Safeguard rules for coal mines

The removal of the distinction between open cut and underground coal mines, in section 17 of Schedule 1, is very sensible.

Based on Queensland coal mine data, the default emission intensity for coal mines should be higher than 0.0653

Taking the default emission intensity for a coal mine as the average of 0.0653 and the facility-specific emissions intensity is a logical nonsense.

A slower transition to the default emissions intensity could be achieved by amending the transition proportion table in section 13 of schedule 1 in the Safeguard Rule to show slower increases for coal.

The claim that the variability in emissions intensity is widest in the coal sector is not supported by any published figures, and may not be accurate.

The high emission intensities of all seven Queensland underground mines may largely reflect failure to use methane capture or flaring.