Audit requirements for programs administered by the Clean Energy Regulator

1.4.1 National Greenhouse and Energy Reporting audits

National Greenhouse and Energy Reporting (NGER) audits, or ‘greenhouse and energy audits’, are assurance and verification engagements that are conducted under the NGER legislation. The NGER Act describes the circumstances in which the Clean Energy Regulator might initiate a greenhouse and energy audit.

If the Clean Energy Regulator has reasonable grounds to suspect non-compliance with the NGER legislation, it can initiate a compliance audit by providing a written notice to the corporation to be audited.

In these types of engagements, the audited body must appoint an audit team leader from the Register of Greenhouse and Energy Auditors and arrange for the audit to be undertaken. The audited body must also arrange for a copy of the audit report to be provided to the Clean Energy Regulator (under sections 73 and 73A of the NGER Act).

As these audits occur in cases where the Clean Energy Regulator suspects non‑compliance, an audit may be undertaken as a precursor to the application of enforcement measures, including investigations by authorised officers, civil penalties and criminal proceedings.

In addition, the Clean Energy Regulator may initiate greenhouse and energy audits for reasons other than suspected non-compliance. For example, the Clean Energy Regulator may initiate audits on a risk management basis or to gather information on the regulated community’s compliance with particular aspects of the NGER Act. The Clean Energy Regulator would appoint the audit team leader and must notify the audited body before the audit engagement starts (sections 74 and 74A of the NGER Act).

The information collected through audits informs decisions on matters such as the targeting and effectiveness of capacity-building activities among registered corporations. These engagements also inform decisions on further compliance monitoring and enforcement actions.

The NGER Audit Determination specifies requirements that audit team leaders must meet when preparing for and carrying out greenhouse and energy audits. It also specifies requirements for audit team leaders in preparing an assurance engagement report and a verification engagement report.

Main features of NGER audits

The table below outlines the main elements of NGER audits.

Legislation/guidance	NGER Act, sections 73, 73A, 74, 74A, 74B and 74C NGER Regulations, Divisions 6.3–6.7 National Greenhouse and Energy Reporting (Measurement) Determination 2008 (NGER Measurement Determination) NGER Audit Determination Applicable standards: ASAE 3000 Assurance Engagements other than Audits or Reviews of Historical Financial Information ASAE 3100 Compliance Engagements ASAE 3410 Assurance on Greenhouse Gas Statements ASAE 3450 Assurance Engagements involving Corporate Fundraisings and/or Prospective Financial Information ASQM 1 Quality Management for Firms that Perform Audits and Other Financial Information or ASQM 2 Engagement Quality Reviews ISO 14064-3:2006 Greenhouse gases–Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions, and AS ISO 14064.3-2006 Greenhouse gases–Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions. ASAE 3450 is only relevant for safeguard mechanism audits as it provides guidance on forecasted abatement. Auditors should use this standard as guidance.
Nature of engagement	Reasonable assurance, limited assurance or verification engagement initiated by the Clean Energy Regulator, after submission of a greenhouse and energy report under the NGER Act, for compliance or monitoring purposes.
Assurance practitioner	The audit team leader must be a registered greenhouse and energy auditor, Category 2. Other members of the audit team do not need to be registered. However, the NGER Regulations do contain requirements for other members of an audit team. Voluntary engagements or verification audits may be led by Category 1 or 2 registered greenhouse and energy auditors.
Subject matter	The registered corporation’s energy and emissions report under section 19 of the NGER Act, or specified compliance requirements. Compliance requirements may include: the controlling corporation’s scope 1 and 2 emissions, energy production and energy consumption registration requirements record-keeping requirements, and amount of NGER uncertainty.
Criteria	Energy and emissions report (under section 19 of the NGER Act): NGER Measurement Determination for emissions and energy quantification, and NGER Act, sections 11, 11A, 11B or 11C, for operational control. Selected compliance requirements: NGER Act, and NGER Regulations.

1.4.2 Renewable Energy Target—Exemption certificate audits

Provisions under the Renewable Energy (Electricity) Act 2000 (RET Act) and the Renewable Energy (Electricity) Regulations 2001 (RET Regulations) set out audit requirements for exemption certificate audits under the production calculation method or the electricity use method. From 2020 only the electricity use method is used.

Electricity use method—when an audit report is required (regulation 22UG):

Applicant uses the electricity use method for the first time

The applicant has not previously made an application in relation to the site using the electricity use method.
The amount of exemption (in MWh) applied for exceeds 15 000 MWh for the application year.

Every five years

The year is at least two years after the last year the applicant submitted an application accompanied by an audit report.
The amount of exemption (in MWh) applied for exceeds 15 000 MWh for the application year.

On request by the Clean Energy Regulator

The Clean Energy Regulator gives the applicant notice in writing for an audit report.
The method to work out the exemption is materially different from the previous year.

Main features of exemption certificate audits—Electricity use method

The table below outlines the main features of exemption certificate audits where the application uses the electricity use method.

Legislation/ guidance	REE Act, paragraph 46A(2)(bb) REE Regulations, regulation 22UH NGER Audit Determination Applicable standards: ASAE 3000 Assurance Engagements other than Audits or Reviews of Historical Financial Information ASAE 3100 Compliance Engagements, and ASQM 1 Quality Management for Firms that Perform Audits or Reviews of Financial Reports and Other Financial Information or ASQM 2 Engagement Quality Reviews.
Nature of engagement	Reasonable assurance report in accordance with the REE Regulations, NGER Audit Determination and ASAE 3000, submitted with exemption certificate applications.
Assurance practitioner	Category 2 registered greenhouse and energy auditor. The auditor must have no conflict of interest with the applicant.
Subject matter	The relevant matters set out in regulation 22UH of the REE Regulations, include the: activities set out in the exemption certificate application electricity use method advice, and electricity use method advice being reasonable and is not likely to result in including an amount of electricity that is not a use amount.
Criteria	REE Regulations Schedule 6 for emissions-intensive trade exposed (EITE) activity definitions and requirements.

1.4.3 Emissions Reduction Fund audits

Amendments to the Carbon Credits (Carbon Farming Initiative) Act 2011 (CFI Act) make provision for administering the Emissions Reduction Fund.

Auditing of projects under the Emissions Reduction Fund provides the Clean Energy Regulator with confidence that the abatement reported represents genuine total net abatement for a project for a nominated reporting period. It is an essential component in the decision-making by the Clean Energy Regulator to issue Australian carbon credit units.

The Clean Energy Regulator takes a risk-based approach to audits under the Emissions Reduction Fund, utilising the Clean Energy Regulator audit framework. For most projects, this will mean a minimum of three scheduled audits across the seven plus year crediting period, which are arranged and paid for by scheme participants. An audit schedule is set for projects against criteria specified in the Carbon Credits (Carbon Farming Initiative) Rule 2015 (CFI Rule). The audit schedule sets out the frequency and scope of audits required for the project.

There are three main types of audit:

scheduled initial audit
scheduled subsequent audits, and
unscheduled or triggered audits.

The Clean Energy Regulator may also request a compliance audit to be carried out for a project, under Part 19 of the CFI Act.

Auditors are reminded that each project must be assessed and audited individually, and that an opinion must be provided for each project.

Scheduled audits

The first scheduled audit for a project must be an initial audit and must be a reasonable assurance engagement.

An initial audit report must be submitted with the first offsets report, where the offsets report is submitted between six months to two years into the crediting period for emissions avoidance projects, or five years into the crediting period for sequestration projects.

Where allowed for in the CFI Rule, a project may be eligible to report more frequently than every six months. In these cases, the initial audit must cover a period of at least six months and must be submitted with the final report covering the six month period.

The exceptions to this are the Carbon Farming Initiative (CFI) projects that were registered before the Emissions Reduction Fund came into effect and had previously submitted an audit report. These projects will be required to submit a minimum of three additional audits at subsequent audit scope during the crediting period.

The number of scheduled audits will depend on the project size in terms of the average annual abatement expected to be generated. All projects will be required to submit an initial audit report, and depending on the amount of expected carbon abatement, projects will be required to submit two, three or five subsequent audit reports.

Unscheduled or triggered audits

There are three types of unscheduled audits:

threshold audits, where a single report claims abatement over 100 000 tonnes of carbon-dioxide equivalent (tCO₂-e)
qualified or other conclusion audits, where a previous audit report did not give a reasonable assurance conclusion, and
variance audits, where there is variance from any one or combination of:

the project’s total forward abatement estimate
other similar projects, or
a general abatement profile of the method used by the project.

