Submission to the Clean Energy Regulator: Enhancing Method 2 for Coal Mine Emissions Reporting

This submission by Ember to the Clean Energy Regulator argues that 'Method 2' for reporting fugitive methane emissions from Australian coal mines is scientifically inadequate and leads to significant under-reporting. The document highlights a growing gap between increasing coal production and stagnant or declining reported emissions, particularly in New South Wales. Ember recommends urgent reforms, including mandated regular updates to emission factors, increased borehole density, independent third-party verification, and the integration of satellite-based atmospheric monitoring to ensure the integrity of Australia's national emissions inventory.

• There is a significant discrepancy between coal production growth and reported fugitive methane emissions from open-cut mines between 1990 and 2022. While production grew by approximately 224%, reported fugitive emissions rose by only 95%. Since the 2005 international emissions baseline, production increased by 45% while fugitive emissions grew by only 13%.
• The shift from state-based to site-specific emissions estimates (Method 2) has led to a substantial reduction in reported emissions. Reputex estimates this shift has consistently decreased reported fugitive methane emissions by 65% to 70%. In New South Wales, the reported fugitive emissions intensity of open-cut mines is six times lower than the state-based emissions factor.
• Satellite analysis using TROPOMI indicates that official reporting significantly underestimates methane emissions. In New South Wales, satellite estimates for 2020 identified 721 kt of methane compared to the officially reported 379 kt, despite only accounting for about 61% of production. For 2021, satellite estimates (679 kt) were 106% higher than official reports (329 kt).
• Method 2 contains critical technical flaws in its sampling and modelling requirements. Specifically, the minimum of three boreholes per gas domain is insufficient for complex geological settings, and the requirement for gas models to extend only 20 metres below the final pit floor is described as 'arbitrary' and fails to account for vertical gas migration or residual gas in deeper strata.
• Current reporting guidelines lack independent oversight, allowing sampling plans to be reviewed by internal company personnel and relying on 'expert judgement'. This creates a risk of bias, especially given the incentive structures of the reformed Safeguard Mechanism.
• Method 2 and ACARP guidance fail to account for several methane sources, including emissions from non-coal strata, mine water ponds, waste material, spontaneous combustion, and lateral gas migration beyond lease boundaries.

APA

Wright, C. (2025). Submission to the Clean Energy Regulator: Enhancing Method 2 for Coal Mine Emissions Reporting. Ember. https://ember-energy.org/app/uploads/2025/04/Ember-Submission_-Enhancing-Method-2-for-Coal-Mine-Emissions.pdf

Chicago

Wright, Christopher. Submission to the Clean Energy Regulator: Enhancing Method 2 for Coal Mine Emissions Reporting. Ember, 2025. https://ember-energy.org/app/uploads/2025/04/Ember-Submission_-Enhancing-Method-2-for-Coal-Mine-Emissions.pdf.

Wikipedia

{{cite report |last1=Wright |first1=Christopher |title=Submission to the Clean Energy Regulator: Enhancing Method 2 for Coal Mine Emissions Reporting |publisher=Ember |date=17 April 2025 |url=https://ember-energy.org/app/uploads/2025/04/Ember-Submission_-Enhancing-Method-2-for-Coal-Mine-Emissions.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{wright2025submission, author = {Wright, Christopher}, title = {{Submission to the Clean Energy Regulator: Enhancing Method 2 for Coal Mine Emissions Reporting}}, institution = {Ember}, year = {2025}, month = apr, url = {https://ember-energy.org/app/uploads/2025/04/Ember-Submission_-Enhancing-Method-2-for-Coal-Mine-Emissions.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }