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

The document assesses the impact of Method 2 on coal mining emissions reporting in Australia, highlighting a significant gap between reported fugitive methane and satellite-derived estimates. It argues that the shift from state-based to site-specific emission factors has led to a consistent decrease in reported emissions, particularly in New South Wales, while production has continued to grow. The author recommends mandating regular updates to emission factors, increasing borehole density, expanding gas modelling extent, and implementing independent atmospheric verification using tools like the TROPOMI satellite to ensure the integrity of Australia's national inventory.

• Between 1990 and 2022, reported fugitive methane emissions from Australian surface coal mines grew by only 95%, which is less than half the rate of production growth (approximately 224%) over the same period.
• The transition from state-led emissions factors to company-led estimates under Method 2 has consistently reduced 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, indicating a mismatch between regulator averages and operator reports.
• Satellite analysis using TROPOMI across six coal mining clusters indicates that fugitive methane levels are at least 40% higher than officially reported for Australia as a whole.
• Specific satellite estimates for New South Wales show a significant discrepancy: in 2021, the study identified 679 kt of methane (with a range of 533 - 825 kt), while official reports stated 329 kt, representing a 106% difference despite only capturing 64% of production.
• Current Method 2 requirements are deemed inadequate, specifically the minimum of three boreholes per gas domain, which fails to capture spatial heterogeneity in complex regions like the Hunter Coalfield.
• The current gas modelling requirement 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.

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} }