Submission to the Safeguard Mechanism: International Best Practice Benchmarks Consultation

Ember argues that new coal facilities entering the Safeguard Mechanism should be held to a net zero emissions intensity baseline to align with 1.5 degree climate pathways. While supporting the proposed production variable of 0.0653 CO2-e per tonne of run-of-mine coal for driving reductions in high-intensity underground mines, Ember warns that open-cut mines may receive windfall Safeguard Mechanism Credits (SMCs) without performing genuine abatement due to outdated emissions reporting factors.

• Ember recommends that the emissions intensity 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 international consensus for a 1.5 degree pathway.
• To align with a 1.5 degree pathway, Ember's analysis suggests Australian coal production needs to decrease from 500 Mt to 200 Mt by 2030, primarily through a thermal coal phaseout.
• The proposed production variable of 0.0653 CO2-e per tonne of run-of-mine coal is expected to incentivise underground coal facilities to reduce emissions by up to 1 million tonnes of CO2-e by 2030, assuming constant production.
• Implementing best practice methane mitigation across Australian coal mines would cost approximately $500 million AUD annually and could reduce methane emissions by 42.6% by 2030.
• Ember expresses concern that open-cut coal facilities may generate Safeguard Mechanism Credits (SMCs) without actual abatement because they rely on factor-based emissions estimates that are not regularly updated or independently verified.
• Ember proposes that the principles for setting benchmarks be revised to be 'effective, robust, consistent (revised) and science-based', arguing that the current 'practical' principle—which considers 'low cost'—may undermine emissions reductions.
• The MetCoal Methane Partnership (MMP) is identified as an appropriate standard, with a proposed best practice intensity for metallurgical coal of 1-3 kg of methane per tonne of marketed coal.

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} }