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This submission by Ember to the Clean Energy Regulator argues that 'Method 2' for reporting fugitive methane emissions from Australian coal mines is scientifically inadequate and leads to significant under-reporting. The document highlights a growing gap between increasing coal production and stagnant or declining reported emissions, particularly in New South Wales. Ember recommends urgent reforms, including mandated regular updates to emission factors, increased borehole density, independent third-party verification, and the integration of satellite-based atmospheric monitoring to ensure the integrity of Australia's national emissions inventory.