Submission: HVO North and South Open Cut Coal Continuation Projects

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Submission to the NSW Independent Planning Commission Panel
HVO North and South Open Cut Coal Continuation Projects
(SSD-11826681 & SSD-11826621)

A. Introduction

1. The Australasian Centre for Corporate Responsibility (ACCR) welcomes the opportunity to make a submission to the NSW Independent Planning Commission (the Commission) in respect of HVO Operations Pty Ltd's proposed HVO North and South Open Cut Coal Continuation Projects (the Projects).
2. ACCR is a philanthropically-funded, not-for-profit, research and shareholder advocacy organisation, focused on the investment risks and opportunities brought about by the global energy transition. ACCR seeks to strengthen market integrity, safeguard long-term financial value and accelerate the energy transition in line with the best available science.
3. ACCR recommends that the Commission refuse the development applications for the Projects as it cannot be satisfied that the adverse impacts of the Projects will be sufficiently mitigated, nor that the Projects are consistent with the public interest and principles of ecologically sustainable development, for the following reasons:

a. the Projects will generate a net economic benefit to NSW that is significantly less than what has been represented by HVO Operations Pty Ltd (the Proponent);

b. the Projects will materially impede the achievement of NSW's legislated emissions reduction targets;

c. the Proponent's proposed emissions reduction strategy is uncertain and largely dependent on offsets and unproven technology; and

d. the Projects are consistent with over 2°C of warming, which will cause significant environmental and social impacts, in the locality and region.

4. Each of these issues is addressed below and the following reports by individual ACCR staff members are attached in support:

a. report prepared by Mr Pranav Dayal dated 5 August 2026;

b. report prepared by Dr Dimitri Lafleur dated 24 July 2026; and

c. report prepared by Dr Sophie Lewis dated 31 July 2026.

B. Relevant mandatory considerations

5. The Commission is the consent authority in respect of the development applications for the Projects as provided by s 4.5(a) of the Environmental Planning and Assessment Act 1979 (NSW) (the EPA Act) and cl 8A of the State Environmental Planning Policy (State and Regional Development) 2011 (NSW).

6. The following matters must be taken into account in determining the development applications:

   a. any environmental planning instruments that apply to the land to which the development applications relate;^[1]
   b. the significant likely impacts of the developments, including environmental impacts on both the natural and built environments, and social and economic impacts in the locality;^[2]
   c. any submissions made in accordance with the EPA Act or the associated regulations;^[3]
   d. whether the proposed developments are in the public interest;^[4]
   e. whether any consent should be issued subject to conditions aimed at ensuring that the development is undertaken in an environmentally responsible manner, including conditions to ensure that greenhouse gas emissions are minimised to the greatest extent practicable;^[5] and
   f. an assessment of the greenhouse gas emissions (including downstream emissions) of the proposed developments, having regard to any applicable State or national policies, programs or guidelines concerning greenhouse gas emissions.^[6]

7. Relatedly, the Commission's determination of the development applications must be guided by the objects of the EPA Act, which include:

   a. the promotion of the social and economic welfare of the community and a better environment by the proper management, development and conservation of the State natural and other resources;^[7]
   b. the promotion of resilience to climate change and natural disasters through adaptation, mitigation, preparedness and prevention;^[8]
   c. the facilitation of ecologically sustainable development by the integration of relevant economic, environmental and social considerations in decision-making about environmental planning and assessment;^[9]
   d. the promotion of a proportionate and risk-based approach to environmental planning and assessment;^[10] and
   e. the promotion of the orderly and economic use and development of land.^[11]

8. Following the passage of the Climate Change (Net Zero Future) Act 2023 (NSW), the NSW Government and Net Zero Commission have also emphasised that consent authorities should consider the State's legislated greenhouse gas emissions reduction targets in the course of their decision-making.^[12]

9. As the consent authority and relevant decision-maker, the Commission must weigh and balance the above listed factors, including the social, economic and environmental benefits (and any detriments) of the Projects, to determine whether the Projects should proceed. The remainder of this submission addresses matters relevant to these mandatory considerations.

C. The Projects' net economic benefit is likely significantly overstated

10. The Commission must consider the likely economic impacts of the Projects, including the net economic benefit that the Projects are expected to generate to NSW. While the Projects can be expected to generate some economic benefit to NSW, ACCR submits that those benefits have been materially overstated.
11. The cost-benefit analysis contained in the Proponent's economic impact assessment does not account for greenhouse gas (GHG) emissions costs that have been calculated in line with the most current 'target-consistent' methodology recommended by NSW Treasury. When ACCR applied this methodology to the information available about the Projects, the Projects' expected GHG emissions costs increased by almost 600 times. This reduced the net economic benefit of the Projects by approximately 40%.^[13]
12. According to the cost-benefit analysis contained in the Proponent's economic assessment, the Projects are expected to generate $5.69 billion (NPV) in net benefits to NSW, accounting for $3.8 million (NPV) in GHG emissions costs.^[14] However, this estimate of emissions costs relies on a 'damage-consistent approach' to valuing carbon emissions. The damage-consistent approach estimates the global economic cost of climate damages associated with GHG emissions using a social cost of carbon that is then apportioned to NSW based on NSW's share of the global population. A damage-consistent approach was set out in NSW Treasury Guidance TPP17-03 (TPP17-03), which was current in 2015 and 2018 when the DPHI Guidelines for the Economic Assessment of Mining and Coal Seam Gas Proposals and associated Technical Notes were respectively published.^[15]
13. In 2023 and 2024, TPP17-03 was superseded by NSW Treasury Guidance TPG23-08 NSW Government Guide to Cost-Benefit Analysis (TPG23-08) and TPG24-34 Carbon emissions in the Investment Framework (TPG24-34), which replaced the damage-consistent approach with a 'target-consistent approach' to valuing the cost of emissions.^[16] The target-consistent approach estimates the marginal cost of reducing GHG emissions along a trajectory necessary to reach NSW's legislated emissions reduction targets.
14. In TPG24-34, NSW Treasury identified several difficulties with the damage-consistent approach, including disagreement on modelling assumptions and discrepancies between estimates produced in different jurisdictions, its failure to account for the State's legislated emissions reduction targets, and the challenge of confining the damage cost assessment to NSW, given the global nature of carbon emissions and damages.^[17]
15. TPG24-34 addresses these issues, setting out a 'best practice standard' emissions valuation methodology that is consistent with NSW's legislated emissions reduction targets and aligned with the direction of international best practice.^[18] Mr Dayal made submissions to this effect at the Commission's public hearing on 16 July 2026, emphasising that NSW Treasury describes this methodology as the 'preferred approach' to valuing carbon emissions.^[19] The report of Mr Dayal (attached as Annexure A) details the methodological differences between the approach that has been taken by the Proponent and the approach endorsed by the latest NSW Treasury Guidance.^[20]
16. ACCR submits that the methodology set out in TPG24-34 is the most relevant to the Commission's assessment of economic impact of the Projects, as it models the marginal abatement costs consistent with NSW's legislated emissions reduction targets in order to value emissions costs. The Commission must consider whether the Projects are in the public interest and this requires the Commission to consider the Projects' economic benefits and costs, as well as the Projects' likely impact on NSW's legislated emissions reduction targets. These mandatory considerations are best served by the use of an emissions costs valuation methodology that reflects best available practice and which is internally consistent with NSW's legislated targets. The methodology contained in NSW Treasury Guidance TPG24-34 serves this purpose.
17. In its Assessment Report, the NSW Department of Planning, Housing and Infrastructure (the Department) states that the Projects are expected to generate a net benefit of $5.69 billion (NPV) to NSW.^[21] Based on this figure and the average 1,311 FTE jobs expected over the life of the Projects, the Department concludes that the Projects will result in 'net economic benefits to local and regional areas in proximity to the [Projects] and to the State of NSW'.^[22] The Department notes that even after accounting for costs of GHG through a GHG sensitivity analysis, the Projects would still generate a net benefit to NSW under all scenarios (ranging from $3.8-$5.0 billion (NPV)).^[23] The Department appears to consider this net benefit to be a substantial component of the overall public benefit that will likely be delivered by the Projects.^[24]
18. ACCR refers the Commission to the analysis in Mr Dayal's report which steps out the application of TPG24-34 to the Projects.^[25] When applying TPG24-34, ACCR's sensitivity analysis shows that the Projects will generate a net economic benefit of $2.0-$4.0 billion (NPV) to NSW.^[26]
19. The estimated present value of the Projects' gross scope 1 and scope 2 emissions is approximately $2.1 billion (in FY25 present value terms) when the central-case carbon values in TPG24-34 are applied to the information available about the Projects. The Projects' total emissions costs increase to approximately $2.3 billion (in FY25 present value terms) when intrastate rail emissions within NSW are also accounted for.^[27]
20. Based on this analysis and holding all other assumptions in the Proponent's environmental impact assessment constant, the net economic benefit of the Projects to NSW is approximately $3.4 billion (NPV), being 40% less than the benefit reported by the Proponent in its economic impact analysis.^[28] As noted by Mr Dayal in his report: 'Other matters, including additional project related emissions occurring within NSW, future coal price assumptions, changes to carbon values and sensitivities, and the calculation of gross economic benefits could also materially affect the estimated net benefit from the Projects.'^[29]
21. For the reasons set out in [16] above, ACCR submits that the Commission ought to have regard to the net benefit that is derived when applying TPG24-34 to the Projects in the course of weighing the Projects' expected impacts against their expected benefits to NSW.

D. The Projects pose a material threat to the achievement of NSW's legislated emissions targets

22. ACCR submits that the Projects are not in the public interest as they will materially impede the State's ability to achieve its legislated emissions reduction targets and place significant pressure on other sectors of the economy to decarbonise more quickly than would otherwise be required.
23. NSW has committed to reducing its net statewide GHG emissions in line with the following targets, as measured against a 2005 baseline:
    a. at least 50% by 30 June 2030;
    b. at least 70% by 30 June 2035; and
    c. to zero by 30 June 2050.^[30]
24. However, NSW's projected gross emissions under both business-as-usual and current policy scenarios remain above the emissions trajectory required to achieve the targets.^[31] NSW not on track to meet its targets^[32] and the approval of the Projects will further jeopardise these goals. As noted by the Net Zero Commission in its 2026 Annual Progress Report: 'Continued approval of coal mining extensions and expansions is a barrier to resources sector decarbonisation and achievement of legislated targets.'^[33]
25. The coal mining sector is a growing source of emissions and is decarbonising at a slower rate compared to other sectors, undermining the State's ability to achieve its legislated targets.
26. In 2022, coal mining accounted for approximately 12% of NSW emissions. The sector's emissions have sharply increased in the years since, diverging from both statewide emissions reduction pathways and the legislated targets. Under business-as-usual projections, the coal mining sector's share of NSW emissions is expected to increase to 18% by 2030 and to almost 20% by 2040. This stands at odds with the Net Zero Commission's advice that significant decarbonisation in the electricity and energy sector will be required to meet the State's 2030 and 2035 targets.^[34]

Figure 1

Source: ACCR analysis of NSW greenhouse gas emissions projections 2024: methods paper (Figure 1, 21, 24), HVO GHG Assessment.

27. If NSW's emissions reduce in line with the legislated emissions reduction targets, the Projects will produce 1% of the State's emissions budget in 2027 and this share will increase to 3% by 2042. This is depicted in Figure 2 below, and is based on the emissions estimates disclosed by the Proponent. However, the Projects' emissions are likely to be greater than the Proponent's estimates. As noted by Dr Lafleur in his report (attached as Annexure B), the Projects' forecast emissions have likely been underestimated, due in part to the widespread underreporting of fugitive emissions.

Figure 2

ACCR analysis of the Projects' share of NSW annual emissions between 2027 and 2045 (green dotted line). Projected scope 1 and 2 emissions (in orange); linear projected NSW annual emissions based on legislated targets (in dark blue). Both HVO CP and NSW emission reductions have been rebased to 2027. Data sources: Australia's National Greenhouse Accounts (2026); EMM, Hunter Valley Operations (2025) Hunter Valley Operations Continuation Project Amendment Report, Appendix E.

28. The Proponent proposes to rely on the purchase of Safeguard Mechanism credits (also known as 'SMCs') and Australian carbon credit units (also known as 'ACCUs' or 'offsets') to comply with the net emissions reduction required under the national Safeguard Mechanism and to realise the Proponent's additional voluntary contributions to NSW's legislated targets.^[35]
29. However, the Proponent relies on an incorrect assumption that nation-wide ACCUs will contribute towards NSW's emissions reduction targets. The EPA Guide for Large Emitters explicitly states, 'offsets generated outside of NSW do not currently count towards the NSW emissions reduction inventory'.^[36] Similarly, the Net Zero Commission has advised that 'for offsets to be counted against the State's net zero targets [and] emissions reduction targets, the underlying abatement activity represented by the credit needs to have occurred within NSW.'^[37] This position has been reinforced by the NSW Department of Climate Change, Energy, the Environment and Water, most recently in its meeting with the Commission.^[38]
30. The Proponent's approach to offset use is also out of step with the best available science. As Dr Lafleur explains in his report, the Projects are expected to use a maximum of 5.6 to 7.1 million tonnes (Mt) CO₂-e in offsets.^[39] Between 2019 and 2026, over 65% of ACCUs were nature-based, so it is likely that a large portion of the offsets that will be available to the Proponent during the life of the Projects will also be nature-based.^[40] The best available science shows that fossil fuel emissions cannot be offset by nature-based solutions, as fossil fuel emissions reside in the atmosphere for centuries while nature-based carbon projects only store carbon on a decadal time scale.^[41] Therefore, and contrary to the Proponent's proposed approach, gross project emissions should be reduced within the project value chain and residual fossil fuel-related emissions can only be balanced by permanent CO₂ removal.^[42]
31. In these circumstances, ACCR submits that the Commission cannot be satisfied that the Projects' scope 1 and 2 emissions will be adequately mitigated through the use of offsets. This means, in turn, that the Projects will endanger the State's ability to meet its legislated emissions reduction targets and cause significant adverse impacts.
32. Should the Projects go ahead, other sectors of the NSW economy will be required to undertake more rapid emissions reduction or constrain future growth in emissions-intensive activities to compensate for the emissions generated by the Projects. In circumstances where NSW is already falling short of the emissions reduction milestones required to reach its legislated targets, the approval of the Projects would impose a significant additional burden on the State's decarbonisation effort.

E. The Projects' emissions are likely underestimated but are already consistent with more than 2°C in warming, and the proposed emissions mitigation strategies are inadequate

33. In addition to considering the impact that the Projects will have on NSW's emissions reduction targets, the Commission must give due weight to the impact that the Projects' actual cumulative GHG emissions will have on temperature outcomes and the resulting climate-related impacts. As detailed below, the Projects will make a substantial contribution to cumulative global GHG emissions and are consistent with warming above 2°C. The measures proposed to mitigate the Projects' GHG emissions are also uncertain, unproven and inconsistent with the need for real emissions reduction in the near term.

34. The Projects are expected to generate at least 809 Mt of carbon dioxide equivalent (CO₂-e) cumulative scope 1, 2 and 3 GHG emissions.^[43] These emissions would constitute a material contribution to global and localised warming, and associated climate-related impacts. In his report, Dr Lafleur emphasises that available scientific evidence indicates that existing and approved global fossil fuel developments already exceed the remaining carbon budget consistent with limiting warming to below 2°C.^[44] If approved, the Projects would add cumulative emissions to an already over-allocated carbon budget and can therefore be considered consistent with warming exceeding 2°C.

35. This level of projected warming and the significant climate, environmental, social and economic impacts associated with more than 2°C should weigh heavily against the approval of the Projects being in the public interest.

36. This submission gains greater force when the fact that the Projects' estimated fugitive emissions have likely been understated is taken into account.^[45]

37. Pursuant to s 2.20(2) of the State Environmental Planning Policy (Resources and Energy) 2021 (NSW), the Commission is required to consider an assessment of the GHG emissions of the Projects. The Proponent relies on an Air Quality and Greenhouse Gas Assessment, which estimates that the Projects will generate 35.16 Mt CO₂-e scope 1 and 2 emissions over their total life.^[46] However, this assessment likely presents an incomplete picture of the Projects' future emissions.

38. As discussed by Dr Lafleur in his report, there is a high likelihood that the Projects' scope 1 emissions have been materially underestimated.^[47] In 2025, a satellite study showed that the actual detected emissions from the Hunter Valley and Illawarra coal fields (representing 60% of NSW coal production and including the Proponent's existing mine area) were double the emissions that were officially reported.^[48] This undermines the reliability of the Proponent's existing GHG emissions assessment and raises questions about the adequacy of any approval conditions or mitigation measures that have been proposed on the basis of the existing emissions assessment.

39. There are also several issues with the measures that have been proposed for reducing the Projects' emissions:
    a. It is widely accepted that there is no proven technology available to effectively mitigate fugitive emissions from an open-cut coal mine. The Proponent has committed to undertaking a feasibility trial for the pre-drainage of gas in gas domain 3 of the Projects, but this technology remains experimental in nature and there is no guarantee of its success.^[49]
    b. Based on the information available about the Projects, a final decision on whether pre-drainage will form part of the Proponent's mitigation strategy may not occur until around 2030. It would be inconsistent with EPA guidelines and priorities to delay the decision on pre-drainage by up to three years. If the Projects are approved and commence before any final decision regarding pre-drainage is made, there will be a risk as time passes that any pre-drainage could become ineffective and even commercially unviable if gas concentrations are too low.^[50]
    c. The Proponent has not committed to meaningful diesel decarbonisation despite the EPA's guidance identifying this as a major opportunity for emissions reduction.^[51]
    d. Even if methane emissions reduction is achieved, the Project is expected to facilitate approximately 780 Mt CO₂-e of scope 3 emissions from coal combustion. This scale of downstream emissions is inconsistent with the State's stringent climate mitigation objectives and reduces the overall benefit of any methane reduction that is ultimately achieved.^[52]

40. The Projects' emissions are consistent with warming exceeding 2°C and the evidence indicates that the Projects lack a credible, proven or timely strategy for avoiding or substantially reducing GHG emissions. In these circumstances, the Commission cannot be satisfied that the GHG emissions of the Projects will be effectively or adequately mitigated, nor that the Projects are consistent with the public interest and with principles of ecologically sustainable development.

41. For the avoidance of doubt, any submission that the Projects' emissions may represent a small fraction of the global total of GHG emissions or that some other hypothetical and uncertain alternative fossil fuel development may produce the same GHG emissions instead is no answer to the projected adverse impacts. In Gloucester Resources Limited v Minister for Planning,^[53] Preston CJ rejected similar arguments made by the proponent of the Rocky Hill Coal Project and held that the mine should be refused due to its unacceptable impacts that could not be satisfactorily mitigated.

42. In his reasons for judgment, Preston CJ noted:

[515] ... In aggregate, the Scope 1, 2 and 3 emissions over the life of the [Rocky Hill Coal] Project will be at least 37.8Mt CO₂-e, a sizeable individual source of GHG emissions. It matters not that this aggregate of the Project's GHG emissions may represent a small fraction of the global total of GHG emissions. The global problem of climate change needs to be addressed by multiple local actions to mitigate emissions by sources and remove GHGs by sinks...

[516] Many courts have recognised this point that climate change is caused by cumulative emissions from a myriad of individual sources, each proportionally small relative to the global total of GHG emissions and will be solved by abatement of the GHG emissions from these myriad of individual sources.

[545] There is also a logical flaw in the market substitution assumption. If a development will cause an environmental impact that is found to be unacceptable, the environmental impact does not become acceptable because a hypothetical and uncertain alternative development might also cause the same unacceptable environmental impact. The environmental impact remains unacceptable regardless of where it is caused. The potential for a hypothetical but uncertain alternative development to cause the same unacceptable environmental impact is not a reason to approve a definite development that will certainly cause the unacceptable environmental impacts. In this case, the potential that if the [Rocky Hill Coal] Project were not to be approved and therefore not cause the unacceptable GHG emissions and climate change impacts, some other coal mine would do so, is not a reason for approving the Project and its unacceptable GHG emissions and climate change impacts.

43. It is open to the Commission to adopt this same approach in its assessment of the Projects, noting that the Projects are expected to generate at least 806 Mt CO₂-e in gross emissions which is over twenty times greater than the 37.8 Mt CO₂-e in gross emissions that were projected for the Rocky Hill Coal Project. In ACCR's submission, the Projects will lead to a net increase in local and global emissions and therefore contribute to an increase in global temperatures and climate change impacts. The Commission ought to reject any submission to the contrary.

F. The Projects will cause significant environmental, social and economic impacts in the locality which cannot be sufficiently mitigated

44. Should the Commission accept that the scope 1, 2 and 3 emissions resulting from the Projects will contribute to global climate change, the Commission is required by s 4.15(1)(b) of the EPA Act to consider the resulting environmental impacts that will be experienced in the locality of the Projects.^[54] ACCR submits that the Projects' cumulative emissions will have an unacceptable impact on the climate system and environment of the Hunter region, in turn causing cascading social and economic impacts in the locality.

