Submission to the NSW Parliament inquiry into Net Zero

Ember's submission to the NSW Parliament inquiry into Net Zero highlights that the coal mining sector is the biggest potential risk to the state's emission goals. The document argues that existing federal mechanisms, such as the Safeguard Mechanism and the Coal Mine Waste Gas method, are insufficient to drive material onsite reductions. Using Tahmoor Colliery as a case study, Ember demonstrates that Ventilation Air Methane (VAM) mitigation via Regenerative Thermal Oxidiser (RTO) technology is technically and commercially feasible but underutilised due to a lack of state-led regulatory pressure and the availability of carbon offsets. The submission calls for a pause on new coal mine expansions and a dedicated report from the Net Zero Commission by June 2025 to assess sectoral risks and develop a coal-specific emissions target.

• Coal mining emissions are identified as the primary risk to New South Wales' legislated emission reduction goals, with the sector's Scope 1 impact creating an economy-wide risk that may force other sectors to increase their own reductions.
• The federal Safeguard Mechanism is deemed insufficient for driving onsite cuts in NSW because its flexibility allows mines to use carbon offsets instead of investing in mitigation technology, and its design may perversely reward lower-emitting open cut mines.
• There is evidence of significant emissions underreporting in open cut coal mines; a Reputex study indicates that switching to site-specific estimates has decreased reported emissions by 65–70% over the last decade, potentially leading to a nationwide unverified reduction of 10.6 Mt CO2-e.
• Tahmoor Colliery serves as a case study for high emissions intensity and the risk of expansion; the mine has the third highest emissions intensity in Australia, and proposed modifications could increase annual onsite emissions by up to 45% by FY2033, reaching 1.44 million tonnes of CO2-e.
• Regenerative Thermal Oxidiser (RTO) technology is a technically feasible solution for Ventilation Air Methane (VAM) mitigation at mines like Tahmoor, with the potential to reduce fugitive methane emissions by 79% to 89%, potentially abating 9-11 million tonnes of CO2-e between 2025 and 2033.
• While upfront costs for full-scale VAM systems in Australia are high (estimated at $AU 50 - $100 million), they remain commercially viable as the cost of abatement is estimated at or below the current ACCU spot price of $AU 35 per tonne of CO2-e.

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} }