Boggabri Coal Mine Modification 10 EPBC ref 2024/09887 Submission to Australia’s Department of Climate Change, Energy, Environment and Water on the proposed modification of Boggabri coal mine and the potential for it to have a significant, under evaluated impact on fugitive emissions increases

Ember argues that the Boggabri coal mine's fugitive emissions are severely under-reported, using a self-led estimate that is 95 times lower than NSW state guidance. The submission warns that the proposed Modification 10, which involves mining deeper coal seams between 2033 and 2040, could result in Scope 1 emissions being 9 million tonnes higher than reported if state-recommended factors were used. Ember highlights a lack of assessment regarding how increased mining depth affects methane release and calls for a peer-reviewed assessment of pre-mine drainage mitigation before approval.

• Boggabri Coal Mine uses a self-led fugitive emissions intensity estimate of 0.00064 t CO2-e/t ROM coal, which is approximately 95 times lower than the NSW state-led Method 1 recommendation of 0.061 t CO2-e/t ROM coal.
• The use of an unverified Method 2 estimate results in an annual under-reporting of Scope 1 emissions by nearly 500,000 tonnes of CO2-e, reducing reported emissions to 192,864 t CO2-e compared to 685,134 t CO2-e if Method 1 were applied.
• The proposed Modification 10 to mine an additional 58.1 Mt of ROM coal between 2033 and 2040 could lead to a discrepancy in Scope 1 reporting exceeding 9 million tonnes of CO2-e when comparing the mine's current approach to NSW Method 1 guidance.
• The mine proposes to increase mining depth from approximately 180m to between 270m and 290m to reach the Templemore Coal Seam, yet claims this will have no impact on emissions, contradicting IPCC guidance that depth is a key determinant of coal gassiness.
• Ember asserts that direct emissions monitoring via satellites, drones, and laser-sensing technology will likely be widespread and integrated into the NGERs scheme before the 2033 modification begins, increasing transparency and potentially altering emissions estimates.
• Boggabri Coal Mine has not implemented or evaluated fugitive emissions mitigation measures, such as pre-mine drainage, which Ember argues should be a requirement for approval, similar to standards applied to the Hunter Valley Operations (HVO) expansion.

APA

Wright, C. (2024). Boggabri Coal Mine Modification 10 EPBC ref 2024/09887 Submission to Australia’s Department of Climate Change, Energy, Environment and Water on the proposed modification of Boggabri coal mine and the potential for it to have a significant, under evaluated impact on fugitive emissions increases. Ember. https://ember-energy.org/app/uploads/2024/10/Boggabri-Mine-Modification-Submission-Aug-2024.pdf

Chicago

Wright, Chris. Boggabri Coal Mine Modification 10 EPBC ref 2024/09887 Submission to Australia’s Department of Climate Change, Energy, Environment and Water on the proposed modification of Boggabri coal mine and the potential for it to have a significant, under evaluated impact on fugitive emissions increases. Ember, 2024. https://ember-energy.org/app/uploads/2024/10/Boggabri-Mine-Modification-Submission-Aug-2024.pdf.

Wikipedia

{{cite press release |last1=Wright |first1=Chris |title=Boggabri Coal Mine Modification 10 EPBC ref 2024/09887 Submission to Australia’s Department of Climate Change, Energy, Environment and Water on the proposed modification of Boggabri coal mine and the potential for it to have a significant, under evaluated impact on fugitive emissions increases |publisher=Ember |date=1 August 2024 |url=https://ember-energy.org/app/uploads/2024/10/Boggabri-Mine-Modification-Submission-Aug-2024.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{wright2024boggabri, author = {Wright, Chris}, title = {{Boggabri Coal Mine Modification 10 EPBC ref 2024/09887 Submission to Australia’s Department of Climate Change, Energy, Environment and Water on the proposed modification of Boggabri coal mine and the potential for it to have a significant, under evaluated impact on fugitive emissions increases}}, publisher = {Ember}, year = {2024}, month = aug, url = {https://ember-energy.org/app/uploads/2024/10/Boggabri-Mine-Modification-Submission-Aug-2024.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }