Submission to the Clean Energy Regulator: Enhancing Method 2 for Coal Mine Emissions Reporting

This submission is part of Ember’s contribution to the Australian Government’s review of the National Greenhouse and Energy Reporting (NGER) framework.

The submission focuses on the urgent need to improve “Method 2”, a site-specific approach to estimating coal mine methane emissions at open-cut coal mines that has been voluntarily implemented by companies since 2011, but now could become the default measurement approach across the vast majority of coal production in Australia.

Following a previous governmental review, which recommended to phase out state-wide average emissions factors for coal mines in Queensland and New South Wales, Method 2 has now been made compulsory for large open cut coal mines across the country. While its site-specific nature is meant to provide more accurate reporting, Ember’s analysis of its historical implementation has shown that critical measurement, a lack of independent verification and transparency gaps have undermined its potential.

This submission also draws on our recent satellite analysis of Australia’s coal sector, to highlight that the uncertainty of site-specific emissions estimates are in urgent need for reform in order to improve Australia’s emissions inventory, and international confidence in our emissions reporting. Unless these issues are addressed, Method 2 has the potential to significantly distort climate policy at both state and federal levels.

However, this is also a critical opportunity. As this submission outlines, there have been significant improvements in measurement approaches since Method 2 was first designed in the late 2000’s, and recent technological progress in a diverse range of stationary and atmospheric measurement approaches offer further cost-effective opportunities to improve reporting in the next few years. If combined with critical reforms in data collection, modelling, and verification, Australia’s open-cut coal mines could become a global leader in emissions accuracy, and a trustworthy pillar of effective climate policy going forward.

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Authored by Christopher Wright, this report was submitted as part of Ember’s contribution to the Australian Government’s review of the National Greenhouse and Energy Reporting (NGER) framework.