not automatically. Existing NGER information can support emissions reporting, while the EPA’s forward estimates and public plan requirements still need to be addressed for covered premises. Check the site’s applicability and reporting arrangements.
Must every NGER boundary difference be resolved by recalculating the inventory?
No. EPA guidance allows the closely related NGER report with an explanation of relevant boundary or operational differences. Additional required information must still be provided. Review that route before deciding whether recalculation is needed.
Should all existing emissions records be discarded when preparing the CCMAP?
No. Reuse suitable activity data, methods, calculations and reporting documents. Identify the gaps against the EPA requirements and document how the existing evidence supports the result.