Wainwright and the Coal Mine

https://you.38degrees.org.uk/petitions/no-new-coal-mine-in-cumbria

This is the latest comment on an article in the Times about Wainwright and his famous Coast to Coast walk.

“I wonder what Wainwright would have made of the plan to install a massive new noisy coal yard and rail track at the start of this walk? The plan to open the first deep coal mine in the UK in decades under the sea at the beautiful St Bees Heritage Coastline is a national scandal that has gone weirdly under the radar. Not least the radar of the conservation bodies who should be up in arms about this. Instead it was nuclear safety campaigners who first raised the alarm – and continue to do so. This mine would extend to 5 miles from Sellafield, which houses the worlds biggest concentration of radioactivity. The nuclear connections don’t stop there. The CEO of the developers West Cumbria Mining has been appointed to the government body tasked with ‘delivering a geological disposal facility’. As well as the CEO of West Cumbria Mining also sitting on this Radioactive Waste Management government committee, the former Operations Director of the coal mine development is now Head of Site Selection at Radioactive Waste Management “Site Selection” for a Geological Disposal Facility (we call it a nuclear dump) may or may not be under the Irish Sea, as Egremont and Ennerdale have also been eyed up. However the truth is that Cumbria is realistically the only place in the UK that is in the frame and Copeland Council who are all in favour of this coal mine have also just opened up discussions with government about the geological dump too. Are they mad? Alfred Wainwright famously called Calder Hall an “atomic carbuncle.” That was in the halcyon days when the nuclear sprawl at Sellafield was so much smaller. There are so many reasons to stop the new coal mine next door.

PLEASE SIGN THE PETITIONhttps://you.38degrees.org.uk/petitions/no-new-coal-mine-in-cumbriaStop the Coal Mine in Cumbria

Cumbria and the Coal Mine

Many thanks to the iconic Cumbria magazine and writer Fiona Campbell for the interesting and timely article in this months issue.

The article outlines some of the history surrounding the ongoing battle to stop the coal mine and questions the shortsightedness of shoehorning such a dirty industry directly back into West Cumbria. Whitehaven and the St Bees coastline is only just recovering from the massive industrial blight of Marchon (which was known for producing soap but was actually the largest single site producer of sulphuric acid in Europenecessary to the reprocessing of nuclear spent fuel ) and the old Whitehaven Coal Industry. There is still much left to recover from!

But will this heart stoppingly beautiful coastline ever be given the time and space to recover some of its health and integrity?

Speaking to friends in Whitehaven this week they say that there are more tourists staying in the town and spending their money here.

“A ‘staycation’ on the wonderful West Cumbrian Coast would not be enhanced by noisy diesel trains transporting coal!”

Intimacy Between WCM and the “Need” for a Geological Disposal Facility (to facilitate new nuclear build there needs to be a ‘solution’ to the waste- this is it)

Sellafield to Ennerdale
Sellafield to Ennerdale – Ennerdale Granite is one of the areas in the frame for a GDF? WCM executives are in this nuclear dumping game as well as in the coal game.  (google map)

What with obsessing about “need for coking coal for steel” and emissions of carbon and methane from the proposed coal mine,  I totally missed this appointment back in November 2019.  Along with, it seems, the press and everyone else.

I wonder if the councillors would have been as keen to offer unanimous approval to embed West Cumbria Mining into the fabric of Cumbria had they been thinking about the intimate connections between WCM and the grandson of NIREX  – RWM.

Radioactive Waste Management is the government quango (previously NIREX, then MRWS) tasked with delivery of the plan for the Geological Disposal Facility for heat generating nuclear wastes.

We already knew that Steve Reece the former Operations Director of West Cumbria Mining had been appointed to the Head of Site Evaluation at Radioactive Waste Management but we were warned off flagging this up by various, focussed on climate, folks who said it would ‘cloud the issue’ of the coal mine.

So we have kept quiet about this connection for quite some time.

However – Steve Reece has now been joined in the GDF game by the CEO of West Cumbria Mining, Mark Kirkbride. Mark Kirkbride told me in front of councillors and other campaigners at the last planning meeting (where councillors again voted unanimously for the coal mine) to “Get a Conscience, Marianne!”

OK – well my conscience (or whatever) is bothering me a bit about this intimacy between WCM and the plan to “facilitate a GDF”  under a  “volunteer community.”

Of course the plan for the coal mine may not actually be to use the voids for concrete paste dispersal of “exempt” or “high volume very low level radioactive wastes”.

However, it is clear by the appointments to RWM of West Cumbria Mining executives that the expertise for deep mining to ‘dispose’ of heat generating nuclear wastes is being embedded in Cumbria.

‘Get a Conscience’ indeed.

 

Excellent letter from Dr Henry Adams on Steel without Coal.

Steel without coal – letter to Westmorland Gazette July 2020 [this version has added notes with links]

 

Two letters in the 18 June issue and others before, repeated the myth that steel cannot be made without coal, when they criticized Extinction Rebellion (XR) and other protestors against the coal mine proposed by WCM at Whitehaven. XR gained their knowledge about steel-making from investigations by people including myself, who have collated facts from the steel industry and associated research bodies, and also University researchers into the decarbonisation of the steel industry:

Natural gas has been used for years over the world as an alternative to coal to provide gas to reduce iron ore to iron using the Direct Reduced Iron process (DRI)i. Also, Electric Arc Furnaces (EAFs), which don’t needcoal, produce steel from scrap (as well as from DRI), and there is much scope for recycled steel to be of better quality if contaminants such as copper are removed beforehandii.

The steel industry is determined to decarbonise its steel-making by 2050, with for example SSAB planning to reduce its emissions in Sweden “by 25% in 2025”iii, and ArcelorMittal in Europe “by 30% by 2030”iv. Green hydrogen produced using renewable energy1 will replace coal as iron ore reducing agent in many cases, and fossil-free H-DRI plants are planned to become commercial from 2025v.

This aim is backed by the EU and governments, including the UK, and will mean significant reductions in coal use in Europe for steel-making starting around 2025, and followed by likely major drops in the 2030’s.The UK can produce most or all of its steel using EAFs well before 2050, both from UK scrap (now mostly exported) and from H-DRI (imported or otherwise), or from other non-coal methods.

WCM are thus very wrong in claiming that the big shift to coal-free steel-making won’t happen within the 50 year lifetime of the minevi. My sources can be checked here2: bit.ly/steelnews

Steel-making can and must shift away from using coal, for the UK and EU to comply with the 2015 ParisClimate Accord temperature goals, which include “pursuing efforts to limit the temperature increase to 1.50C above pre-industrial levels”. You will see from charts of global temperature change that we are likely to hit +1.5 degrees C around 2030 if not before3. This is two decades before UK’s NetZero 2050 target,meaning the latter is too late. XR already knows this, but supporters of the mine ignore these facts about climate (and steel). Thus XR is correct in its ‘Heads in Sand’ implications.

Note that any claimed “emissions savings” from shorter transport distances for the coal would only be a tiny percentage of the end-use emissions of that coal – which at 8.54 million tonnes CO2e per year would be huge and non-compliant with the Paris temperature goals.

Dr Henry Adams, Kendal

1 Electricity from renewables such as wind and solar can be used to electrolyse water to produce hydrogen. Ifproduced this way the product is ‘green hydrogen’. This converts to water in the H-DR process, with no carbonemissions. ‘Grey hydrogen’ is produced from methane with CO2 emissions; if CCS added then it is ‘blue hydrogen’.

2 The most powerful report showing that WCM is incorrect in its timeline is the MPI report commissioned by SLACCtt, and is linked to in http://www.bit.ly/steelnews (MPI = Materials Processing Institute [research part of UK steel industry]).

3 And climate scientist Joelle Gergis writes: “The scientists show that this revision now means that 2°C of global warming is likely to be reached sometime around 2040 based on our current high-emissions trajectory.”https://www.themonthly.com.au/issue/2020/july/1593525600/jo-lle-gergis/witnessing-unthinkable#mtr
(and this corresponds to 1.5 being reached around 2025 on Greg Jericho’s chart in The Guardian in his worst of 3linear extrapolations).

4 8.5 using BEIS 2018 conversion factor. The 2020 BEIS CF has increased by 5%, thus upping these emissions to 9.0

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i Search under MIDREX – the company that has built numerous natural gas DRI plants (NG-DRI) as well as syngas DRI plants.

ii

https://www.uselessgroup.org/outreach/publications/reports/steel-arising

iii SSAB on Hybrit: https://www.ssab.com/company/sustainability/sustainable-operations/hybritiv

v E.g. SSAB, LKAB and Vattenfall one step closer to production of fossil-free steel on an industrial scale – SSAB press release 1/6/20 https://www.ssab.com/news/2020/06/ssab-lkab-and-vattenfall-one-step-closer-to-production-of- fossilfree-steel-on-an-industrial-scale

& e.g. “ArcelorMittal Hamburg’s hydrogen project: We are in the design and funding phase of an industrial-scale project to use hydrogen instead of natural gas in the direct reduction of iron ore (DRI). The objective is to reach industrial commercial maturity of the technology by the mid-2020s, initially producing 100,000 tonnes of sponge iron a year.” ibid

vi “The ETC is confident that a complete decarbonization of the steelmaking industry is achievable by mid-century”MISSION POSSIBLE REACHING NET-ZERO CARBON EMISSIONS FROM HARDER-TO-ABATE SECTORS BY MID-CENTURY –SECTORAL FOCUS: STEEL – The Energy Transitions Commission (ETC) 2018http://www.energy-transitions.org/sites/default/files/ETC%20sectoral%20focus%20-%20Steel_final.pdf

The ETC, co-chaired by Lord Adair Turner, has a big industry input including from the steel sector, as well as academics

Compare this with WCM’s May 2020 Planning Statement R22:

“Emerging technologies are capable of producing steel without metallurgical coal. However these technologies are in their infancy and, as Dr Bristow explains, will not replace blast furnace steel production as the primary process for steel production for the foreseeable future, and indeed for the proposed life of the planning permission.”

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Postcards from Cumbria Expo

Postcards from Cumbria Expo is an online multi-media exhibition celebrating Cumbria’s life, geology, wildlife and much more through the distorting lens of past, present and ‘promised’ voids.

 

the sea cannot be depleted

We are delighted to be able to include this thought provoking and poignant work by Wallace Heim.

“the sea cannot be depleted” can be listened to here

Writer and Producer, Wallace Heim describes the project …….

An estuary is continual turbulence. The tidal forces of the open sea move hard against the higher regions of land, the regions from where maps are made. Those maps mark the two lands, split by the tides and softened by the imperative of rivers as they run to the sea. Maps can chart a channel, a changing sandbank, a buried ship, a danger zone. But they cannot show the restless pull of sea and wind. Or mark the intimacies between the life of the sea and the life of the land.

The tides of the Solway Firth are among the most turbulent around this island, a fast sweep from the Irish Sea into the soft sands of the rivers Esk, Eden and Nith. A line across the blank blue of a map etches the division between Scotland and England. The middle of that sea is not a place where humans can live, but we can find sanctuary in the unfolding of life in the tidal muds and in the migrations of the human imagination across the sea surface. The Latin word vastus described the immensity of the sea, its emptiness and its waste.

The UK Ministry of Defence fired at least 30 tonnes of artillery shells containing Depleted Uranium into the Solway Firth, to test those munitions on behalf of an unnamed ‘Customer’. The firings began in the 1980’s from the Kirkcudbright Training Range in Dumfries and Galloway, and on land at Eskmeals in Cumbria. The date of the latest confirmed firings is not certain, possibly 2011 or 2013, and the license to test fire may be continuing beyond that date. The MOD have justified this illegal dumping of radioactive waste into the sea as being ‘placements’. Attempts to retrieve the shells have failed. Their locations are unknown. MOD scientific reports declare that there is no hazard presented to human military or civil populations from this dumping, or from the misfires or contaminated materials on land.

The firings were a rehearsal and were hostile fire on a homeland, not only the infusion of nuclear waste into the wild sea. How can one understand the slow corrosion that remains? What does it mean for a place, a people, to cohere with the unseen objects of war? What is it to be a target? How do you make a life with, or disavow, the symptoms of the civil-military nuclear complex?

Outrage is a power. This arts project intends to transform those energies and make them work in other ways.

‘the sea cannot be depleted’ is not a continuation of the investigative journalism or activist research that brought this situation into the public domain. Instead, three fictional characters speak their thoughts, from both sides of the estuary. Too, this project sees the firings as episodes in the interlocked mesh of relations between the military, the nuclear industries, the arms corporations, capital, colonialism and political desires for international status. Uranium makes the situation timeless and without location. It casts a silence around the sea, and around the human place.

www.theseacannotbedepleted.net

The project is funded by Future’s Venture Foundation.

Voices

Camille Marmié, Vincent Friell, Lisa Howard

Composer & Sound Designer

Pippa Murphy

Writer & Producer

Wallace Heim

NEW CALL IN REQUEST FROM KEEP CUMBRIAN COAL IN THE HOLE TO THE SECRETARY OF STATE.

Cumbrian Mud Patch
Campaign group, Keep Cumbrian Coal in the Hole has sent in a Call In request to the Secretary of State Robert Jenrick MP.
The World Wide Fund for Nature have already sent in a call in request to the Secretary of State.  KCCH say they agree with the points WWF make but have advised the Secretary of State of ” further overwhelming reasons for this development to be called in”
These reasons include:
1. West Cumbria Mining are asking for conditions to be relaxed in order to facilitate the addition of lower quality middlings coal to the development
( previously middlings coal was to be a “by product” of this “premium” coal mine ).
2. West Cumbria Mining propose mitigating against subsidence by backfilling 25% of the mined area  with cement paste ( the below land area and also close to the Marine Conservation Zone).  However 75% of the proposed void which includes the area beneath the Cumbrian Mud Patch would not be backfilled.  There is potential for marine radiological pollution as a result of the subsidence induced re-suspension of the heavily radioactively contaminated sea bed sediments of the Cumbrian Mud Patch and surrounding sea bed areas.
3.  The Sellafield and Moorside site are at “high risk” of liquefaction (as outlined in a 2018  report by Geologists https://pygs.lyellcollection.org/content/62/2/116/tab-figures-data )  -this would be exacerbated by coal mine induced seismic impacts.
From KCCH’s Call In letter..

The original selling point of this mine was that it would produce “premium quality” coking coal for steel manufacture.   West Cumbria Mining in attempting to address the challenge from Keep Cumbrian Coal in the Hole regarding “middlings coal” as a “by-product” have made this proposed development even more absurd by adding a new onsite process to render the extracted thermal/middlings coal into coking coal.

The relaxing of conditions necessary to facilitate this inclusion of lower grade coal are applied for in this new amended application and detailed in West Cumbria Mining’s Planning Statement R20 – page 51.

STEEL MANUFACTURE?

Condition 3 – This condition relates to the coal being for use in steel manufacture only.  As this stands it appears that the developers are asking that this condition be removed to refer to authorisation of the “extraction of Metallurgical Coal” – rather than specifying the end use.

QUALITY – ASH AND SULPHUR CONTENT

Condition 76 – This condition relates to the quality of the end product. The quality of the product is to be further reduced from the already generous allowance of 8% Ash content and 1.2% Sulphur content to 9% Ash content and 2% Sulphur content.

AND

A new paper has been written on the radiological impacts of the coal mine.   Tim Deere-Jones is an Independent & non-aligned Marine Pollution Researcher & Consultant whose clients include: WWF, The UK Wildlife Trusts, European Climate Foundation, Greenpeace International, European Coastal Local Authorities and many others.

This comprehensive report concludes that the plan by West Cumbria Mining should be abandoned.

It is concluded that there is a real potential for subsidence to occur as a result of the “mass removal” and the creation of extensive sub-sea void spaces, and it is noted that such subsidence could generate earthquake and liquefaction effects which may extend onshore as far as the Sellafield/Moorside sites.
Full Letter can be read below

Rt Hon. Robert Jenrick MP

Secretary of State

Department for Communities and Local Government 2 Marsham Street

London

SW1P 4DF

 

1st July, 2020

Dear Secretary of State,

 

APPLICATION REFERENCE NUMBER 4/17/9007 – WEST CUMBRIA MINING

Dear Secretary of State,

You may remember that on 29th October 2019 Tim Farron MP delivered a petition to you in Parliament on behalf of 1,852 people asking that the Secretary of State call in the application by West Cumbria Mining for the first new deep coal mine in decades which was approved by Cumbria County Council in March 2019 and ratified on 19th October 2019.

Now, the Developers have applied for amendments to that original planning application.The Council (whose decision was to be challenged through Judicial Review) are not relying on their original twice approved planning decision but will look at

the amendments as a new application.

We are writing to support the World Wildlife Fund for Nature’s call in of the amended planning application. We agree with the points they make but would like to add further overwhelming reasons for this development to be called in for your consideration.

Previous letters and the petition to you are included for your consideration alongside the new evidence below.

WCM ASK CUMBRIA COUNTY COUNCIL FOR RELAXATION OF CONDITIONS

The original selling point of this mine was that it would produce “premium quality” coking coal for steel manufacture. West Cumbria Mining in attempting to address the challenge from Keep Cumbrian Coal in the Hole regarding “middlings coal” as a “by-product” have made this proposed development even more absurd by adding a new onsite process to render the extracted thermal/middlings coal into coking coal.

The relaxing of conditions necessary to facilitate this inclusion of lower grade coal are applied for in this new amended application and detailed in West Cumbria Mining’s Planning Statement R20 – page 51.

STEEL MANUFACTURE?

Condition 3 – This condition relates to the coal being for use in steel manufacture only.As this stands it appears that the developers are asking that this condition be removed to refer to authorisation of the “extraction of Metallurgical Coal” – rather than specifying the end use.

QUALITY – ASH AND SULPHUR CONTENT

Condition 76 – This condition relates to the quality of the end product. The quality of the product is to be further reduced from the already generous allowance of 8% Ash content and 1.2% Sulphur content to 9% Ash content and 2% Sulphur content.

This is NOT by industry standard a premium metallurgical coal product. By contrast the Global Platts Metallurgical Specifications 2020 guide for Australian Premium Coking Coal is Sulphur no more than 0.05% while Hard Coking Coal is no more than 0.06% Sulphur content. Which makes the Woodhouse product look positively shoddy. No wonder the developers appear to want the condition erased that the end use should be for steel manufacture only.

3 – The permission hereby granted authorises the Winning and Working of Metallurgical Coal for use in steel manufacture only.
Reason: This permission authorises the development for the extraction of Metallurgical Coal. For the avoidance of doubt, Middlings Coal is also produced as a by-product during the processing of Metallurgical Coal.
Reason: This permission authorises the development for the extraction of Metallurgical Coal. The reason needs to be amended because middlings coal will no longer be produced.
76 – Metallurgical Coal (definition)
Coal with particular physical and chemical characteristics that makes it suitable for use in the production of steel and separated from industrial/ Middlings Coal and reject material during processing at the Coal Handling and Processing Plant. For the avoidance of doubt ‘Metallurgical Coal’ shall be defined as having a maximum ash content of 8% and a maximum sulphur content of 1.25%.
Metallurgical Coal (definition)
Coal with particular physical and chemical characteristics that makes it suitable for use
in the production of steel and separated
from reject material during processing at the Coal Handling and Processing Plant. For the avoidance of doubt ‘Metallurgical Coal’ shall be defined as having a maximum ash content of 9% a maximum sulphur content of 2%.
The original maxima as stated do not reflect the product which will be produced by Woodhouse Colliery

Page 51 – WCM Planning Statement R20

CLOSE PROXIMITY TO SELLAFIELD AND THE CUMBRIAN MUD PATCH

Cumbrian Mud Patch

Image and Text from : RADIOLOGICAL IMPLICATIONS of POTENTIAL SEABED SUBSIDENCE SEISMICITY & “FAULT RE-ACTIVATION” beneath The CUMBRIAN MUD PATCH: INDUCED BY “MASS REMOVAL”, RAPID EXTRACTION & VOID SPACE CREATION – Briefing Paper by Tim Deere Jones for Keep Cumbrian Coal in the Hole

A new paper has been written on the radiological impacts of the coal mine. Tim Deere-Jones is an Independent & non-aligned Marine Pollution Researcher & Consultant whose clients include: WWF, The UK Wildlife Trusts, European Climate Foundation, Greenpeace International, European Coastal Local Authorities and many others.

This comprehensive report concludes that the plan by West Cumbria Mining should be abandoned.  The introduction and Major Conclusions are reproduced below…..

Introduction:This Briefing offers a review of the possible seabed morphological changes and marine pollution implications of the sub-sea coal mining venture proposed by West Cumbria Mining (WCM) at their Woodhouse Colliery site near St Bees Head.

WCM have designated and identified a sub-sea mining zone of the Irish Sea lying to the west of St Bees Head and extending at least 8kms offshore and southwards to within about 8km of the Sellafield site.

The WCM extraction proposals, using continuous mining methods, predict the extraction of approximately 3 million tonnes of coal per year over a 50 year period. This extraction rate will eventually generate a huge subterranean void space of approximately 136 million cubic metres (a volume greater than that of Wastwater Lake).

This briefing considers the impact of the creation of such a sub-sea void space on the possibility of sea bed subsidence in the area of the WCM designated sub-sea mining zone, and the subsequent potential for marine radiological pollution as a result of the subsidence induced re-suspension of the heavily radioactively contaminated sea bed sediments of the Cumbrian Mud Patch and surrounding sea bed areas.

Major Conclusions

It is noted that there is a lack of data about the status of the existing historical galleries and workings of the West Cumbrian Coalfield. It is noted that there is a lack of accurate data about the history and status of any subsidence seismicity in the coalfield.It is noted that the BGS have concluded that the coalfield is heavily faulted and has a long history of subsidence and that it appears that there are no plans to monitor for any subsidence prior to, during the operational phase or in the post operational phase of the Woodhouse Colliery.It is noted that sub-sea monitoring equipment is available and could be deployed in the region in order to monitor for any subsidence effects arising as a result of the proposed Woodhouse Colliery “mass removal” extraction.

It is concluded that there is a real potential for subsidence to occur as a result of the “mass removal” and the creation of extensive sub-sea void spaces, and it is noted that such subsidence could generate earthquake and liquefaction effects which may extend onshore as far as the Sellafield/Moorside sites.

It is concluded that any seabed subsidence in the WCM designated sub-sea mining zone would generate re-suspension of Cumbrian Mud Patch heavily radioactive seabed sediments. It is noted that such an event would generate elevated doses of man-made radioactivity to coastal zone populations and sea users along both the Cumbrian coast and at “downstream” regions further afield.

Given the potential for such a radiological effect and the delivery of increased doses of radioactivity to relevant coastal zone communities, some of which have already been identified by the authorities as Coastal Critical Groups, the Woodhouse Colliery proposal (especially in the absence of any precautionary mandatory subsidence monitoring) is strongly contra-indicated and should be abandoned.”

Keep Cumbrian Coal in the Hole have been raising awareness about the climate and radiological impacts of this proposed development since 2017. If not now – when will this plan be deemed too dangerous to continue with? Please call in this amended planning application for this deep coal mine development which if allowed to continue on its disastrous trajectory will impact locally, nationally and internationally.

Tomorrow is too late.

Yours sincerely,

Marianne Birkby

on behalf of Keep Cumbrian Coal in the Hole.(a Radiation Free Lakeland campaign)

“Unprecedented Numbers of Representations” on Cumbrian Coal Mine Plan!!!

 

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PETITION 

STOP PRESS….

A message from Cumbria County Council …

“West Cumbria Mining Planning Application.

Due to unprecedented numbers of representations being received on this application, including some received after the Consultation deadline and some that have contained new evidence, the Council has decided to postpone taking this application to the Development Control and Regulation Committee for a decision on 8th July in order to properly consider all representations and documentation received. The Council will now look to provide an alternative date. Please check our website on www.cumbria.gov.uk for further information”

Well Done to Everyone who has written into Cumbria County Council opposing this plan – It is NOT A DONE DEAL !!

WWF ASKS FOR ‘CALL IN’ – GREAT NEWS!

Sellafield from St Bees
Sellafield – spitting distance from the proposed coal mine off St Bees  Head  (where the sheep are)

 

The World Wide Fund for Nature has asked for a “call in” of the planning decision due to be taken by Cumbria County Council.

This is Great News!

We shall also continue our  lobbying of the Secretary of State to intervene and stop  the plan for the first deep coal mine in the UK in decades.

The full “call in” letter from WWF can be read below.  It is very good but there is no reference at all to the close proximity of Sellafield, a burning but neglected issue which we at Keep Cumbrian Coal in the Hole will continue to flag up.

Rt Hon. Robert Jenrick MP
Secretary of State
Department for Communities and Local Government 2 Marsham Street
London
SW1P 4DF

Dear Secretary of State,

19th June, 2020

APPLICATION REFERENCE NUMBER 4/17/9007 – WEST CUMBRIA MINING

WWF-UK wrote to you in July 2019 to ask you to call in the previous application madeby West Cumbria Mining, which was approved by Cumbria County Council’sDevelopment Control and Regulation Committee; you declined to do so. The county council decided to grant planning permission and local campaigners commenced judicial review proceedings.

Following the grant of permission to proceed with the challenge, the developer filed an amended planning application to develop the coal mine. However, we consider the case for you to call in this application is strong, particularly in light of events occurring since we wrote to you last summer, and some of the information submitted by the developer in support of the amended application.

Caborn criteria
We consider that at least two of the Caborn criteria for call-in are met in this case. The first is that the proposal conflicts with national policy on important matters – in particular policy on mitigating climate change, the presumption against coal extraction in para. 211 of the National Planning Policy Framework, and duties to reduce CO2emissions under the Climate Change Act 2008 and under international law by the Paris Agreement. As we set out in our correspondence of last year, the development is in breach of policy adding to the global coal stock, assumes a long-term reliance on coking coal that is contrary to the trajectory indicated by UK and EU climate policy and legislation (informed by the Paris Agreement) and seeks to put in place new, long-term and environmentally invasive infrastructure.

Second, and again as per our letter last year, the proposal gives rise to national controversy; our previous letter provides evidence of this. Since our last letter, the application has been subject to judicial review proceedings and a wide cross section of groups have spoken out against it, including local campaigners, national NGOs (e.g.

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Green Alliance, WWF) and independent academics (e.g. Professor Ekin).

You will be aware that the application by Banks Mining for an open-cast coal mine at Highthorn, Northumbria was called in and remains undetermined. So far as administrative law imposes a duty to treat like cases alike, WWF suggests you must give careful consideration to treating Woodhouse Colliery in like manner, calling it in.

Detail
We see nothing in the revised planning application that negates our original three grounds for objecting to the proposed project (set out in more detail in our letter to you of 15th July, 2019). These are set out (in summary) below together with a number of new points in response to the amended application.

  • That government is committed to a net-zero greenhouse gas emissions target by 2050, under the Climate Change Act 2008 – a decision that theCommittee on Climate Change is clear “must be embedded and integratedacross all departments, at all levels of government, and in all major decisionsthat impact on emissions.” The iron and steel industries – the customers for coking coal produced from this proposed mine – are no exception to this.
  • The declining need for coal production of this nature over the short-term and over the 50-year proposed lifespan of the project, and the impact on greenhouse gas emissions of extracting it – in short, whether the benefits from the project outweigh its likely environmental impacts. The previous caseconcluded that industry’s need for metallurgical coal outweighed theenvironmental impacts, but with no sound evidence that coal from this proposed colliery would replace, rather than supplement, existing supplies, whether in the UK or in other markets.
  • The impact on the rights of children and future generations. A mine would generate significant carbon emissions over the course of the next 50 years and for at least 20 years after the UK is required to meet its net zero greenhouse gas emissions target in 2050. The consequences of those emissions (eg: in terms of their contribution to global heating) and the responsibility to offset them to meet the new 2050 target will fall disproportionately on the young, impacting on their human rights – including Article 8 of the European Convention of Human Rights in a manner which we believe cannot be justified at a time of climate crisis. The mine is also liable to generate significant air quality impacts and it is well established that air pollution disproportionately affects the young because their lungs are still developing1. As set out previously, the UN Convention on the Rights of the Child applies here (because the ECHR is in play) and requires decision makers to ensure that the best interests of children are a primary consideration and that the impacts of the decision on children are assessed and taken into account. There is no evidence that such an assessment has been undertaken in relation to the amended application, hence the flaw identified previously remains.New grounds

• Global footprint – the developer has failed to assess the carbon impacts of

use of the coal in steel foundries overseas. WWF considers that the exported

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emissions (must be assessed pursuant to the council’s duty to take account ofthe Paris Agreement following important new case law (Friends of the Earth v Secretary of State for Transport). Paris provides a temperature limit which is the shared responsibility of states to achieve. It is therefore unsustainable not to take into account the emissions arising abroad as a result of activities within the UK when the duty to achieve the temperature limits in the Paris Agreement are imposed collectively on all states. Further, WWF argues that thedeveloper’s approach either fails to comply with the EIA Directive or fails to enable the planning authority to take account of material consideration by failing to assess the likely scale of the impact of burning the coal abroad.

• High carbon development – the developer has wrongly categorised thedevelopment as “low carbon” because it has failed to assess the exported emissions as aforesaid. No consideration has been given to the likelihood that coal which may be edged out of use in European steel works by coal produced from the development would be burnt regardless leading to an overall increase in global greenhouse gas emissions. This fact flows both from the laxity of current commitments made by states under the Paris Agreement by way of Nationally Determined Contributions to date2 and the failure of many states (including the UK) to prohibit exported emissions in domestic legislation. Nor can the section 106 agreement proposed by the developer (to assess every 5 years whether the development continues to comply with carbon budgets) remedy the problem because carbon budgets do not build in exported emissions either. Far from being low carbon, the development is arguably high carbon, will add significantly to the emission of greenhouse gases (understood in a broader sense) and therefore conflicts with NPPF para 211. It must be called in.

• Net Zero – the net zero target was adopted before the original planning application was resolved to be granted by the County council. However, there is a suggestion in the amended planning application that this is not for the planning authority to take account of (because the duty in the Climate Change Act fastens on the Secretary of State). WWF is confident that the Secretary of State does not take such a view and he agrees with us that the target is a material consideration for the purposes of section 70 of the Town and Country Planning Act 1990. . However, to ensure the planning authority does not fall into error, WWF considers the safest route would be for the Secretary of State to call in.

  • Carbon plan – no consideration has been given to the fact that government has yet to adopt a carbon plan which sets out how the net-zero target will be met –nor has it yet explained how it will bring itself into compliance with carbon budgets from the mid-2020s onwards. By granting planning permission at this point for such a long-term, high carbon development, the council risks locking in high carbon infrastructure for many decades to come thereby pre-emptingimportant decisions about the UK’s pathway to net-zero which are pre- eminently for ministers to take. A decision to grant would be premature at this stage.
  • Equality – the council is subject to a duty in domestic law to have regard to the need to advance equality of opportunity as between people who have protected characteristics and those who do not (section 149 Equality Act 2010). As set

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out above, the development will impact disproportionately on the young yet no Public Sector Equality Duty assessment appears to have been undertaken. Should the failure continue, it leaves the application vulnerable to challenge.

We cannot decarbonise our economy at the speed and depth required to avert catastrophic impacts of climate change by substituting one source of fossil fuels for another.

WWF-UK has modelled an emissions reduction scenario for the UK to 2045 and to 2050 in a report with Vivid Economics, entitled Keeping It Cool3. This demonstrates the degree of decarbonisation needed in each sector, as well as the overall pathway. This makes clear that we will not need metallurgical coal for the next 45-50 years that this mine will be producing it. We do not need a new source of metallurgical coal in the short-term and it is spurious to argue that the emissions from this coal will be slightly lower than existing sources, when to achieve this would (a) add to the existing stock of metallurgical coal in the marketplace overall, (b) do so for far longer than any country can be relying on fossil fuels, and (c) do so in a way that generates new emissions from the construction, running and transport out of the country of the coal produced at the mine. It is clear that the need case in respect of the application is simply not made out.

Keeping global warming to 1.5°C requires that we stop using coal, as soon as possible, both for power generation and industry. Modelling by a group of 20 researchers indicates that keeping to 1.5°C without geoengineering requires the virtually complete elimination of fossil fuel emissions and fossil fuel infrastructure by 2050 and that global coal production must decline by 5886 million tonnes a year in 2015 to only 407 tonnes in 2050 – a reduction of around 93%4.

Given this and given the UK’s avowed global leadership on climate change – not least as holders next year of the presidency of the crucial UNFCCC Conference of the Parties (COP) 26 – allowing new coal production on its own shores would be perverse. Not only does it send a particularly unwelcome signal to the wider world about its commitment to climate action, but it adds to the already daunting scale of decarbonisation that would be required in other sectors in order to make net-zero possible by 2050.

Additionally, it continues to pile the costs of delayed climate action, and of climate impacts, onto children and future generations.

This is most definitely a consideration for national government (owners of the legally- binding target for net-zero by 2050), for local government (who cannot simply abrogate their responsibility for additional emissions from projects such as these on the basis that they are but one small contributor), and for local people (who will bear the costs of growing climate impacts).

3 https://www.wwf.org.uk/sites/default/files/2018-11/NetZeroReportART.pdf
4 Teske S. Ed. “Achieving the Paris Climate Agreement Goals, Global and Regional 100% Renewable energy scenarios with Non-energy GHG pathways for +1.5C and +2C” https://link.springer.com/book/10.1007%2F978- 3-030-05843-2

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We object to this proposal and we believe that you should call it in. Yours,

GARETH REDMOND-KING Head of Climate Change

 

STOP THE COAL MINE IN CUMBRIA -PETITION

PLEASE SIGN THE PETITION –  LETS SEND CUMBRIA COUNTY COUNCIL THE MESSAGE 

STOP THE COAL MINE

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Nearly 4000 people, including Chris Packham have signed the petition to Stop the Coal Mine in Cumbria – Please keep sharing and signing.  As well as signing the petition – People can STILL WRITE individual letters to Cumbria County Councillors who will be making the decision on this to let them know STOP THE COAL MINE!

The main points to make are that this mine would fly in the face of the Council’s own climate commitments and its own stated commitments to protect the health, safety (this is 8km from Sellafield) and well being of all Cumbrians. Send an email to development.control@cumbria.gov.uk –or if you have time to all the Development Control and Regulation Committee members  quoting the application reference number 4/17/9007 and including your name and address.

 

Keep Cumbrian Coal in the Hole say: Turn Down Dangerous Coal Mine Plan, For Cumbria and For the Planet

Yesterday was the last ‘official’ date to send in objections to the new ‘amended’ planning application.  You can still send in letters of objection up to the Planning Meeting which is scheduled for the 8th July (if this goes by previous form the meeting will be rescheduled again and again).  Please do send in letters to members of the planning committee. (They have voted yes to this diabolic plan twice before,).

This is the Keep Cumbrian Coal in the Hole objection …

                                          15th June 2020

West Cumbria Mining: Planning Application Ref 4/17/9007: 

Woodhouse Colliery, High Road, Whitehaven

Dear Development Control and Regulation Committee,

I write on behalf of Keep Cumbrian Coal in the Hole, a campaign by Radiation Free Lakeland to ask that the County Council do not approve this amended planning application

We are a civil society group that aims to remove the risk of environmental damage both nationally and internationally that may arise from the presence of an extensive nuclear industry close (to the Lake District National Park, a World Heritage Site). 

On 19th March Cumbria County Council (CCC) granted conditional planning permission for a resumption of the long abandoned onshore coal mining at St Bees to West Cumbria Mining Limited (WCM). This would be followed by the ‘profit making’ offshore phase.   On 20 June 2019, our lawyers Leigh Day wrote to Cumbria County Council. The letter addressed a number of legal issues, including Cumbria County Council’s failures to consider:

  • Greenhouse gas (GHG) emissions of the mining operations
  • The need for, and GHG impacts of, Middlings Coal
  • The Government’s Net Zero target.

Despite being alerted to those concerns, Cumbria County Council ratified its decision on 31 October 2019. Mrs Justice Beverley Lang agreed that those legal issues  we raised were arguable and justified a public hearing.

In order it seems to circumvent the scrutiny afforded by Judicial Review and the criticisms levelled in the Green Alliance report the Developers have now submitted a new planning application.  This is despite the  CEO of West Cumbria Mining publicly stating that : “If you asked me to get planning for another one, I would say it would be impossible right now unless something significantly changed,”  Mark Kirkbride, British Tunnelling Society lecture reported in New Civil Engineer 26th February 2020    

The CEO of West Cumbria Mining went on to say:

“When we applied for planning it was a different set of planning rules. Now if you were to submit planning you’d have to try and do whole life greenhouse gas assessments.”  Given that steel can and should be produced without the use of coking coal – the additional GHG emissions arising from the use of coking coal from this mine to make steel should be taken into account . 

The amended planning application while attemping to address the original challenges we raised has compounded our concerns about the cumulative impacts of this mine. Regarding climate The use of coal from this mine will undermine the government’s net zero target, carbon budgets and policy to adhere to the Paris Agreement. 

NEW PROCESS TO TURN THERMAL/MIDDLINGS COAL INTO COKING COAL

The original big selling point of this mine proposal was that it would produce “premium” quality coking coal. In order to answer legitimate criticisms on the previous ‘by-product’ of middlings, the developers propose now to turn the 15% (or more) by-product of middlings/thermal coal into coking coal.  The details on this are sketchy. WCM say that in order to turn the thermal coal to coking coal there will be an additional process to enhance separation and removal of pyritic sulphur matter but then go on to claim optimistically that: 

“ Since this adjustment relates only to the internal process …. and no difference to external appearance …. it is not considered that it will give rise to any material effects of the proposal.”   This is clearly impossible – the removal of pyritic sulphur and the myriad other polluting imupurites from the middlings would leave an additional and unaddressed toxic footprint.  There would also be additional energy and freshwater usage.   In order to address the issue of the new and inferior quality of product, West Cumbria Mining propose a relaxation of the conditions that determine the specification for metallurgical coal.  The developer justifies a relaxation on the grounds that the original specification does not reflect the (now inferior) product that will be the final output from the Woodhouse Colliery, specifically with regard to ash and sulphur content.  WCM are also asking for removal of the condition that the product must be used only for steelmaking.  This is entirely understandable as once exported, WCM have no way of ensuring their coal is used solely for steel making (despite their considerable PR in this regard). 

METHANE

The WCM report by Dr Neil Bristow says that “WCM is committed and obliged to install a methane capture and drainage system. …It will be put to use as an energy source of the mine with no atmospheric impact.”    This disingenously suggests the impossible namely that 100% of the methane emitted by the mine (continuously by the exposed and broken coal) would be “used” …”with no atmospheric impact.” In the first two decades after its release, methane is 84 times more potent than carbon dioxide Overall it is roughly 30 times more potent than CO2 as a GHG.   WCM propose to build the methane capture plant by year 5.  Calculations have been done independently which suggest that “ 13.9MCu m of methane could be produced and if the Capture system is not operational by then (year 5) it is possible that 38.75M cu m will be released before then. That is an equivalent effect on the atmosphere of 856486 T of Co2.  From year 5 the Methane capture plant will need to capture about 13.9Mcu m per year if there is to be ‘no atmospheric impact’. Where will it be stored? To put this volume into context the old style town gasometers held about 50000cu m. So WCM are planning to capture and store the equivalent of 5.3 gasometers per week, every week!!!   This is a substantive GHG impact on which the council needs information.

POLICY DC20 THE WATER ENVIRONMENT

Cumbria County Council’s Policy DC20 states “Proposals for developments should demonstrate that they would have no unacceptable quantitative or qualitative adverse effects on the water environment, both within the application site and its surroundings, including surface waters, coastal waters, private water supplies and groundwater resources. Proposals that minimise water use and include sustainable water management will be favoured.” 

FRESH WATER

Despite requests to them for information by us and other NGOs, West Cumbria Mining have not demonstrated what the impact on ground water will be.  There is no information in the public domain regarding the projected quantity of freshwater abstraction from the Byerstead Fault or potential hydrological impact.   This is an important issue in West Cumbria which is already suffering from fresh water stress.   WCM again use disingenous language to suggest that virtually all freshwater would be recycled suggesting that there would be minimal abstraction.  There is no indication of exactly how much water WCM expect to abstract per day from the Byerstead Fault – a named geological fault.  The Marine Conservation Zone documentation describes it thus.. “This site lies within the boundary of the rMCZ11 and is situated in Saltom Bay on the Cumbrian coast north of St Bees Head. The site includes an area known locally as Byerstead Fault, a recovering intertidal zone that is showing a return of species diversity..

“Water is heavily used in coal processing and would be obtained from the following sources: Groundwater (Byerstead Fault) “   

WCM presentation to CCC 19th March 2019

Cumbria County Council’s Minerals and Waste Local Plan states:

  • “16.36  Proposals will, therefore, be required to demonstrate that they do not have unacceptable adverse impacts on water resources. Any adverse impact should be avoided or, if unavoidable, suitable mitigation measures should be proposed. Unacceptable quantitative or qualitative impacts are those which are deemed so by the Environment Agency, as part of the planning application process.
  • 16.37  Sites proposed for development will need to be subject to site specific hydro- geological assessment, in order to determine their acceptability. Some factors influencing this process are the type of facility, the pollution control measures adopted, the potential impacts on groundwater resources and the groundwater vulnerability of the site.
  • 16.38  With respect to mineral applications, there is a requirement to establish the relationship that the development has with the water table. If the base of the excavation is near or below the anticipated water table, then there will be a requirement to establish an appropriate monitoring scheme. In some circumstances, the development may be considered unacceptable if it is carried out below the level of the water table”. 

Not only will WCM be abstracting fresh water from the Byerstead Fault but the development is in the region of the West Cumbria Aquifer – a water resource that is currently used to provide fresh water for much of West Cumbria.  A region that is heavily faulted and complex.

WCM have revealed so litte detail about their fresh water usage that there can be no proper scrutiny or oversight by Cumbria County Council or the public.
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Aquifer beneath West Cumbria in the vicinity of WCM proposal

Image: BGS

 

 

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The image above is from ESI retained by WCM for “hydrological and hydrogeological support”. 

The amended planning application gives no idea of exactly how much water  would be abstracted from the Byerstead Fault (see above) at peak production of the mine – or of the damage likely to be caused by this abstraction

HAZARDOUS INSTALLATIONS – COAL AND NUCLEAR WASTE AT SELLAFIELD (and DRIGG)

When preparing Local Plans, local planning authorities are required to have regard to the prevention of major accidents and limiting their consequences. They must also consider the long-term need for appropriate distances between hazardous establishments and population or environmentally sensitive areas. They must also consider whether additional measures for existing establishments are required so that risks to people in the area are not increased.

