Submission to Australia’s National Greenhouse and Energy Reporting Scheme 2023 Proposed Amendments

This submission was made to the Australian government’s 2023 National Greenhouse and Energy Reporting (NGER) Scheme updates and consultation process in April 2023.

Ember’s submission is solely in relation to the proposed update to Method 1 for estimating emissions of methane from Queensland open cut coal mines. Method 1 is an improvement upon the historical emissions factor for Queensland, but still inadequate for estimating the methane pollution from Queensland open cut coal mines.

Ember acknowledges the Traditional Custodians of the many nations across Australia and their enduring connection to Country and the lands, seas and skies. We pay our respects to Elders past and present and extend that respect to all Indigenous Peoples today.

Method 1 underestimates methane pollution from Queensland open cut coal mines and should be phased out. Instead, all coal facilities should be required to report direct measurements from a multi-input model.

While Method 1 is an improvement upon the historical emissions factor for Queensland, it is still wholly inadequate for estimating the methane pollution from Queensland open cut coal mines because:

• State-based emissions factors do not account for the variability of methane pollution from a coal mine; and

• State-based emissions factors disguise major pollution events and methane super emitters, undermining the integrity of NGERS and risking Australia’s climate targets.

Method 1 therefore is likely to be an underestimate of the methane intensity of open cut coal mines across Queensland.

Ember recommends that:

• Method 1 is phased out from the National Greenhouse and Energy Reporting (Measurement) Determination 2008 (Cth).
• All Australian surface mines, including those in Queensland, be required to directly measure their emissions through a combination of technologies to generate a multi-input model. This will improve the accuracy and integrity of methane measurement, reporting and verification (MRV) at Australian coal mines.