Project compliance with legislation

Subsequent audit reports must provide assurance that in all material respects, the offsets report(s) for the periods of time covered by the audit has been prepared in accordance with section 76 of the CFI Act. Where information regarding changes to a project’s compliance with eligibility or monitoring requirements has been notified with a offsets report, or with a previous unaudited offsets report, the scope of the subsequent audit will be increased to review those eligibility factors, although will not extend to reviewing previously assured eligibility criteria.

As circumstances may change over time, the Clean Energy Regulator expects any subsequent audits of a registered project to consider whether that project continues to meet the method requirements and continues to be carried out in accordance with the section 27 declaration (see section 27 of the CFI Act).

Legal right

In all circumstances, audits will be required to test the legal right of the participant to undertake the project.

Auditors must be aware that, for aggregated projects under the Emissions Reduction Fund, the legal right over at least one or more specified sites or assets must be demonstrated to carry out that project at the time of project registration.

The information required to demonstrate the legal right to carry out the project varies depending on the role or position within the project.

Where consent is required to demonstrate legal right, evidence provided to the Clean Energy Regulator must include the following information:

a clear statement from the relevant stakeholder that the participant is able to carry out the project for the length of the crediting period
a clear statement from the relevant stakeholder that the participant is able to obtain financial benefit from the project including through the Emissions Reduction Fund for the length of the crediting period, and
a brief description of the activities being undertaken as part of the project.

It is noted that where consents were not available at eligibility and relevant to the first offsets report, the initial audit will cover whether the information provided demonstrates legal right.

An initial audit report must note that legal right has been tested.

If there is any change or addition to the participant’s legal right to carry out the project at any time after the first offsets report, the Clean Energy Regulator must be notified and a subsequent audit will cover whether the information provided demonstrates legal right since the change occurred.

Again, it must be noted in the subsequent audit report that legal right has been tested, including over additional sites for aggregated projects.

The table below outlines the evidence required to be registered as a participant.

Evidence required	Participant is the site/asset owner	Participant is the site/asset lessee	Participant is the service provider
Declaration of legal right to undertake the project for the length of the crediting period	✔Yes	−No	−No
Consent from the site/asset owner to undertake the project for the length of the contract period	−No	✔Yes	✔Yes
Consent from relevant rights holders to undertake the project for the length of the contract period	✔Yes	✔Yes	✔Yes
Declaration of intention to gain consents (where they are not available at eligibility)	✔Yes	✔Yes	✔Yes

See further information on legal right.

Technical questions

In providing reasonable assurance opinions over projects, auditors must refer to the relevant methods, explanatory statements and method guidance. The method determinations can be complex and each poses its own technical questions that a reasonable assurance engagement needs to address. The determinations are also subject to periodic change and auditors need to ensure they are accessing the most recent version of them.

Information regarding the determinations is available under Emissions Reduction Fund. Additional guidance related to specific methods may also be provided on the website. It is suggested that audit team leaders refer to such guidance, if available, prior to conducting an audit.

Clean Energy Regulator initiated engagements

The Clean Energy Regulator may initiate an assurance engagement or agreed-upon procedures engagement (verification) on one or more aspects of a project participant’s compliance with the CFI Act or associated provisions for compliance or monitoring purposes.

While the subject matter of these engagements is at the Clean Energy Regulator’s discretion, the main Emissions Reduction Fund compliance requirements relate to whether the project activity conforms to the applicable method, including unit entitlement calculators, data collection, monitoring, reporting and record keeping, and other legislative requirements.

Main features of ERF audits

The table below outlines the main features of audits of Emissions Reduction Fund projects.

Legislation/guidance	CFI Act, sections 13 and 76 CFI Rule, Part 6, Division 3 Carbon Credits (Carbon Farming Initiative) (Audit Thresholds) Instrument 2015 (CFI Audit Thresholds Instrument) Applicable standards: ASAE 3000 Assurance Engagements other than Audits or Reviews of Historical Financial Information ASAE 3100 Compliance Engagements ASAE 3410 Assurance on Greenhouse Gas Statements ASQM 1 Quality Management for Firms that Perform Audits or Reviews of Financial Reports and Other Financial Information or ASQM 2 Engagement Quality Reviews ISO 14064-3:2006 Greenhouse gases – Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions, and AS ISO 14064.3-2006 Greenhouse gases – Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions. Only some components of ASAE 3410 will be relevant. Auditors should use this standard as guidance.
Nature of engagement	Reasonable assurance engagement report in accordance with the NGER Audit Determination, submitted with an application for an abatement statement (formerly known as a certificate of entitlement) for an Emissions Reduction Fund registered project and with lodgement of an offsets report.
Assurance practitioner	The audit team leader must be a registered greenhouse and energy auditor, Category 2. Other members of the audit team do not need to be registered. However, the NGER Regulations do contain requirements for other members of an audit team.

Legislation/guidance

CFI Act, sections 13 and 76
CFI Rule, Part 6, Division 3
Carbon Credits (Carbon Farming Initiative) (Audit Thresholds) Instrument 2015 (CFI Audit Thresholds Instrument)
Applicable standards:

ASAE 3000 Assurance Engagements other than Audits or Reviews of Historical Financial Information
ASAE 3100 Compliance Engagements
ASAE 3410 Assurance on Greenhouse Gas Statements
ASQM 1 Quality Management for Firms that Perform Audits or Reviews of Financial Reports and Other Financial Information or ASQM 2 Engagement Quality Reviews
ISO 14064-3:2006 Greenhouse gases – Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions, and
AS ISO 14064.3-2006 Greenhouse gases – Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions.

Only some components of ASAE 3410 will be relevant. Auditors should use this standard as guidance.

Nature of engagement

Reasonable assurance engagement report in accordance with the NGER Audit Determination, submitted with an application for an abatement statement (formerly known as a certificate of entitlement) for an Emissions Reduction Fund registered project and with lodgement of an offsets report.

Assurance practitioner

The audit team leader must be a registered greenhouse and energy auditor, Category 2.

Other members of the audit team do not need to be registered. However, the NGER Regulations do contain requirements for other members of an audit team.

Types of audit

	Subject matter	Criteria
Initial audits	Scheme participant‘s offsets report and application for Australian carbon credit units. Compliance of project with: section 27 declaration of project in operation for the project applicable method for the project, and requirements of the CFI Act. Project participant‘s compliance with applicable method.	Audit covers the period specified at section 74 of the CFI Rule. Project operated and implemented in accordance with section 27 declaration. Project in accordance with relevant methodology determination. Participant meets requirements of relevant methodology determination under subsection 106(3) of the CFI Act. Offsets report prepared in accordance with section 76 of the CFI Act. CFI Act requirements, where the project or proponent ‘must’ do something in relation to the claiming of ACCUs. This would exclude anything required of the regulator, and the auction or compliance components of the act. Auditors should not necessarily test compliance with each specific element of the CFI Act but should be aware of the elements when performing their risk assessment. As a minimum, auditors should be aware of: eligibility fit and proper person reporting methods multiple proponents record keeping, and notification. Relevant methods for: offset activity quantification content of offsets report information to be provided to the Clean Energy Regulator, and record keeping and monitoring.
Subsequent audits	Scheme participant’s abatement or sequestration number and whether the offsets report(s) has been prepared in accordance with section 76 of the CFI Act. Where there is a previously unaudited change in a project, for example a change relating to eligibility requirements, monitoring requirements, scope or location of the project, the continued compliance of the project with: section 27 declaration of project in operation for the project applicable method for the project, and requirements of the CFI Act. Project participant‘s compliance with applicable method.	Number of subsequent audits is in accordance with section 75 of the CFI Rule and the CFI Audit Thresholds Instrument. Offsets report prepared in accordance with section 76 of the CFI Act. Changes to the project are reported in accordance with section 76 of the CFI Rule. CFI Act requirements, including notification and record keeping. Relevant methods for: offset activity quantification content of offsets report information to be provided to the Clean Energy Regulator, and record keeping and monitoring.
Triggered audit—threshold or variance	The project’s abatement number and whether the offsets report has been prepared in accordance with section 76 of the CFI Act. Any other matter notified in writing by the Clean Energy Regulator.	Offsets report prepared in accordance with section 76 of the CFI Act. CFI Act requirements, including notification and record keeping. Relevant methods for: offset activity quantification content of offsets report information to be provided to the Clean Energy Regulator, and record keeping and monitoring.
Triggered audits–qualified or other conclusion	The matter in relation to which the reasonable assurance conclusion was not given has been appropriately addressed and the project has operated and been implemented in accordance with: the section 27 declaration that is in operation for the project the method used for the project the requirements of the CFI Act, and any other aspect of the project notified in writing by the Clean Energy Regulator.	Offsets report prepared in accordance with section 76 of the CFI Act. Compliance of the project with: section 27 declaration of project in operation for the project applicable method for the project, and requirements of the CFI Act. Any other aspect of the project required by the Clean Energy Regulator. Project participant‘s compliance with applicable method.

