Executive Summary
Action to cut methane emissions from coal mines is needed in parallel with measures to reduce coal consumption. Yet global coal demand is set to rise in 2022 amid the upheaval of the energy crisis and this will have implications for meeting current emissions-reduction targets. Under the IEA’s Net Zero Emissions by 2050 Scenario, methane emissions from coal operations fall by more than 70% to 2030 while the world’s coal supply falls close to 50%. Dedicated abatement measures are therefore essential to driving emissions reductions at the pace and scale needed. Reductions in methane emissions are especially important for coking coal, mainly used in steel making, which often comes from underground mines where large-scale emissions cuts are most feasible. For steam coal, reductions in consumption are likely to be the best way to reduce methane emissions, as it can often be cost-effectively replaced by renewables in the power sector, and it is mostly produced from surface mines, where methane abatement is less feasible. The Global Methane Tracker 2023 provides information on the sources and abatement opportunities for coal mine methane (CMM), such as drainage for power generation or ventilation air methane oxidation.

Introduction
Action is needed on methane Methane emissions are responsible for around 30% of the current rise in global average temperatures. Rapid and sustained reductions of these emissions represent a significant opportunity to limit the near-term effects of climate change. Reducing methane has a major and immediate climate benefit because it has a much shorter atmospheric lifetime than carbon dioxide (around 12 years compared with centuries for CO2), and it absorbs much more energy while it remains in the atmosphere: Over a 20-year period, methane absorbs more than 80 times the energy of a comparable volume of CO2. Over 100 years, methane’s absorption rate drops to about 30 times that of CO2. Action on methane will be particularly important in the period to 2030 because sharp cuts in methane can deliver a net cooling effect within a relatively short period. This could help to keep the door open to a 1.5°C stabilisation in global average temperatures, while the world simultaneously pursues reductions in CO2 emissions. The Global Methane Pledge was launched at COP26 in November 2021 to catalyse action to reduce methane emissions. Led by the United States and the European Union, the Pledge now has 150 country participants who together are responsible for around 50% of global human-caused methane emissions. By joining the Pledge, countries commit to work together to collectively reduce methane emissions by at least 30% below 2020 levels by 2030.

Ten steps in implementing new regulations

How to use this guide
This guide is divided into two main components, the Roadmap and the Toolkit. The Regulatory Roadmap treats in detail each of the ten steps highlighted above and identifies key considerations and decision points for each step. The steps are presented sequentially, but will generally prove to be modular, with feedback loops and iterations between different stages of policy making. Feel free to focus on the steps that you have greatest interest in and skip steps that you have already mastered. Next, the Regulatory Toolkit presents different elements of policy making to support regulators throughout the policy development and implementation phases. It discusses general regulatory strategies, providing further detail on the four general regulatory approaches described above and illustrating their use through examples of current methane regulations. As with the Roadmap steps, each topic is intended to be modular and stand-alone, and you may wish to refer to aspects of the Toolkit as you walk through the Roadmap steps. The last section of the Toolkit presents additional resources, including reports, tools and institutions that support coal mine methane mitigation.

Air pollution regulation

Industry profile
One of the most important aspects of your industry is the makeup of its participants. Key stakeholders in the coal mining industry include: national and local governments giving mining concessions and natural resource rights; mining authorities that regulate the sector; mining operators with mine leases; service companies; end-use consumers that use coal as raw material; and investors. All of these actors have a stake in the progressive regulation of the sector.

CMM abatement through the coal mining life cycle

Methane can be released in all stages of the coal mining life cycle; however, there are significant variations in estimated emissions depending on mine type, age, and depth. The IEA’s Global Methane Tracker 2023 presents a more detailed discussion on the different sources of methane emissions from coal mines and related abatement measures. How might the particular characteristics of the industry in your jurisdiction affect the types of policies you put into place? If coal production is under the purview of state-owned companies, government agencies may be able to exercise greater influence over methane abatement through direct regulation. This is the case in India, where around 80% of coal is produced by the state-owned mining company Coal India Limited (CIL) under the Ministry of Coal. A CIL subsidiary, CMPDI, has been active in CBM recovery and utilisation since the 1990s, and has thus far been awarded over 30 CBM blocks for commercial development. The company also specialises in generating CBM data in the exploratory phase and has partnered with domestic and international partners on research and development projects for concurrent exploitation of coal and CMM/AMM. As CIL is currently expecting to increase production from deeper – and more gaseous – coal deposits to meet energy independence goals, there is heightened potential for CMM recovery through degasification projects.

Estimated level of emissions Most likely, you will need to develop an initial estimate of your emissions to use as reference point in setting your goals and tracking progress. Given that CMM emissions vary significantly depending on the gassiness of the mine, production rates, coal permeability and other factors – and that data collection and reporting requirements may be scarce relative to other sectors – generating reliable emissions estimates may require additional research and planning. By studying data about methane emissions from different points and activities in the mining life cycle, you can track general trends going forward and adjust your policies accordingly. You can take a phased approach for this, looking to estimate emissions from the most likely large sources first and undertaking additional efforts as more resources become available.

