Submission: NSW Environment Protection Authority

2 October 2025 

To: NSW Environment Protection Authority 
Re: Climate Change Licensee Requirements and Greenhouse Gas Mitigation Guide for NSW Coal Mines

Thank you for the opportunity for the Institute for Energy Economics and Financial Analysis (IEEFA) to provide input on the NSW Environment Protection Authority (EPA)’s consultation on its proposed Climate Change Licensee Requirements and Greenhouse Gas Mitigation Guide for NSW Coal Mines. 

IEEFA is an independent energy finance think tank that examines issues related to energy markets, trends and policies. The Institute’s mission is to accelerate the transition to a diverse, sustainable and profitable energy economy.

IEEFA thanks the NSW EPA for the significant work in developing the draft guidelines. IEEFA commends the EPA for proposing to take a more active approach to greenhouse gas (GHG) emission reporting and monitoring, instead of relying solely on the federal Safeguard Mechanism and Clean Energy Regulator reporting frameworks. IEEFA also supports the NSW EPA proposal to mandate methane abatement actions at underground coal mines in NSW. 

However, the proposed Climate Change Licensee Requirements and Greenhouse Gas Mitigation Guide for NSW Coal Mines still present risks to NSW meeting its state-based emissions reduction targets. Most importantly, the proposed guidelines currently do not propose mandating any methane abatement action at open-cut coal mines in NSW, which could leave the majority of coal mine methane emissions unabated.

IEEFA proposes that the following points be incorporated into the Greenhouse Gas Mitigation Guide for NSW Coal Mines:

• Methane abatement action at open-cut coal mines should be mandated, in line with underground mines.
• Focusing only on underground coal mine methane ignores a potentially greater source of fugitive methane emissions in the state.
• The proposal to make regenerative thermal oxidation (RTO) technology mandatory is supported. The EPA should be open to factors to mitigate delays to implementation and to tighten up opt-out provisions. 

Kind regards

Anne-Louise Knight, Lead Research Analyst, Australian Coal
Andrew Gorringe, Energy Finance Analyst, Australian Coal