Dear Friends,
*Thank you* to everyone who wrote to Cumbria County Council about their shocking decision to approve deep mining under the Irish Sea.
The next step is to ask the Secretary of State to call in the decision.
Tim Farron MP has done thisand I have also written on behalf of Keep Cumbrian Coal in the Hole to the Secretary of State to ask that the decision by Cumbria County Council approving the Coal Mine is Called In.
The more people and groupsthat write and request that the Secretary of State calls in the decision made by Cumbria County Council on 19th March, the better.
In fact, a show of force may demonstrate the strength of feeling against the mine. The letter should be addressed to James Brokenshire MP, the Secretary of State. james.brokenshire@communities.gsi.gov.uk.
Re: Application Reference No. 4/17/9007 – Former Marchon Site, Pow Beck Valley and area from Marchon Site to St Bees Coast, Whitehaven, Cumbria
Our full letter is below – but you don’t need to write that much – the main point to make is that West Cumbria Mining has not given figures on CO2 Emissions with no independent assessments and there has been no detailed scrutiny or debate on the close proximity of deep mining to Sellafield’s high level radioactive wastes
ALSO
The petition has been updated to request that James Brockenshire MP, Secretary of State Calls In the Decision.
DEMO AND PETITION HAND OVER ON WEDNESDAY 10th APRIL 2-4 pm
OUTSIDE the MINISTRY OF HOUSING, COMMUNITIES & LOCAL GOVERNMENT
2 Marsham Street
London
SW1P 4DF
United Kingdom
https://you.38degrees.org.uk/petitions/keep-cumbrian-coal-in-the-hole-its-too-near-sellafield
LETTER TO THE SECRETARY OF STATE From KEEP CUMBRIAN COAL IN THE HOLE
james.brokenshire@communities.gsi.gov.uk
The Rt Hon James Brockenshire MP,
Secretary of State for Housing, Communities & Local Government, Ministry of State for Housing, Communities & Local Government, 2 Marsham Street,
London SW1P 4DF.
3rd April 2019
Dear Secretary of State,
Re: Application Reference No. 4/17/9007 – Former Marchon Site, Pow Beck Valley and area from Marchon Site to St Bees Coast, Whitehaven, Cumbria
I write on behalf of Keep Cumbrian Coal in the Hole, a campaign by Radiation Free Lakeland to ask that the Secretary of State calls in the above decision.
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).
The applicant has confirmed that their onshore proposal is commercially dependent upon the extraction of coal from under the adjacent coastal waters of the Irish Sea for which they would need agreement from the Marine Management Organisation.
Our concerns primarily relate to potential cross boundary radiation impacts resulting from damage to Sellafield as a result of aggressive deep mining activity in methane rich coal beds and freshwater extraction to wash the coal (from a geological fault). We are, however, also concerned about wider environmental impacts arising from the mine, including climate change.
We support the call in by Tim Farron MP, and we refer you to the climate scientists and experts (Dr Laurie Michaelis, Dr Henry Adams and others) who have outlined the cross boundary climate impacts that would result from this mine (impacts as outlined by the Climate Change Act 2008).
We request the Secretary of State calls this application in for his own determination on the basis that the proposal fulfils the following (Caborn) criteria for call-in:
1. The proposal conflicts with national policies on important matters
We refer to paragraphs 205, 211, 7 and of the National Planning Policy Framework (NPPF) 2019.
NPPF Paragraph 205 states: When determining planning applications, great weight should be given to the benefits of mineral extraction, including to the economy” except in relation to the extraction of coal, in which case reference is made to paragraph 211.
Paragraph 211 states: Planning permission should not be granted for the extraction of coal unless:
a) the proposal is environmentally acceptable, or can be made so by planning conditions or obligations; or
b) if it is not environmentally acceptable, then it provides national, local or community benefits which clearly outweigh its likely impacts (taking all relevant matters into account, including any residual environmental impacts).
