Comments to the ‘Public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG)’ Coal Mine Methane

Ember argues that the EU should lead by example in reducing coal mine methane (CMM) emissions, proposing a differentiated approach to state aid based on the type of methane project. The organization opposes state aid for 'Drained CMM' from active mines to avoid extending mine lifetimes, but supports aid for Ventilation Air Methane (VAM) destruction and Abandoned Mine Methane (AMM) capture, provided strict safeguards are in place to ensure these measures do not increase coal production or profitability.

• Coal mine methane (CMM) is a potent greenhouse gas with a global warming potential 86 times that of carbon dioxide over the first 20 years. In 2018, operating underground coal mines in Poland emitted 584 kilotonnes of methane, which is equivalent to 50 million tonnes of CO2 emissions.
• Ember opposes state aid for Drained Coal Mine Methane (Drained CMM) from active mines because these projects typically have good economics and government support could risk "improving mine profitability and increase its operational lifetime."
• State aid is recommended for Ventilation Air Methane (VAM) mitigation at active mines because VAM has very low concentrations (typically around 0.5%) and lacks a revenue stream outside of carbon or government incentives. Such aid is viewed as pragmatic since it has "minimal effect on coal mine profitability" and is unlikely to increase production.
• Abandoned Mine Methane (AMM) projects are considered highly suitable for state aid because they provide significant environmental benefits and do not risk extending a mine's operational life. Germany and the Czech Republic have already demonstrated that capturing AMM for electricity generation provides economic and environmental benefits.
• Ember proposes specific amendments to the CEEAG Annex 2 to include the costs of sealing coal mines and operating methane extraction systems, as well as costs for flaring facilities when no other economically viable utilization exists.
• For state aid to be granted to CMM abatement projects, Ember recommends cumulative requirements, including independent assessments to ensure aid does not extend mine lifetimes and that flaring is used only as a "option of last resort."

APA

Smirnov, A., & Kasprzak, M. (2021). Comments to the ‘Public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG)’ Coal Mine Methane. Ember. https://ember-energy.org/app/uploads/2021/08/CEEAG-Comments-Ember.pdf

Chicago

Smirnov, Anatoli, and Małgorzata Kasprzak. Comments to the ‘Public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG)’ Coal Mine Methane. Ember, 2021. https://ember-energy.org/app/uploads/2021/08/CEEAG-Comments-Ember.pdf.

Wikipedia

{{cite press release |last1=Smirnov |first1=Anatoli |last2=Kasprzak |first2=Małgorzata |title=Comments to the ‘Public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG)’ Coal Mine Methane |publisher=Ember |date=2 August 2021 |url=https://ember-energy.org/app/uploads/2021/08/CEEAG-Comments-Ember.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{smirnov2021comments, author = {Smirnov, Anatoli and Kasprzak, Małgorzata}, title = {{Comments to the ‘Public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG)’ Coal Mine Methane}}, publisher = {Ember}, year = {2021}, month = aug, url = {https://ember-energy.org/app/uploads/2021/08/CEEAG-Comments-Ember.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }