Two weeks out, NGER reports close at midnight AEDT on Monday 2 November, and the Clean Energy Regulator is plain about it: no extensions can be granted. I read this round's amendment list expecting housekeeping, and most of it is. One line changes how a group gets to describe its electricity, and it's landing on reports that are already half written.
The take: the Scope 2 choice you now make once
The 2025-26 amendments add a requirement for consistent use of the market-based method across all facilities in a controlling corporation's group. That closes off something plenty of groups have done for years: report market-based where a site has a green contract or surrendered certificates behind it, and location-based everywhere else, because that's where the paperwork happened to be in order.
I understand how it happened. Certificates sit with procurement, facility data sits with operations, and whoever assembles the NGER report inherits both on a deadline. Mixing methods usually came down to whichever paperwork was ready, and it made a group's Scope 2 total hard to compare year to year, because the method shifted every time the contract book did.
Two other changes travel with it. The CER has clarified when certificates can be surrendered and still count toward market-based emissions, and Schedule 4 now asks you to identify the surrender ID numbers of those certificates. In practice, a market-based figure has to trace back to specific surrendered certificates. A line in a PPA summary won't carry it.
Then there are the location-based factors, which moved more than usual in places. Tasmania goes from 0.15 to 0.20 kg CO2-e per kWh, a third higher on identical consumption. Queensland drops from 0.71 to 0.67, New South Wales and the ACT from 0.66 to 0.64, and Victoria ticks up from 0.77 to 0.78. A national portfolio can post a Scope 2 movement this year that has nothing to do with anything it did.
So before 2 November, make one decision and do one check. The decision: market-based or location-based for the whole group, chosen deliberately and written down with the reason, because it now binds every facility and you'll want the same answer next year. If it's market-based, the check is whether you hold surrender IDs for every certificate you're relying on. Any you can't trace, take out now rather than at audit.
Then restate last year's Scope 2 on this year's factors and put both numbers in front of whoever signs off. If your entity also reports under AASB S2, the same electricity figure is heading into a disclosure that gets assured, and the time to separate a factor change from a real reduction is before anyone writes the narrative around it.
Quick hits
Batteries now set the NEM price about a third of the time. AEMO's Q2 Quarterly Energy Dynamics has battery charging and discharging setting prices in 36% of dispatch intervals, up from 17% a year earlier, with daytime grid-battery charging up 1,009 MW (211%). So what: the low-priced midday hours your load-shifting case was built on now have competition. Re-test the midday-to-evening spread on current data before you renew a time-of-use structure on last year's shape.
Three US grids set all-time peaks this summer. The EIA reports PJM at 162.6 GW on 2 July, ERCOT at 91.1 GW on 22 July (6.5% above its 2024 record) and SPP at 58.0 GW on 27 July, and puts most of these peaks down to regional heat waves in the hottest US summer on record. So what: these records will get quoted as proof of data centre load. The agency that measured them points at weather, so ask which driver a speaker means before you accept a US peak as evidence for anyone's forecast.
Britain's half-hourly settlement programme hits Milestone 14 on 28 October. From then, every supplier must be able to access MPANs under the new target operating model, and Elexon expects about 80% of meters to be in the new arrangements by October, with migration finishing in May 2027. So what: if you validate UK bills, a site's settlement basis changes when it migrates. Ask your supplier which of your MPANs have moved and when, and check the first bill after each switch against interval data rather than last year's profile.
From the blog
Our guide to location-based and market-based Scope 2 reporting covers how each method is calculated, which is worth ten minutes before you lock in a group-wide choice. Read it here.
The sign-off
AEMO's Q3 Quarterly Energy Dynamics is due in the coming weeks, and I'll be reading it for one thing: whether batteries kept taking a bigger share of price-setting through spring. If they did, midday stops being the automatic home for flexible load, and a lot of business cases deserve a second look.
On NGER, I'm curious which way groups go now they have to pick. My guess is more land on location-based this year than you'd expect, simply because the certificate records aren't ready, and treat market-based as next year's project. That's a defensible call if you make it on purpose. Tell me which way you went.
Until next fortnight,
Cohen