12th February, 2026

To Senator Murray Watt, Minister for the Environment and Water,

I welcome the opportunity to comment on the EPBC referral of Glencore’s Hail Creek Coal Eastern Margin Extension Project (EPBC 2025/10403). I urge you to find this project ‘clearly unacceptable’ due to its contribution to climate change and its impacts on water resources. 

Below, I outline why it is ‘clearly unacceptable’ on each of the following grounds;

The project should be determined ‘clearly unacceptable’ in relation to the following matters of national environmental significance under the EPBC Act:

• Climate accountability and legal action, noting the International Court of Justice (ICJ) Advisory Opinion, which emphasises that states, including Australia, have obligations to protect the climate system and may be held liable for harm caused to Pacific nations.
• A water resource in relation to unconventional gas and large coal mining developments (ss 24D, 24E), due to groundwater drawdown and pollution of surface water from runoff.
• World Heritage properties (ss 12, 15A), due to pollution entering the Great Barrier Reef catchment and greenhouse gas emissions from the project contributing to climate change impacts on World Heritage properties, including the Great Barrier Reef.

Justice and accountability to the Pacific

Australia will lead pre-COP negotiations with a Pacific partnership, focusing on Pacific priorities, later this year. Yet this relationship cannot be genuine while Australia continues to fuel the climate crisis.

As one of the largest exporters of fossil fuels, and a major beneficiary of historical fossil fuel use, Australia must rise to its responsibility to lead on climate action now and support other countries to enable their energy transition and adaptive capacity as they navigate living in a climate crisis.

The government describes Australia as ‘part of the Pacific family’ and ‘a neighbour to the Pacific’, while still backing coal, oil and gas—the key drivers of the region’s greatest existential threat. To gain Pacific support in this year’s pre-COP negotiations, Australia must commit to phasing out fossil fuels and demonstrate real climate leadership. 

Australia must also contribute its fair share of finance for loss and damage, and compensate countries that have not had the opportunity to develop using fossil fuels and whose development is now constrained because they are dealing with a climate crisis created largely by other nations, especially Australia.

The science has confirmed this, communities on the frontlines have called for it, and now the International Court of Justice has affirmed that Australia has obligations to protect the climate. Failure to do so could result in liability for damage caused to other states, particularly vulnerable Pacific island nations. This indicates that any ongoing approval of coal and gas projects may constitute wrongful acts under international law, potentially creating legal risks for the Australian government.

The Australian Government promised action on climate change when it was elected and must now hold itself accountable to that commitment. Allowing an extension of such a high‑emitting facility would be clearly inconsistent with Australia’s climate commitments and with the urgent need, identified by leading scientific bodies, to rapidly reduce greenhouse gas emissions this decade. 

Climate impacts

To limit global warming to below 2°C and avoid the worst impacts of climate change, no new coal mines or extensions to existing coal mines can proceed. This position has been clearly articulated by the International Energy Agency, the United Nations, the Intergovernmental Panel on Climate Change (IPCC), and the international scientific community.

Climate change, driven primarily by the mining and burning of coal, oil and gas, is the greatest threat to the environment, including matters protected under Australia’s national environmental law such as threatened species and ecological communities. Approving new coal projects is fundamentally inconsistent with the objective of protecting these matters and safeguarding a livable climate.

One of the most effective actions the Australian Government can take to protect the environment and protected matters is to stop approving new coal mines and extensions, including the Hail Creek Eastern Margin Extension.

Glencore’s existing Hail Creek coal mine has already been identified as a super-emitter of methane. Independent analysis indicates that methane pollution from this mine may be significantly under-reported and could be up to eight times higher than Glencore’s own estimates. The coal seams at Hail Creek contain very high concentrations of methane, a potent and fast-acting greenhouse gas that has a global warming impact approximately 82 times greater than carbon dioxide over a 20-year period.

A paper published in by Dutch researchers of Energy & Climate 2021 analysed two years of satellite measurements of methane from coal mines in Queensland. It concluded that Hail Creek was the biggest emitter and is estimated to emit 20% of Australia’s methane emissions from coal mining while accounting for just 1% of national coal production.The research paper found Hail Creek emitted 230,000 tonnes of methane in 2018–19. Because methane traps more than 80 times more heat than carbon dioxide in its first two decades in the atmosphere, the mine had the same short-term warming impact as roughly 19 million tonnes of CO2 a year.

This means Hail Creek could be polluting the atmosphere with around 40 million tonnes of CO2-e each year, from the combustion of the exported coal and the release of fugitive methane gas during the mining process. Hail Creek is likely to be the most polluting mine in Australia and one of the most polluting mines in the world.

Impacts on water resources, and watercourses in the Great Barrier Reef

Glencore is wrong to assert that the impact of the project on water resources will not be significant. I strongly urge you to apply the controlling provisions for a water resource in relation to unconventional gas development and large coal mining development (sections 24D and 24E), due to the impacts of groundwater drawdown and pollution of surface water from runoff.

The project should also be assessed with controlling provisions for World Heritage properties (sections 12 and 15A) and the Great Barrier Reef Marine Park (sections 24B and 24C), due to the impacts of water pollution entering the Great Barrier Reef catchment and the link between greenhouse gas pollution from the project and climate change impacts on World Heritage properties such as the Great Barrier Reef.

Hail Creek coal mine recently released 5,784 megalitres—equivalent to 2,315 Olympic swimming pools—of mine-affected water into the Great Barrier Reef catchment after flooding rains battered Central Queensland in January. The impact of such potential pollution from the extension project needs to be thoroughly assessed. 

Glencore’s Annual Groundwater Monitoring Report 2025 reported elevated levels of nutrients in mine-affected water at Hail Creek and an apparent build-up of sediment and potentially metal contamination downstream.Hail Creek is in the Great Barrier Reef catchment, yet Glencore has not fully investigated these issues, despite being requested to do so by the Queensland Government. The extension will prolong whatever operational impacts are currently occurring for another four years.

The project also proposes to divert a section of Hail Creek, which poses a long-term stability risk that could be undermined by future flooding events. This diversion proposal should be thoroughly assessed under the EPBC Act.

The proposed extension will leave three final voids, which will result in permanent drawdown of groundwater. The voids will be vulnerable to flooding, and the proposed flood protection will not provide a permanent solution. If the voids become flooded, this could lead to groundwater and surface water contamination. The contamination makes water unsafe for human consumption, agricultural irrigation, and aquatic ecosystems, further degrading local ecosystems.

The extension will bring mining even closer to the Brumby Waterholes, which are of cultural significance to the Widi Traditional Owners, as well as providing important aquatic habitat. There is still insufficient information on the groundwater regime around the lowest of the waterholes, and Glencore is resisting the installation of the additional groundwater monitoring bores required.

Impacts on water resources are permanent and irreversible. The impacts of Hail Creek will combine cumulatively with those of other mines in the Fitzroy Basin. As the increased rainfall variability driven by climate change is already putting more pressure on our water resources, we cannot afford to allow further negative impacts.

In light of the overwhelming scientific evidence, the clear guidance from international agencies, and the significant climate and environmental risks posed by this project, I respectfully submit that the Hail Creek Eastern Margin Extension should not be approved.

I hope that you will consider my strong opposition to the proposed Hail Creek Eastern Margin Extension and that you will not approve this project.

Jacynta Fa’amau

On behalf of the Pacific Climate Warriors

350.org Pacific