For Climate Change Licensee Requirements and Climate Change Mitigation and Adaptation Plan (CCMAP), Ember calls for more ambitious targets by following measures:
- Extend requirements to all coal mines, regardless of reported emissions.
- Enhance reporting and data transparency
- Set ambitious baseline and continuous review, including public inputs
- Ensure facility-level emissions data and mitigation plan in CCMAPs
- Embed reporting improvement and closure strategies in CCMAPs
To ensure effective CMM abatement, Ember recommends that the Greenhouse Gas Mitigation Guide for NSW Coal Mines should be strengthened through following adjustments:
- Include pre-mine drainage for open cut coal mines
- Ensure coal mines implement VAM mitigation through consistent project planning
- Include abandoned mine methane (AMM) emissions management and mine closure strategy
- Develop appropriate incentives and support mechanisms to encourage proactive mitigation actions.
- Define clear evaluation criteria and consequences for non-compliance.