Submissions close 5pm Tuesday 7th October
Link to the proposed documents here
What is the NSW EPA’s public consultation on reducing coal mine greenhouse gas emissions?
The NSW Environmental Protection Authority (EPA) is the state’s independent environment regulator. The EPA issues environmental protection licenses to coal mining companies and monitors compliance. It is seeking feedback on proposed licencing changes for NSW’s largest greenhouse gas emitters (mines that emit more than 25,000 tonnes CO2eq per year in Scope 1 & 2 emissions).
The EPA public consultation covers three areas: Climate Change Licensee Requirements, Climate Change Mitigation and Adaptation Plans, and Greenhouse Gas Mitigation Guide for NSW Coal Mines.
Why is tackling methane the priority?
Methane is a short-lived and highly potent greenhouse gas. Reducing methane emissions is one of the fastest ways to slow the rate of warming in Australia. Coal mines are big emitters and methane emissions are under reported.
What is the EPA proposing?
The EPA proposes to set ‘expectations’ on coal mine companies that will become legally enforceable in time. This includes setting emission reduction goals and measuring and reporting against them. It includes implementing technologies and practices to reduce emissions in coming years. Importantly, it does not include a cap or limit on methane emissions.
What is the failing of the EPA proposal?
There is no requirement for coal mine companies to limit methane emissions to a set level.
Emissions from coal sold and burnt overseas are excluded and this comprises most of the emissions.
Expectations for coal mine companies to implement technologies and practices to reduce emissions are weak, and timelines need to be brought forward to ensure real change happens this decade.
Under the proposal, companies could avoid requirements by arguing that a measure is “not feasible to implement.”
The proposal lacks ambition and urgency. It will not effectively address emissions from operating coal mines nor limit coal mine expansions or extensions.
Why is your voice important?
The EPA has broad powers under enabling legislation and an obligation to address climate change, but as written, the proposals are a missed opportunity to reign in emissions and safeguard NSW from climate change impacts.
The coal industry is powerful, and we need to push back.
Make a submission before October 7
The EPA's proposals fall far short of what is needed to cut emissions from NSW coal mines. Rather than driving urgent change, they would preserve the status quo and make it impossible for NSW to achieve its legislated emission cuts of at least 50% by 2030 and 70% by 2035.
In your own words, consider calling for the following measures in your submission:
- Enforceable caps or limits on emissions are needed, with a focus on methane. Offsetting to meet limits should not be allowed. To determine facility level caps, the EPA should work with the Net Zero Commission to determine a sectoral coal mine emissions target for 2030 and 2035 consistent with a 1.5 degree warming pathway.
- Move the timeframe for gas drainage and addressing methane leaks at underground mines forward to 2026.
- Require methane abatement (Ventilation Air Methane) at underground mines this decade.
- Require methane drainage and destruction at all open cut mines.
- Require a faster and ambitious schedule for the electrification of vehicles at coal mine sites and require all mines to utilise renewable energy for electricity by 2030.
- Remove the proposed exemption to allow coal companies to avoid requirements and withhold environmental protection licences from companies that fail to comply.
- Introduce measures to address emissions from coal sold and burnt overseas (Scope 3 emissions).
How to make a submission
Send your submission via email to [email protected]