Submission: HVO Coal Continuation Project – Additional information

This submission builds on our previous submission of 10 July, and responds to two key issues raised in HVO’s recent correspondence:

  • First, while HVO does not contend that the impacts of its coal burned overseas are irrelevant, or that the framework for national climate targets under the Paris Agreement is a complete answer, it asserts that the Commission’s legal obligation to consider downstream pollution can be satisfied because importing countries have their own climate targets. This does not change the fact that the coal will be burned, fuelling the impacts of climate change that the Commission is obliged to consider. It also contradicts HVO’s own economic case, which depends on strong coal demand persisting for the next 19 years.
  • Second, HVO’s dismissal of the Future Jobs and Investment Bill and failure to undertake transition planning to date, despite claiming to be committed to creating “a positive legacy for the local region” must not give it a licence to continue polluting.

The Commission’s obligation to consider the full climate impact of a coal proposal — regardless of where the coal is ultimately burned — has never been more critical. Since HVO submitted its Response to Request for Information dated 1st September, the United Nations has released new analysis confirming the world no longer has a realistic pathway to avoid exceeding 1.5°C of warming: the upper limit of what vulnerable communities, coral reefs, and many ecosystems can withstand, and beyond which we risk triggering irreversible and cascading catastrophic climate impacts (UNEP 2026). On 3 September, the World Meteorological Organization announced that the current El Niño may become the strongest on record, driving extreme weather and severely impacting communities, economies, and supply chains in Australia and across the globe (WMO 2026).

HVO’s refusal to consider anything shorter than its proposed 19 year extension serves only one interest: the profits of Glencore and Yancoal. Its failure to prepare a mine exit strategy and transition plan for its workers and the community must not become an excuse to further fuel global heating and worsening extreme weather that is already severely impacting communities in the Hunter. 

The Commission must reject the HVO Continuation Project proposal.  

The world is set to cross 1.5°C within the next few years because of our failure to drive down greenhouse gas emissions from coal, oil and gas. Every tonne left in the ground, and every fraction of degree avoided means more lives, livelihoods, species and ecosystems saved.

At a moment when the evidence for urgent, drastic emissions cuts has never been clearer, approving the HVO Coal Continuation Project would push NSW’s communities, economy and environment further into harm’s way.

The NSW Independent Planning Commission has a responsibility to consider the likely impacts of this project’s climate pollution – including its scope 3 emissions – on the local community and environment. The Commission cannot approve the project on the assumption that someone else, somewhere else, bears responsibility for the harm that this project will cause. 

No new or expanded coal project – of any duration – is consistent with a safe climate future. The Commission must reject the HVO Continuation Project proposal.

Submission: HVO Coal Continuation Project

The Climate Council welcomes the opportunity to make a submission to the NSW Independent Planning Commission’s (IPC) assessment of the Hunter Valley Operations North and South Open Cut Coal Continuation Projects (the HVO Continuation Project).

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