Comments About the Bill

Ember provides a submission on the Climate Change Bill 2022 and the Climate Change (Consequential Amendments) Bill 2022, arguing that Australia's emissions targets are implausible without aggressive action on coal mine methane (CMM). The document highlights that CMM dominates Australia's energy sector methane emissions and suggests that official figures may be significantly underestimated.

• Ember asserts that Australia's target to reduce emissions by 43% by 2030 compared to 2005 levels would be "implausible" without addressing coal mine methane emissions. This is exacerbated by the fact that official methane emissions figures are likely underestimated; the International Energy Agency suggests they could be double the officially reported amounts, with some mines leaking more than 10 times the amount reported to regulators.
• Coal mine methane (CMM) is the primary source of methane emissions from Australia's energy sector. In 2019, CMM accounted for 68% of the energy industry's total methane emissions, which is nearly three times the emissions produced by oil and gas facilities combined. Over a 20-year period, the climate impact of these CMM emissions would exceed all automobile emissions in Australia for that same year.
• Australia is identified as the world's 6th largest coal mine methane emitter and could become the 3rd worst if current mine proposals proceed. Consequently, Ember describes Australia as the "most important developed country" that has not yet joined the Global Methane Pledge, which seeks a global reduction of methane emissions by at least 30% by 2030.
• Ember recommends that Australia adopt the highest standards for methane measurement, reporting, and verification, specifically calling for direct measurement for open cut coal mines instead of relying on default emissions factors. Additionally, they suggest using methane's 20-year global warming potential (GWP) of 82.5—rather than the 100-year GWP of 29.8—as part of the domestic climate strategy to better reflect methane's short-term impact.

APA

Ember (n.d.). Comments About the Bill. https://ember-energy.org/app/uploads/2024/10/Australia-Bill-Comments.pdf

Chicago

Ember. Comments About the Bill. n.d. https://ember-energy.org/app/uploads/2024/10/Australia-Bill-Comments.pdf.

Wikipedia

{{cite press release |author=Ember |title=Comments About the Bill |url=https://ember-energy.org/app/uploads/2024/10/Australia-Bill-Comments.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{emberndcomments, author = {{Ember}}, title = {{Comments About the Bill}}, publisher = {Ember}, url = {https://ember-energy.org/app/uploads/2024/10/Australia-Bill-Comments.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }