Mod 8 - Ulan West Continued Operations.

There must be no more expansion of coal mining to maintain a safe climate. It would release over 105 Mt of additional Greenhouse Gas emissions.
It has poor monitoring and reporting of methane emissions.
As it is outside existing mine boundary with additional infrastructure disturbance, it should be
assessed as a new project
Constructing a large new tailings dam area of 132 ha within a revegetated, rehabilitated
old open cut pit next to Goulburn River is risking leakage of toxic contaminants
Being wholly west of Great Dividing Range within the Murray Darling Basin results in loss of flows to
Talbragar River, tributary of Macquarie River feeding into significant Macquarie Marshes. The extended water releases into Goulburn River increasing salt load downstream to Hunter
There would be loss of Aboriginal cultural heritage and spiritual landscape for Wiradjuri Nation –
impacting 71 known sites, including rock art and disturbing an additional 1743 ha with sandstone escarpment, caves and overhangs.
It would destroy an additional important habitat for the nationally threatened Large-eared Pied
Bat, Eastern Cave Bat, Regent Honeyeater and Koala and critically endangered Box Gum
Woodland. There would be an acumulative impact on these species across 3 mines in region.
The final layout of surface infrastructure is not yet determined and the mine plan is not finalised to be adequately assessed.
It would undermine 17 private properties directly impacting 4 houses and 6 private bores.
There would be increasing social impacts, loss of farm water and ongoing disturbance of rural way of life
This project is not needed to provide regional jobs – there is a huge workforce shortage
for renewable energy projects and other industries in the Central West.

Submission opposing the Ulan Coal Mine Mod 8 – Ulan West Continued Operations proposal
Peter Sainsbury 8 November 2025

I am opposed to Glencore’s proposal for several reasons:
• To begin with, the proposal concerns activities beyond the boundaries of the current mine. As such, it is to all intents and purposes a new mine and should be assessed with all the requirements that involves rather than as a ‘continued’ operation.
• If approved, the mine will have multiple harmful effects on Aboriginal heritage, the natural environment and human health.
• The world is facing a major crisis with global warming. The major cause is the burning of fossil fuels. The scientific evidence clearly indicates that global warming must be limited to no more than 1.5oC, that greenhouse gases must be reduced to net (preferably absolute) zero as soon as possible, that to achieve this the burning of fossil fuels must be rapidly reduced, that we already have enough fossil fuels available without developing new mines etc., and that fossil fuels must be left in the ground. There is no need for more fossil fuel extraction sites to be developed.
• The evidence is also clear that every additional fraction of a degree of warming adds to the dangers associated with global warming and that every additional ton of coal burnt contributes to an additional fraction of a degree of warming. That is, the argument that this proposal involves an irrelevantly small amount of coal on a global and historical scale is wrong and deceitful.
• Glencore’s proposal is reckless as the GHGs released when the coal is burnt (it does not matter where it is burnt) will unnecessarily add to global warming.
• As a retired public health doctor, I am very aware of the dreadful harm that is already being done to people’s health by climate change and the unnecessary premature deaths that it is causing here in Australia and worldwide. This is inevitably going to get worse as global heating continues to increase, particularly the longer we keep burning fossil fuels and the longer we keep digging up coal, oil and gas. The situation is now so bad that it constitutes a serious threat to the very survival of humanity. The real tragedy is that we know the problems, including the damage to human health, being caused by global heating, we know what to do to remedy the situation, we have the technology and the economic resources but we are failing to act with the urgency required. Part of that failure is that governments continue to approve fossil fuel extraction projects. Nowhere is this failure more obvious than in Australia.
• The construction of the mine and the associated infrastructure will cause irreparable damage to the local natural environment and further reduce habitat for endangered animal and plant species such as bats, Regent honeyeaters, Koalas, owls and Box Gum woodland.
• The proposed tailings dam will not only damage the land it is built on but risks contaminating the Goulburn River, particularly as Glencore has no adequate monitoring program for leaks.
• The mine will further reduce the water flows in the Talbragar and Goulburn Rivers.
• I will let more people with more expertise detail the additional damage to Aboriginal cultural heritage that the mine will cause.
• I strongly encourage you to reject Glencore’s proposal.

I object to the proposed Ulan Coal Mine Mod 8 – Ulan West Continued Operations on the following points;

1. Releasing over 105 Mt of additional Greenhouse Gas emissions, poor monitoring and
reporting of methane emissions.
2. Outside existing mine boundary with additional infrastructure disturbance - should be
assessed as a new project
3. Constructing a large new tailings dam area of 132 ha within a revegetated, rehabilitated
old open cut pit next to Goulburn River risking leakage of toxic contaminants
4. Wholly west of Great Dividing Range within the Murray Darling Basin - loss of flows to
Talbragar River, tributary of Macquarie River feeding into significant Macquarie Marshes
5. Extended water releases into Goulburn River increasing salt load downstream to Hunter
6. Loss of Aboriginal cultural heritage and spiritual landscape for Wiradjuri Nation –
impacting 71 known sites, including rock art
7. Disturbing an additional 1743 ha with sandstone escarpment, caves and overhangs:
Destroying additional important habitat for the nationally threatened Large-eared Pied
Bat, Eastern Cave Bat, Regent Honeyeater and Koala, critically endangered Box Gum
Woodland. Cumulative impact on these species across 3 mines in region.
8. Final layout of surface infrastructure not yet determined – mine plan not finalised
9. Undermining 17 private properties directly impacting 4 houses and 6 private bores
10. Increasing social impacts, loss of farm water and ongoing disturbance of rural way of life
11. This project is not needed to provide regional jobs – there is a huge workforce shortage
for renewable energy projects and other industries in the Central West.

I am writing as a concerned citizen to formally object to the proposed Ulan Coal Mine Mod 8 (Ulan West Continued Operations Project). This proposal represents a major new expansion of coal mining rather than a modification of existing approvals, and it poses serious local, regional, and global environmental risks that cannot be justified in the context of a worsening climate crisis.

1. A New Project, Not a Modification

The Mod 8 proposal lies entirely outside the existing mining lease area, introduces a large new 132-hectare tailings dam, new ventilation structures, access tracks, and other infrastructure, and would disturb an additional 1,743 hectares of land. These substantial new impacts mean the proposal must be assessed as a new project, not a modification. Proceeding otherwise undermines the integrity of environmental planning processes in NSW.

2. Global Climate and Greenhouse Gas Impacts

The project will release over 105 million tonnes of additional CO₂-equivalent emissions. In a world already experiencing record heat, fires, droughts, and floods, continuing to expand coal production is incompatible with Australia’s and NSW’s net-zero commitments and with the global effort to limit warming to 1.5°C under the Paris Agreement.

Methane emissions—an especially potent greenhouse gas—are poorly monitored and reported by Glencore. The company has previously altered its emissions baselines to avoid offset obligations under the Federal Safeguard Mechanism. Allowing further expansion of coal mining in the Central West Orana Renewable Energy Zone sends a contradictory signal at a time when we urgently need to accelerate the transition to clean energy.

3. Threats to Water Resources

This project would intensify pressure on groundwater and river systems that sustain regional communities and ecosystems. Predicted losses include 26.5 million litres per year of flow from the Talbragar River, which feeds the Macquarie River and the internationally significant Macquarie Marshes. Extended mine-water discharges into the Goulburn River would add over 15,000 tonnes of salt downstream, degrading water quality and harming aquatic life. These cumulative impacts have never been properly assessed.

4. Risks from New Tailings Storage

The proposed tailings dam, located beside the Goulburn River on previously rehabilitated land, poses an ongoing risk of toxic leakage and contamination. There are no proposed monitoring points to detect seepage, and the site’s unstable foundation of backfilled coal rejects makes it unsuitable for permanent waste storage. This design would create a new toxic legacy in a sensitive river catchment.

5. Cultural and Biodiversity Loss

The expansion threatens 71 additional Wiradjuri cultural heritage sites, including rock art and spiritually significant landscapes. These losses compound the destruction already caused by decades of mining in the Ulan area.

It will also destroy or fragment habitat for threatened species such as the Large-eared Pied Bat, Eastern Cave Bat, Regent Honeyeater, Koala, and the critically endangered Box Gum Woodland. Much of this habitat is irreplaceable and cannot be offset. Cumulative biodiversity impacts across the three Ulan mines remain unassessed.

6. Social and Regional Impacts

Seventeen private properties will be directly affected, including four homes undermined by mining subsidence and six private bores predicted to lose water. Such impacts erode rural communities and livelihoods. Glencore has a long record of property buyouts in the area due to noise, water loss, and subsidence—consequences that continue to divide and weaken local communities.

7. No Justification for Further Coal Expansion

The Central West region faces a labour shortage, not a lack of jobs. Skilled workers are urgently needed in renewable energy, construction, and infrastructure projects, particularly within the Central West Orana Renewable Energy Zone. Extending coal production to 2041 undermines economic transition efforts and increases climate risk for future generations.

Conclusion

At this stage of the climate emergency, no new or expanded coal mine can be justified. The Mod 8 proposal would lock in decades of additional greenhouse emissions, damage water systems and biodiversity, and create new toxic and cultural legacies—all for a product the world must rapidly phase out.

For these reasons, I respectfully urge the Department to reject the Ulan Mod 8 modification application and require Glencore to submit a new development application for full and independent assessment, including cumulative climate, environmental, and social impacts.

Sincerely,
Nicolas Sprauel

Objection to the Ulan Mine Mod 8.

Firstly I do not accept that this is a 'modification' as it is entirely outside the current mining lease and would thus cause new impacts, so needs to be assessed as a new project, with full independent merit assessment.
In any case, the project of which it is theoretically an extension, Ulan Mod 6, while approved, is currently under legal appeal, so no action should be taken in connection with it.

The Glencore Ulan Mine already has approval to mine 20MT of thermal coal until 2035.
That will do enough harm to our carbon budget when burnt, wherever that may be.
As a grandmother, I cannot believe that further coal extraction, a further 43MT up to 2041, is being considered, releasing 105MT of extra GHG, when we know that reducing emissions, not increasing them, is essential.
We want our grandchildren to have liveable future, and new mine/modification makes the possibility of such a future even less likely.

The mine is different from the others in the region as it is wholly west of the Great Dividing Range, within the Murray-Darling Basin, so the loss of water from the Talbragar River, a tributary of the Murray, would impact both it and the Macquarie Marshes it feeds.

But its post-mining-process water impacts is of great concern too. The large tailings dam proposed, of 132 ha., in a revegetated old open cut, is next to the Goulburn River. The risk of contaminants leaking into that plus the releases of ex-mine water into the river and the attendant salt levels downstream on the Hunter River are impacts that should not be considered.

There have already been huge impacts from mining on the Wiradjuri cultural heritage here, and this project would impact 71 more known significant sites, including rock art. When will we stop such desecration?

Underground does not mean no impact aboveground.
Of course there will be huge impacts on the rural areas here, as it will undermine 17 private properties, directly impacting four homes and six bores. This a dry are and farms depend on those bores.
The destruction of community from the three mines in this area is cumulative, as is every impact, including environmental.
It cannot be said that all this is warranted due to the 'jobs', as there is already a shortage of labour for the renewable energy industries taking off as the Central West Orana Renewable Energy Zone gets underway. Ulan is within that Zone; so why expand this very non-renewable coal mine??
Just because the coal deposit exists no longer means it is OK to dig it up, purely for Glencore's profit.

Key concerns with the Ulan Mod 8 mine expansion:

1) Extends Coal Mining:
Seeks to extend thermal coal mining for a further six years (to 2041), extracting an additional 43 million tonnes of coal
Minimises cumulative impacts of coal mining that straddles the 
Great-Dividing-Range affecting two major catchments 
Murray-Darling Basin & Hunter River.

2) Climate Impact:
Would add 105 Mt CO2-e of Scope 3 emissions, an additional 45% on the currently approved operations (including Modification.

3) Water & Groundwater Damage:
Reduces base flows to the Talbragar River, threatening the Macquarie Marshes (Ramsar-listed wetland) and the Goulburn-Hunter catchment.
Will export over 15,000 tonne salt loads to the Goulburn and Hunter River system by extending the Mine water discharge for six years.
Plan to significantly increase toxic tailings dam infrastructure to the river edge (132 ha area), risking the see page to the river flow and downstream Goulburn River National Park and the Drip Gorge ecosystem.

3) Biodiversity Loss:
The project will impact 101.45ha of native vegetation, 
including 34ha of Box Gum Woodland.

4) Threatened Species:
It will affect habitats of endangered species, including the Large-Eared Pied Bat and Eastern Cave Bat
Direct impacts on the critically endangered Regent Honeyeater (habitat in Mudgee-Wollar Key Biodiversity Area)
Risks to Koala, Brush-tailed Rock Wallaby.

5) Cultural Heritage Risk:
The project is on Wiradjuri Country, subject to a Native Title Claim and will impact 71 known Aboriginal sites.
The area holds cultural significance for the Wiradjuri people.
This is a flawed approval process that should be assessed as a New Project – not a Modification, which removes scrutiny by the Independent Expert Panel for Mining.

The ulan complex is an integral part of the Mudgee community, creating jobs for locals, support for sporting clubs and community grants. Being a local who has grown up and lived in Mudgee and now have a family of 5 myself. Has seen the ulan complex help make Mudgee what it is today.
Without companies and big business like glencore in the Mudgee area the town would really suffer.

I am firmly in support of a mining extension and the continued growth of the Mudgee town and region.

I strongly object to the Ulan West Mod 8 proposal on the following grounds
- an extension of thermal coal mining that would see an extra 105Mt of CO2e unnecessarily released into the atmosphere during a climate crisis is immoral and totally irresponsible. It further endangers the futures of our children, grandchildren and all of the non-human species who have no say in the matter.
- in addition, the mining of coal releases fugitive emissions of methane which Glencore does not report. Methane is responsible for one third of the current warming we are experiencing globally, and one third of that methane comes directly from MINING COAL! There is no adequate measure or accounting for fugitive methane, but tackling it is described as the best handbrake we can put on warming right now. More methane is reckless madness.
- the scope of the proposed Mod8 extension goes beyond the existing mine boundary and will require new infrastructure - it should be considered as a NEW proposal, not a modification
- the project poses unnecessary risks to groundwater from subsidence, affecting flows into rivers that are directly connected to the internationally regarded Macquarie Marshes.
- further risk is posed to a number of endangered (large eared pied-bat and eastern cave bat) and critically endangered species (regent honeyeater) through habitat loss, some of which is unique and therefore CANNOT be offset.
- the shortage of skilled labour in the Central West puts at risk construction of urgently needed housing in the area, and - critically - construction of the region's Renewable Energy Zone. These are where the future jobs of the region lie - in industry that doesn't cost our planet.
- Finally, and thankfully, the Land and Environment Court's finding on Friday Nov 14 that the ULan Mod 6 approval was INVALID because of the impact it would have on climate change and the resulting climate harms it would cause to the local community renders Mod8 unworkable (Mod 6 extended the mine’s life from 2033 to 2035, Mod 8 covers 2035 to 2041. Now that Mod 6 has been overturned, Mod 8 has no basis to proceed.Mod 8’s proposed infrastructure is also directly attached to Mod 6’s underground longwall panels. Without Mod 6, that infrastructure cannot exist).
For these and so many other reasons, I urge you to reject this proposal.

The proposed mine expansion should not be assessed as a modification because it falls entirely outside the current mining lease causing new previously unassessed environmental impacts and therefore differs substantially from the current approved mine. This ‘modification’ proposal should be assessed as a new project so that it receives full independent merit assessment.
These are my key points of objection:
1. Releasing over 105 Mt of additional Greenhouse Gas emissions, poor monitoring and reporting of methane emissions.
2. Outside existing mine boundary with additional infrastructure disturbance - should be assessed as a new project
3. Constructing a large new tailings dam area of 132 ha within a revegetated, rehabilitated old open cut pit next to Goulburn River risking leakage of toxic contaminants
4. Wholly west of Great Dividing Range within the Murray Darling Basin - loss of flows to Talbragar River, tributary of Macquarie River feeding into significant Macquarie Marshes
5. Extended water releases into Goulburn River increasing salt load downstream to Hunter
6. Loss of Aboriginal cultural heritage and spiritual landscape for Wiradjuri Nation – impacting 71 known sites, including rock art
7. Disturbing an additional 1743 ha with sandstone escarpment, caves and overhangs:
Destroying additional important habitat for the nationally threatened Large-eared Pied
Bat, Eastern Cave Bat, Regent Honeyeater and Koala, critically endangered Box Gum
Woodland. Cumulative impact on these species across 3 mines in region.
8. Final layout of surface infrastructure not yet determined – mine plan not finalised
9. Undermining 17 private properties directly impacting 4 houses and 6 private bores
10. Increasing social impacts, loss of farm water and ongoing disturbance of rural way of life
11. This project is not needed to provide regional jobs – there is a huge workforce shortage for renewable energy projects and other industries in the Central West

Submission Opposing Ulan West Operations – Modification 8

To: NSW Department of Planning, Housing and Infrastructure
Re: Ulan Coal – Ulan West Operations – Modification 8 SUB-99719210

Date: 17/11/2025

I object to Modification 8 (Mod 8) on scientific, environmental, and public-interest grounds. The modification increases risks to groundwater, ecosystems, and community wellbeing, and it lacks adequate technical justification.

1. Groundwater & Hydrogeological Risks
Mod 8 intensifies extraction in an area already affected by regional aquifer drawdown. The proponent’s modelling indicates additional pressure reductions in the Permian fractured-rock aquifer, which is hydraulically connected to:
* Triassic sandstone units used for stock and domestic bores
* Alluvial aquifers supporting baseflow to the Goulburn River and local creek systems
Key technical concerns include:
* Reliance on MODFLOW modelling with insufficient calibration points, particularly in deeper fractured zones
* Underestimation of hydraulic conductivity variability, which increases the risk of wider-than-predicted impacts
* Lack of confidence intervals or uncertainty analysis to quantify error margins
* No demonstration of full post-mining groundwater recovery, which may take several decades to centuries in fractured systems
Given cumulative impacts from Wilpinjong and Moolarben, Mod 8 risks exceeding acceptable regional drawdown thresholds.

2. Surface Water & Baseflow Reduction
Subsidence-induced fracturing can significantly alter surface–groundwater connectivity. Scientific studies show that undermining in similar geological settings produces:
* Loss of perennial and intermittent flow due to drainage into subsidence cracks
* Changes in alluvial recharge patterns
* Reductions in ecological baseflow, affecting riffle-dependent aquatic species
The proponent does not adequately quantify these risks or provide hydraulic continuity mapping for affected creeks.

3. Biodiversity & Ecological Integrity
Mod 8 affects vegetation communities classified as Endangered or Vulnerable, including box–gum woodland and riparian forest. Key technical issues include:
* Increased fragmentation of movement corridors for Squirrel Glider, microbats, and Grey-crowned Babblers
* Risk of subsidence-induced loss of hollow-bearing trees
* Lack of monitoring methodology using statistically valid sampling (e.g., BACI design)
* Offset ratios that do not reflect actual ecological timeframes for woodland recovery (which exceed 100+ years for functional equivalence)
The proposal fails to demonstrate “no net loss” of biodiversity values.

4. Subsidence Science & Geomechanical Concerns
The subsidence predictions rely on empirical models that often underestimate maximum tensile strain. Concerns include:
* No explicit modelling of strain zones along drainage lines, which are particularly vulnerable
* Insufficient geotechnical data on lithological variability across longwall panels
* No assessment of potential for irreversible diversion of surface flow through subsided fractures
These risks are not mitigated by the proposed monitoring triggers, which are reactive rather than preventative.

5. Air Quality, Noise & Cumulative Impacts
The air quality model shows additional PM10 and PM2.5 contributions, yet:
* No cumulative model incorporating emissions from all Ulan Complex and regional mines is provided
* Meteorological modelling uses a limited dataset that does not reflect extreme conditions (heatwaves, inversion layers)
* WHO guidelines for PM2.5 are not addressed, despite being more protective than current Australian standards
Noise modelling similarly averages conditions in a way that masks peak-period exceedances.

6. Climate & Public Benefit
The modification extends coal extraction during a period when NSW aims for a 70% emissions reduction by 2035. The proposal:
* Adds to downstream Scope 3 emissions
* Delays rehabilitation, prolonging land disturbance
* Provides no comprehensive lifecycle emissions assessment
The claimed public benefits are not substantiated through independent economic analysis.

Conclusion
Mod 8 introduces significant hydrogeological, ecological, geotechnical, and air-quality risks. The technical assessments rely on uncertain modelling, insufficient field data, and inadequate cumulative analysis. On scientific, environmental, and public-interest grounds, I request that Modification 8 be refused.

Hi,

Please reject the Mod 6 project.

- Mod 6 extended the mine’s life from 2033 to 2035.
- Mod 8 relies entirely on that time extension — it covers 2035 to 2041. Now that Mod 6 has been overturned, Mod 8 has no basis to proceed.
- Mod 8’s proposed infrastructure is also directly attached to Mod 6’s underground longwall panels. Without Mod 6, that infrastructure cannot exist — meaning Mod 8 is fundamentally unworkable.

Thank you

I strongly object to anymore mine expansions in this region.
The amount of green house gases that will continue to be released is an atrocious act that will greatly harm the environment.
The impact of Climate Change is a serious issue that has seen the rise in natural disasters which causes significant increases to the cost of living, as well as the loss of human lives.
I call on your moral compass to think deeply about your actions and consider what is the most valuable asset we have … the planet …. And how we take care of it and every living entity that resides here.

According to experts in a range of disciplines including Science, Economics and Agriculture, the expansion and approval of fossil fuel projects will: drive global temperatures to levels that will threaten all life on the planet; in certain areas like this one, affect water supply and quality; cost trillions more dollars if we delay mitigation; inhibit the necessarily rapid transition to clean renewable energy.
The area under consideration is: precious to the Indigenous people and should be reserved for agriculture. The expansion will affect the lives of nearby residents because of coal dust pollution but above all else is the wrong project for our times as we must not make an already dire situation worse.

The approval will extend the life of mine for the Ulan complex which will provide ongoing employment for over 700 people, continue to support businesses & suppliers, many of them local, and will pay taxes, royalties and other payments that help fund vital public services such as infrastructure, teachers, nurses and police. Ulan complex also provides a variety of contributions throughout the local community including supporting local charities, not-for-profit organisations, and junior sporting clubs, as well as major projects such as the Mudgee 4 Doctors initiative, Country Universities Centre in Mudgee, and the Mudgee High School LINK Program.

