Ongoing Compliance and Performance Monitoring

Westernfield Holdings has adopted the framework for compliance and performance monitoring whereby an applicant undergoes a rigorous assessment during the accreditation phase (‘validation’), including, where necessary, the use of pre-accreditation audits to verify the information provided. Once accredited, the abatement certificate provider is subject to auditing and reporting requirements as a means of ensuring its ongoing compliance with the Greenhouse Gas Reduction Scheme (GGAS) (‘verification’).

The compliance monitoring regime imposed on each abatement certificate provider is tailored to the applicant at the time of accreditation. It specifies the audit regime, whether Annual Reports are required, and identifies the nominated number of certificates which may be created by the abatement certificate provider on an annual basis.

Here at Westernfield Holdings we recognize good compliance performance and, if appropriate, relax an abatement certificate provider's compliance monitoring regime.

Ongoing audit requirements

WesternFiled Holdings imposes a regime of ongoing compliance audits on each abatement certificate provider at the time of accreditation. In determining the appropriate ongoing audit regime, this exercises its judgment taking into account the individual circumstances of each accreditation and deciding on a case-by-case basis.

So far, Westernfield Holdings has imposed three different types of audit requirements in various combinations, depending upon the abatement certificate provider’s circumstances:

• pre-registration audits
• periodic audits (annual, biennial, etc)
• spot audits.

In conducting the ongoing audits, auditors may be engaged directly by abatement certificate provider's. However, all audit appointments by abatement certificate provider's must be approved by the according business prior to the commencement of the audit.

The scope of audit activity will vary. Generic audit scopes have been developed by the industry and are discussed in more detail within the Audit Guideline.

Ongoing reporting requirements

Standard annual reporting requirements have been imposed as a condition of accreditation on the majority of accreditations. Annual reporting by abatement certificate providers is a key aspect of the  ability to monitor ongoing compliance.

To facilitate compliance with annual reporting requirements, standard templates for an Annual Report Statement have been developed. The standard scope of the annual reporting condition is designed to confirm:

• that the subject of the accreditation (i.e. the generating system or abatement project) is still fully operating in the manner indicated in the abatement certificate provider’s application for accreditation that the characteristics and details of the subject of the accreditation are not materially different from the characteristics and details identified in the abatement certificate provider's application for accreditation and the number of NSW Greenhouse Abatement Certificates (NGACs) created by the abatement certificate provider during the reporting period (usually a calendar year) together with supporting calculations.

In addition to the annual reporting requirements, the General Accreditation Conditions require abatement certificate providers to notify auditors of any changes to their record keeping arrangements or metering equipment at the time those changes are implemented.