The MCA considers the NPI will only achieve its aims if it is relevant for users, contains meaningful data and provides a complete picture of material emissions/transfers. Furthermore, NPI requirements should be non-duplicative and set at the minimum effective level. If the NPI is to deliver a genuine public benefit, then each of these factors must be considered.
For the NPI to meet its stated objectives, the states and territories should be required to fulfil their commitment to regularly complete diffuse emissions data estimates for non-industrial sources and sub-threshold industry. The absence of this data negates any benefit the NPI may have and removes its status as a truly ‘national’ pollutant inventory.
An incomplete emissions picture can create a public misunderstanding of emissions in Australia and in some cases may lead to unnecessary concern over certain types of industrial activity. This may also impact on the effectiveness of government policy, creating a perception that regulated industry is the primary driver of emissions and environmental risk, while ignoring the potentially higher risk impacts from diffuse emissions.
The NPI data itself has limited utility for the minerals industry. A survey of members in 2014 indicated that the majority undertook NPI reporting to meet regulatory and compliance requirements, rather than to inform decision making.
The industry has concerns there is public confusion and misinterpretation of NPI data. Making data available does not necessarily translate into understanding. Contextual information (e.g. at an airshed level) is needed.
Reporting to the NPI is a significant reporting burden for the minerals sector. Accordingly, reporting requirements should be set at the minimum level required to meet the aims of the NPI. Mandatory collection of further (e.g. non-emission) information would not be seen as value-adding.
Streamlining and/or aligning NPI requirements with other reporting regimes would be highly beneficial. The MCA recommends government undertake an audit of related Commonwealth and state/territory reporting requirements to identify opportunities for streamlining.
NPI reporting is already a significant cost for industry. As a public good, additional costs for reforming the NPI should be borne by government.
Read the full submission MCA Submission Review of NPI 180809.pdf