Cumbria County Council are no exception and the Minerals and Waste Local Plan states that:

  • 5.102. “Permission should not be given for the extraction of coal unless the proposal is environmentally acceptable, or can be made so by planning conditions or obligations; or if not, it provides national, local or community benefits which clearly outweigh the likely impacts to justify the grant of planning permission”. 

and…

13.23  In some cases, a proposed development may itself have multiple environmental impacts that would be acceptable on their own, but which may exacerbate adverse impacts caused by other developments. Such cumulative environmental impacts can derive either from a number of developments with similar impacts being operational at the same time in an area, or from a number of concurrent developments in an area with different impacts or from a succession of similar developments over time. They can include the impacts of noise or traffic, and impacts on local communities, the landscape, water resources or wildlife habitats.

  • 13.24  Local Plan policy needs to take account of the extent to which a particular locality, community, environment or wider area can reasonably be expected to tolerate such adverse cumulative impacts. This may involve mitigation of impacts or the timing of permissions and phasing of operations to make a proposal acceptable. Where cumulative impact presents a potential issue, applicants should be able to demonstrate that this has been adequately assessed and addressed in a planning application.

The Office for Nuclear Regulation’s official remit to consult on planning applications is 7.4 km from Sellafield. The coal mine extends to 8km from Sellafield i.e. 600 metres difference. In the absence of any detailed regard to cumulative impacts by either the developers or Cumbria County Council or the regulators we have commissioned a Briefing Paper on the radiological implications of West Cumbria Mining’s plan.

The author of the paper, Tim Deere-Jones is an Independent & non-aligned Marine Pollution Researcher & Consultant whose clients include: WWF, The UK Wildlife Trusts, European Climate Foundation, Greenpeace International, European Coastal Local Authorities and many others.

This comprehensive report concludes that the plan by West Cumbria Mining should be abandoned.

The introduction and Major Conclusions are reproduced below…..

Introduction:                                                                                                                                                        This Briefing offers a review of the possible seabed morphological changes and marine pollution implications of the sub-sea coal mining venture proposed by West Cumbria Mining (WCM) at their Woodhouse Colliery site near St Bees Head.

WCM have designated and identified a sub-sea mining zone of the Irish Sea lying to the west of St Bees Head and extending at least 8kms offshore and southwards to within about 8km of the Sellafield site.

The WCM extraction proposals, using continuous mining methods, predict the extraction of approximately 3 million tonnes of coal per year over a 50 year period. This extraction rate will eventually generate a huge subterranean void space of approximately 136 million cubic metres (a volume greater than that of Wastwater Lake).

This briefing considers the impact of the creation of such a sub-sea void space on the possibility of sea bed subsidence in the area of the WCM designated sub-sea mining zone, and the subsequent potential for marine radiological pollution as a result of the subsidence induced re-suspension of the heavily radioactively contaminated sea bed sediments of the Cumbrian Mud Patch and surrounding sea bed areas.

………………………………………………………………………………………………………………………………………………….  

Major Conclusions

It is noted that there is a lack of data about the status of the existing historical galleries and workings of the West Cumbrian Coalfield. 

It is noted that there is a lack of accurate data about the history and status of any subsidence seismicity in the coalfield.  

It is noted that the BGS have concluded that the coalfield is heavily faulted and has a long history of subsidence and that it appears that there are no plans to monitor for any subsidence prior to, during the operational phase or in the post operational phase of the Woodhouse Colliery.  

It is noted that sub-sea monitoring equipment is available and could be deployed in the region in order to monitor for any subsidence effects arising as a result of the proposed Woodhouse Colliery “mass removal” extraction.

It is concluded that there is a real potential for subsidence to occur as a result of the “mass removal” and the creation of extensive sub-sea void spaces, and it is noted that such subsidence could generate earthquake and liquefaction effects which may extend onshore as far as the Sellafield/Moorside sites.

It is concluded that any seabed subsidence in the WCM designated sub-sea mining zone would generate re-suspension of Cumbrian Mud Patch heavily radioactive seabed sediments. It is noted that such an event would generate elevated doses of man-made radioactivity to coastal zone populations and sea users along both the Cumbrian coast and at “downstream” regions further afield.

Given the potential for such a radiological effect and the delivery of increased doses of radioactivity to relevant coastal zone communities, some of which have already been identified by the authorities as Coastal Critical Groups, the Woodhouse Colliery proposal (especially in the absence of any precautionary mandatory subsidence monitoring) is strongly contra-indicated and should be abandoned”

The full report is attached as a pdf

CONCLUSION

The weight of evidence is overwhelmingly clear that this application should be unequivocally refused.  We urge Cumbria County Council to take eagerly with both hands this new opportunity, via the amended planning application, to turn down this dangerous coal mine plan, for Whitehaven, for Cumbria, and for the Planet.  

 

Refs:

Cumbrian Campaign Group Granted Permission for Judicial Review https://www.leighday.co.uk/News/Press-releases-2020/February-2020/Cumbrian-campaign-group-granted-permission-for-jud

The Case Against New Coal Mines – Green Alliance https://www.green-alliance.org.uk/the_case_against_new_coal_mines_press_release.php

Cumbrian Coal Mine Could be ‘the last one’ in the UK – Tradelink Publications Ltd  https://mqworld.com/2020/02/26/cumbria-coal-mine-last-one-uk/

A more potent greenhouse gas than carbon dioxide, methane emissions will leap as Earth warms – Science Daily https://www.sciencedaily.com/releases/2014/03/140327111724.htm

Methane https://keepcumbriancoalinthehole.wordpress.com/2020/06/11/big-holes-in-mine-developers-plan/

UU Plans to Keep Drawing West Cumbria’s Water from Egremont Boreholes https://www.newsandstar.co.uk/news/17345135.united-utilities-plans-to-keep-drawing-west-cumbrias-water-from-egremont-boreholes/

Byerstead Fault – Marine Conservaton Zone https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/82717/mcz-i1-irish-seas-20121213.pdf

West Cumbria Aquifer https://www.bgs.ac.uk/research/groundwater/shaleGas/aquifersAndShales/maps/aquifers/CarboniferousLimestone.html

WCM have not demonstrated how much freshwater would be abstracted from the Byerstead Fault at peak production –  https://esi-consulting.co.uk/our-work/minerals-waste/hydrological-hydrogeological-support-proposed-metallurgical-coal-mine/?fbclid=IwAR2xvAcZjPly1AGS0nT8TLVHOuEAzKcciH_–G9NQv_m5kGFNznBdOOMc9s

Nightmare Coalmine Near Sellafield Approved. https://realmedia.press/sellafield-coal-mine/