Recommendations

Mitigating CMM presents a major near-term climate win, yet current policies still miss the scale of abatement opportunities. Strengthening measurement, verification and reporting to address data inconsistencies, alongside clearer methane targets and incentivised mitigation, can unlock crucial emissions reductions.

Governments: require direct measurement and reporting for all coal mines

Implementing continuous (or near-continuous) measurement at every coal mine, including surface, underground and decommissioned sites allows for a clearer understanding of emissions and abatement potential, improving methane management and lowering explosion risk for workers in underground mines.

For underground mines, Ember recommends MRV requirements to Level 5, as specified by the United Nations International Methane Emissions Observatory (UN IMEO), covered in their technical documents on drainage methane and ventilation air methane.

For surface mines, Ember strongly recommends against the use of emission factors if used without frequent, direct measurement verification. This includes mine-specific emission factors which were recently found to exhibit significant, systematic differences from airborne quantifications.

Major improvements to currently accepted “best-practice” methodologies used to estimate mine-specific emission factors are required, including coal core gas sampling procedures, borehole spatial distribution requirements and gas content modelling approaches.

Ember recommends that mine-by-mine methane emissions should be made publicly available annually to promote transparency in emissions and allow for third-party verification.

Governments and regulators: integrate independent data and satellite verification into methane inventories

National CMM monitoring and reporting systems should integrate independent data sources to verify asset-level reported emissions. This includes data such as satellite observations, aerial surveys and third‑party ground measurements.

Regularly comparing bottom-up mine-level estimates with top-down atmospheric measurements helps identify and resolve any reporting inconsistencies.

Ember recommends that governments track CMM super-emitters via available data platforms. Publicly available platforms include IMEO MARS, Carbon Mapper and Kayrros. Several super-emitter tracking mechanisms are available for seamless uptake. These include Carbon Mapper’s super-emitter alert feature which provides daily, weekly or monthly updates on specific areas of interest. Similarly, IMEO MARS provides a notification system of detected super-emitter events based on dedicated focal points. Governments should embrace available CMM super-emitter tracking platforms and leverage their emission notification tools.

Satellite operators: expand targeted coverage over major coal-producing regions

Satellite operators and data providers should prioritise tasking high-resolution point-source imagers over the world’s largest coal-producing regions, particularly where theoretical detectability is favourable but observed detection rates remain low, such as India, South Africa and Australia.

Examples such as Poland and Canada demonstrate that focused satellite attention, driven by regulatory requirements or dedicated regional programmes, can substantially increase detection rates beyond what random overpass frequency alone achieves. Targeted tasking of instruments such as Carbon Mapper’s Tanager-1 over high-priority mines, combined with regular revisit schedules, would help close the gap between regions with favourable conditions and those where emissions remain hidden.

Extending the operational lifetime of existing missions, such as EMIT, which has already proven highly effective at identifying methane super-emitters, should also be supported to maintain continuity of observation and fill gaps where newer instruments have limited coverage.

Given that low‑cost CMM abatement technologies are already available, embedding mitigation into national legislation can achieve substantial emissions cuts, maximising emissions reductions per dollar spent.

This section highlights the strengths of selected regulations aimed at reducing CMM emissions, and outlines recommendations to enhance their effectiveness.

Ban venting from drainage systems at active and closed underground mines – as the EU Methane Regulation does

Adopted in 2024, the EU Methane Regulation mandates MRV at both operating and closed coal mines. To mitigate CMM emissions, the regulation bans venting from drainage systems at active mines and from closed or abandoned mines. For methane from ventilation air shafts, it sets limits on the methane intensity of coal.

Strengths: The ban on venting of drainage methane from both active and non-active underground mines targets the most easily avoidable emission sources. By restricting high-concentration methane releases, the regulation creates a strong incentive for methane capture and utilisation. For example, Poland’s coking coal company JSW aims to achieve capturing 50% of its methane emissions in the drainage systems, and use 95% of this, demonstrating the technical feasibility of such approaches.

Gaps: The regulation leaves implementation, verification and enforcement – including penalties for non-compliance – to individual Member States. To ensure mine operators fully comply with requirements, a robust and harmonised verification and penalty framework should apply.

Hold large emitting operators accountable through binding reduction requirements – as Australia’s Safeguard Mechanism does

Australia’s Safeguard Mechanism launched in 2016 and updated in 2023, covers the country’s largest emitters, requiring them to progressively reduce emissions towards 2030 or offset any excess through the purchase of carbon credits. This approach creates accountability for large emitters and encourages reductions to meet national targets. In 2026, it continues to operate with declining baselines while the government assesses future settings.

Strengths: The regulation covers around 31% of national emissions from high-emitting facilities, ensuring that major emitters are directly accountable for emissions reduction efforts. The regulation introduces a declining emissions limit (baseline), which aligns with the country’s climate goals and provides a clear pathway for the company’s long-term investment in low-emissions technologies.

Gaps: The regulation does not fully address potential underreporting issues of coal mine methane emissions, undermining the true mitigation potentials from large emitters. In addition, the flexibility to meet obligations through carbon offsets can weaken incentives for on-site abatement, especially for non-CO2 greenhouse gas emissions, such as methane.

Establish incentive mechanisms for mitigating VAM – as China’s CCER does

In January 2024, China relaunched its voluntary carbon market, China Certified Emission Reduction (CCER), which, as of January 2025, allows for the generation of carbon offset credits from the use of coal mine gas with a methane volume concentration below 8%.

Strengths: The inclusion of low-concentration methane within CCER methodologies provides a formal pathway for crediting VAM mitigation, making China one of the few jurisdictions where such projects are explicitly recognised within a carbon crediting framework. The CCER scheme justifies its financial support for low-concentration methane mitigation as the solutions are seen as capital-intensive, therefore creating an additional revenue stream for emissions reductions. According to the Global Methane Initiative, there are currently 10 VAM mitigation projects active in China, and early uptake under CCER is beginning to materialise, with at least three low-concentration coal mine methane projects submitted for registration, including two in Shanxi province and one in Shaanxi province.

Gaps: VAM mitigation projects remain limited in practice. This is likely due to the very low methane concentrations in VAM, higher abatement costs and relatively low credit revenues, which have limited the uptake of VAM projects under CCER. A dedicated VAM methodology, carbon price support, streamlined MRV and stronger integration with China’s ETS could improve viability and demand.

Phasing down coal

Phasing down coal use is the most effective way to curb CMM emissions. The International Energy Agency’s Net Zero by 2050 report shows that no new coal mines or extensions should be approved after 2022.

For example, The Government of Canada has passed regulations to accelerate the phase out of unabated coal-fired electricity by 2030, which is expected to cut carbon pollution by approximately 13 Mt in 2030.

By linking coal phase-down targets with CMM reduction objectives, governments can enable early action at the highest-emitting mines.

Mine-closure requirements

Requiring coal companies to submit closure and transition plans that include specific methane abatement measures, clear timelines and post-closure monitoring commitments prevents ongoing emissions from decommissioned sites.

Coal remains central to major industries, with steel being the largest industrial coal user. In 2024, global crude steel production reached 1,885 million tonnes, with around 70% still produced via the blast oxygen furnace route using coal-derived coke. While low-emissions alternatives are emerging, progress is not yet aligned with net zero. Methane from coking coal mining adds at least 27% to steel’s warming impact, but is largely absent from Scope 3 disclosures despite being one of the quickest and most affordable decarbonisation opportunities available before 2030.

Ember recommends that industry, in particular steelmakers, require mine-level measurement, transparent reporting, verified abatement in procurement and transition planning.