Problem sources The amount of methane in a given coal seam varies widely based on geological and environmental factors, meaning there is no one-size-fits-all approach to CMM abatement. There is a wide variation in the methane intensity of coal production (the amount of methane emitted by unit of coal produced). The worst-performing coal emits as much as 100 times more methane than the best-performing.

Indirect CO2 and methane emissions from global coal supply, 2021

Often, a few mines will be responsible for an outsized volume of emissions. These sites could also be the least costly to abate due to high methane concentrations and economies of scale – which makes them an interesting target for policy efforts. Implementing abatement technologies at these sites could open the way to spread such practices to other mines, since the industry will be more familiar with them and institutional barriers less prominent. Coal mine methane emissions vary based on the type of coal produced (steam, coking, lignite), the type of mine (surface, underground, active, abandoned), and other characteristics, including mine depth and age. Deeper coal seams tend to contain more methane than shallower seams, while older seams have higher methane content than younger seams. Underground mines tend to have higher methane emissions than surface mines. Although most methane emissions occur during the active phase of the coal mining life cycle, gas may continue to leak from abandoned mines for decades in the absence of mitigation measures. This may include biogenic methane from old mines.

Abatement solutions The final set of considerations relates to the available technologies and abatement strategies that match your regulatory, industry and emissions context. Where successful technologies and strategies have been identified, your policy could require their use or set performance standards that can be met through their adoption. In China, the biggest emitter of coal mine methane, a 2020 notice on environmental impact assessments for coal developments requires improvements in the utilisation rate of coal mine methane. It stipulates the need to use CMM where concentrations are above 8% and encourages its utilisation even when concentrations are below that level. Since the 1990s, China has implemented several large-scale CMM projects for power and heat generation, some of which have received funding under the Clean Development Mechanism of the Kyoto Protocol.

Enforcement Depending on your institution’s legal authority, you may be empowered to investigate regulated entities and enforce compliance with your methane rules. Enforcement actions may be made based on reported and submitted information, or through regulatory inspections or third-party complaints. It will be important to think through ahead of time what tools you will have to police and investigate potential cases of non-compliance as this may affect your regulatory design choices. In some cases, agencies issuing regulations have limited direct authority to enforce their own regulations, particularly against state-owned firms. In this case, you may need to co-ordinate with partner agencies to ensure that they have the information they need to develop an effective enforcement regime or to otherwise induce compliance.

Approaches to regulation What types of tools are best suited for your strategy and setting? We have outlined four main regulatory approaches in our typology of regulatory approaches. Here, we explore examples of these different approaches and consider some of the benefits and drawbacks of each approach, as summarised below.

Regulatory approaches drawbacks and benefits

It bears emphasis that the choice for regulators is to select the right approach for a given regulatory goal and institutional context. Often, a methane regulation is part of a broader effort with multiple policies that are co-ordinated towards reaching a larger goal. It can also be designed to align with efforts from other jurisdictions, allowing for fair competition among areas that share common markets. Ultimately, an effective policy effort will likely involve the co-operation of different stakeholders and a mix of different regulatory approaches and tools – all working together to tackle methane emissions in a complementary manner. Thus, different regulatory approaches can build on and complement one another. An information-based regulation might help to identify key sources that are then tackled by prescriptive or performance-based instruments. Over time, as a regulator improves their understanding of the industry and abatement options, it may be possible to adopt market-based or other economic instruments to facilitate company compliance or create incentives for the industry to go above and beyond existing requirements. That said, a lack of information or institutional resources need not delay methane regulation: Rather, it may suggest certain policy design options to compensate for – and perhaps overcome – those deficiencies.

Monitoring and reporting Monitoring encompasses systematic observation and review of selected parameters. The identification and assessment of methane sources, including purposeful venting, unlit flares, releases due to emergency situations, and fugitive emissions all depend on recurrent surveillance efforts. Monitoring can be deployed to detect or quantify methane releases. Detection is sufficient to verify the need for action (e.g., repairs in abatement systems), but quantification is needed for a better understanding of emissions and to establish baselines and related goals (Step 6). Quantification through a bottom-up approach is the more common way to estimate general emissions. It relies on activity data (e.g., the number of mines, the amount of coal produced) and either general or specific emission factors (e.g., IPCC standard emission factors or facility-level estimates) to calculate overall emission rates. Top-down quantification features direct measurement, normally by ground, airborne or satellite sensors, of atmospheric methane concentrations to infer emission releases. Top-down measurements often do not require support from operators and can be used on a larger scale. Monitoring systems often combine bottom-up and top-down approaches for optimal results, and consider a range of information sources to improve accuracy (e.g., coal gas composition, since monitoring devices may be affected by the presence of other gases than methane).

Source:http://IEA