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In a press release, the climate group projected the shortfall between legislated targets and expected greenhouse gas pollution was 6.6 million tonnes.

That is partly due to the proposal made by Yancoal and Glencore, Hunter Valley Operations (HVO) North and South.

The Minns government announced its coal industry outlook for 2025-2050 this month, ruling out new coal mines but not expansions to existing ones including the Hunter proposal.

Emissions requirements would be a condition of any project expansions, the government has said, but the Net Zero Commission has argued any coal production expansion is contrary to meeting the targets.

Nancy Chang, chief executive of the NSW Environmental Protection Agency said the proposal was "the largest coal mining proposal ever put forward in NSW."