Submission to Australia’s National Greenhouse and Energy Reporting Scheme 2023 Proposed Amendments

Ember submits that Method 1 for estimating methane emissions from Queensland open cut coal mines is inadequate because it relies on State-based averages that ignore spatial and temporal variability and disguise 'super emitters'. The document recommends phasing out Method 1 in favor of a multi-input measurement model combining geotechnical cores, drones, fixed monitoring, and satellite verification to ensure accurate reporting and support Australia's climate targets.

• Method 1 for estimating methane emissions from Queensland open cut coal mines is considered inadequate and likely to underestimate methane intensity because State-based emissions factors do not account for the variability of pollution or identify 'super emitters'.
• The proposed update to Method 1 increases the State-based emission factor for Queensland open cut coal mines from 0.023 to 0.031 tonnes of CO2-e per tonne of coal, which represents a 35% increase in estimated methane emissions.
• State-based factors fail to capture significant methane variability; for example, measurements from 10 Queensland open cut mines showed some had emission factors approximately 50 times higher than others.
• Satellite data reveals the existence of super emitting mines that far exceed Method 1 estimates; the Hail Creek Open Cut Coal Mine emitted approximately 230 thousand tonnes of methane in 2018-2019, with a methane intensity 30 times higher than the proposed 1.1 kg per tonne of coal.
• Ember recommends that all Australian surface mines be required to use a multi-input model for direct measurement, incorporating geotechnical cores, field gas models, regular drone surveys, fixed gas monitoring, weather monitoring, and ground-based measurements.
• The document suggests integrating the Met Coal Methane Partnership (MMP) draft Level 5 MRV standards into the NGER Determination to align Australian measurement with best practice, including site-level reconciliation and satellite verification.

APA

Reynolds, A., & Assan, S. (2023). Submission to Australia’s National Greenhouse and Energy Reporting Scheme 2023 Proposed Amendments. Ember. https://ember-energy.org/app/uploads/2024/10/FINAL-Ember-Submission-to-2023-NGERS-Updates_website-copy-1.pdf

Chicago

Reynolds, Annika, and Sabina Assan. Submission to Australia’s National Greenhouse and Energy Reporting Scheme 2023 Proposed Amendments. Ember, 2023. https://ember-energy.org/app/uploads/2024/10/FINAL-Ember-Submission-to-2023-NGERS-Updates_website-copy-1.pdf.

Wikipedia

{{cite report |last1=Reynolds |first1=Annika |last2=Assan |first2=Sabina |title=Submission to Australia’s National Greenhouse and Energy Reporting Scheme 2023 Proposed Amendments |publisher=Ember |date=28 April 2023 |url=https://ember-energy.org/app/uploads/2024/10/FINAL-Ember-Submission-to-2023-NGERS-Updates_website-copy-1.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{reynolds2023submission, author = {Reynolds, Annika and Assan, Sabina}, title = {{Submission to Australia’s National Greenhouse and Energy Reporting Scheme 2023 Proposed Amendments}}, institution = {Ember}, year = {2023}, month = apr, url = {https://ember-energy.org/app/uploads/2024/10/FINAL-Ember-Submission-to-2023-NGERS-Updates_website-copy-1.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }