Indonesia is a country committed to reducing Greenhouse Gas (GHG) emissions and combating the climate crisis caused by global warming. Since 2016, Indonesia has ratified the Paris Agreement through Law No. 16 of 2016, which concerns the ratification of the Paris Agreement to the United Nations Framework Convention on Climate Change (UNFCCC). The Paris Agreement requires Indonesia to develop and communicate climate resilience actions in a nationally determined document called the Nationally Determined Contributions (NDC), which is then submitted to the UNFCCC Secretariat. Indonesia’s NDC set a target to reduce GHG emissions by 29% unconditionally (through its own efforts) and 41% with international support by 2030. 1

Climate Watch states that the energy sector contributes nearly three-quarters, or 75%, of global GHG emissions. In the energy sector, the largest source of emissions comes from electricity and heat generation, followed by transportation and manufacturing.2 At the national level, the International Energy Agency (IEA, 2021) reported that electricity generation and heat production in Indonesia account for 43% of total emissions. Meanwhile, fossil fuel combustion in the energy sector, with coal as a primary source, contributes 51% of CO2 emissions.3

The extractive sector, particularly oil and gas (O&G) mining, mineral, and coal mining, is also a significant contributor to GHG emissions. In 2023, oil and gas activities contributed for approximately 15% of global energy-related emissions, equivalent to 5.1 billion tons of GHG emissions.4 McKinsey (2021) noted that mining is responsible for 4-7% of global GHG emissions. Furthermore, McKinsey (2020) estimated that the mining industry generates between 1.9 and 5.1 gigatons of CO2-equivalent GHG emissions each year. Most emissions come from coal mine methane, released during coal mining (1.5 to 4.6 gigatons), especially from underground mining operations. Methane is one of the GHGs, alongside others like carbon dioxide (CO2), sulfur dioxide (SO2), nitrogen monoxide (NO), nitrogen dioxide (NO2), and chlorofluorocarbons (CFCs).5 When trapped in the atmosphere, these gases contribute to global warming.

Indonesia is one of the largest coal producers globally. In 2023, Indonesia ranked as the third-largest coal producer in the world, behind China and India.6 According to data from the Ministry of Energy and Mineral Resources through Minerba One Data Indonesia (MODI), coal production and sales in Indonesia reached their highest level in eight years in 2023, totaling 770.80 million tons, exceeding the production target by 110.99%.7

This high level of coal production in Indonesia leads to increased emissions of methane, one of the GHGs. According to EMBER (2024), emissions from coal mines could be up to eight times higher than the official figures released by the Indonesian government.8 EMBER further found that the government’s emission data for coal mining is significantly lower than findings from independent studies.

This discrepancy is attributed to several factors, including a lack of data transparency, inaccurate emission factors, the Global Warming Potential (GWP) of methane, and the exclusion of emissions from underground coal mining.9 As a result, there is a substantial gap between government-reported emissions and independent findings, particularly when compared with satellite data and coal production reports in Indonesia.

Official government data on GHG emissions, as reported by the Ministry of Environment and Forestry (KLHK) in the Third Biennial Update Report-UNFCCC (2021), specifically for the energy sector in 2019, only includes coal mine emissions from surface mining, excluding emission from underground mines. Emissions from underground coal mining are categorized under GHG emission types but have no reported figures.10 This omission results in a cumulative national GHG emission total that overlooks emissions from underground coal mines.

In fact, underground coal mines generate higher emissions than surface mines due to increased methane release under higher pressure and depth. According to Global Energy Monitor, 85% (44 Mt) of global methane emissions from coal mining come from underground mines, with the remaining 15% coming from surface mines.11 It is estimated that if emissions from PT Qinfa Mining’s newly established underground coal mine were included in Indonesia’s 2019 emissions report, total methane emissions would increase by around 332 kilotons (ktCH4), tripling the reported total. Underground coal mines emit more methane than surface mines due to deeper coal seams and higher-quality coal.12 In underground mines, methane is released through degassing and ventilation systems, whereas surface mines produce emissions from the extraction process at the surface.13

Transparency in emissions data from underground coal mines is crucial for reducing GHG emissions. Given the potential for higher emissions from these mines compared to surface mining, inaccurate emissions reporting not only undermines the credibility of national emissions data but also weakens Indonesia’s global14 commitment to climate action and transparency.

Currently, emissions data for coal mines at the company level (whether surface or underground) is not publicly available. The Indonesian government has only made aggregate data for surface coal mines available, as seen in the Third Biennial Report to the UNFCCC. While some coal companies have voluntarily disclosed emissions data in their sustainability reports, this is limited to publicly listed companies and is not mandatory. Therefore, data availability is restricted to companies that choose to report their emissions. Fewer companies report their coal mining emissions compared to the total number of mining licenses in Indonesia. EMBER reported that only seven companies currently disclose emissions data through sustainability reports, and these reports often suffer from underreporting due to unpublicized calculation methods. The seven companies are Bukit Asam Resources, Golden Energy Mines, Berau Coal, Bumi Resources, Adaro Energy, Bayan Resources, and Indika Energy.15

Moreover, Indonesia’s carbon tax regulations and emission standards currently only apply to carbon dioxide (CO2) emissions from coal-fired power plants (PLTUs). Methane emissions from coal mining operations have yet to be regulated. According to Law No. 7 of 2021 on the Harmonization of Tax Regulations, the carbon tax on PLTUs is scheduled for implementation from 2022 to 2024. However, it is likely that carbon trading will be expanded by 2025, potentially including methane emissions from coal mining. This expansion could lead to methane’s inclusion in the future carbon tax framework.

