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

Ember's submission to the Australian government argues that the National Greenhouse and Energy Reporting Scheme (NGERS) relies on inadequate state-based emissions factors for Queensland open cut coal mines. The document recommends phasing out 'Method 1' in favor of direct measurement and multi-input models to accurately capture methane variability and super-emitting events.

• Ember argues that 'Method 1' for estimating methane emissions from Queensland open cut coal mines is inadequate and should be phased out because state-based emissions factors fail to account for methane variability and disguise major pollution events or 'super emitters'.
• The historical emissions factor for Queensland open cut coal mines was 0.023 tonnes of CO2-e per tonne of coal, based on limited studies from the early 1990s. The proposed update to Method 1 increases this to 0.031 tonnes of CO2-e per tonne of coal, which represents a 35% increase in estimated methane emissions for the state.
• State-based factors are deemed inaccurate due to three primary types of variability: spatial variability (methane concentrations can vary by a factor of 100), temporal fluctuations (impacted by location, depth, and weather), and changes in coal seam permeability as overburden is removed.
• Satellite data indicates that some mines are 'super emitters' with intensities far exceeding state averages. For example, the Hail Creek Open Cut Coal Mine emitted approximately 230 thousand tonnes of methane in 2018-2019, with a methane intensity of 34 kg per tonne of coal—30 times higher than the proposed Method 1 intensity of 1.1 kg per tonne.
• Ember recommends that all Australian surface mines transition to a multi-input model for direct measurement. This model should include geotechnical cores, field coal gas models, regular drone surveys, fixed gas monitoring, weather monitoring, and ground-based measurements, with satellite imagery used for top-down verification.
• The submission suggests that the Department of Climate Change, Energy, the Environment and Water (DCCEEW) integrate the Met Coal Methane Partnership (MMP) draft Level 5 MRV standards, which require site- and source-specific measurements and site-level reconciliation to achieve the lowest uncertainty in reporting.

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} }