Submission to the Safeguard Mechanism: International Best Practice Benchmarks Consultation

Ember submitted two statements to the Australian government regarding the Safeguard Mechanism in August 2023. The submissions focus on establishing stringent international best practice benchmarks for new coal mines and evaluating the proposed production variable for run-of-mine coal to ensure it drives genuine methane emissions reductions without creating windfall credits for open-cut facilities.

• Ember recommends that the emissions intensity benchmark for new coal facility entrants to the safeguard mechanism be set at net zero, specifically 0 CO2-e per tonne of run-of-mine coal, to align with a 1.5 degree pathway.
• To align Australia's coal mine methane emissions with a 1.5 degree pathway, Ember's analysis suggests coal production needs to decrease from 500 Mt to 200 Mt by 2030, primarily through the phaseout of thermal coal.
• Ember proposes that the principles for setting international best practice benchmarks be revised to be 'effective, robust, consistent (revised) and science-based,' arguing that the current 'practical' principle—which considers 'simple' and 'low cost' options—could undermine emissions reductions.
• Regarding the MetCoal Methane Partnership (MMP) standards, Ember notes a proposed intensity standard of 1-3 kg of methane per tonne of marketed coal for metallurgical coal, but suggests open cut facilities should be held to a stricter baseline of 0-1 kg of methane per tonne of coal.
• Ember supports the proposed production variable of 0.0653 CO2-e per tonne of run-of-mine coal, estimating it could incentivise underground coal facilities to reduce emissions by up to 1 million tonnes of CO2-e by 2030.
• The International Energy Agency (IEA) indicates that implementing best practice methane mitigation in Australian coal mines would cost approximately $500 million AUD annually and could reduce methane emissions by 42.6% by 2030.
• Ember warns that the current industry average production variable may allow open cut coal facilities to generate Safeguard Mechanism Credits (SMCs) without actual abatement, particularly those using factor-based emissions estimates that are not independently verified.

APA

Ember (2023). Submission to the Safeguard Mechanism: International Best Practice Benchmarks Consultation. https://ember-energy.org/app/uploads/2024/10/Two-submissions-to-the-Safeguard-Mechanism-August-2023.pdf

Chicago

Ember. Submission to the Safeguard Mechanism: International Best Practice Benchmarks Consultation. 2023. https://ember-energy.org/app/uploads/2024/10/Two-submissions-to-the-Safeguard-Mechanism-August-2023.pdf.

Wikipedia

{{cite press release |author=Ember |title=Submission to the Safeguard Mechanism: International Best Practice Benchmarks Consultation |date=11 August 2023 |url=https://ember-energy.org/app/uploads/2024/10/Two-submissions-to-the-Safeguard-Mechanism-August-2023.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{ember2023submission, author = {{Ember}}, title = {{Submission to the Safeguard Mechanism: International Best Practice Benchmarks Consultation}}, publisher = {Ember}, year = {2023}, month = aug, url = {https://ember-energy.org/app/uploads/2024/10/Two-submissions-to-the-Safeguard-Mechanism-August-2023.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }