I support the HVO continuation project as it provides 1515 jobs to the local community.
Has 802 suppliers creating work and employment for the wider community. With a $1.720b distribution into the economy.
HVO has an annual spend of $1.05b and supports charities that help people in the community and not for profit organisations. With $276m taxes and royalties paid annually and the other inputs into the community, HVO as I see is a great contributor to our nation as a whole.

I am the sixth generation of a farming family from Merriwa, in the Upper Hunter. Through my lifetime, I have witnessed the vital, fertile lands of the Hunter destroyed by mining, our mighty Hunter River, reduced to a trickle, and our farming communities reduced to a diaspora. This is all before I come to the HVO proposal itself.
The costs and benefits of the HVO proposal don't stack up from a current and projected economic perspective, and certainly through the lens of carbon emissions and costs. Even with the now reduced project size, the HVO Continuation Project represents almost 40% of emissions in the NSW Government’s coal project approval pipeline. With existing coal mining projects already straining the ability of NSW to meet its legislated emissions reduction targets, if HVO is approved, it will further strain the state’s ability to meet its targets and shift the burden onto other sectors to make deeper emissions reductions. A detailed cost benefit analysis produced by ACCR (https://www.accr.org.au/research/more-cost-less-benefit-for-nsw-the-flawed-rationale-for-the-hunter-valley-coal-mine-expansion/) provides reliable evidence that the financial benefit does not justify the cost.

I note the analysis of Geoscience Australia on the impact of the proposal on already scarce ground and surface. This is at the expense of the food that we all rely upon for survival. Where is the benefit in further diminishing our capacity to feed the nation? I further note the impact on threatened species and habitats, specifically, those listed in the Protected Matters Search Tool report (PMST), dated 20 November 2023, which identified 66 listed threatened species and communities that are likely or known to occur within 10 km of the proposed action. Based on the location of the proposed action, the likely habitat present in the area of the proposed action, and the nature of the proposed action, that impacts arose in relation to the following Part 3 protected matters :
(i) Central Hunter Valley Eucalypt Forest and Woodland (CHVEFW) – Critically endangered – listed ecological community,
(ii) Warkworth Sands Woodland of the Hunter Valley – Critically endangered – listed ecological community, and
(iii) Striped Legless Lizard (Delma impar) – Vulnerable – listed threatened species.
In my view, the mitigation and management proposals do not meaningfully address the threat to these habitats and species, amongst others.
Whilst lifecycle emissions are not a component of the project assessment, it is the giant elephant in the room. How can these projects be considered when the impacts are so catastrophic? Project documents show the intended additional coal mined is 429 million tonnes, producing over 15 million tonnes of Scope 1 and 2 emissions and more than 793 million tonnes of Scope 3 CO2e emissions, which is equivalent to almost seven times NSW’s total annual emissions from all sources. This is insanity. Insurance premiums are becoming impossible to afford, reconstruction costs after the ever more intense and frequent floods and fires are skyrocketing, and many smaller farmers like my family's are simply giving up. The multinationals may make a fortune while the state starves - you can't eat coal. We need to protect our precious nature and the farming land and waters needed to produce food for the nation.

Climate change costs not properly considered, legal precedent ignored
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* The recent decision by the NSW Court of Appeal on the Mt Pleasant coal mine expansion found that the full contribution of downstream emissions (Scope 3) to climate change from a coal mine must be assessed, even if the fuel is burnt overseas.

* They found that the full environmental, social and economic impacts of climate change on a locality must be considered in making a decision on a project. This should include costs like rising insurance premiums and increasing costs of repairing roads and infrastructure after extreme weather.

* But the Hunter Valley Operations revised assessment specifically EXCLUDES consideration of downstream emissions in its economic assessment, and as a result it drastically underestimates the negative economic impacts of the project.

* The revised assessment should be withdrawn and the full assessment required by the Court of Appeal must be undertaken for the project - and it should then be placed back on public exhibition.

Scale of project, greenhouse gas emissions and climate targets
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* This is the biggest coal mine project ever considered in NSW. In total it proposed to mine 429 million tonnes of coal and extend the operation of this huge mining complex to 2045.

* Overall, this coal mine expansion would add 803 million tonnes of lifecycle greenhouse gas pollution to the atmosphere between now and 2045. That equates to 7 times the total annual emissions from all sources in New South Wales.

* Even the direct emissions from the project, caused by releasing methane from the coal seam and from diesel used in operating the mine, will make a huge contribution to NSW emissions and make it even more difficult for NSW to meet climate targets.

* The NSW Large Emitters Guide states that coal mines should be on the same emissions reduction trajectory as NSW - to reduce emissions by 50% by 2030 and 70% by 2035.

* But this expansion does the direct opposite - it will result in massive increases in direct emissions by expanding the project. The expansion will actually double methane emissions compared to the existing mine (as at FY24) and then they will remain at elevated levels until 2042.

Impacts to land and water
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* The proposed mine expansion will have devastating impacts on land and water in the Hunter Valley.

* The HVO mine complex straddles the Hunter River and the expansion intends to mine directly into strategic agricultural land and the River’s alluvial aquifer.

* Mining for the Continuation Project will worsen groundwater drawdown already affecting the Hunter River’s alluvial aquifer by half a metre.

* Cumulative drawdown of Wollombi Brook alluvium will be up to 2 metres and this impact will extend long after mining ceases.

* Recent monitoring has identified that groundwater in the alluvium and other affected areas is exceeding water quality triggers in the HVO area. A large tailings storage dam adjacent to the river was found six years ago to be seeping into groundwater.

* Instead of expanding the mine, Glencore and Yancoal should be cleaning up the huge HVO site and investing in long-term environmental remediation of it.

I support hvo continuation project

Hunter Valley Operations has not completed the revised assessment for the mine. It has ignored the recent Court of Appeal decision on the Mt Pleasant coal mine.

The judgement of the Court of Appeals said it is mandatory for developments like this to provide a full, up-to-date assessment of climate impacts and engage in meaningful consultation with affected communities on those impacts.

Hunter Valley Operations has not done this. Its proposed development would increase emissions and make it impossible for the NSW Government to meet its emissions reduction targets.
HVO should not be given the go ahead for its proposed development.

We object to approval of this project at least until a proper environmental impact assessment for Australia has been done and, in any case, it goes against the IPCC and IEA advice to limit global heating to 1.5 degrees Celcius - see attached submission. We have also written to the Commonwealth Environment Minister on this issue, with recommendations as to how the EIA Guidelines could be improved to correctly assess the impact of global heating as a result of greenhouse gas, particularly methane, emissions.