It is our view that the proposal cannot be made acceptable by planning conditions or obligations and that any national, local or community benefits do not outweigh the likely impacts.
We also refer the Secretary of State to key paragraphs of the NPPF concerning sustainable development (as set out in paragraphs 7-14).
We also refer to a paper published by the Interdepartmental Liaison Group on Risk Assessment (ILGRA), in 2002 entitled The Precautionary Principle: Policy and Application. This paper highlighted a number of important points including noting that the precautionary approach should be invoked when: there is good reason to believe that harmful effects may occur to human, animal or plant health, or to the environment; and the level of scientific uncertainty about the consequences or likelihood of the risk is such that best available scientific advice cannot assess the risk with sufficient confidence to inform decision-making.
The proposal potentially conflicts with paras of the NPPF concerned with *Meeting the challenge of climate change, flooding and coastal change* (see pages 44-45).
2. The proposal could have significant effects beyond their immediate locality; give rise to substantial cross-boundary or national controversy. We draw your attention to the close 8km proximity of this coal mine to Sellafield’s uniquely dangerous storage of high level wastes and highly active liquors (see Consequences in Norway of a hypothetical accident at Sellafield: Potential release – transport and fallout Strålevern Rapport 2009:7. Østerås: Norwegian Radiation Protection Authority)
Cross boundary impacts: For example, there is no guarantee that subsidence will not occur following mining and backfill of the voids with a cement mix. If subsidence does occur, there is a significant risk that highly carcinogenic and dangerous radioactive and chemical sediment and silt will be re-suspended from the Irish Sea bed and mobilised with the tides not only to Cumbrian beaches but also to European beaches (and beyond). Similarly, mining and freshwater abstraction from faults is known to increase seismic activity. It is significant that the only area of the UK ever to experience a liquefaction event from a minor seismic event is a small village not far from Sellafield in the 1800s. A recent paper published by the Yorkshire Geological Society (The susceptibility of glacigenic deposits to liquefaction under seismic loading conditions: a case study relating to nuclear site characterization in West Cumbria by Martin Cross, Anass Attya and David J. A. Evans Proceedings of the Yorkshire Geological Society,18 September 2018) found that Sellafield and its surrounds are at “high risk” of liquefaction.
If a liquefaction event happened at Sellafield as a result of mining the consequences would be catastrophic, not just for Cumbria but for the rest of Europe. Given the catastrophic radiological impacts that a seismic event at Sellafield induced by nearby coal mining could have on other EU countries this proposal is potentially subject to Article 37 of the Euratom Treaty. Article 37 requires Member States to provide the Commission with general data so that they may give an opinion on whether the proposal is likely to have an impact on other Member States. Post Brexit we hope that this protection afforded to other European Countries is honoured.
Keep Cumbrian Coal in the Hole has a following of approximately 1500 supporters including academics and scientists. We have been campaigning to raise awareness about this development since 2015. In 2016 Radiation Free Lakeland received a personal letter of thanks for our ongoing civil society work in nuclear safety from Austria’s Federal Ministry of Agriculture, Forestry, Environment and Water Management who are equally concerned at the danger Sellafield poses to Europe even without deep coal mining under the Irish Sea.
Finally, we would also highlight that there remains a significant question about the extent of the climate change impacts arising from this scheme (even if coal used in steel production, there will be CO2emitted). In this respect, we note the purpose of the power under s.77 Town and Country Planning Act 1990 is to give the Secretary of State the power to call in planning applications where he considers that this is *necessary or desirable in the national interest* (R. (on the application of Adlard) v Secretary of State for the Environment, Transport and the Regions[2002] 1 WLR 2515). We would submit this is clearly one such case.
In light of the above, we urge the Secretary of State to call this application in for his own determination at the earliest opportunity.
Yours sincerely,
Marianne Birkby
On behalf of Keep Cumbrian Coal in the Hole A Radiation Free Lakeland campaign
https://you.38degrees.org.uk/petitions/keep-cumbrian-coal-in-the-hole-its-too-near- sellafield
