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

The document argues that coal mine methane (CMM) is a critical but underreported driver of emissions in New South Wales, accounting for over 90% of the state's energy sector methane emissions. Ember proposes two new pillars for the NSW EPA's Action Plan: 'Inform and Plan' and 'Mitigate'. The 'Inform and Plan' pillar suggests collaborating with international initiatives like the International Methane Emissions Observatory and implementing high-tier IPCC measurement, reporting, and verification (MRV) methodologies to address reporting gaps. The 'Mitigate' pillar recommends a 75% reduction target for methane emissions by 2030, the closure of 'gassy' thermal coal mines, and a commitment to no new coal mines or expansions. The report highlights that current reporting may be significantly underestimated, citing IEA estimates that Australia's reported CMM emissions could be missing 800 thousand tonnes.

• Coal mines in New South Wales are responsible for more than 90% of the state's methane emissions from the energy sector and 36% of its total methane emissions.
• There is significant evidence that coal mine methane emissions in Australia are underreported; the IEA suggests reported emissions may be missing 800 thousand tonnes, implying actual emissions are nearly double the 2020 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 that the NSW EPA should collaborate with international bodies, including the Climate and Clean Air Coalition, the Global Methane Initiative, the International Methane Emissions Observatory, and the Global Methane Hub, to develop measurement, reporting, and verification (MRV) requirements.
• Current measurement methods for underground mines are insufficient because they rely on periodic measurements and monitors designed for safety rather than precise emission tracking; Ember recommends continuous measurements on all drainage and ventilation systems.
• Open-cut mine emissions are often underestimated because they rely on default emission factors that do not account for the variability of specific coal deposits; satellite data showed the Hail Creek mine emitted ten times its reported levels from 2018 to 2021.
• Methane emissions from abandoned mines can persist indefinitely if not shuttered responsibly, yet Australia only counts cumulative emissions for up to 20 years after closure.

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} }