P-PRCP-100669070 · CENTURION COAL MINING PTY LTD

Department foundTable 2.1 presents a summary of Peabody’s Greenhouse Gas Abatement Plan (GHG Abatement Plan). This Table indicates that the reference point for emissions for this project is the Centurion Coal Mine. The following statement is made ‘Emission reduction will be measured based on the site- specific emission intensity approved by the Clean Energy Regulator for the Centurion Coal Mine.’ The current EA amendment relates to activities proposed to occur at the Centurion North project. The Centurion Coal Mine reference above, and in Table 2.1 is a distinctly different operation, occurring in a different location and authorised under a different Environmental Authority. The GHG Abatement plan does not explain why a neighbouring project has been used as the emissions reference point for the project or justify the appropriateness of this approach.

Asked for1. Provide an explanation as to why the neighbouring project Centurion Coal Mine has been used as the emissions reference point for the Centurion North Project. 2. Justify the use of the Centurion Coal Mine as the emissions reference point for the Centurion North project with consideration of the fact that the current EA amendment being assessed for the Centurion North project, occurs on an unrelated tenement under an unrelated environmental authority to that the Centurion Coal Mine. 3. If part of the explanation relies on the two projects being operated as a singular Safeguard Facility under the Commonwealths Safeguard Mechanism, provide details of the appropriateness of this approach.

Notice, page 3

Department foundTable 2.2 of the GHG abatement plan states ‘operation of flares at >95% availability and the response time are generally 20 minutes to restart flaring.’ Table 3.2 in Section 3.7 ‘Equipment’ indicates that venting systems will also be installed, presumably to facilitate direct venting when flaring is not in operation. Given the large volume of methane to be extracted over the life of the proposed project, the resulting GHG emissions from direct venting into the atmosphere when flaring is not available, during re-start of flaring, and/or leaking could be significant. The GHG emissions produced in these instances must be estimated.

Asked for1. Provide a detailed discussion in the GHG Abatement Plan of any direct venting that is proposed as part of the project. This must include more specific information about any venting systems required, the expected frequency of venting and any safety or technical considerations that have been contemplated in the development of the project. Any further regulatory requirements that have been considered must also be detailed. 2. Provide an estimate of the Scope 1 emissions that is inclusive of GHG emitted during direct venting and during restart of flaring. 3. Consider the impact that any leakage could have of the GHG emissions estimates, and if required includes the estimated emissions from any leakages in the Scope 1 estimate. Identify and discuss the implementation of mitigation measures in order to reduce the leakage of GHG emissions as a result of direct venting and during restart of flaring.

Notice, page 4

Department foundTable 6.7 of the supporting report ‘Environmental Authority Amendment Application Supporting Report’ outlines the emissions factors that have been considered in the Greenhouse Gas Assessment, based on the National Greenhouse Account Factors. It is noted that one of the emissions factors referred to is for ‘coal seam methane that is captured for combustion’. The National Greenhouse Account Factors Table also provide a factor for ‘coal mine waste gas’, which has not been considered in Table 6.7. It is not clear whether using the coal mine waste gas factor has been considered in preparing the GHG assessment or the justification for ultimately using the coal seam methane factor. It may be appropriate to use the coal mine waste gas factor given one of the objectives of the project is to inform environmentally conscious management plans for eventual extraction of coal from ML1790.

Asked for1. Confirm whether the National Greenhouse Account Factor for ‘coal seam waste gas’ was considered in developing the GHG assessment. 2. If the ‘coal seam waste gas’ factor was considered, provide details on how each of the National Greenhouse Account Factors for ‘coal seam methane’ and ‘coal seam waste gas’ were considered and why the ‘coal seam methane’ factor was used in the development of the assessment. 3. Alternatively, if the ‘coal seam waste gas’ factor was not considered, provide an assessment on it’s applicability to the project and revise the GHG assessment as required.

Notice, page 4

Department foundSections 6.2.2.3 and 6.2.2.4 discuss the operation of the vertical and lateral wells, and the summary of GHG emissions estimates. From these sections, it appears that the operation of 13 vertical wells has been included in estimating the scope 1 emissions, however it is not clear that the operation of 10 lateral wells has been accounted for. Further information is requested to explain how the operation of the 10 lateral wells contributes to the emissions profile of the project.

Asked for1. Provide further details on how the 10 lateral wells will operate in conjunction with the vertical wells, and whether any emissions will be produced through their operations. 2. If the operation of the 10 lateral wells will contribute to the scope 1 emissions for the project, revise the GHG assessment to make clear what these emissions are estimated to be and how they have been incorporated.

Notice, page 5

Department foundThe GHG abatement plan presented in Table 2.2 ‘Project Specific Greenhouse Gas Abatement Plan’ generally lacks the detail required as specified in Appendix A of the GHG Guideline. Matters that are required to be addressed in accordance with Appendix A, which are currently considered absent from the GHG abatement plan include the following: • Emission Reduction Targets • A GHG emissions reduction program • A discussion of advancing technologies and opportunities • Details on monitoring and auditing. It must also be noted that the GHG emissions reduction program is required to provide detailed information as outlined in Appendix B of the GHG Guideline. Further, the information that has been supplied in Table 2.2 to meet the Appendix A requirements lacks the detail and specificity required to allow the department to understand the effectiveness of the proposed mitigation measures, emissions reduction measures and abatement opportunities.

Asked for1. Revise and update the GHG abatement plan to address sections (d), (e), (f) and (g) in accordance with Appendix A of the GHG guideline. Note that part (e) must be addressed in accordance with Appendix B of the GHG Guideline. 2. Revise and update the GHG abatement plan to provide further details on parts (b), (c) and (h). It must be noted that the requirements outlined in Appendix A are a majority of the content requirements needed for the GHG abatement plan. The current approach to address these requirements in table and dot point formation does not meet the level of detail expected.

Notice, page 5

Department foundSection 6.5.2.1 of the supporting document identifies that the project will intercept an area of regulated vegetation that is classified as ‘Of Concern’ RE 11.8.11. However, the application indicates that the RE is not classified as MSES in accordance with the definition of prescribed regional ecosystem given in the Environmental Offset Regulation 2014, which refers to section 8(b) of the Vegetation Management Act 1999. The VM REDD referred to in the Vegetation Management Act 1999 classifies ‘grassland’ and woody grassland’ separately and section 8b refers only to the grassland structural category. RE 11.8.11 has a structural category of woody grassland. Thus the exclusion provided in the prescribed regional ecosystem definition does not apply to RE 11.8.11. The supporting information must identify the impact to RE 11.8.11 as an impact to MSES and undertake a significant residual impact assessment accordingly.

Asked for1. Revise the supporting document to identify RE 11.8.11 as MSES regulated vegetation and address any significant residual impact to this regulated vegetation.

Notice, page 6