Note: An individual audit opinion must be provided for each individual project. A single audit opinion should not cover multiple projects to ensure appropriate levels of assurance have been given for each project or audit. Multiple projects may be listed on a single report, however the opinion must only cover one project at a time.

1.4.4 Safeguard mechanism audits

The safeguard mechanism ensures that emissions reductions purchased through the Emissions Reduction Fund are not offset by significant increases in emissions above business-as-usual levels elsewhere in the economy. It does this by encouraging large businesses not to increase their emissions above emissions baselines the agency sets.

Facilities whose total amount of covered emissions exceed the safeguard threshold, which is currently 100 000 tonnes of carbon dioxide or equivalent, must keep their emissions at or below a baseline set by the Clean Energy Regulator.

Emissions baselines represent the reference point against which future emissions performance are measured under the safeguard mechanism.

Baselines are set in different ways depending on whether the facility is new, the facility’s industry sector and the productive outputs of the facility.

A baseline may be adjusted to accommodate increased production, natural resource variability or other circumstances where the current baseline is not representative of future business-as-usual emissions performance for the facility.

Responsible emitters who reasonably expect their facility emissions to exceed the baseline have a number of options available. For example, a responsible emitter may purchase Australian carbon credit units (ACCUs) and surrender them to offset the excess emissions or generate their own ACCUs by carrying out a project under the Emissions Reduction Fund. They may also apply for multi-year monitoring period, a calculated baseline or access other management options.

The safeguard mechanism is administered through the NGER scheme and is designed to minimise additional mandatory reporting requirements. As well as the requirement for emissions to remain below the baseline, safeguard facilities are subject to the usual reporting and recordkeeping requirements of the NGER scheme.

The NGER Audit Determination applies to all safeguard mechanism audits. Safeguard mechanism guidance material is available.

Main features of safeguard mechanism audits

The table below outlines the main features of audits under the safeguard mechanism.

Legislation or guidance	National Greenhouse and Energy Reporting (Safeguard Mechanism) Rule 2015 (the Safeguard Rule) NGER Audit Determination NGER Act NGER Regulations NGER Audit Determination Applicable standards: ASAE 3000 Assurance Engagements other than Audits or Reviews of Historical Financial Information ASAE 3100 Compliance Engagements ASAE 3450 Assurance Engagements involving Corporate Fundraisings and/or Prospective Financial Information ASQM 1 Quality Management for Firms that Perform Audits or Reviews of Financial Reports and Other Financial Information or ASQM 2 Engagement Quality Reviews ISO 14064-3:2006 Greenhouse gases—Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions, and AS ISO 14064.3-2006 Greenhouse gases—Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions.
Nature of engagement	Reasonable assurance and/or limited assurance engagement conducted by the designated large facility in accordance with the Safeguard Rules and NGER Audit Determination, submitted with an application for baseline determination.
Assurance practitioner	The audit team leader must be a registered greenhouse and energy auditor, Category 2. Other members of the audit team do not need to be registered. However, the NGER Regulations do contain requirements for other members of an audit team.

Legislation or guidance

National Greenhouse and Energy Reporting (Safeguard Mechanism) Rule 2015 (the Safeguard Rule)
NGER Audit Determination
NGER Act
NGER Regulations
NGER Audit Determination
Applicable standards:

ASAE 3000 Assurance Engagements other than Audits or Reviews of Historical Financial Information
ASAE 3100 Compliance Engagements
ASAE 3450 Assurance Engagements involving Corporate Fundraisings and/or Prospective Financial Information
ASQM 1 Quality Management for Firms that Perform Audits or Reviews of Financial Reports and Other Financial Information or ASQM 2 Engagement Quality Reviews
ISO 14064-3:2006 Greenhouse gases—Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions, and
AS ISO 14064.3-2006 Greenhouse gases—Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions.

Nature of engagement

Reasonable assurance and/or limited assurance engagement conducted by the designated large facility in accordance with the Safeguard Rules and NGER Audit Determination, submitted with an application for baseline determination.

Assurance practitioner

The audit team leader must be a registered greenhouse and energy auditor, Category 2.
Other members of the audit team do not need to be registered. However, the NGER Regulations do contain requirements for other members of an audit team.

Types of audits

	Subject matter	Criteria
Calculated emissions baseline determination audits	Applications for calculated-emissions baseline determination audits must be accompanied by an audit report that complies with section 28 of the Safeguard Rule.	The matters to be audited and covered by the audit report are whether, in all material respects: Reasonable assurance: if the applicant relies on the transitional calculated baseline criteria, new facility criteria or inherent emissions variability criteria, then that those criteria are satisfied the application has been prepared in accordance with section 27 of the Safeguard Rule, and is presented fairly, and each production variable has been identified correctly. Limited assurance: The estimates of the quantity of each production variable under paragraph 27(1)(c) and any estimates of the emissions intensity of any relevant production variables are: based on the applicants assumptions which provide a reasonable basis for the emissions calculated on the basis of the applicant’s assumptions and any historical data that is stated fairly, and (if related to emissions intensity) reasonably expected to reflect the emissions intensity of the facility in the financial year determined under paragraph 27(1)(c), and reasonable. Audit conducted in accordance with the NGER Audit Determination.
Benchmark emissions baseline determination audits Note: The benchmark emissions baseline determination to which the application relates is to commence on or after 1 July 2020	Applications for benchmark-emissions baseline determinations must be accompanied by an audit report which complies with section 36 of the Safeguard Rule.	The matters to be audited and covered by the audit report are whether, in all material respects: Reasonable assurance: If the significant expansion criteria are relied upon by the applicant, those criteria are satisfied. That the application has been prepared in accordance with section 35 and presented fairly. Each production variable has been identified correctly. Limited assurance: The estimates of the quantity of each production variable under paragraphs 35(1)(b), (2)(b) and (2)(c): meet the requirements in subsection 35(3) are based on the applicant’s assumptions which provide a reasonable basis for the estimates are calculated on the basis of the applicant’s assumptions and any historical data that is fairly stated, and are reasonable. Audit conducted in accordance with the NGER Audit Determination.
Production adjusted baseline determination audits	Applications for production-adjusted baseline determinations must be accompanied by an audit report which complies with section 42 of the Safeguard Rule.	The matters to be audited and covered by the audit report are whether, in all material respects: Reasonable assurance: The selection of the production variable for the facility: if the determination is to commence after a benchmark-emissions baseline determination or paragraph 40(1)(b) applies—is applicable to the facility in accordance with the Benchmark Emissions-Intensity Index, and is supported by historical data that is fairly stated, and if the production variables are designated as prescribed production variables, they meet any requirements set out in Schedule 2 or 3 of the Safeguard Rule. The application has been prepared in accordance with section 41, and presented fairly, and The estimates of the quantity of each production variable under paragraph 41(1)(a) or (2)(a) meet the requirements in subsection 41(3) and are supported by historical data that is fairly stated. Audit conducted in accordance with the NGER Audit determination.
Variation of baseline determination for reduction in emissions intensity audits	Applications for variation of baseline determination for reduction in emissions intensity must be accompanied by an audit which complies with section 46 of the Safeguard Rule.	For a facility that is not a landfill facility, the matters to be audited and covered by the audit report are whether, in all material respects: Reasonable assurance: The emissions intensity test is satisfied The application has been prepared in accordance with section 48, and presented fairly That the estimates of the quantity of each production variable meet the requirements of subsection 48(2) or paragraph 48(3)(a) and are supported by historical data that is fairly stated, and The calculation of the emissions intensity of each production variable meets the requirements of subsection 47(4) and is supported by historical data that is fairly stated. Audit conducted in accordance with the NGER Audit determination.