Submission to NSW EPA: Climate change licensee requirements

This submission by Ember to the New South Wales (NSW) Environmental Protection Agency (EPA) provides recommendations to strengthen proposed climate change requirements for large greenhouse gas emitters, specifically focusing on coal mine methane (CMM) reporting and abatement to align with NSW's Net Zero Emissions targets.

• Ember identifies a significant discrepancy between official methane emissions reporting in New South Wales and satellite-based observations. In 2020, while the state reported 379 kt of methane, a satellite study identified 721 kt, despite only accounting for approximately 61% of the state's coal production.
• There is a mismatch between state-led emissions factors and company-led estimates for open-cut coal mines. In NSW, reported fugitive emissions intensity from these mines is approximately six times lower than the state-based emissions factor, whereas reporting in Queensland remains largely consistent with state-based factors.
• Onsite coal mine methane abatement is considered both technically and economically viable. The IEA estimates that 40% (685 kt) of Australian coal mine methane emissions could be abated using existing methods, with 32% (542 kt) achievable at a cost lower than the market price of Australian Carbon Credit Units (ACCUs).
• The EU Methane Regulation, adopted in 2024, creates regulatory risks for Australian metallurgical coal exporters. Starting in 2027, foreign suppliers must meet monitoring and reporting standards equivalent to EU coal mines, and by August 2030, imported coal must comply with a maximum methane intensity or face fees.
• Ember recommends that the NSW EPA extend climate change requirements to all coal mines, regardless of whether they emit the proposed 25,000 tCO2-e threshold. To manage capacity differences, Ember suggests a phased approach where mines below this threshold are included by 28 February 2027.
• The submission proposes that Climate Change Mitigation and Adaptation Plans (CCMAPs) must include a mine closure strategy for underground coal mines. This strategy should detail the monitoring and management of abandoned mine methane (AMM) emissions for at least 70 years after operations cease.
• Ember advocates for making pre-mine drainage mandatory for both underground and open-cut coal mines. For open-cut mines, it 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} }