Why the EPL premises and agricultural sources matter when checking the new climate reporting requirements.
Which agricultural businesses should check?
The EPA licenses activities including intensive livestock accommodation, livestock processing and agricultural processing. Examples include feedlots, piggeries, dairies and meat processing premises. Having one of these activities does not, by itself, establish that the climate reporting threshold is met.[3]
Grazing livestock operations are not regulated through this EPA licensing framework. Start with whether an EPL exists for the premises, then assess the relevant sources and threshold. Avoid treating a whole supply chain or all farms supplying a processor as the processor’s licensed premises.
What is the emissions boundary for a feedlot or processing plant?
Locate the EPL premises description and map. Section A2 usually identifies the location. Then map the activities and relevant emissions sources within that boundary.[3]
The EPA’s agricultural guidance states that ownership or contractual arrangements do not change this premises-based boundary. For example, third-party ownership of animals does not automatically remove emissions arising at the licensed site.
Illustrative boundary check: a company operates a feedlot, a feed mill and a processing plant. Before combining their emissions, identify which activities sit inside each EPL premises. Common ownership alone does not establish one reporting boundary.
Use an existing corporate inventory as evidence, while documenting any differences between its consolidation approach and the licensed premises.
Which emissions and records need checking?
| Source or activity | Examples of records to locate |
|---|---|
| Livestock | Animal numbers and classes, occupancy, feed and management information appropriate to the method |
| Manure and effluent | Handling and treatment systems, solids pathways, storage and operating records |
| Wastewater treatment | Treatment configuration, relevant flow and loading data, gas capture and operating information |
| Fuels and energy | Fuel use, stock movements, meter data, invoices and allocations to the premises |
| Refrigeration and process sources | Equipment details, maintenance records and relevant activity data |
The sources depend on actual operations. Use the list to plan a data request, then determine the method and evidence required for each source. The EPA identifies livestock, manure and other on-site agricultural activities that can matter to the assessment.[3]
For food processing refrigeration, our refrigerant emissions guide explains useful maintenance and equipment records.
Is there one cattle headcount that proves a CCMAP is required?
Do not use headcount alone as a final applicability decision. A defensible assessment needs the relevant activity, animal and management information, an appropriate method, other emissions sources and the EPL boundary.
Use any initial screen to decide what evidence to collect. Keep it separate from the completed site calculation. In a data request, distinguish maximum licensed capacity from actual occupancy or throughput during the reporting period.
How do you choose an agricultural emissions method?
EPA guidance requires an applicable NGER method where one is available. Where no suitable method exists, it permits relevant National Greenhouse Accounts factors or a recognised public methodology using 100-year global warming potentials.[3][2]
Document the activity data, method, factor version, assumptions and data limitations for each source. Complex livestock, manure or wastewater calculations may need specialist inputs. Establish that requirement before agreeing an inventory scope.
Production figures used for intensity measures should have an identified source and unit. Keep reported client data and independently checked information clearly distinguished in the calculation records.
When do affected agricultural licensees report?
The EPA identifies 31 March 2027 for first annual reporting and forward estimates, and 31 August 2027 for the first public agricultural CCMAP. Check whether a particular premises falls into an earlier publication category.[3]
Review the full NSW EPA CCMAP deadline guide when setting the internal timetable. The guidance’s below-threshold outlook exclusion also needs assessment against expected operations for the next three financial years.
What if the group already reports under NGER?
Start with the existing inventory and its source register. Compare those sources with the EPL activities, identify agricultural or other information gaps and document the boundary reconciliation.
The next task may be a focused review of missing sources and forecasts rather than a complete rebuild. The NGER and CCMAP comparison explains what to check before deciding the remaining scope.
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 registration automatically settle a feedlot’s CCMAP obligations?
No. Check the EPL premises and the emissions sources required by the EPA. Agricultural sources such as enteric fermentation and manure management can affect the EPA threshold assessment even where the NGER inventory does not include them.
Are purchased livestock emissions automatically Scope 1 at the processing plant?
No. Distinguish emissions occurring within the licensed premises from upstream emissions associated with purchased livestock. Map where each activity occurs and apply the relevant classification and method. The EPA agriculture guidance treats purchased livestock supply-chain emissions as an example of optional Scope 3 information.
Is Scope 3 mandatory for an agricultural CCMAP?
The EPA agriculture guidance makes Scope 3 optional for the CCMAP. That does not remove separate customer or other reporting requirements. Define the EPA scope separately from any broader corporate or supply-chain inventory.