China Strengthens Coal Mine Methane-Emission Requirements

On December 1, 2024, China’s Ministry of Ecology and Environment and State Administration for Market Regulation jointly released the amended Emission Standard for Coalbed Methane (Coal Mine Gas) (GB 21522—2024). The Amended Standard applies nationally to new and existing coal mines and coalbed methane development systems in China. The Amended Standard is an important step in implementing China’s Methane Emissions Control Action Plan (2023), which refers to the need to “fully implement the standards for coal mine gas emissions limits” in Section 6(15). (IGSD’s English reference translation of the Action Plan is available here.)

Highlights of the Amended Standard include:

• Strengthening coalbed methane emissions requirements. Coal mine gas with a methane concentration of 8% or more and an extraction purity of 10 cubic meters per minute or more shall not be directly emitted (the standard amendment also clarifies that the methane concentration and extraction purity refer to the 24-hour average values).

• Emphasizing coal mine safety as the prerequisite for implementing the Standard. The Amended Standard incorporates new provisions on the management of low-concentration gas (in accordance with Standard GB 40881). Additionally, the Standard provides that in the event of safety emergencies, coal mine enterprises can first discharge coal mine gas in accordance with relevant regulations and then report the emergency incident(s) per the requirements of the Amended Standard.

• Adjusting the requirements for the utilization and destruction of coal mine gas. In the Amended Standard, coal mine enterprises are required to construct utilization facilities for the utilization of coal mine gas with a methane concentration of 8% or more and extraction purity of 10 cubic meters per minute or more. The Standard also mandates that the gas shall be destroyed if it cannot be utilized. (IGSD Note, China intends to incentivize further utilization and reduction of coal mine gas with methane concentration lower than 8% through greenhouse gas emissions trading. In this regard, see Greenhouse Gas Voluntary Emission-Reduction Project Methodology for Utilization of Low-Concentration Gas and Ventilation Air Methane in the Coal Mine Sector (Draft for Comments) (24 July 2024).)

• Requiring the incorporation of sensors into methane discharge pipelines of coalbed methane collection and transmission stations, compression station discharge pipes, gas extraction pumping stations, gas utilization and destruction facilities, the emergency discharge pipelines, and other facilities. The aim of incorporating such sensors is to monitor methane emission concentrations, flow rates, pressure, temperature and humidity, and other relevant parameters. (The standard amendment also refers to other standards applicable to methane monitoring and the technical specifications for sensors, such as Standard AQ 6204.)

The Amended Standard will take effect for newly constructed coal mines and coalbed methane development systems as of April 1, 2025. For existing coal mines and coalbed methane development systems, the Standard implementation date is delayed to April 1, 2027. However, provincial governments are allowed to voluntarily adopt an earlier Amended Standard implementation date for covered facilities within their jurisdiction. According to the China Ministry of Ecology and Environment, implementation of the Amended Standard will reduce methane emissions by about 50 million tons of carbon dioxide equivalent per year.

Additional IGSD China resources:

• IGSD (8 November 2024) China Enacts Energy Statute with Significant Implications for the Climate.

• IGSD (3 June 2024) China Issues Measures to Regulate the Utilization of Domestically Produced and Imported Natural Gas. IGSD’s annotated, English reference translation of the Administrative Measures on Natural Gas Utilization is available here.

• Xiaopu Sun, Tad Ferris, and Valerie Fajardo, China’s Ongoing Efforts to Address Methane Emissions and Opportunities to Further Raise China’s Methane Mitigation Ambition (in collaboration with the Asia-Pacific Centre for Environmental Law, National Singapore University (2024).

• IGSD (7 November 2023) China releases Methane Emissions Control Action Plan. IGSD’s annotated, English reference translation of the China Methane Emissions Action Plan is available here.