I call for Mod 8 to be rejected for the following reasons:
1. It would generate more than 105 Mt in additional greenhouse gas emissions, with inadequate monitoring and reporting of methane.
2. It lies outside the current mine footprint and involves new infrastructure disturbance, and it should therefore be evaluated as an entirely new project.
3. It proposes a major new 132-ha tailings storage facility within a revegetated former open-cut pit next to the Goulburn River, creating a risk of toxic leakage.
4. Located entirely west of the Great Dividing Range within the Murray–Darling Basin, leading to reduced flows to the Talbragar River, a tributary of the Macquarie River that supports the important Macquarie Marshes.
5. Longer-term water discharges into the Goulburn River would increase downstream salinity levels in the Hunter.
6. Would result in the loss of Wiradjuri cultural heritage and spiritual landscapes, affecting 71 known sites including rock art.
7. Involves disturbance of an additional 1,743 ha containing sandstone escarpments, caves, and overhangs, destroying key habitat for nationally threatened species such as the Large-eared Pied Bat, Eastern Cave Bat, Regent Honeyeater, Koala, and critically endangered Box-Gum Woodland; adds to cumulative impacts from three mines in the region.
8. Surface infrastructure layout remains undecided, indicating the mine design is still incomplete.
9. Plans to mine beneath 17 private properties, directly affecting four homes and six private water bores.
10. Would heighten social impacts, reduce farm water availability, and further disrupt rural lifestyles.
11. The project is unnecessary for regional employment — the Central West is already experiencing significant workforce shortages in renewable energy and other industries.

The project will secure ongoing jobs for local workers, strengthen the regional economy, and make the most of existing mine infrastructure.

Coal mining remains a vital industry for our community. Ulan has a strong record of safe and responsible operations, and I believe the proposed extension will continue that standard while ensuring long-term stability for local families and businesses.

I strongly support the approval of this modification.

Please find attached my full submission report objecting to UWCO Modification 8.
Thank you for the opportunity to comment.
The proposed UWCO mine expansion impacts are substantial extending and intensifying environmental damage to the surface water catchment and groundwater systems that flow to the Talbragar River (Murray Darling Basin) and Goulburn River (Hunter catchment). It is far more substantial than a simple “modification” and should be subject to a forensic, independent expert assessment as a New Project.
For background, I have lived and worked in the Ulan area for over 40 years, and have been a keen observer of the local ecosystems and biodiversity. My submission report on the proposed MOD 8 expansion draws on my PhD research with NSW Office Water on the impact of changing land-use and climate on the Goulburn River surface and groundwater systems (completed through Australian National University) combined with my extensive local knowledge and experience.
I am a local representative on the Ulan Coal Mine CCC and a member since its inception in 2003. I was a Board Member on the Hunter Central Rivers Catchment Authority for 9 years (2004 -2013).
Key concerns of the UWCO Modification include:
• Underground mine subsidence causing fracturing and depressurisation from the coal seam to the surface causing complete drainage of the groundwater system, over an additional 1734 hectares, affecting waterways and creeks within and surrounding the mining footprint
• Another six years of continued direct and indirect groundwater interference and drawdown
• No confidence in water modelling predictions
• Inadequate monitoring of groundwater aquifers, alluvial aquifers, streams and GDEs with insufficient number of key monitoring points and incomplete data sets
• Continued discharge of mine water with a salt load up to 17.3 tonnes /day) into the Goulburn/Hunter River catchment unti 2041 (ie total >30,000 tonnes salt)
• Proposed installation of coal tailings storage facilities (dams) within a 132ha area abutting the Goulburn River diversion, requiring the excavation of old open cut workings containing reject and spoil material creating a significant long-term risk of seepage contamination of the Goulburn River. and downstream National Park
• Absence of past and current monitoring and reporting of groundwater levels and water quality associated with the existing tailings dams (4) connected to the East Pit water storage, with potential connectivity through river alluvium with the Goulburn River should groundwater levels reach a critical height.

Granting Mod 8 for UWO will provide continued employment and financial gain for the local economy. In addition, ongoing underground coal mining will maximise resource usage with the smallest possible surface disturbance as well as minimal dust, noise and light pollution. UWO and Ulan as a whole maintain good relationships with local stakeholders and regularly donate to local community groups, the approval of Mod 8 will see this community benefit continue through to 2041.

Objection to Glencore’s Ulan Coal Mine Modification 8.
Glencore’s Ulan Coal Mine Modification 6 has been overturned in Court.
This means that Modification 8 cannot proceed, as it depends entirely on Mod 6.
• Mod 6 extended the mine’s life from 2033 to 2035.
• Mod 8 relies entirely on that time extension — it covers 2035 to 2041. Now that Mod 6 has been overturned, Mod 8 has no basis to proceed.
• Mod 8’s proposed infrastructure is also directly attached to Mod 6’s underground longwall panels. Without Mod 6, that infrastructure cannot exist.
Mod 8 is fundamentally unworkable.
Please stop this application in its entirety.

To whom it may concern,
I am writing to lodge my strong objection to the proposed Ulan Coal Mine Mod 8 – Ulan West Continued Operations Project.
The proposal represents a substantial expansion—entirely outside the existing mining lease—and should not be assessed as a modification. It introduces major new environmental, social and cultural impacts that have not been previously assessed, and therefore requires a full, independent merits assessment as a new project.

Key Grounds for Objection
Climate impact – Mod 8 would release over 105 million tonnes of additional greenhouse gas emissions. Methane monitoring and reporting remain inadequate, with previous baseline changes unexplained.

Not substantially the same project – The proposal expands beyond the current boundary, adds new infrastructure including a 132-ha tailings dam, affects 1,743 ha of new land, undermines private properties, and introduces major new impacts on groundwater, biodiversity and cultural heritage.

Risk to water systems in the Murray–Darling Basin – As the project lies wholly west of the Great Dividing Range, it will further deplete flows to the Talbragar River and consequently the Macquarie River and the internationally significant Macquarie Marshes. Extended discharge into the Goulburn River will add more than 15,000 tonnes of salt over six years, with cumulative impacts never properly assessed.

New 132-ha tailings dam and contamination risks – The proposed tailings facility is located in a rehabilitated former open cut pit adjacent to the Goulburn River, with no adequate groundwater or seepage monitoring. This poses long-term contamination risks to The Drip and downstream ecosystems.

Aboriginal cultural heritage impacts – The project will damage at least 71 known Wiradjuri cultural heritage sites, including rock art, within a landscape of deep cultural significance. Cumulative impacts across the region have not been assessed.

Biodiversity loss – Clearing will destroy sandstone escarpment and cave habitat essential for the nationally threatened Large-eared Pied Bat, Eastern Cave Bat, and critical habitat for the Regent Honeyeater, Koala, and Box Gum Woodland CEEC. These losses are irreplaceable and cannot be offset.

Incomplete and uncertain mine plan – The final layout of major surface infrastructure is unresolved due to ongoing negotiations with landholders, yet the project has been accepted for assessment without a complete mine plan.

Social and property impacts – Seventeen private properties will be affected, including undermining of homes and dewatering of private bores. Long-term water replacement is not guaranteed, continuing the diminishing of rural communities already impacted by previous expansions.

Not justified – Claims about economic necessity are unfounded. The region faces workforce shortages, especially in construction and renewable energy projects within the Central West Orana Renewable Energy Zone. Expanding coal mining undermines regional transition efforts and future employment opportunities.

Conclusion

Given the scale of new disturbances, unacceptable environmental and cultural impacts, and the profound deviation from the currently approved project, Ulan Mod 8 must not proceed as a modification. It should be rejected or, at minimum, assessed as a new project through a transparent and rigorous merits process. Furthermore, in the context of the Central West Orana Renewable Energy Zone, expanding coal mining is inconsistent with climate, water stewardship and regional transition priorities.

I urge the Department to reject this proposal.

Thank you for considering my submission.

Sincerely,
Melville Fernandez