Safeguard Mechanism Consultation - Response for Coal Mine Methane

Ember's consultation response argues that Australia's Safeguard Mechanism must be significantly strengthened to address coal mine methane (CMM) emissions, which it claims are underestimated by 30-40%. The document advocates for a mandate against new coal mines, the adoption of a 20-year Global Warming Potential (GWP) for methane, and the implementation of strict industry benchmarks (1-3kg/tonne) to drive the closure of 'super-emitting' mines and the adoption of available capture technologies.

• Reported coal mine methane emissions in Australia are underestimated by 30-40%, a discrepancy supported by satellite imagery and IEA analysis. This inaccuracy undermines the emissions basis and budget of the Safeguard Mechanism.
• The approval of new coal mines and expansions threatens Australia's climate targets; if only 75% of proposed mines proceed, fugitive methane emissions could increase 1.5 times by 2030, adding 45 Mt of CO2e (100-yr GWP) annually.
• Ember proposes an industry benchmark for methane emissions intensity of 1-3kg/tonne. Mines unable to meet this through mitigation should be closed, and new facilities should only be permitted if they can adhere to this best-practice benchmark.
• The document argues for the use of the 20-year Global Warming Potential (GWP) for methane, which is 82.5x more than CO2, rather than the 100-year GWP, to reflect the urgency of the climate emergency and methane's short-term impact.
• Specific measurement failures are highlighted: the Oaky North Underground Mine emitted nearly double its reported levels in 2018-2019, and Glencore’s Hail Creek Open Cut mine emitted 10 times its reported emissions from 2018 to 2021.
• Low-cost mitigation technologies are available and should be deployed, including improved methane drainage for underground mines and pre- and post-drainage for surface mines. Ventilation Air Methane (VAM) accounts for approximately 70% of CMM emissions.
• Ember opposes 'inter-temporal' banking and borrowing arrangements for Safeguard Mechanism Credits in the coal industry, arguing such mechanisms are easily gamed and conflict with the need for immediate methane reductions.

APA

Ember (n.d.). Safeguard Mechanism Consultation - Response for Coal Mine Methane. https://ember-energy.org/app/uploads/2024/10/Safeguard-Consultation-Response.pdf

Chicago

Ember. Safeguard Mechanism Consultation - Response for Coal Mine Methane. n.d. https://ember-energy.org/app/uploads/2024/10/Safeguard-Consultation-Response.pdf.

Wikipedia

{{cite report |author=Ember |title=Safeguard Mechanism Consultation - Response for Coal Mine Methane |url=https://ember-energy.org/app/uploads/2024/10/Safeguard-Consultation-Response.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{emberndsafeguard, author = {{Ember}}, title = {{Safeguard Mechanism Consultation - Response for Coal Mine Methane}}, institution = {Ember}, url = {https://ember-energy.org/app/uploads/2024/10/Safeguard-Consultation-Response.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }