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 submitted a statement to Australia's Department of Climate Change, Energy, Environment and Water arguing that the Boggabri Coal Mine's Modification 10 proposal significantly underestimates fugitive emissions. Ember contends that the mine uses an unverified, decade-old emissions factor that is 95 times lower than state guidance, potentially under-reporting Scope 1 emissions by millions of tonnes, especially as the mine seeks to operate at greater depths.

• 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 write-down of nearly 500,000 tonnes of CO2-e in reported Scope 1 emissions. For the previous year, the mine reported 192,864 t CO2-e, whereas Method 1 would have required reporting 685,134 t CO2-e.
• The proposed Modification to mine an additional 58.1 Mt of ROM coal between 2033 and 2040 could result in Scope 1 emissions that are over 9 million tonnes higher than the mine's current reporting approach suggests.
• The mine proposes to increase mining depth from approximately 180m to between 270m and 290m (the deepest section of the Templemore Coal Seam), yet claims this will not impact emissions, contradicting established 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 become widespread and potentially integrated into the NGERs scheme before the 2033 modification begins, increasing transparency and accuracy of fugitive emissions estimates.
• Boggabri Coal Mine has not implemented fugitive emissions mitigation measures or pre-mine drainage assessments, unlike the Hunter Valley Operations (HVO) expansion, which included detailed assessments and proposals for third-party peer reviews.

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} }