Globally, there has been a growing push for methane inventories in the extractive sector, particularly for coal mining. In 2024, the United States began imposing a methane emission fee as part of its climate action strategy, which currently applies only to the oil and gas sectors. Although U.S. methane emission volumes were relatively low in 2021, methane has a much stronger climate impact compared to CO2, with one ton of methane having a greater warming effect than one ton of CO2.16 Therefore, methane is often measured in CO2-equivalent terms. While this regulation does not yet extend to coal mining, it is expected to raise global awareness of the importance of including methane emissions in carbon tax systems.

Indonesia has also committed to the Global Methane Pledge, which aims to monitor and address coal-related GHG emissions more rigorously, including improving data transparency, understanding methane emission challenges, and implementing effective mitigation measures.17 Additionally, Indonesia is part of global initiatives that prioritize transparency, including the Extractive Industries Transparency Initiative (EITI) and the Open Government Partnership (OGP), with Indonesia being a founding member of OGP since 2011.

Since 2010, Indonesia has been an EITI implementing country, as mandated by Presidential Regulation No. 26/2010 on Transparency of State and Regional Revenue from the Extractive Industry, which was amended by Presidential Regulation No. 82/2020 on the COVID-19 Handling and National Economic Recovery Committee. EITI has a set of standards that implementing countries and extractive companies must adhere to, and these standards are updated regularly to improve global governance in the extractive sector. The latest EITI Standard (2023) specifically includes a requirement (Requirement 3.4) for countries and extractive companies to disclose their GHG emissions data.18

To enhance the integrity of Indonesia’s climate transparency commitments, the government should mandate the disclosure of emissions data from all coal mining companies, whether surface or underground, through regulations such as incorporating this data into the Coal Mining Work Plan and Budget (RKAB). This would help ensure that emissions data reporting reaches the thousands of registered mining licenses. Given that underground coal mining emissions are expected to be much higher than surface mining emissions, it is crucial for Indonesia, as an EITI member, to implement the EITI 2023 standard and compel extractive companies to report GHG emissions data.

Opening up more comprehensive emissions data could also help curb coal production and optimize energy transition efforts. From 2015 to 2023, coal production in Indonesia has consistently exceeded targets by up to double the expected amount, highlighting the government’s significant reliance on coal.19 This reliance is at odds with climate action goals. Therefore, by increasing transparency in coal mining emissions, including methane emissions, and integrating them into carbon tax inventories, Indonesia can improve its climate mitigation strategies and achieve more effective, comprehensive climate action.

  1. Bappenas. Discussion on Nationally Determined Contributions (NDC) in Efforts to Reduce National Emissions. Link accessed on June 4, 2024.
  2. Climate Watch. Greenhouse Gas (GHG) Emissions. Link accessed on June 4, 2024.
  3. IEA. Indonesia Emissions. Link accessed on June 5, 2024.
  4. IEA (2023). Emissions from Oil and Gas Operations in Net Zero Transitions. International Energy Agency, Paris. Link (Licence: CC BY 4.0).
  5. KLHK (Ministry of Environment and Forestry). Measuring and Reducing Greenhouse Gases. Link accessed on June 4, 2024.
  6. Katadata. The Largest Coal Producers in the World in 2023. Link.
  7. Minerba One Data Indonesia (MODI). Link accessed on June 4, 2023.
  8. EMBER (2024). Uncovering the Hidden Challenges of Methane Emissions in Indonesia, p. 4.
  9. Ibid.
  10. Ministry of Environment and Forestry (2021). Indonesia’s Third Biennial Update Report under the United Nations Framework Convention on Climate Change, p. 69. Link.
  11. Global Energy Monitor (2022). Bigger than Oil or Gas: Sizing up Coal Mine Methane, pp. 17-18.
  12. EMBER. Op. cit., p. 5.
  13. Ibid.
  14. Ibid., p. 4.
  15. Focus Group Discussion by PWYP Indonesia with Dodi Setiawan, Researcher at EMBER, on June 14, 2024.
  16. Tax Foundation (January 2, 2024). Methane Fee to Take Effect in 2024: A Mini Carbon Price. Link.
  17. Ibid., p. 3.
  18. PWYP Indonesia (September 28, 2023). The Urgency of Transparency in Greenhouse Gas (GHG) Emissions Data and Its Impact on Climate Change. Link.
  19. Minerba One Data Indonesia (MODI). Loc. cit.

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