
Breadcrumbs
Major loopholes for coal mines in EU methane regulation
Two major loopholes in the EU methane regulation would allow coal mines to release additional methane emissions equivalent to Belgium and Czechia’s annual CO2 emissions combined. Ember’s recommendations could help Europe to realise one of the most cost effective ways to achieve its climate ambitions
About
In this analysis we look at which countries are emitting the most methane from coal mines, and what impact the EU methane regulation would have on emissions reductions, with a particular focus on Polish mines.
Executive summary
EU methane regulation negotiations risk increasing coal mine emissions
Coal mines are the largest single source of energy sector methane emissions in the EU, and yet the current methane regulation proposes to mitigate less than half of emissions.
Methane analyst, Ember
The European Union led 150 nations to sign the Global Methane Pledge but now risks shying away from taking action at home. Reducing coal mine methane emissions is realistic, affordable and doesn’t cost jobs. Let’s safeguard the EU’s original sensible proposal on coal mine methane and encourage other global producers to take on one of the easiest wins in tackling the climate crisis.

Background
Coal Mine Methane from the EU
Methane (CH4) is one of the most potent greenhouse gases and coal mines are the largest source of energy sector methane emissions in the EU. EU coal mine methane (CMM) emissions are dominated by Poland’s gassy underground mines, with the country responsible for almost two thirds of the EU’s CMM emissions.
Romania is the EU’s second largest CMM emitter. Its abandoned and closed coal mines released 200 thousand tonnes of methane in 2021, representing 85% of the EU’s abandoned mine methane (AMM) emissions.
Czechia is the only other European producer of hard coal, reportedly mining 2 million tonnes in 2021 which emitted 21 thousand tonnes of methane. The country however emits most of its CMM emissions from surface mines (mining lignite coal), which amounted to 41 thousand tonnes of methane emissions in 2021.
EU Methane Regulation
Scope and gaps in the regulation
The EU Methane regulation covers mitigation at active and abandoned underground mine operations which together represent 76% of EU CMM emissions. The latest revision would cut CMM by 47%, falling short of the EU’s 58% target and leaking an extra 2.2 million tonnes of methane by 2050, more than Belgium and Czechia’s annual CO2 emissions combined.
Recommendations
Looking ahead
It is realistic for the EU methane regulation to deliver on its goal of 58% reductions this decade, by tightening venting thresholds for both thermal and coking coal mines, closing Poland’s seven gassiest mines and mitigating or capturing methane from Romania’s closed mines.
Once the Regulation is agreed there will still be several potential loopholes which can be abused. Member States have the power to designate the “competent authorities responsible for monitoring and enforcing the application of this Regulation” (Article 4.1), creating scope for national authorities to be sympathetic to local coal companies. This risk is heightened by worrying provisions such as the period between inspections being as much as five years (Article 6.3) and Member States themselves laying down the rules on applicable penalties (Article 30.1). In this context, the Commission and Member States are expected to form a network (Preamble (10)) which will be important for working on the practicalities of applying the Regulation.
Supporting Material
Methodology
Global Warming Potential
Global Warming Potential (GWP) is a measure to express the effects of GHGs in CO2 equivalent terms. Given that CH4 absorbs much more energy when in the atmosphere, but has a shorter lifetime than CO2, the IPCC considers its impact over 20 years (GWP = 82.5) and over 100 years (GWP = 29.8). One of the shortcomings of this metric is that it assumes a constant value of methane’s effects over time, when in reality it varies significantly.
Historically, the 100-year value has been used by Governments and in major international agreements on the basis that global warming is a long term challenge.
At Ember, we propose to use the 20-year GWP. Climate change is an emergency, and the next 20 years are critical with regards to climate action. Methane’s short atmospheric lifetime means emissions reductions can reduce global heating in the near term.
Business As Usual scenario
We estimate that the twelve high-methane Polish coal mines would emit approximately 9.8 million tonnes of methane by 2050 if following a business as usual (BaU) scenario, including their established closure dates. We assume the “high methane” coal mines continue mining the same tonnage of coal every year, until their respective phase out dates. We also assume that the methane intensity of coal remains the same. This means our BaU estimates likely underestimate future methane emissions, as the methane intensity of the mines in question is likely to increase with time, as the mines dig deeper.
The analysis in this report is based on officially reported data (UNFCCC, and Polish nationally reported data), and consequently our estimated reduction potentials do not take into account any underreported CMM emissions. It is likely that some reduction potentials are greater than estimated in this analysis. Emission reduction strategies will need to improve quantification of emissions to apply meaningful targets.
As far as we are aware, “low-methane” mines do not currently report any methane emissions. Within our calculations we have therefore assumed that all reported emissions are only from the “high-methane” mines. Although we do expect low methane mines to have minor emissions, for lack of data we excluded them from this analysis.
Data Sources
We used publicly available data of coal production and methane emissions collated by Instrat from 12 “high methane” mines in Poland. These mines represented all of Poland’s and 93% of EU methane emissions from mining activities at underground mines, respectively.
All other methane emission data was collated from the IEA, and UNFCCC Greenhouse Gas Reporting database.
Acknowledgements
Conal Campbell
AcknowledgementsThis report greatly benefited from the support and insights of: Jan Balcerowski at Instrat.
Cover imageHeadframes at Chwalowice coal mine are seen at dawn in Rybnik, Poland in 2022. The mine is among the most methane-intensive in Europe. Credit: Reuters / Alamy