In addition to HVO's known social and economic benefits to the Hunter and Australian economy's, the fact is we are part of the global trading world. HVO exports all of its coal to overseas markets. As per the IEA's 2024 energy outlook, Australia's key export markets for coal represent some of our key industrial import markets for energy intense manufactured goods. These countries such as Japan, India and Korea are deficient in their domestic energy production and are net energy importers as opposed to Australia. Japan as a key example represents a market that Australia benefits greatly from its high emission manufactured imports such as motor vehicles which Australia does not domestically produce. If Australia wants to import energy intense goods that we do not produce domestically we must face the reality that part of our obligation as an energy rich nation is that we must support the countries that complete this work for us. Coal represents a key stable and reliable fuel source for these countries even through the transition to net zero.

Please accept this as my objection to Glencore and the HVO Continuation Project.

A 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. 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, which we are experience more frequently in recent years. 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. As such, the revised assessment should be withdrawn and the full assessment required by the Court of Appeal must be undertaken for the project and it should then be put on public exhibition again.

There is no level of public benefit from expanded coal mining operations that can offset the trauma, dislocation and loss being experienced by communities all over the globe from increasing extreme weather crises. The cost of repairing damaged infrastructure and disruption to many industries has a crippling impact on the economy. This must be factored into consideration of the merit of the proposed project.

This is a huge project and the biggest ever coal mine considered in New South Wales. 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. Considering just 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 which is to reduce emissions by 50% by 2030 and 70% by 2035.
However this expansion does the opposite and will result in huge increases in direct emissions. The expansion will double methane emissions compared to the existing mine (as at FY24) and then remain at elevated levels until 2042. 

This proposed 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. This poses great risks to groundwater levels which is already affecting the Hunter River’s alluvial aquifer by half a metre. However it is not only the Hunter River but also Wollombi Brook alluvium will be up to 2 metres lower and this effect will remain long after mining ceases. We must also take into consideration water quality for residents in the Hunter region and farmers. Glencore and Yancoal should be cleaning up the huge HVO site and investing in long-term environmental remediation.

There is no justification for the NSW Government to continue to approve coal mine expansion and extension. The way forward is to encourage investment in a range of different scale renewable energy projects. Climate change is a threat to all communities and all industries and cannot be ignored.

The project be rejected on the grounds of no clear justification, no clear evidence of public benefit and the requirement for responsible government decision-making under ESD principles.

I ask for the decision to be made in the public interest rather than for short term private corporate gain.

Submission Objecting to the Hunter Valley Operations (HVO) North and South Open Cut Coal Continuation Projects

I am writing to strongly object to the HVO North and South Open Cut Coal Continuation Projects. The proposed expansion represents one of the most environmentally and socially damaging coal projects ever considered in New South Wales. It is inconsistent with legal precedent, climate science, and the urgent need to protect land, water, and communities in the Hunter Valley.

Below I outline my objections under three key areas: (1) failure to properly consider climate change costs and legal precedent, (2) scale of greenhouse gas emissions and incompatibility with NSW climate targets, and (3) devastating impacts on land and water resources.

1. Failure to Consider Climate Change Costs and Legal Precedent

The revised economic assessment for the HVO Continuation Projects excludes downstream (Scope 3) greenhouse gas emissions. This approach is inconsistent with established legal precedent in New South Wales.

In the recent NSW Court of Appeal decision on the Mt Pleasant coal mine expansion, the Court made it clear that:

The full contribution of downstream emissions to climate change must be assessed, even when combustion occurs overseas.

The full environmental, social, and economic impacts of climate change on a locality must be considered when deciding whether to approve a project.

This includes real costs such as:

Rising insurance premiums as extreme weather becomes more frequent and destructive.

Increased expenditure on repairing roads, bridges, and other infrastructure damaged by floods, bushfires, and storms.

Ongoing health and productivity losses caused by heatwaves, smoke events, and climate-related stress.

By deliberately excluding Scope 3 emissions, the HVO Continuation assessment drastically underestimates the true economic and environmental costs of the project. This makes the document fundamentally flawed.

I therefore submit that the revised assessment must be withdrawn, and a new assessment undertaken that complies fully with the Court of Appeal’s ruling. This new assessment must be placed back on public exhibition to allow the public to properly evaluate its findings.

2. Scale of Project, Greenhouse Gas Emissions, and Climate Targets

The HVO Continuation is the largest coal project ever proposed in New South Wales, with plans to:

Mine 429 million tonnes of coal,

Continue operations until 2045, and

Add 803 million tonnes of lifecycle greenhouse gas pollution to the atmosphere.

To put this in perspective:

The project’s emissions are seven times greater than the annual emissions of the entire state of New South Wales.

Its direct methane and diesel emissions will significantly increase NSW’s baseline emissions at a time when all sectors must be rapidly reducing them.

The NSW Government’s Large Emitters Guide makes it clear that major emitters, including coal mines, must align with the state’s emissions reduction pathway:

A 50% cut by 2030, and

A 70% cut by 2035.

