Feedback to New South Wales’ Environment Protection Authority’s Public Consultation on the draft Climate Change Policy and draft Action Plan 2022-2025

Ember provides feedback to the New South Wales (NSW) Environment Protection Authority (EPA) regarding its draft Climate Change Policy and Action Plan 2022-2025. The submission argues for a specific focus on coal mine methane (CMM) emissions, proposing new actions to improve measurement, reporting, and verification (MRV) and to implement mitigation strategies to align with international targets and the Global Methane Pledge.

• Coal mines in New South Wales are responsible for 36% of the state's total methane emissions and over 90% of its methane emissions from the energy sector.
• There is evidence that coal mine methane emissions in Australia are significantly underreported. The IEA suggests that reported emissions in 2020 missed 800 thousand tonnes of methane, implying actual emissions were nearly double the reported figures.
• To limit global temperature rise to 1.5C, the International Energy Agency (IEA) indicates that methane emissions from the coal mining industry must be reduced by 75% from 2020 levels by 2030.
• Ember proposes a new 'Inform and Plan' pillar for the NSW EPA, which includes collaborating with international initiatives like the Global Methane Hub and the International Methane Emissions Observatory to develop world-leading MRV requirements.
• Ember proposes a 'Mitigate' pillar to minimize methane leaks and venting from active, closed, and abandoned mines. Recommended actions include a 75% reduction target by 2030, a commitment to no new coal mines or expansions, and the closure of 'gassy' thermal coal mines unless emissions drop below 0.5kg per tonne of coal.
• Current measurement methods for underground and open-cut mines are criticized as insufficient. Satellite data has shown that the Hail Creek mine emitted ten times its reported levels for four consecutive years (2018-2021), and the Oaky North Underground Mine emitted nearly double its reported emissions in 2018 and 2019.
• Abandoned mine methane is a significant issue because emissions can continue indefinitely if mines are not shuttered responsibly. In New South Wales, only one of 644 mines has ever been fully closed, according to the Australian Conservation Foundation.

APA

Smirnov, A., & Assan, S. (2022). Feedback to New South Wales’ Environment Protection Authority’s Public Consultation on the draft Climate Change Policy and draft Action Plan 2022-2025. Ember. https://ember-energy.org/app/uploads/2022/11/Ember-EPA-Feedback-November-2022.pdf

Chicago

Smirnov, Anatoli, and Sabina Assan. Feedback to New South Wales’ Environment Protection Authority’s Public Consultation on the draft Climate Change Policy and draft Action Plan 2022-2025. Ember, 2022. https://ember-energy.org/app/uploads/2022/11/Ember-EPA-Feedback-November-2022.pdf.

Wikipedia

{{cite report |last1=Smirnov |first1=Anatoli |last2=Assan |first2=Sabina |title=Feedback to New South Wales’ Environment Protection Authority’s Public Consultation on the draft Climate Change Policy and draft Action Plan 2022-2025 |publisher=Ember |date=2 November 2022 |url=https://ember-energy.org/app/uploads/2022/11/Ember-EPA-Feedback-November-2022.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{smirnov2022feedback, author = {Smirnov, Anatoli and Assan, Sabina}, title = {{Feedback to New South Wales’ Environment Protection Authority’s Public Consultation on the draft Climate Change Policy and draft Action Plan 2022-2025}}, institution = {Ember}, year = {2022}, month = nov, url = {https://ember-energy.org/app/uploads/2022/11/Ember-EPA-Feedback-November-2022.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }