Mod 8 - Ulan West Continued Operations

Department of Planning, Housing and Infrastructure
Re: Submission on Ulan West Modification 8 (Glencore)
From: Watershed Landcare Inc.

To whom it may concern,

Watershed Landcare appreciates the opportunity to comment on the proposed Ulan West Modification 8. Our organisation supports landholders and communities across the Mid-Western Region under the vision Healthy Landscapes, Healthy Community, and we hold deep concern about the significant environmental, cultural, and community impacts of this proposal.

We oppose Modification 8 and believe it should be assessed as a New Project, not a modification. The scale of the changes, including seven additional longwall panels, an extra 38–43 million tonnes of coal, extended operations to 2041, major new tailings infrastructure, and substantial impacts to water, biodiversity, and cultural heritage, goes far beyond the scope of the existing approval. Bypassing rigorous scrutiny undermines community confidence in the assessment process.

Water Resources and Catchment Health
Groundwater drawdown has already affected springs, bores, and small farms that rely on stable water tables. The modification would further reduce baseflows to the Talbragar River, placing the Macquarie Marshes at risk, and extend saline mine water discharge by six additional years, adding an estimated 15,000+ tonnes of salt to the Goulburn–Hunter system. The proposal to expand tailings storage to 132 ha near river systems poses unacceptable long-term contamination risks.

These impacts compromise the resilience of two major catchments, the Murray–Darling Basin and Hunter River, on which regional agriculture, ecosystems, and communities depend.

Biodiversity and Landscape Integrity
The proposal will clear more than 190 hectares, including 101.45 hectares of native vegetation and 34 hectares of Box Gum Woodland, a critically endangered ecological community. Habitat loss will affect a suite of threatened species, including the Large-eared Pied Bat, Eastern Cave Bat, Regent Honeyeater, Koala, and Brush-tailed Rock-Wallaby. These losses undermine extensive community-led restoration efforts across the Watershed.

Cultural Heritage on Wiradjuri Country
The project area contains 71 known Aboriginal cultural heritage sites within a landscape of deep significance to the Wiradjuri people. Risks from subsidence, clearing, and hydrological change cannot be adequately mitigated. Protection of Country should be paramount.

Climate, Community Health, and Public Benefit
The proposal would add 105 Mt CO₂-e in Scope 3 emissions, a 45% increase on current approvals, contributing to climate-related pressures already affecting farms and rural communities. Local air quality, noise, and amenity impacts would also intensify.

Despite long-standing approvals to extract 20 million tonnes per year, Ulan Mine produced only 9.29 million tonnes in 2024, weakening the economic justification for further expansion while its environmental and social costs continue to escalate.

Modification 8 conflicts with the long-term health and sustainability of our region. In line with our vision of Healthy Landscapes, Healthy Community, we strongly recommend that the Department:

Reject the proposal, or

Require a full New Project assessment, including independent expert review and comprehensive public scrutiny.

Thank you for considering this submission,
Regards,
Maddison O'Brien
Watershed Landcare
Local Landcare Cooridnator

18 November 2025

Submission to the NSW Government Planning Portal
objecting to the proposed Ulan Coal Mine Mod 8 – Ulan West Continued Operations

Running Stream Water Users Association objects to Glencore’s proposed extension of the Ulan Coal Mine. The cumulative impact of this project applies to water loss and pollution, as well habitat loss and Aboriginal cultural heritage loss. Below we list our specific concerns about this proposed mine expansion.

Glencore’s controversial Ulan Coal Mine already has approval to mine 20 Mt/year of thermal coal, up to August 2035. It is a wholly underground longwall mining operation, disturbing over 120 square kilometres of farmland and bushland with high biodiversity values. Ulan Mine crosses under the Great Dividing Range, intercepting water from the Murray-Darling Basin and the Hunter catchment.

The proposed mine expansion (Ulan Mod 8) 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. Disguised as a simple “modification”, this proposal would extend mining to 2041, threatening our water, climate, and wildlife. It is a major new project in all but name, deliberately avoiding the independent scrutiny such a huge project requires. It should be assessed as a new project so that it receives full independent merit assessment.

Our key concerns with impacts of the Ulan Mod 8 expansion are:
• It extends mining: The proposed six-year extension will mine an additional 43 million tonnes of coal, in contravention of Australia’s Paris climate obligations. Moreover, the final layout of surface infrastructure not yet determined – the mine plan is not finalised.
• It will have massive emissions: The extension will add 105 million tonnes of Greenhouse Gas emissions, a 45% increase.
• It spans major catchments: Operations will impact both the Hunter and Murray-Darling basins, threatening water security for thousands of people, farmers and wildlife. It will decrease water flows to the Murray-Darling Basin and the Macquarie Marshes and will increase the amount of salt flowing into the Goulburn and Hunter rivers.
• Risky tailings dam: The proposal involves construction of a large new tailings dam area of 132 hectares within a revegetated, rehabilitated old open-cut pit next to the Goulburn River. This risks leakage of toxic contaminants downstream into a national park.
• Habitat and species loss: The project would clear more than 100 hectares of native vegetation, including 34 hectares of Box Gum Woodland, impacting threatened species like the Regent Honeyeater and Koala. It would also disturb an additional 1743 hectares, with sandstone escarpments, caves and overhangs, destroying additional important habitat for the nationally threatened Large-eared Pied Bat, Eastern Cave Bat, Regent Honeyeater and Koala, as well as critically endangered Box Gum Woodland.
• Cultural heritage risk: The project would impact 71 Aboriginal sites, including rock art, on Wiradjuri Country, which are under a Native Title claim. This will lead to the loss of Aboriginal cultural heritage and destruction of the spiritual landscape for the Wiradjuri Nation.
• The mine extension would undermine seventeen private properties, directly impacting four houses and six private bores, increasing social impacts, loss of farm water and leading to ongoing disturbance of a rural way of life.
• This project is not needed to provide regional jobs – there is a huge workforce shortage in the Central West for renewable energy projects and other industries.
• Flawed process: The project is being assessed as a “modification” to avoid community scrutiny. It is outside existing mine boundary with additional infrastructure disturbance.
It should be assessed as a new project.

More detailed information
1. Methane monitoring – Scope 1 emissions
Glencore does not report methane emissions and altered the baseline calculation for annual CO2 -e emissions in 2014 to below requirement for offsets under the Federal Safeguard Mechanism, with no explanation.

2. New tailings dam
A new 132-hectare tailings dam area (and associated stockpile) is additional to the current approved mining impacts. The proposed area for storage of coal waste from the washery abuts the Goulburn River, with no monitoring points to measure seepage into the river. This is a threat to The Drip gorge and downstream water users, including Goulburn River National Park. The chosen site is an old revegetated open-cut mine, backfilled with coal rejects and disturbed soils. This is a new toxic legacy in the landscape, further risking river health. No details are provided on how this significant infrastructure will be managed or groundwater leakage monitored.

3. Water impacts
Subsidence or land collapse caused by underground mining damages groundwater systems that store water in the landscape. Groundwater provides base flows to rivers and creeks. This mine expansion will cause a predicted additional loss of 26.5 million litres per year of flow to the Talbragar River – the proposal does not report cumulative loss of flows from current approvals.

The Talbragar River is a major tributary of the Macquarie River, in the Murray-Darling Basin, that flows in below Burrendong Dam. These flows are directly connected to the internationally significant Macquarie Marshes.

The Goulburn River will also be impacted by additional loss of base flow.

Most importantly, it will add another six years of mine water discharge, carrying over 15,000 tonnes of salt (7 tonnes per day) into the Goulburn/Hunter River ecosystem. The cumulative impact of the three large local coal mines on the Goulburn River has never been fully assessed.

4. Aboriginal cultural heritage impacts
The cumulative loss of significant Aboriginal cultural heritage in the Ulan area is not assessed. There is ample evidence of continuous Wiradjuri occupation of the region, with spiritual connection to Country. Ulan Mod 8 will impact an additional seventy-one recorded Aboriginal sites.

5. Biodiversity impacts
The proposed extension of mine disturbance will impact areas of fragile sandstone landscape, including 6.5 kilometres of escarpment with rocky outcrops and cliff lines higher than 10 metres. These provide important habitat for the endangered Large-eared Pied Bat and Eastern Cave Bat.

This habitat loss cannot be offset. The cumulative loss of irreplaceable microbat habitat across the three adjacent mines is not assessed.
The cumulative loss of mature, healthy Box Gum Woodland CEEC in the region through mine clearing has not been assessed. This ecosystem provides important habitat for a range of threatened woodland animal species.

Regent Honeyeater: The ongoing loss of important habitat for the critically endangered Regent Honeyeater is not recognised or assessed. There are current records of breeding activity in the district that are not identified in the assessment report.

Koalas: Ongoing disturbance of Koala habitat from mining is not assessed.

The area of impact also provides habitat for the threatened Barking Owl and the Powerful Owl.

6. No final mine plan
The final placement of infrastructure in the landscape has not yet been provided because of ongoing negotiations with private landholders. This issue should have been resolved before the proposal was lodged and accepted by the Department of Planning. A final mine plan should be submitted for consideration.

7. Social impacts
The proposal will impact seventeen private properties, directly undermining four homes and lowering water availability in six private bores, including total dewatering of one. The mitigation measure of providing replacement water will not continue after mining is finished. The Ulan Mine has bought numerous properties over time because of severe impacts of subsidence and noise from ventilator fans. This diminishes the local community and removes neighbourhood support in a remote rural area.

8. Not substantially the same project
The proposed extension should not be assessed as a modification because it is not substantially the same as the current mine approval:
• It falls entirely outside the current mining lease.
• It introduces new infrastructure (e.g. a new 132-hectare tailings disposal area, additional ventilators, tracks, roads).
• It impacts an additional 1734 hectares of landscape.
• It increases impacts on groundwater, creeks and rivers.
• It destroys irreplaceable endangered species habitat.
• It causes additional biodiversity impacts under Federal environmental law.
• It destroys a new area of Aboriginal cultural heritage significance, impacting seventy-one recorded Aboriginal sites.
• It directly impacts seventeen private properties, threatens built structures and private bores.
• It releases 105 Mt additional greenhouse gas emissions.

9. Not justified
There is no need for extended coal mining in the region to provide local jobs. Mining is competing for skilled labour urgently required in the construction, housing and renewable energy industries. There is a major labour shortage in the Central West, with local workers needed for the CWO REZ construction. The NSW Government has prioritised the Central West Future Jobs and Investment Authority to manage the transition away from coal mining. The Mudgee region has many opportunities to diversify the economy.


We trust that the issues noted above will be carefully considered, and that Glencore’s modification request for Ulan Coal Mine will be denied.

Yours sincerely,
Fiona Sim, President
(on behalf of Running Stream Water Users Association)

(* Please note that I attempted several times to upload our submission as a PDF document, but the portal would not let me do so. It is therefore submitted here, minus formatting and letterhead.)

Submission to the NSW Government Planning Portal objecting to the proposed Ulan Coal Mine Mod 8 – Ulan West Continued Operations

I object to Glencore’s proposed extension of the Ulan Coal Mine, which threatens to damage public health, the environment and Aboriginal cultural heritage. Below I list my specific concerns about this proposed mine expansion.

Glencore’s controversial Ulan Coal Mine already has approval to mine 20 Mt/year of thermal coal, up to August 2035. It is a wholly underground longwall mining operation, disturbing over 120 square kilometres of farmland and bushland with high biodiversity values. Ulan Mine crosses under the Great Dividing Range, intercepting water from the Murray-Darling Basin and the Hunter catchment.

The proposed mine expansion (Ulan Mod 8) 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. Disguised as a simple “modification”, this proposal would extend mining to 2041, threatening our water, climate, and wildlife. It is a major new project in all but name, deliberately avoiding the independent scrutiny such a huge project requires. It should be assessed as a new project so that it receives full independent merit assessment.

My key concerns with impacts of the Ulan Mod 8 expansion are:
• It extends mining: The proposed six-year extension will mine an additional 43 million tonnes of coal, in contravention of Australia’s Paris climate obligations. Moreover, the final layout of surface infrastructure not yet determined – the mine plan is not finalised.
• It will have massive emissions: The extension will add 105 million tonnes of Greenhouse Gas emissions, a 45% increase.
• It spans major catchments: Operations will impact both the Hunter and Murray-Darling basins, threatening water security for thousands of people, farmers and wildlife.
• Risky tailings dam: The proposal involves construction of a large new tailings dam area of 132 hectares within a revegetated, rehabilitated old open-cut pit next to the Goulburn River. This risks leakage of toxic contaminants downstream into a national park.
• Habitat and species loss: The project would clear more than 100 hectares of native vegetation, including 34 hectares of Box Gum Woodland, impacting threatened species like the Regent Honeyeater and Koala. It would also disturb an additional 1743 hectares, with sandstone escarpments, caves and overhangs, destroying additional important habitat for the nationally threatened Large-eared Pied Bat, Eastern Cave Bat, Regent Honeyeater and Koala, as well as critically endangered Box Gum Woodland.
• Cultural heritage risk: The project would impact 71 Aboriginal sites, including rock art, on Wiradjuri Country, which are under a Native Title claim. This will lead to the loss of Aboriginal cultural heritage and destruction of the spiritual landscape for the Wiradjuri Nation.
• The mine extension would undermine seventeen private properties, directly impacting four houses and six private bores, increasing social impacts, loss of farm water and leading to ongoing disturbance of a rural way of life.
• This project is not needed to provide regional jobs – there is a huge workforce shortage in the Central West for renewable energy projects and other industries.
• Flawed process: The project is being assessed as a “modification” to avoid community scrutiny. It is outside existing mine boundary with additional infrastructure disturbance.
It should be assessed as a new project.


More detailed information
1. Methane monitoring – Scope 1 emissions
Glencore does not report methane emissions and altered the baseline calculation for annual CO2 -e emissions in 2014 to below requirement for offsets under the Federal Safeguard Mechanism, with no explanation.

2. New tailings dam
A new 132-hectare tailings dam area (and associated stockpile) is additional to the current approved mining impacts. The proposed area for storage of coal waste from the washery abuts the Goulburn River, with no monitoring points to measure seepage into the river. This is a threat to The Drip gorge and downstream water users, including Goulburn River National Park. The chosen site is an old revegetated open-cut mine, backfilled with coal rejects and disturbed soils. This is a new toxic legacy in the landscape, further risking river health. No details are provided on how this significant infrastructure will be managed or groundwater leakage monitored.

3. Water impacts
Subsidence or land collapse caused by underground mining damages groundwater systems that store water in the landscape. Groundwater provides base flows to rivers and creeks. This mine expansion will cause a predicted additional loss of 26.5 million litres per year of flow to the Talbragar River – the proposal does not report cumulative loss of flows from current approvals.

The Talbragar River is a major tributary of the Macquarie River, in the Murray-Darling Basin, that flows in below Burrendong Dam. These flows are directly connected to the internationally significant Macquarie Marshes.

The Goulburn River will also be impacted by additional loss of base flow.

Most importantly, it will add another six years of mine water discharge, carrying over 15,000 tonnes of salt (7 tonnes per day) into the Goulburn/Hunter River ecosystem. The cumulative impact of the three large local coal mines on the Goulburn River has never been fully assessed.

4. Aboriginal cultural heritage impacts
The cumulative loss of significant Aboriginal cultural heritage in the Ulan area is not assessed. There is ample evidence of continuous Wiradjuri occupation of the region, with spiritual connection to Country. Ulan Mod 8 will impact an additional seventy-one recorded Aboriginal sites.

5. Biodiversity impacts
The proposed extension of mine disturbance will impact areas of fragile sandstone landscape, including 6.5 kilometres of escarpment with rocky outcrops and cliff lines higher than 10 metres. These provide important habitat for the endangered Large-eared Pied Bat and Eastern Cave Bat.

This habitat loss cannot be offset. The cumulative loss of irreplaceable microbat habitat across the three adjacent mines is not assessed.

The cumulative loss of mature, healthy Box Gum Woodland CEEC in the region through mine clearing has not been assessed. This ecosystem provides important habitat for a range of threatened woodland animal species.

Regent Honeyeater: The ongoing loss of important habitat for the critically endangered Regent Honeyeater is not recognised or assessed. There are current records of breeding activity in the district that are not identified in the assessment report.

Koalas: Ongoing disturbance of Koala habitat from mining is not assessed.

The area of impact also provides habitat for the threatened Barking Owl and the Powerful Owl.

6. No final mine plan
The final placement of infrastructure in the landscape has not yet been provided because of ongoing negotiations with private landholders. This issue should have been resolved before the proposal was lodged and accepted by the Department of Planning. A final mine plan should be submitted for consideration.

7. Social impacts
The proposal will impact seventeen private properties, directly undermining four homes and lowering water availability in six private bores, including total dewatering of one. The mitigation measure of providing replacement water will not continue after mining is finished. The Ulan Mine has bought numerous properties over time because of severe impacts of subsidence and noise from ventilator fans. This diminishes the local community and removes neighbourhood support in a remote rural area.

8. Not substantially the same project
The proposed extension should not be assessed as a modification because it is not substantially the same as the current mine approval:
• It falls entirely outside the current mining lease.
• It introduces new infrastructure (e.g. a new 132-hectare tailings disposal area, additional ventilators, tracks, roads).
• It impacts an additional 1734 hectares of landscape.
• It increases impacts on groundwater, creeks and rivers.
• It destroys irreplaceable endangered species habitat.
• It causes additional biodiversity impacts under Federal environmental law.
• It destroys a new area of Aboriginal cultural heritage significance, impacting seventy-one recorded Aboriginal sites.
• It directly impacts seventeen private properties, threatens built structures and private bores.
• It releases 105 Mt additional greenhouse gas emissions.

9. Not justified
There is no need for extended coal mining in the region to provide local jobs. Mining is competing for skilled labour urgently required in the construction, housing and renewable energy industries. There is a major labour shortage in the Central West, with local workers needed for the CWO REZ construction. The NSW Government has prioritised the Central West Future Jobs and Investment Authority to manage the transition away from coal mining. The Mudgee region has many opportunities to diversify the economy.

I trust that the issues noted above will be carefully considered, and hope that Glencore’s modification request for Ulan Coal Mine will be denied.

Yours sincerely,
Fiona Sim, Running Stream, NSW

Here is a list of reasons why I object to the Mod 8 - Ulan West Continued Operations

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 Wes

Glencore’s Ulan Coal Mine Modification 6 has been overturned in the Mudgee District Environment Court.
Modification 6 extended the mine’s life from 2033 to 2035. However, Modification 8 covers the period from 2035 to 2041 and therefore depends on Modification 6 to cover the period up to 2035. Now that Mod 6 has been overturned, Mod 8 has no basis to proceed. In addition, Mod 8’s proposed infrastructure is also directly attached to Mod 6’s underground longwall panels. If Mod 6 is not proceeding and the panels are not completed, the Mod 8 infrastructure cannot exist. As a result, Mod 8 is essentially inoperative.

The extension of the coal mine is essential for the ongoing stability and growth of the Mudgee region. It supports hundreds of local jobs, strengthens small businesses, and keeps money circulating within the community. The mine operates under strict environmental and safety standards, and its continued operation ensures these high standards remain in place. The industry also contributes significantly to local infrastructure, sponsorships, and community programs, making it a cornerstone of the region’s economic and social wellbeing. Extending the mine provides stability for families, supports the town’s future, and maintains reliable energy supply during Australia’s long-term transition

I am pleased to put forth my support for the proposed expansion of Ulan West.
As a Co-Owner of a local business and, for the most part, lifetime local of Mudgee, I have seen the profoundly positive community impact that Ulan West/Glencore have made.
While providing countless jobs to new and existing Mudgee residents and supporting local businesses, their community support for local initiatives such as the Mudgee 4 Doctors and Country Universities Centre, alongside their continuing support of our local sporting clubs and charities, help to ensure this generation and future have an environment where they and their families are supported and help cultivate a local sense of pride in our community.
I am confident that the implementation of this expansion will continue to yield positive change, helping to ensure that our community continues to become a vibrant and prosperous place for current and future generations who will, and do, call Mudgee home.

NSW Planning Portal
Major Projects: SSD Modifications
Contact Planner: Genevieve Lucas

Submission of Objection: Ulan Coal Mine Mod 8 – Ulan West Continued Operations

Introduction

Glencore is seeking approval for Ulan Coal Mine Mod 8. This would allow an extra 45 Mt of coal to be extracted and would extend mining to 2041. It includes expanding the underground mining area and building new surface infrastructure. These changes push the mine into new areas and would have major environmental and social impacts.

I object to Mod 8.

In May 2025, Ulan Mod 6 was approved. On 14 November 2025, that approval was declared invalid by the NSW Land and Environment Court. Because Mod 8 relies on Mod 6, and depends on its extended mine life, Mod 8 has no valid basis and should be refused. Even so, I outline the broader issues below.

This proposal carries serious risks for water, biodiversity, climate, cultural heritage and local communities. It also lacks an economic case. I ask that Mod 8 be rejected.

Project Assessment

Mod 8 is not a valid Modification

The scale and nature of Mod 8 mean it should be treated as a new project, not a modification. It does not meet the requirement of being “substantially the same project”.

The proposal moves mining into an area without a Mining Lease. The company identifies resources in Exploration Licences (EL) 8687 and 9363, which do not grant mining rights. Seeking approval to mine this area through a Modification is not valid.

The proponent claims there are “no significant changes to environmental impacts”, yet its own documents show new and serious impacts. There are also gaps, conflicting statements, and recommendations within the reports themselves to revisit key assessments, including the Groundwater Impact Assessment (PDF page 289).

The precautionary principle should apply.

Mod 8 relies on Mod 6, which is invalid

The Court’s decision means Mod 6 no longer exists. Mod 6 extended the mine from 2033 to 2035. Without it, the mine must cease in 2033. Mod 8 depends on the Mod 6 timeframe to justify operations from 2035–2041.

The underground layout for Mod 8 was also tied to the Mod 6 longwall panels. Without Mod 6, these panels cannot exist. This makes Mod 8 unworkable.

Environmental Impacts
Greenhouse Gas Emissions

Mod 8 would release more than 105 Mt of additional greenhouse gases. Allowing this would go against national and international climate commitments. Methane reporting is also unreliable and not acceptable.

Climate Change impacts on the locality

Recent decisions, including the NSW Court of Appeal ruling on Mt Pleasant and the invalidation of Ulan Mod 6, confirm that local climate impacts must be assessed.

This region has suffered droughts, fires and floods with huge financial and emotional costs. Loss of crops, livestock, buildings and fencing is only part of the burden. There are ongoing costs through insurance increases, repair of public infrastructure, and the damage to ecosystems after the 2019–20 fires. Those fires caused major biodiversity loss, increased vulnerability of species, and long-term land stress.

Mod 8 would further pressure Box-Gum Woodland (Critically Endangered Ecological Community) across 1743 ha, a key refuge post-fire. These climate-related impacts must be assessed and have not been.

Water Resources

This project affects land on both sides of the Great Dividing Range and influences the Murray Darling Basin and Hunter River systems. Water impacts must be rigorously assessed, and this project should be referred to the Independent Expert Panel for Mining.

Major concerns include:

Groundwater interception: Mod 8 would continue groundwater drawdown for another 6 years, drying out springs and seeps that support community, cultural and ecological values.

Poor water modelling: There is a major gap between predicted “simulated” and real “measured” groundwater levels. Monitoring is inadequate.

Subsidence and dewatering:

Predicted impacts: 17 properties and 14 private bores with more than 2 m drawdown, with 1 bore completely dewatered.

Loss of flow to the Talbragar River, with flow-on effects to the Macquarie River and the Ramsar-listed Macquarie Wetlands of International Significance.

Reduced inflows to the Goulburn River.
These impacts cannot be allowed.

Goulburn River and The Drip (GDE):

Predicted groundwater declines of 2–50 m below the Goulburn River and The Drip.

Consent Condition 33 requires “NO IMPACT” on water supply to The Drip.
Mod 8 does not meet this requirement.

Salt load:

An extra 6 years of mine water discharge.

Salt load of 8–16 t/day entering the Goulburn–Hunter catchment.

This would affect the Goulburn River National Park and all downstream users.
Cumulative impacts from Ulan, Moolarben and Wilpinjong have not been fully assessed.

New tailings dam (132 ha):
There is almost no detail on construction, seepage prevention or management. A dam of this size beside the Goulburn River diversion poses long-term pollution risk.

The water impacts alone justify refusal.

Biodiversity and Ecosystems

Mod 8 would disturb 1743 ha of habitat, including escarpments, caves and overhangs. The BDAR and MNES reports show major inconsistencies and assessment failures.

Key concerns include:

• Poor assessment of species facing Serious and Irreversible Impacts (SAII), including:
– Large-eared Pied Bat
– Eastern Cave Bat
– White Box–Yellow Box–Blakely’s Red Gum Woodland

• Inadequate assessment of threatened species such as:
– Regent Honeyeater
– Koala
– New Holland Mouse
All of these species are known in the region.

The district is an Important Bird Area and recent Regent Honeyeater breeding has been recorded on the Goulburn River. Koala habitat mapping (Science for Wildlife) shows strong potential habitat near the site.

Subsidence impacts on key species have not been properly investigated.

After 19 million ha burned in 2020, remaining habitat must be protected. Mod 8 cannot be justified.

Community and Social Well-being

Mod 8 affects 17 private landholdings. The company has a pattern of buying out impacted properties after approval, leading to community decline that has not been measured cumulatively. Combined with purchases linked to Moolarben and Wilpinjong, the area has steadily hollowed out.

The proposal would undermine 4 homes and directly affect 6 farm bores, threatening farm viability and weakening emergency response capacity.

Cultural Heritage

There is long-standing Wiradjuri cultural connection to this area, including the headwaters of the Goulburn River. Mod 8 would impact 71 known sites, including rock art. Given the cumulative harms from three mines along the Goulburn River, further cultural damage is not acceptable.

Cumulative Impacts

The proponent claims low cumulative impact, but excludes greenhouse emissions, climate costs, water impacts, biodiversity loss, social disruption and cultural harm. When these are included, the cumulative impact is major.

Assessing each mine in isolation hides the true extent of regional damage from Ulan, Moolarben and Wilpinjong.

Economic Implications

The claimed economic benefits do not outweigh long-term costs from climate impacts, water loss, contamination, rehabilitation liabilities and biodiversity decline.

The mine sits inside the Central West Orana Renewable Energy Zone. Expanding coal here conflicts with NSW energy policy and strains a workforce already needed for renewable energy jobs, construction and housing.

Conclusion

Mod 8 should be refused because:

• It relies on the invalid Mod 6.
• It is not a genuine Modification, but a new project.
• It poses major risks to climate, water, biodiversity and cultural heritage.
• It harms community well-being.
• It has no sound economic basis.

For the sake of the environment, community and future generations, Mod 8 must not proceed.

Sincerely,
A.

Submission Opposing Ulan Coal Mine Modification 8

To: NSW Department of Planning, Housing and Infrastructure
Re: Ulan Coal Mine – Modification 8 (Mod 8) – Objection

I strongly oppose the proposed Ulan Coal Mine Modification 8 and request that the application be rejected. The scale, nature and location of this proposal constitute a new mining project, not a modification, and it must therefore undergo a full and independent merit assessment.

Background
Ulan Coal Mine, owned by Glencore, currently holds approval to extract 20 Mt/year of thermal coal until August 2035. Though operating wholly as an underground longwall mine, its workings extend beneath more than 120 km² of high-value farmland and bushland, traversing the Great Dividing Range and intercepting water from both the Murray–Darling Basin and the Hunter catchment.
Mod 8 seeks approval to extract a further 43 Mt of coal, extending operations to 2041. This proposal is effectively an expansion outside the approved mining envelope, introducing new, unassessed environmental and social impacts. It also follows closely from Mod 6, a recent expansion now cancelled by the L&E Court.
Ulan Mine sits within the Central West Orana Renewable Energy Zone (CWOREZ). Continued coal expansion in this region is inconsistent with state and national climate and energy objectives.

Grounds for Objection
1. Massive Additional Greenhouse Gas Emissions
Mod 8 would enable the release of over 105 Mt of additional greenhouse gas emissions, undermining efforts to maintain a safe climate. Methane emissions at Ulan are poorly monitored, inadequately reported, and inconsistent with Australia’s commitment to improve emissions transparency and reduce fugitive emissions.
2. Proposal Falls Outside Existing Mine Boundary – Must Be Assessed as a New Project
All proposed longwall panels and associated disturbance lie outside the approved mining area. This introduces substantial, previously unassessed impacts. The scale and location of the proposal exceed the intent of a “modification” and should trigger a new project assessment.
3. New 132 ha Tailings Dam Adjacent to Goulburn River
Construction of a large new tailings storage facility within a previously rehabilitated open-cut pit creates major contamination risks. The proximity to the Goulburn River raises the likelihood of leaching of toxic substances, undermining decades of rehabilitation work and threatening downstream ecosystems.
4. Impacts to the Murray–Darling Basin and Talbragar River
Because the expansion is located west of the Great Dividing Range, subsidence and water interception will reduce flows to the Talbragar River, a tributary of the Macquarie River, which feeds the internationally significant Macquarie Marshes. These hydrological impacts are unacceptable and incompatible with Basin Plan objectives.
5. Increased Salinity in the Goulburn River
The proposal continues and expands the release of mine-affected water into the Goulburn River, increasing salinity and harming downstream water users, agriculture, and riverine ecosystems within the Hunter catchment.
6. Destruction of Aboriginal Cultural Heritage
The development would impact at least 71 known Wiradjuri cultural heritage sites, including rock art, artefact scatters, and areas of spiritual significance. Subsidence and landscape fragmentation threaten the integrity of this cultural landscape, effectively erasing irreplaceable heritage.
7. Loss of Critical Biodiversity and Habitat
Mod 8 proposes disturbing an additional 1,743 hectares of sandstone escarpment, caves, and overhangs—habitat essential for several threatened and nationally significant species, including:
• Large-eared Pied Bat (nationally threatened)
• Eastern Cave Bat
• Regent Honeyeater
• Koala
• Critically endangered Box Gum Woodland
The cumulative impact of three major mines in the region has already pushed these species toward collapse. Further disturbance is ecologically unjustifiable.
8. Incomplete and Uncertain Mine Design
The proponent has not finalised the surface infrastructure layout or the mine plan, preventing meaningful assessment by regulators or the community. Approving a project of this magnitude without clarity on fundamental design elements is inappropriate and risky.

9. Subsidence Impacts on Private Properties
The proposal would undermine 17 private properties, directly affecting 4 homes and 6 private water bores. Reduced groundwater availability and structural risks impose unacceptable burdens on landholders who have already been heavily impacted by mining.

10. Escalating Social Impacts
Rural amenity, farm productivity, and community wellbeing will deteriorate further. Loss of property water, increased noise, dust, traffic, and landscape degradation contribute to long-term social decline for residents in the Ulan–Rylstone–Mudgee region.

11. No Economic Justification – Renewable Sector Faces Workforce Shortages
Mod 8 is not required to support regional employment. The Central West Orana Renewable Energy Zone has well-documented workforce shortages across construction, trades, and operations. Extending a thermal coal mine does not align with the region’s economic transition priorities.
Conclusion
Mod 8 is not a minor change but a substantial new mining project with far-reaching environmental, cultural, social, and climate impacts. Approving it as a “modification” would be inappropriate and inconsistent with NSW planning principles.

For these reasons, I urge the Department to:
• Reject Modification 8, and
• Require Glencore to submit any future proposal as a full new development application subject to independent merit assessment.

OFNCS objects to this coal mine expansion as it needs to be assessed as a new project not a modification, it will impact on a number of threatened species and EECs. It will permanently impact groundwater and potentially add pollutants to river systems. Aboriginal sites and cultural heritage will be damaged and local landholders and communities will be affected. And finally, the impact on climate change from so much coal being extracted and greenhouse gas being produced must be assessed both locally and at a wider scale.

Dear Sir/Madam,

I make strong objection to Mod 8 - Ulan West Continued Operations (MP08_0184-Mod-8).

I find it very disturbing that once again the community is being asked to make comment on a supposed modification project that is in effect a new planned activity in terms of its environmental and social impacts. A new activity that doesn’t even seem to have a final mine plan!

It should be considered as a new project, with full supporting documentation, to ensure rigorous planning and environmental assessment of a project, including by independent mining experts. Existing coal mines just can’t continue to “tack” on new bits of activity as if the increased environmental impacts and cumulative impacts of more greenhouse gas pollution from coal extraction are irrelevant.

Cumulative pollution impacts do matter especially to those currently too young to comment on these incessant expansion projects but will be forced to live with the continuing devastating impacts of a changing climate in 2041 and beyond.

It seems ludicrous that rehabilitation of past open cut mining activity can be “adaptively reused” as a proposed tailings dam for this project – a tailings dam located next to a river that runs through a national park! It begs the question of whether there will be any proper closure of any coal mining activity in the Hunter if further disturbance can occur via modifications.

What are legislated conditions of consent meant to control if they can be “modified” in a subsequent proposal at a later date?

This project is especially concerning given its potential impact on the Murray Darling Basin – Australia’s largest waterway system where a third of our food is produced and 40% of our farms are located.

Coal mining is a thirsty land use activity on a continent that is often devastatingly dry. Coal mining is also polluting, and the last thing western NSW needs is more salt from poorly controlled mining activity.

Groundwater flows and their connection with surface water flows within the Macquarie catchment are very complex. Groundwater dependent ecosystems rely on these connections especially during drought. It is unclear from the separate surface and groundwater supporting reports whether this complex connectivity has been fully considered by the applicant.

Further, the groundwater impact assessment report does not appear to take a comprehensive cumulative approach to the impacts on groundwater from all coal mining activity within the catchment. This cumulative impact needs to be rigorously assessed and considered.

Also, I am not confident that two consecutive days of sampling at the end of Summer is adequate assessment of the impact on stygofauna within local groundwater systems affected by coal mining activity. Results seem limited. Stygofauna are critical to groundwater health and nutrient cycling.

Overall, it is not in the public interest to approve yet another modification to the Ulan Coal Complex and I urge that it be rejected.

Yours sincerely
Cathy Merchant

Key Reasons for Refusal of Ulan Coal Mine Mod 8
1. Excessive Additional Greenhouse Gas (GHG) Emissions

The project would release a very large quantity of additional GHG emissions (your earlier figure of >105 Mt CO₂-e already places it among the higher-impact proposals).

Approval would be inconsistent with:

NSW Climate Change (Net Zero) targets

Commonwealth 43% by 2030 emissions reduction target

International climate commitments under the Paris Agreement

Scope 1 and 2 emissions from underground coal mines, especially methane leakage, are a major contributor to Australia’s fugitive emissions inventory.

No credible demonstration that the mine can mitigate methane beyond business-as-usual levels—methane monitoring and reporting at Ulan has historically been incomplete or underestimated.

The NSW IPC and Land & Environment Court have both ruled (in cases like Rocky Hill and Bylong) that climate impacts alone can justify refusal of coal expansions.

2. Poor Monitoring, Reporting, and Control of Methane Emissions

Evidence from previous reviews shows inadequate measurement of methane using outdated monitoring points and low-frequency sampling.

Fugitive methane from longwall mining is often 10–20 times higher than modelled due to poor capture.

Without accurate measurement, claims of “net impact” or “mitigation effectiveness” cannot be relied on.

This raises compliance concerns under:

Mining Act

Protection of the Environment Operations Act (POEO Act)

National Greenhouse & Energy Reporting (NGER) Scheme

3. Project Extends Beyond Approved Mining Boundary — Should Trigger a New Project Assessment

Mod 8 proposes mining and infrastructure outside the existing approved mine footprint.

Under NSW planning law and recent IPC precedents, significant new disturbance areas cannot be treated as a modification.

The modification pathway (s4.55) is not intended for major expansions or new impacts of this scale.

Treating Mod 8 as a minor change undermines transparency, denies the public proper participation, and risks:

Inadequate cumulative impact assessment

Incomplete biodiversity offset requirements

Insufficient surface-water and groundwater modelling

4. Risk of Contamination from a Large New Tailings Dam (≈132 ha)

The proposal includes a large new tailings storage facility built inside a rehabilitated former open-cut pit adjacent to the Goulburn River.

Risks include:

Seepage of saline, metal-laden or toxic contaminants into the alluvium or river

Structural stability issues due to the tailings dam being placed on partially rehabilitated substrates

Long-term legacy impacts that remain after mine closure

Tailings storage failures are a major global mining risk, and a facility of this scale so close to a river system should require the highest level of scrutiny.

No robust demonstration of:

Liner performance

Long-term seepage modelling

Adequate monitoring bores

Long-term rehabilitation strategy

5. Impacts on the Goulburn River and Regional Water Resources

Ulan already operates in a water-stressed catchment.

Mod 8 may cause:

Increased drawdown of groundwater

Potential impacts on Goulburn River flows

Reduced water availability for ecosystems and downstream users

NSW Water legislation requires strong justification for additional water take, which has not been met.

6. Biodiversity Impacts and Habitat Disturbance

New disturbance areas will clear habitat for threatened species, including:

Regent Honeyeater (regional records)

Box Gum Woodland ecological community

Cumulative habitat loss in the western coalfields is already severe, and offsets are unlikely to deliver genuine “no net loss”.

7. Cultural Heritage Concerns

The extension affects landscapes used by Wiradjuri people and may impact:

Scarred trees

Cultural sites

Songlines across the Goulburn River Valley

Consultation has been insufficient and does not meet best-practice free, prior and informed consent standards.

8. Dust, Noise, and Social Impacts on Nearby Communities

Increased longwall operations will prolong:

Noise pollution

Dust emissions (PM10 and PM2.5)

Traffic movements

Village communities such as Ulan and Mudgee have raised ongoing health and lifestyle concerns.

9. Inadequate Justification for Economic Benefit

Most jobs are not new but extensions of existing employment.

The economic assessment does not properly account for:

Climate-related costs

Water externalities

Land rehabilitation liabilities

Global coal markets are declining; long-term demand assumptions are overly optimistic.

10. Inconsistent with Strategic Planning and Energy Transition

NSW’s Strategic Statement on Coal (2020) emphasises a transition away from thermal coal.

Mod 8 delays regional diversification and risks creating stranded assets.

Robert McLaughlin
0405555901

Bathurst Community Climate Action Network (BCCAN) is a network of organisations and individuals working together to promote action on climate change and sustainable and equitable development. BCCAN has about 45 members and a mailing list of a further 250. BCCAN is an active participant in public discussions about environmental policy in the Central West of NSW, addressing environmental issues both locally and in the wider area.
We oppose the Glencore Ulan ‘Modification 8’ application on many grounds.
It is imperative that we cease coal mining to do our best to maintain a liveable and safe climate. Mining 43 Mt of coal would certainly add a significant amount of greenhouse gas (GHG) emissions to the atmosphere, contributing to growth in instabilities in the climate both in the region where it is extracted and worldwide.
As flagged by the NSW Net Zero Commission in correspondence to the state planning department in September 2025, it considers scope 3 emissions to be “an important factor in addressing climate change locally and globally, particularly for sectors like coal mining”.
We welcome the 14 November 2025 NSW Land and Environment Court ruling¹ which acknowledged the direct causal link between the extraction of coal in NSW and climate harms suffered by locals. In this ruling, it cancelled the Ulan Modification 6 approval, incidentally rendering the ‘Modification 8’ proposal unfeasible.
Since the NSW Land and Environment Court has established that climate change must be a mandatory consideration, for which it also rejected the Mount Pleasant coal mining application in July, this Modification 8 expansion must also be rejected.
Apart from the defining climate change grounds for rejection of this application, there are multiple other concerns.
As Glencore Ulan ‘Modification 8’ applies to mine a new area, not an extension, it should be designated as a new project requiring a full independent merit assessment. The process of applying for modifications is inappropriate, as it aims for approval of a huge amount of coal mining over many years of continuous modification applications for the three local mines.
The cumulative impact of the Ulan, Wilpinjong and Moolarben mines, which are side by side, needs to be fully assessed. In addition to the GHG emissions, the three mines are permitted to release discharges into the Goulburn River. This Modification 8 Ulan mine expansion would be expected to add another 7 tonnes of salt per day into the Goulburn /Hunter River ecosystem, which is an unacceptable additional load. Huge salt and other discharges, continuously for years, must have impacts. The piecemeal approach of seeking approval to ‘modifications’ prevents assessment of the overall cumulative impacts.
As the authority responsible to decide to allow such great environmental consequences, this is a salutary consideration and should ring alarm bells.
Damage to sandstone formations and natural water absorption:
The applicant’s paperwork notes, ‘as a guide’: ‘Perceptible cracking and shear displacement on up to 50-70% of the length of sandstone outcrops directly above and within the subsidence affectation area. Tensile cracking or shear movements disturb the aesthetics of the rock formations, potentially causing minor dislocation of rock material and reducing the stability of overhangs and steep slopes.’
And: ‘On average, rock falls occur on up to 20% of the length of sandstone formations located directly over longwall panels and inter-panel chain pillars. In areas where sandstone formations are unfavourably oriented with respect to mining direction, this proportion may be locally increased.’
This area is home to several bat species, which rely on suitable sandstone cliff formations for roosting and raising their young. Naturally there are limited places where this exists in tandem with suitable feeding habitat, and any loss will be sorely missed and irreplaceable. Such impacts are already being inflicted locally by mining. Again, we understand that this aspect has never been cumulatively assessed across the 3 large, adjoining mine sites.
From Modification Report Final October 2025: ‘Above the proposed additional mining area, vertical subsidence is expected to be in the range of 1.7 to 2.1 m…’ This means, if we understand this correctly, that aside from some strips directly above the inter-panel chain pillars, the area above the longwalls will be lowered by at least 1.7m – a huge impact to the life on the ecosystems above them that have flourished, interdependent, for tens of thousands of years. Rough calculations from the supplied map estimate this area to be 18 km².
The Report also notes: ‘Impacts to the general landform are predicted to be mainly in the form of cracking and distortions which are expected to be repairable.’
Members of BCCAN have seen some extensive cracks due to mining in the Gardens of Stone State Conservation Area, which were certainly not repairable – the cracks were metres long and appeared to be deep. Nothing could be done to repair these, nor reverse the ongoing situation where rain water, by disappearing down the cracks, is lost to the surface ecology, thus contributing to drying out the landscape, impacting the web of life there, and allowing bushfires to burn where none have previously. In other words, this cracking would imperil the capacity of the whole existing ecosystem to survive and thrive.
Combined impacts on fauna and flora:
Quoted the applicant’s submission: ‘Drilling will continue to be undertaken … to obtain further information regarding the resources to be mined, and to define geological and geotechnical information relevant to the mining and construction activities. UCMPL undertakes exploration and prospecting activities across approved lease and licence areas for the purposes of geotechnical, geological and hydro geological investigations…. Additional drilling to install groundwater and gas monitoring bores may also be required. Construction, sealing and decommissioning of boreholes will be undertaken…. Drilling for exploration and installation of groundwater monitoring equipment will be undertaken.’
Mining is planned to continue 24/7. Due to these many instances of drilling noted above, the combination of subsidence, continuous accompanying noise from ventilation shafts, vibrations and cliff collapses will create disturbance and stress to the fauna. The effect on owls and bats is particularly concerning.
Loss of water flows to inland rivers: If this ’Modification 8’ is approved, we lament the loss of another 26.5 ML of inflow into the Talbragar River, anticipated due to this mine. Water flows west of the Great Dividing Range are lower per hectare of catchment, and support farmlands and ecosystems of greater extent than those east of the Divide; therefore, any loss of flows is important.
Should this ‘modification’ be approved, we ask that the following conditions be made.
Concerning the planned new tailings dam: In Ulan West Continued Operations Modification - Modification Report Final October 2025, 3.6.5, Tailings and Reject Storage, does not, as far as we can see, discuss the geology being watertight below the proposed new tailings dam. We ask that this be thoroughly checked, and if in any doubt, require that the tailings dam be lined so as to prevent any leakage. We note:
“… tailings often contain potentially hazardous contaminants. A priority for a reasonable and responsible mining organization must be to proactively isolate the tailings so as to forestall them from entering groundwaters, rivers, lakes and the wind. There is ample evidence that, should such tailings enter these environments they may contaminate food chains and drinking water.
It is ... accepted practice for tailings to be stored in isolated impoundments under water and behind dams. However, these dams frequently fail, releasing enormous quantities of tailings into river catchments. These accidents pose a serious threat to animal and human health and are of concern for extractive industries and the wider community.” ²
BCCAN members strongly oppose ‘Ulan Modification 8’ and urge the Department of Planning to reject it.

References:
¹ Sydney Morning Herald, ‘Courts turn on coal mines over climate impacts,’ November 15, 2025.
² https://www.sciencedirect.com/science/article/abs/pii/S0883292714002212 ‘Mine tailings dams: Characteristics, failure, environmental impacts, and remediation,’ Applied Geochemistry Volume 51, December 2014, Pages 229-245.

Key Reasons for Refusal of Ulan Coal Mine Mod 8
1. Excessive Additional Greenhouse Gas (GHG) Emissions

The project would release a very large quantity of additional GHG emissions (your earlier figure of >105 Mt CO₂-e already places it among the higher-impact proposals).

Approval would be inconsistent with:

NSW Climate Change (Net Zero) targets

Commonwealth 43% by 2030 emissions reduction target

International climate commitments under the Paris Agreement

Scope 1 and 2 emissions from underground coal mines, especially methane leakage, are a major contributor to Australia’s fugitive emissions inventory.

No credible demonstration that the mine can mitigate methane beyond business-as-usual levels—methane monitoring and reporting at Ulan has historically been incomplete or underestimated.

The NSW IPC and Land & Environment Court have both ruled (in cases like Rocky Hill and Bylong) that climate impacts alone can justify refusal of coal expansions.

2. Poor Monitoring, Reporting, and Control of Methane Emissions

Evidence from previous reviews shows inadequate measurement of methane using outdated monitoring points and low-frequency sampling.

Fugitive methane from longwall mining is often 10–20 times higher than modelled due to poor capture.

Without accurate measurement, claims of “net impact” or “mitigation effectiveness” cannot be relied on.

This raises compliance concerns under:

Mining Act

Protection of the Environment Operations Act (POEO Act)

National Greenhouse & Energy Reporting (NGER) Scheme

3. Project Extends Beyond Approved Mining Boundary — Should Trigger a New Project Assessment

Mod 8 proposes mining and infrastructure outside the existing approved mine footprint.

Under NSW planning law and recent IPC precedents, significant new disturbance areas cannot be treated as a modification.

The modification pathway (s4.55) is not intended for major expansions or new impacts of this scale.

Treating Mod 8 as a minor change undermines transparency, denies the public proper participation, and risks:

Inadequate cumulative impact assessment

Incomplete biodiversity offset requirements

Insufficient surface-water and groundwater modelling

4. Risk of Contamination from a Large New Tailings Dam (≈132 ha)

The proposal includes a large new tailings storage facility built inside a rehabilitated former open-cut pit adjacent to the Goulburn River.

Risks include:

Seepage of saline, metal-laden or toxic contaminants into the alluvium or river

Structural stability issues due to the tailings dam being placed on partially rehabilitated substrates

Long-term legacy impacts that remain after mine closure

Tailings storage failures are a major global mining risk, and a facility of this scale so close to a river system should require the highest level of scrutiny.

No robust demonstration of:

Liner performance

Long-term seepage modelling

Adequate monitoring bores

Long-term rehabilitation strategy

5. Impacts on the Goulburn River and Regional Water Resources

Ulan already operates in a water-stressed catchment.

Mod 8 may cause:

Increased drawdown of groundwater

Potential impacts on Goulburn River flows

Reduced water availability for ecosystems and downstream users

NSW Water legislation requires strong justification for additional water take, which has not been met.

6. Biodiversity Impacts and Habitat Disturbance

New disturbance areas will clear habitat for threatened species, including:

Regent Honeyeater (regional records)

Box Gum Woodland ecological community

Cumulative habitat loss in the western coalfields is already severe, and offsets are unlikely to deliver genuine “no net loss”.

7. Cultural Heritage Concerns

The extension affects landscapes used by Wiradjuri people and may impact:

Scarred trees

Cultural sites

Songlines across the Goulburn River Valley

Consultation has been insufficient and does not meet best-practice free, prior and informed consent standards.

8. Dust, Noise, and Social Impacts on Nearby Communities

Increased longwall operations will prolong:

Noise pollution

Dust emissions (PM10 and PM2.5)

Traffic movements

Village communities such as Ulan and Mudgee have raised ongoing health and lifestyle concerns.

9. Inadequate Justification for Economic Benefit

Most jobs are not new but extensions of existing employment.

The economic assessment does not properly account for:

Climate-related costs

Water externalities

Land rehabilitation liabilities

Global coal markets are declining; long-term demand assumptions are overly optimistic.

10. Inconsistent with Strategic Planning and Energy Transition

NSW’s Strategic Statement on Coal (2020) emphasises a transition away from thermal coal.

Mod 8 delays regional diversification and risks creating stranded assets.
AnneMaree McLaughlin

I am a mother and a grandmother of ten beautiful grandchildren, and it is my duty to care for them all in every way I can and first of all they must have a liveable climate. Planet earth is warming exponentially and carbon emissions from extracting and burning fossil fuels are responsible for accelerating this increase in temperature and instability of the climate. Australia is particularly vulnerable to the increasing regularity and severity of damaging droughts, floods and bushfires happening over recent years. I am therefore writing this submission to state that NSW must not approve further expansion of fossil fuel mining.

Today South Korea announced it is phasing out coal fired power production which will drastically reduce coal imports, it is a sign of things to come. Now is the right time for NSW to stop approving new mines to continue mining for many years in the future.

The time has come to transition the work force into new cleaner jobs and focus on rehabilitation of existing mine sites. The mining companies have made enormous profits; it is their responsibility to rehabilitate what they have destroyed. Prior to mining, the Wollar area was a most beautiful valley with fresh clear air, farms, wineries, and horse properties nearby. Now the valley is just an eyesore with noisy, dirty, dusty mining machinery operating 24hrs per day, punctuated by frequent blasting and dust clouds with trucks and bulldozers shirting coal to stockpiles and on to the processing area where it is loaded onto long coal trains. Copious quantities of water are wasted trying to keep the dust down, especially disturbing in times of drought. A far cry from the beautiful, quiet, and peaceful valley it one was and can become once again.

Now is the right time. The NSW Government has prioritised the Central West Future Jobs and Investment Authority to manage the transition away from coal mining. The Mudgee region has many opportunities to diversify the economy. The coal industry has been heavily subsidised by the government for many years; this money can now be devoted to assisting the local community to come alive again. The area has many valued tourist attractions which can be enhanced by thoughtful creative and careful rehabilitation. The mining companies must be required to do this in consultation with government, local government, and communities to produce once again a thriving rural community. The many rail lines can be developed into cycle and walking tracks - an increasingly popular holiday choice these days - which would encourage growth of cafes and restaurants and various types of accommodation from camping to small hotel/motels. The whole valley will be alive again.

The Glencore Ulan coal mine currently has approval to mine to 2033. ULAN Mod 6 seeking to extend until 2035 has just been overturned. Ulan Mod 8 depends on Mod 6 and therefore has no basis to proceed. It is completely unacceptable that it should be seeking approval for Mod 8 to mine up to 2041 anyway. It should just be rejected.

Should this Mod 8 approval be considered worthy of detailed examination there are several serious objections. So many effects of mining in the area have not been properly assessed.

Carbon emissions:
Over 105Mt of additional greenhouse Gas emissions would be added … unacceptable especially as existing emissions are poorly monitored.

Outside existing mine boundary – should be assessed as a separate project
Additional infrastructure disturbance needs environmental impact study

Construction of new tailings dam within a revegetated, rehabilitated old open cut pit next to the Goulburn River
Unacceptable risk of toxic leakage

Within Murray Darling basin leading to Macquarie Marshes
Subsidence or land collapse due to underground mining damages groundwater systems and storage areas. Groundwater flows to rivers and this mining will likely deplete flows into the Talbragar River, a major tributary of the Macquarie River.

Also impact Goulburn River causing additional loss of base flow
– cumulative impact of three large coal mines needs assessment. Water is such a critical necessity.

Mod 8 will impact an additional 71 recorded Aboriginal cultural heritage sites

Biodiversity impacts need consideration
Fragile sandstone landscape including 6.5km of escarpment with rocky outcrops and cliff lines higher than 10m provide important habitat for endangered bat species which cannot be offset. Cumulative loss of irreplaceable microbat habitat and loss of mature healthy Box Gum Woodland CEEC through mining activity is also needed – this ecosystem provides important habitat for a range of threatened animal and bird species including koala, Regent honeyeater, barking and Powerful owls.

Final mine plan not finalised – final plan should be submitted for consideration

Social Impacts
The proposal will impact 17 private properties, directly under-mining 4 houses and lowering water availability in 6 private bores including total dewatering of one. The mitigation measure of providing replacement water will not continue after mining is finished. The Ulan Mine has bought out many properties over time because of severe impacts of subsidence and noise from ventilator fans. This diminishes the local community and removes neighbourhood support in a remote rural area.

In conclusion, now is the right time to reject Mod 8 and prioritise rehabilitation. The many and various impacts outlined above simply strengthen my plea to reject this project. Much of the likely damage would be very difficult to repair, it would be criminal to allow further damage at this time when mine expansion must be halted, biodiversity, liveability, repair, and future generations be given top priority.

We look forward to seeing the beautiful Wollar valley begin to reappear.

I eagerly await your decision to reject this Mod 8 project.

Thank you

Angela C Burrows.

Main issue due to its locations its not just a modification its a major expansion pretending to be a modification.
Also due to world Temperatures already 1.5 degrees above pre-industrial area, and risk of positive feedbacks such as reduced albedo due to reduction in Antarctic and Artic ice, we need to stop approving new coal, or gas mines, and stop approving new oil fields.

Other key concerns with the Ulan Mod 8 expansion:
Extends Mining: Six-year extension to mine an additional 43 million tonnes of coal. Will not help with Federal Governments goal of netzero by 2050, in fact make it much harder to achieve. Because it will add massive emissions, 105 million tonnes of CO2-e, a
45% increase.

Spans Major Catchments: Operations impact both the Hunter and Murray-Darling basins, threatening water security.

Risky Tailings Dam: Expands toxic waste storage near a river, risking seepage downstream into a national park.

Habitat & Species Loss: Clears 100+ hectares of native vegetation, including 34ha of Box Gum Woodland, impacting threatened species like the Regent Honeyeater and Koala. This loss of native vegetation will add more carbon emissions for the project, a time when we need to stop all unnecessary logging of native forests and/or trees, to help with native flora/fauna and manage increasing temperatures due to climate change.

Cultural Heritage Risk: Impacts 71 Aboriginal sites on Wiradjuri Country under a Native Title claim. Unclear if this has been properly assessed.

Lack of community scrutiny many people don't know about this , application, and would think this is a flawed Process with it being Assessed as a "modification" to avoid community scrutiny, instead as a major expansion, as it should be. Majority of people would be against this project.

Also 7 out of 9 Planetary boundaries have been breached, according to the 2025 planetary health check. Approving or expanding new coal mines such as Ulan Coal Mine Mod 8 – Ulan West Continued Operations will only exacerbate the climate crisis, and lead to more frequent and severe bushfire and flooding s in Australia, and the world.

Working a cardiac registered nurse, I'm also concerned about the health impacts increasing climate change, causing more severe and frequent heat waves, can have on people health, especially increased risk of heart attacks, heatstroke, infectious diseases such as dengue fever spreading southward etc. This project if approved will only make climate change worse, when we should stop expanding old coal mines or approving new coal mines.

As a resident of the Mid Western Regional Council, I strongly object to Modification 8 on the following grounds:

It is well past time that Australia stopped fossil fuels mining, if we are honest about our contribution to global warming and profiting by it. I am happy that Modification 6 was rejected and as Modification 8 was contingent on Modification 6’s approval, I suggest that it is disingenuous for the department of planning to even be considering Mod 8.

Shame on NSW Government.

Sincerely yours,
Janet Walk

Objection to Proposal
Ulan Coal Mine Mod 8 – Ulan West Continued Operations
Background
The Glencore Ulan Coal Mine has approval to mine 20 Mt/year thermal coal to August 2035. It is a wholly underground longwall mining operation disturbing over 120 km2 of farmland and bushland with high biodiversity values. Ulan Mine crosses under the Great Dividing Range intercepting water from the Murray-Darling Basin and the Hunter catchment.
The Mod 8 application is to mine a further 43 Mt up to 2041. Ulan Coal Mine falls within the Central West Orana Renewable Energy Zone (CWOREZ). There must be no more expansion of coal mining to maintain a safe climate.
Accordingly, I hereby formally object to this proposal, which I am convinced must be refused for a variety of reasons which I briefly summarise in the following points:

1. This is not substantially the same project as that previously approved.
The proposed extension should not be assessed as being simply a modification, because it is not substantially the same as the current Mine approval, as it:
• Falls entirely outside the current mining lease.
• Introduces new infrastructure e.g. new 132 ha tailings disposal area, additional ventilators, tracks.
• Impacts an additional 1,734 ha landscape.
• Increases impacts on groundwater, creeks, and rivers.
• Destroys irreplaceable endangered species habitat.
• Causes additional biodiversity impacts under Federal environmental law.
• Destroys a new area of Aboriginal cultural heritage significance.
• Directly impacts 17 private properties, threatens built structures and private bores.
• Releases 105 Mt additional greenhouse gas emissions .
• The project is an extension of the recently approved Ulan Mod 6 that is under legal appeal.

2. Methane monitoring – Scope 1 emissions
Glencore does not report methane emissions and altered the baseline calculation for annual CO2 -e emissions in 2014 to below requirement for offsets under the Federal Safeguard Mechanism, with no explanation.

3. Water Impacts
Subsidence or land collapse caused by underground mining damages groundwater systems that store water in the landscape.
Groundwater provides base flows to rivers and creeks. This mine expansion will cause a predicted additional loss of 26.5 million litres per year of flow to Talbragar River – does not report cumulative loss of flows from current approvals. The Talbragar River is a major tributary of the Macquarie River in the Murray Darling Basin that flows in below Burrendong Dam.
These flows directly connect to the internationally significant Macquarie Marshes.
The Goulburn River will also be impacted by additional loss of base flow. Most importantly, it will add another six years of mine water discharge carrying over 15,000 tonnes of salt (7 tonnes per day) into the Goulburn /Hunter River ecosystem. The cumulative impact of the three large coal mines on the Goulburn River has never been fully assessed.

4. Aboriginal cultural heritage impacts
The cumulative loss of significant Aboriginal cultural heritage in the Ulan area is not assessed. There is ample evidence of continuous Wiradjuri occupation of the region with spiritual connection to country. Ulan Mod 8 will impact an additional 71 recorded sites.

5. Biodiversity impacts
The proposed extension of mine disturbance will impact areas of fragile sandstone landscape including 6.5 kms of escarpment with rocky outcrops and cliff lines higher than 10m. These provide important habitat for the endangered Large-eared Pied Bat and Eastern Cave Bat. This habitat loss cannot be offset. The cumulative loss of irreplaceable microbat habitat across the three adjacent mines is not assessed.
The cumulative loss of mature, healthy Box Gum Woodland CEEC in the region through mine clearing has not been assessed. This ecosystem provides important habitat for a range of threatened woodland animal species.
Regent Honeyeater: The ongoing loss of important habitat for the critically endangered Regent Honeyeater is not recognised or assessed. There are current records of breeding activity in the district that are not identified in the assessment report.
Koala: ongoing disturbance of Koala habitat from mining is not assessed
The area of impact provides habitat for the threatened Barking Owl and Powerful Owl

6. Final Mine Plan still to be provided
The final placement of infrastructure in the landscape has not yet been provided because of ongoing negotiations with private landholders. This issue should have been resolved before the proposal was lodged and accepted by the Department of Planning. A final mine plan should be submitted for consideration.

7. Social impacts
The proposal will impact 17 private properties, directly under-mining 4 houses and lowering water availability in 6 private bores including total dewatering of one. The mitigation measure of providing replacement water will not continue after mining is finished. The Ulan Mine has bought out a large number of properties over time because of severe impacts of subsidence and noise from ventilator fans. This diminishes the local community and removes neighbourhood support in a remote rural area.
8. Claim that mine of major benefit for local employment is Not Justified
There is no need for extended coal mining in the region to provide local jobs. Mining is competing for skilled labour urgently required in the construction, housing and renewable energy industries. There is a major labour shortage in the Central West with local workers needed for the CWO REZ construction.
The NSW Government has prioritised the Central West Future Jobs and Investment Authority to manage the transition away from coal mining. The Mudgee region has many opportunities to diversify the economy

Recommendation: That this proposal is unacceptable and must be refused.
Rupert Macgregor
18 November 2025.

To whom it may concern,
My name is G and I live in Northmead, NSW. I wrote previously regarding the now-rejected Mod 6 proposal, which was a very heartening outcome. Following this, I believe Mod 8 is no longer possible, but am writing in just in case.
I’m originally from Adelaide but moved to Sydney in 2020, just after the massive summer bushfires. I moved to Sydney in search of community, employment opportunities, and seeing more of Australia. In my time since moving, I’ve lived here through pandemic lockdowns, flooding, more fires, water pollution, and more. I’ve become increasingly concerned about the impact of climate change on my home here. I see how hot Western Sydney gets compared to the Sydney CBD, and when I chat to my neighbours, I hear them expressing the same concerns. I know people around me plan to move up the coast because they can’t cope with the increasing heat and I worry how those who can’t leave will fare.
As such, I strongly oppose this planned coal mining extension, as I did with the previous Mod 6 extension proposal. Coal mining is a massive greenhouse gas emitter and creates huge amounts of pollution, impacting local communities and biodiversity. I recently visited the town of Wollar to talk to locals about the impact the existing mines have had on their community and it is shocking to me that further expansion is planned. Locals expressed to me how their population had shrunk to due noise, air, and light pollution, and how none of the promised economic boons had eventuated.
I also walked the track to the Drip, and could not believe the plans for mines to come within 500m of such a beautiful and fragile rock formation. During my short walk around there, I saw so many birds, heard frogs, stepped over insects, surprised an echidna, and spotted a lace monitor. All of this would be destroyed by mining coal so close to this habitat. The local and worldwide impact of our coal mines should be diminished, not increased.
In order to protect Wollar and the surrounding communities, including the environment, I have the following asks:
1. Reject this proposal
2. Protect Wollar Village – mining should not be allowed to extend to village boundaries.
3. Stop further destruction of Aboriginal cultural heritage – these extensions risk destroying additional sites significant to the Wiradjuri Nation.
4. Defend critical wildlife habitat – the project threatens endangered species including the Large-eared Pied Bat, Eastern Cave Bat, Regent Honeyeater, and Koala.
5. Protect local water systems – the mine will cause groundwater drawdown of over 20m and reduce creek flows by 21 million litres per year.
6. Prioritise the clean energy transition – Wollar is the gateway to the Central West Renewable Energy Zone. Coal expansion here slows NSW’s transition and competes for workers needed in renewables.
7. Reject unjustified climate and economic impacts – the extra emissions far outweigh any local economic benefit.
Thank you for reading my submission. I truly hope this proposal does not get approved, having witnessed firsthand the severe negative impacts of these coal mines.

FORMAL SUBMISSION: STRONG OBJECTION TO ULAN COAL COMPLEX MODIFICATION 8 – ULAN WEST CONTINUED OPERATIONS PROJECT (MP08_0184-Mod-8)

To: The Secretary, Planning and Environment, NSW Department of Planning and Environment Date: November 17, 2025 Project: Ulan Coal Complex Modification 8 – Ulan West Continued Operations Project (MP08_0184-Mod-8)
I submit this strong objection to the proposed Modification 8 (Mod 8) for the Ulan Coal Complex – Ulan West Continued Operations Project. This proposal, which seeks to extract an additional 38 million tonnes (Mt) of thermal coal and extend operations until 2041, is fundamentally incompatible with the public interest, current scientific consensus, and the State’s legislated climate and environmental protection obligations. The short-term private benefit of this extension is vastly outweighed by the irreversible, long-term environmental, water, and climate costs.
The Escalating Economic and Social Burden of Climate Change in Australia
The central focus of this analysis is that climate change has fundamentally shifted Australia's economic and social baseline, moving from managing isolated, predictable natural hazards to confronting a rapid sequence of interconnected, catastrophic events. This shift, exemplified by the 2019–2024 period (drought, Black Summer bushfires, East Coast floods), has transformed climate risk into Australia's single greatest accelerating fiscal liability.
1. Defining the Total Economic Cost (TEC)
The most critical element of the analysis is the adoption of the Total Economic Cost (TEC) approach. This framework argues that traditional methods, which only count direct, market-priced losses (e.g., repairing infrastructure or insured property damage), severely underestimate the true financial burden, potentially by more than 50%.
The TEC framework integrates the intangible costs which represent the deepest long-term liabilities:
• Mental Health and Public Health System Strain: The immense, long-term psychological burden of continuous disaster.
• Long-term Human Capital Loss: The deterioration of educational outcomes and productivity for affected youth.
• Loss of Regional Resilience: The amplified cost when disasters occur sequentially, giving communities no time or resources to recover between events.
This comprehensive view puts the current annual cost to the Australian economy at $38 billion, projected to escalate dramatically to at least $73 billion per year by 2060.
2. Immediate Fiscal and Infrastructure Costs in NSW
New South Wales (NSW) is highlighted as being at the sharp end of this fiscal impact, with specific, large-scale costs already incurred and massive increases projected.
Cost Driver Specific NSW Impact Financial Magnitude
Bushfires (2019–20) The catastrophic Black Summer event. Estimated $6.4 billion (with some models suggesting up to $100 billion).
Flooding (Annual) Damage to property, infrastructure, and agriculture. $250 million in an average year.
Projected Escalation Total average annual cost of climate change for the state. Predicted to rise by over $10 billion annually in the coming decades.
Infrastructure Damage Severe damage to transport/water networks (e.g., Lismore floods). Lismore LGA alone estimated $350 million in damage to Council assets, with $150–200 million for roads/bridges.
Crucially, the government’s existing policy exacerbates future costs: only 3% of disaster funding is invested in risk mitigation and resilience building, while 97% is spent reactively on recovery. This reactive spending bias ensures that the projected $73 billion national annual threshold will likely be reached faster.
3. The Long-Term Erosion of Human Capital (Intergenerational Costs)
The analysis identifies the damage to Children and Young People (CYP) as the single most profound long-term economic liability. The cumulative cost imposed on this cohort is projected to exceed $100 billion by 2060.
The trauma's economic focus is not the immediate emotional distress but the long-term impact on productivity:
1. Lost Education and Earnings: This is the largest single component, estimated at $5.3 billion in annual lifetime costs due to reduced Year 12 completion rates and subsequent loss of potential workforce earnings.
2. Mental Health and Social Costs: Immediate mental health expenses for CYP are estimated at $662 million annually, alongside $192 million from increased incidence of child abuse.
The fact that the lost earnings cost is eight times larger than the immediate mental health expense demonstrates that the primary economic liability is the long-term deterioration of workforce skills and national productivity.
4. Systemic Financial Risk and the Affordability Crisis
The escalating severity of climate events has led to the commercial failure of the private insurance market to manage the risk, pushing the burden onto the government (sovereign fiscal liability).
• Unsustainable Losses: Insured catastrophe losses hit a record $7 billion in 2022. Since 2013, losses in any single year have exceeded the combined losses of the entire 2000–2004 period, showing the systemic change has outpaced historical models.
• Inflationary Driver: The rapid repricing of risk has caused home insurance premiums to rise by 14% (2022–2023), increasing up to five times faster than the CPI. This makes climate change a non-discretionary inflationary mechanism in the economy.
• Social Affordability Crisis: This repricing is creating a severe social crisis where nearly one in eight Australian households (1.25 million people) suffer from home insurance affordability stress. As the private market prices these households out, the residual cost of rebuilding uninsured properties transfers directly back to the government during subsequent disasters.
Conclusion
In summary, the document establishes that the cost of climate change is not merely an expense, but a rapidly accelerating structural threat to Australia's economy, fiscal stability, public health, and human capital. It mandates an immediate, structural pivot from reactive recovery spending to proactive mitigation and adaptation investment, especially in resilient infrastructure and social services. The analysis concludes by using this economic rationale to argue against new coal mining extensions in NSW.