The HVO Continuation directly contradicts this requirement. Instead of reducing emissions, the project would:

Double methane emissions compared to the current mine (FY24 levels),

Keep emissions at elevated levels until at least 2042, and

Lock NSW into higher long-term emissions, undermining our state’s ability to meet its legislated targets.

Approving this project would not only jeopardize NSW’s climate commitments, it would also undermine Australia’s international credibility and global climate efforts. The scale of greenhouse pollution from HVO is fundamentally incompatible with the urgent task of limiting global warming to safe levels.

3. Impacts on Land and Water in the Hunter Valley

Beyond climate concerns, the HVO Continuation would have severe and lasting impacts on the Hunter Valley’s land and water resources.

Key impacts include:

Strategic agricultural land destruction: The expansion intends to mine directly into land critical for food production, undermining the region’s long-term agricultural viability.

Damage to the Hunter River alluvial aquifer: Mining will worsen existing groundwater drawdown, lowering the aquifer by an additional 0.5 metres.

Cumulative drawdown of Wollombi Brook alluvium: Up to 2 metres of drawdown, with impacts persisting long after mining has ceased.

Water contamination: Monitoring has already found groundwater in the HVO area exceeding water quality triggers. A major tailings dam adjacent to the Hunter River was found to be seeping into groundwater six years ago, posing a serious and ongoing risk.

These impacts threaten the integrity of the Hunter River system, which supports farming, ecosystems, and communities throughout the region. They also raise serious intergenerational equity issues: once groundwater systems are degraded and farmland is lost, they cannot simply be restored.

Rather than expanding the mine and compounding the damage, Glencore and Yancoal should be required to invest in long-term remediation of the existing HVO site. The scale of land disturbance and water risk already created by this operation demands cleanup and rehabilitation, not further expansion.

Conclusion

The HVO North and South Open Cut Coal Continuation Projects represent a massive step backward for New South Wales at a time when we urgently need to be moving forward toward sustainable energy, healthy ecosystems, and climate resilience.

The projects:

Fail to meet the legal and moral requirement to fully assess downstream emissions and climate costs,

Pose an enormous greenhouse burden fundamentally inconsistent with NSW’s climate targets, and

Threaten the long-term health of the Hunter Valley’s land and water.

For these reasons, I respectfully but firmly request that the HVO Continuation Projects be rejected.

Instead of locking NSW into decades more of high-pollution coal mining, Glencore and Yancoal should focus on cleaning up their existing sites, supporting workers and communities in the transition, and investing in industries that secure a safe and prosperous future.

Sincerely,
Michael Niemira-Dowjat.

HVO provides employment to thousands of local people directly or via contractors, subcontractors and suppliers. That supports families, apprentices, small businesses, and regional services securing the future.

HVO contributes billions to the economy with taxes, royalties, and the operational activities.

This is about balance — supporting a strong local economy, caring for our environment, and ensuring our communities aren’t left behind.

I strongly support the continuation of HVO and the extension of its contract. The project provides a safe and reliable work environment for employees while also contributing significantly to the local economy. HVO plays an important role in supporting local businesses, investing in community initiatives, and creating long-term opportunities for families in the region.
By extending this project, we can ensure stability for workers, maintain economic growth in the Hunter Valley, and continue to see positive investment into our communities.

To whom it may concern,
I have been employed at HVO for 16 years, I give my support to the continuation of Hunter Valley Operations. With out the continuation of both the North and South Projects the local area will cease to exist and there will be no employment opportunities for our current working men/women and youth. Without coal mining in the hunter valley there isn't many employment opportunities that don't ride off the back of it. HVO is a large employer in the area that supports both local and regional business's.
It is in the state of New South Wales best interest for the mine to continue operating.

As I have mentioned in my first lot of submissions for this Continuation Project, I believe the the company who own the current lease (Yancoal) should be entitled to mine the lease which if I am correct was granted to Coal and Allied way back in the mid ‘70’s and the mine started up as Hunter Valley No. 1 mine.
Yancoal is still mining the same lease and should be allowed to continue to mine the same lease.
I worked at an engineering firm at the time and worked on lighting plants (brand new) for the project’s start up, so even back then people were being employed and getting paid on this project.
Nothing has changed as far as people being employed and kept in jobs by this project and I see no reason for it not to continue.
There is a ratio that says that for every employee at the mine there are 3 or 4 people indirectly employed supporting the mine.
The local area economy’s are kept going by this mine and to reject the application will throw 3 or 4 people out of jobs for every worker employed at the mine.
Provided that the mine comply’s with all rules and regulations, I see no reason for this project not to continue.

Surely now the Climate Risk report has been released we can say that new and/or expanded fossil fuel projects threaten our lives in both the short and long term. The coal we mine adversely affects the health of the land and people in the Hunter Valley; the coal we export will increasingly affect all the lands and people on Earth. It is simply time to transition away from old sources of power and embrace cleaner, cheaper ones that are already available.

Helping the community, and keeping 1500 jobs alive

I support the project