Submission to the Climate Change Authority’s Issues Paper - May 2023

This submission was made to the Climate Change Authority’s Issues Paper 2023 – Setting, Measuring and Achieving Australia’s Emissions Reduction Targets and consultation process in June 2023.

Ember’s submission provides our recommendations for how the Climate Change Authority should consult on reforming coal mine methane measurement and mitigation, and the implications of coal mine methane emissions for setting, tracking and achieving Australia’s climate targets.

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.

Ember urges the Climate Change Authority to pursue an ambitious agenda for accurately measuring Australia’s coal mine methane, and from that foundation, set a trajectory for significant coal mine methane emission reductions to 2035 and beyond.

We recommend an overhaul of Australia’s coal mine methane measurement, reporting and verification laws. The reporting framework for coal mine methane emissions is outdated and inaccurate, Australia must adopt best practice direct and site-specific measurement standards. All coal facility methane emissions, sources and reporting methodologies should be made publicly available by the Clean Energy Regulator for all facilities that report under Australia’s greenhouse gas emissions measurement laws.

Ember recommends that the Climate Change Authority advise the government to:

• set ambitious 2035 climate targets, which incorporate significant coal mine methane emissions reductions;
• establish a fossil methane indicator of progress, to track whether Australia’s fugitive emissions trajectory is aligned with net zero by 2050;
• develop a coal sector decarbonisation pathway and fossil fuel production phaseout plan.

Ember further recommends that the Climate Change Authority recommend the reform of Australia’s national greenhouse gas emissions measurement laws as follows: 

• the phaseout of Methods 1 and 2 for open cut coal mines;
• the implementation of direct and site-specific measurement standards that require all coal mines to directly measure their methane through a multi-input model;
• the implementation of direct and site-specific measurement standards for all post-mining and abandoned coal mine facilities;
• improving the integrity of coal mine methane measurement, reporting and verification;
• consideration of reforming the measurement of coal mine waste gas flaring; and
• ensuring clear, transparent and accessible reporting of a facility’s methane emissions, the activities undertaken by that facility to mitigate its emissions and the extent of the methane actually destroyed or converted by those measures.