Submission to NSW EPA: Climate change licensee requirements

Ember argues that the NSW EPA's proposed requirements for large emitters are a positive step but lack the ambition needed to meet net zero goals. The report highlights significant underreporting of coal mine methane (CMM) in New South Wales, suggesting satellite data shows emissions could be double official figures. Ember recommends extending reporting requirements to all coal mines, mandating pre-mine drainage for open-cut mines, and requiring 70-year post-closure monitoring for abandoned mine methane. It also emphasizes the need for alignment with the EU Methane Regulation to protect the export viability of metallurgical coal.

• Satellite data analysis indicates that actual methane emissions from coal mining in New South Wales may be up to twice the official reported figures; for 2020, the state reported 379 kt of methane, while a satellite study identified 721 kt.
• There is a significant discrepancy in reporting for open-cut coal mines in New South Wales, where reported fugitive emissions intensity is approximately six times lower than the state-based emissions factor, contrasting with Queensland where reporting is more consistent with state factors.
• Onsite coal mine methane (CMM) abatement is technically and economically viable, with the IEA estimating that 40% (685 kt) of Australian coal mine methane emissions could be abated, and 32% (542 kt) at a cost lower than the market price of Australian Carbon Credit Units (ACCUs).
• The EU Methane Regulation, adopted in 2024, will require foreign coal suppliers to meet monitoring and reporting standards equivalent to EU mines starting in 2027, and comply with a maximum methane intensity by August 2030, posing a regulatory risk for NSW exporters.
• Ember recommends that the NSW EPA extend climate change requirements to all coal mines regardless of emissions levels, potentially using a phased approach where mines emitting below 25,000 tCO2-e per year are included by 28 February 2027.
• The report proposes that Climate Change Mitigation and Adaptation Plans (CCMAPs) must include a mine closure strategy for underground mines that manages abandoned mine methane (AMM) emissions for at least 70 years after operations cease.
• Pre-mine drainage should be mandatory for both underground and open-cut coal mines; for open-cut mines, Ember suggests a phased approach starting with pre-feasibility studies and the development of a new ACCU method to improve economic viability.

APA

Setiawan, D., Assan, D. S., Chang, Y.-T., & Modadugu, R. (2025). Submission to NSW EPA: Climate change licensee requirements. Ember. https://ember-energy.org/app/uploads/2025/10/Ember-submissions-to-NSW-EPA-on-Licensee-Requirements-External.pdf

Chicago

Setiawan, Dody, Dr. Sabina Assan, Yu-Ting Chang, and Rajasekhar Modadugu. Submission to NSW EPA: Climate change licensee requirements. Ember, 2025. https://ember-energy.org/app/uploads/2025/10/Ember-submissions-to-NSW-EPA-on-Licensee-Requirements-External.pdf.

Wikipedia

{{cite report |last1=Setiawan |first1=Dody |last2=Assan |first2=Dr. Sabina |last3=Chang |first3=Yu-Ting |last4=Modadugu |first4=Rajasekhar |title=Submission to NSW EPA: Climate change licensee requirements |publisher=Ember |date=7 October 2025 |url=https://ember-energy.org/app/uploads/2025/10/Ember-submissions-to-NSW-EPA-on-Licensee-Requirements-External.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{setiawan2025submission, author = {Setiawan, Dody and Assan, Dr. Sabina and Chang, Yu-Ting and Modadugu, Rajasekhar}, title = {{Submission to NSW EPA: Climate change licensee requirements}}, institution = {Ember}, year = {2025}, month = oct, url = {https://ember-energy.org/app/uploads/2025/10/Ember-submissions-to-NSW-EPA-on-Licensee-Requirements-External.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }