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The document critiques the draft methodology for energy efficiency in household cooking, arguing that while it improves upon the legacy AMS-II.G methodology, it still contains critical flaws regarding the fraction of non-renewable biomass (fNRB), usage rate reporting, and the frequency of Kitchen Performance Tests (KPTs). Carbon Market Watch advocates for the exclusive use of Ghilardi & Bailis 2024 values for fNRB, a 50% cap on survey-only usage reporting, and annual or quarterly KPTs to prevent over-crediting.

Ember argues that Australia's 43% emission reduction target by 2030 is implausible without addressing coal mine methane (CMM), which dominates the energy sector's methane emissions. The submission urges Australia to join the Global Methane Pledge, improve its methane inventory to address potential underreporting, and adopt a 20-year emissions factor for domestic strategy to better reflect methane's short-term warming power.