45. As noted above with reference to Dr Lafleur's report, the cumulative emissions of the Projects are consistent with more than 2°C of global warming. It is therefore appropriate to consider the local environmental and climate-related impacts that will be experienced in the Hunter region, being the locality of the Projects, if the threshold of 2°C in global warming is breached.

46. The report of Dr Sophie Lewis (attached as Annexure C) details the causal link between GHG emissions, the increase in global temperatures, and regional and local climatic impacts. In summary:
    a. The Hunter region bears several features that make it specifically vulnerable to climate change, and it includes one of the largest and most flood-prone floodplains in NSW.^[55]
    b. If global temperatures increase by 2°C by 2050, the Hunter region will likely experience at that time:
    i. a significant increase in the frequency and intensity of heat extremes, including seven more days each year where maximum temperatures exceed 35°C, compared to the 1990-2009 average;
    ii. considerable changes in rainfall, including an overall decrease in average rainfall by 9% and an increase in the intensity of heavy rainfall events;
    iii. increased exposure to sea level rise of between 14 and 31 centimetres, and associated hazards including coastal erosion, estuarine inundation and coastal overwash; and
    iv. increased severe fire weather days.^[56]
    c. These climate hazards will compound and cascade, dramatically increasing various social, economic and public health-related risks in the Hunter region. Cascading impacts that will likely be felt by the local population include increasing heat-related illness and mortality, disruption to the agricultural industry, reduced productivity in industries that rely on outdoor workers, and infrastructure-related hazards.^[57]

47. The Commission's decision-making must be guided by the objects of the EPA Act, which include 'the promot[ion of] the social and economic welfare of the community and a better environment by the proper management, development and conservation of the State's natural and other resources'.^[58] ACCR submits that the projected impacts described above will undermine the social and economic welfare of the community. The Projects would be a damaging use of the State's resources.

48. Developments in scientific attribution methods have also enabled the GHG emissions of fossil fuel projects to be causally linked to specific amounts of additional global warming and, by extension, specific regional climate consequences. In her report, Dr Lewis applies this methodology to the Projects and concludes that the following future impacts in NSW would be directly attributable to the fraction of warming caused by the Projects' total emissions:
    a. at least one excess heat-related death in NSW over the period 2060-2079;
    b. an annual cost of up to $680,000 to community and businesses in Western Sydney by 2080; and
    c. a reduction of at least 29 jobs in NSW by 2070.^[59]

49. These are serious, significant and irreversible social, economic and health-related impacts in NSW that can be attributed to the Projects that the Commission should have regard to. In ACCR's submission, the approval conditions suggested by the Department will not adequately mitigate the risk of these impacts.

50. The Proponent's development applications and related material do not meaningfully address the climate change impacts that will result in the locality and NSW more widely from the Projects' total cumulative emissions. The risk of these impacts occurring can only be mitigated by the reduction of actual GHG emissions or the effective permanent removal of CO₂ from the atmosphere.

51. As noted by Dr Lafleur in his report, opportunities to use offsets and to mitigate fugitive emissions are limited in availability and effectiveness. There is also limited evidence that the Proponent will take measures to meaningfully reduce diesel emissions associated with the Projects, and no evidence that the Projects' substantial scope 3 emissions will be mitigated. In these circumstances, the Commission cannot be satisfied that the approval of the Projects would be in the public interest, nor consistent with the guiding principles of the Climate Change (Net Zero Future) Act 2023 (NSW).

G. Conclusion

52. Pursuant to s 4.28 of the EPA Act, the Commission is empowered to determine the Proponent's development applications by granting consent (whether unconditional or conditional) or refusing consent.
53. In ACCR's submission, the Projects will cause significant adverse environmental and climate-related impacts at a local, regional and global level, and materially impede NSW's ability to meet its legislated emissions reduction targets. These impacts are unacceptable and are not outweighed by the Projects' net economic benefit, nor can they be mitigated by conditions or modifications. In these circumstances, approval of the Projects cannot be considered to be in the public interest, and the Commission ought to refuse consent for the development applications.

Download Submission: HVO North and South Open Cut Coal Continuation Projects
Annexure A: Report of Mr Pranav Dayal dated 5 August 2026
Annexure B: Report of Dr Dimitri Lafleur dated 24 July 2026
Annexure C: Report of Dr Sophie Lewis dated 31 July 2026