Submission to the NSW Parliament inquiry into Net Zero

Ember submits that coal mining emissions pose a critical risk to New South Wales' net zero targets. The report argues that current federal regulations like the Safeguard Mechanism are inadequate because they allow offsets over onsite mitigation and may underreport emissions from open cut mines. Using Tahmoor Colliery as a case study, Ember demonstrates that onsite VAM mitigation is technically feasible and commercially viable but requires state-led regulatory pressure. Key recommendations include pausing new coal mine approvals and commissioning a detailed risk report from the Net Zero Commission by June 2025.

• Coal mining emissions are identified as the primary risk to New South Wales' legislated emission reduction goals, potentially forcing other sectors to increase their own reductions to compensate. In 2022, coal mining accounted for "ninety-nine per cent" of the resources sector's 13.8 million tonnes of CO2-e emissions.
• Existing regulatory frameworks, specifically the Safeguard Mechanism and the Coal Mine Waste Gas (CMWG) method, are deemed insufficient to drive significant onsite emissions cuts in NSW. The Safeguard Mechanism is estimated by the Department of Climate Change, Energy, the Environment and Water to reduce cumulative onsite CO2-e emissions from the Australian coal sector by only 5% by 2030, partly because unlimited access to offsets may discourage investment in onsite mitigation.
• There is a significant risk of emissions underreporting in open cut coal mines. A Reputex study indicates that shifts to site-specific estimates have decreased reported emissions by 65–70% over the last decade, potentially leading to an unverified nationwide reporting reduction of 10.6 Mt CO2-e, which contradicts satellite evidence.
• Tahmoor Colliery is highlighted as a high-emitting underground mine with the third highest emissions intensity in Australia (0.5454 t CO2-e/ROMt). Proposed modifications to the mine could increase annual onsite emissions by up to 45% by FY2033, reaching 1.44 million tonnes of CO2-e, despite the technical feasibility of using Regenerative Thermal Oxidiser (RTO) technology to reduce fugitive methane emissions by at least 79%.
• Onsite mitigation of Ventilation Air Methane (VAM) is technically and commercially viable but lacks regulatory impetus. RTO technology is proven globally and has been used in NSW at the West Cliff Mine to abate 2 million tonnes of CO2-e. Ember estimates that targeted VAM projects at the highest emitting mines in NSW could be as impactful as a similar strategy in Queensland, which could reduce an additional 10 million tonnes of CO2-e.
• Ember recommends that the NSW government immediately pause approvals for new coal extensions and expansions and request a dedicated report from the Net Zero Commission by June 2025. This report should include a cost-benefit analysis of regulatory measures for onsite mitigation, advice on a coal sectoral target, and an assessment of risks related to emissions measurement and monitoring.

APA

Wright, C. (2024). Submission to the NSW Parliament inquiry into Net Zero. Ember. https://ember-energy.org/app/uploads/2025/02/NSW-Net-Zero-Submission.pdf

Chicago

Wright, Christopher. Submission to the NSW Parliament inquiry into Net Zero. Ember, 2024. https://ember-energy.org/app/uploads/2025/02/NSW-Net-Zero-Submission.pdf.

Wikipedia

{{cite report |last1=Wright |first1=Christopher |title=Submission to the NSW Parliament inquiry into Net Zero |publisher=Ember |date=14 February 2024 |url=https://ember-energy.org/app/uploads/2025/02/NSW-Net-Zero-Submission.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{wright2024submission, author = {Wright, Christopher}, title = {{Submission to the NSW Parliament inquiry into Net Zero}}, institution = {Ember}, year = {2024}, month = feb, url = {https://ember-energy.org/app/uploads/2025/02/NSW-Net-Zero-Submission.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }