OBJECT!!! To the New Plan for the Coal Mine Before 15th June

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Dear Friends,

Thanks to our continued challenges the Developers of the first deep coal mine in the UK in decades have put forward an amended planning application.  The difference with this plan is that the developers propose to make the lower quality middlings coal (previously called a “by product”) into coking coal.

Even if  you have written previously to oppose the plan PLEASE PLEASE write and object again BEFORE 15th June – and ALSO ask to speak at the planning meeting (July 8th).

We have prepared a list of potential issues that you can object to – (this is not an exhaustive list – there are plenty more arguments you can make against this diabolic plan)

So please do use this as inspiration for your own letters of objection.  Even it you can write just a line or two saying that you strongly oppose this plan. – it is all valid and it all helps!!

Send your letters of objection to

developmentcontrol@cumbria.gov.uk

If you have time to write to all the members of the committee then the details are here 

You can tweet Cumbria County Council here ..  @CumbriaCC 

Please include:  West Cumbria Mining – amendment to Application Reference No. 4/17/9007. 

 

OPPOSITION LETTER TO THE COAL MINE

                              

Application Reference No. 4/17/9007. 

Proposal: Development of a new underground metallurgical coal mine and associated development including: the refurbishment of two existing drifts leading to two new underground drifts; coal storage and processing buildings; office and change building; access road; ventilation, power and water infrastructure; security fencing; lighting; outfall to sea; surface water management system and landscaping at the former Marchon site (High Road) Whitehaven; 

• a new coal loading facility and railway sidings linked to the Cumbrian Coast Railway Line with adjoining office / welfare facilities; extension of railway underpass; security fencing; lighting; landscaping; construction of a temporary development compound, and associated permanent access on land off Mirehouse Road, Pow Beck Valley, south of Whitehaven; and

• – a new underground coal conveyor to connect the coal processing buildings with the coal loading facility.

West Cumbria Mining have resubmitted this previously unanimously approved appliction with the change that high quality coking coal would now comprise up to 15% of middlings coal processed on site to render it into coking coal.   

OPPOSITION ON THE GROUNDS OF:

Cumbria County Council Minerals and Local Waste Policy DC13 15.16

This proposal will have unacceptable social and environmental impacts which cannot be mitigated against and would fly in the face of Cumbria County’s own Policy DC13   

a. Loss of Ancient Woodland and degradation of remaining woodland area by the proposed rail conveyor  to cut through two areas of woodland.

b. Large Coal Yard Sidings and Trains Local residents are opposed to Pow Beck Valley hosting  a large coal yard with six daily coal trains “The facts are; a train over 400 metres long; weighing +1500 tonnes; emitting 25.3g CO_2e per tonne km” “126 Coal wagons in their sidings are hardly inconspicuous in our green landscape. More WCM rhetoric at the expense of local residents”.  Local Resident.

c.  Methane Rich coal seams are now safely contained under the Irish Sea. Methane is a potent greenhouse gas.  The developers consultant AECOM has estimated that 74% of the on-site emissions would be the methane emitted from the exposed coal in the mine.  The developers say that “The installation of a methane capture and utilisation plant will potentially eliminate the majority of fugitive methane emissions.”

Methane would continue to be emitted from the broken up coal up till and including the point of use at a steel works.  Methane drainage would potentially only remove a small fraction of total methane.
d.  Zero Carbon Britain – The developers state “If the emissions are less than 1% of the relevant carbon budget, the level of significance is considered to be minor adverse”.   In the context of this long lived coal mine this is nonsensical.  The coal mine is set to continue over 70 years.  By peak production the wildly optimistic 1% of UK carbon emissions from this coal mine would be 5%, 10%  – 20% or even more of an otherwise decarbonised Britain.  In June 2019 the UK became the first major economy to pass net zero emissions law.  The new target will require the UK to bring all greenhouse gas emissions to net zero by 2050.

e. Carbon Neutral.  Cumbria County Council declared a climate emergency in September 2019 and says it is committed to becoming carbon neutral.  West Cumbria Mining have stated in their amended planning applicationand in response to theGreen Alliance Report, that the Coal Mine would NOT be carbon neutral (despite having previously led people including Cumbria County Council to believe that it would be).  In their amended planning statement West Cumbria Mining propose that they have ongoing monitoring requirements on the Development (from 2033 onwards) in order to stop operations past this date if the coal mine compromises the UK’s ability to meet its emissions targets.  This is disingenous.  Cumbria County Council should be brave enough to call a halt to this coal mine sooner rather than later.  

f.  Subsidence and Cement Paste.  The developers propose to fill the voids left by mining with a cement paste in an effort to avoid subsidence of the vulnerable Irish Sea bed and onshore area.  They say the cement backfill :  “will be primarily targeted to sensitive areas including all onshore panels and selected panels close to the Marine Conservation Zone.”  

The planned annual production after 5 years will reach a steady state and is estimated at 2,780,000 tonnes of metallurgical coal, and

150,000 tonnes of reject. The reject will be blended with water and a binder (e.g. cement) and the resultant paste material will be pumped back underground and placed directly behind a working panel as it is mined. When used, the paste will fill an estimated 65 % of the void space behind a worked panel. The use of the paste backfill will significantly increase the stability of mined-out areas and subsidence over backfilled panels will be reduced by at least 65 %. This applies to both single panels and to groups of panels. For example, for a single panel with 65 % backfill the maximum vertical displacement will be reduced from 21 cm to 9 cm. There will be sufficient paste produced each year to fill two of the eight panels mined each year, i.e. 25 % of panels will be backfilled. Backfill will be primarily targeted to sensitive areas includ- ing all onshore panels and selected panels close to the MCZ.

(MCZ referee to Marine Conservation Zone – quote above from WCM Process Change_R10) 

Marine Conservation Zone Areas – Map by North Western Inshore Fisheries and Conservation

 

This is the area of West Cumbria Mining’s Plan

Cement Paste Backfill (of the “panels” – the voids left by the mining process)   is a relatively new and unstable process.  “many factors such as sulfate presence, geothermal factors, and rock pressure in a mine water context have significant effects on the properties of Cement Paste Backfill.”   The last thing needed near the Sellafield nuclear waste plant is a new coal mine with unstable ‘cement paste backfill.’

The Colourful Coast Partnership has noted that : “The impact of any level of subsidence upon the terrestrial or marine hertiage assets and designated sites and landscapes could be significant and permanent, therefore having a detrimental impact…the history of contamination of watercourses in the area raises concerns…”

The Irish Sea bed has been in reciept of Sellafield’s reprocessing wastes for many decades and any resuspension of those radioactive and chemical wastesis to be avoided.

Local planning authorities such as Cumbria County Council 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.   Sellafield is less than five miles from the area of mining proposed in the WCM development.  We have seen no detailed risk assessments for this.

g.  “Water is heavily used in coal processing”   Exactly how much Groundwater would the mine abstract daily from the Byerstead Fault at full peak production ?  West Cumbria Mining have not given any indication of fresh water abstraction. No research has been done on the hydrological and geological impact of this abstraction from the Byerstead Fault?   

“Water is heavily used in coal processing and would be obtained from the following sources:

• • Groundwater (Byerstead Fault)
  • Recycled from the CHPP
  • Mine water ingress
  • Moisture in the coal
  • Harvested rain-water “

(WCM presentation to CCC 19th March 2019)

h.  Blight from Construction and operation.  West Cumbria Mining’s own Environmental Assessement says “the construction and operational activities of the proposals ‘have the potential to generate a number of land contamination related adverse impacts on identified receptors.’ And that “the significance of residual effects related to potential geological and contamination related impacts associated with the Proposal during the construction and operation phases are likely to be minor or moderate adverse, and therefore not significant.”  The blight for  people living near the proposal would be Very Significant. The would experience the coal mine blight of toxic mine tailings, coal dust, chemical pollution,  rail wagons,  and associated noise.  The beginning of the first section of Wainwright’s Coast to Coast walk would be impacted by the noise and disturbance of the coal mine’s rail loading facility.  Should Cumbria County Council approve this plan they would be in contravention of Cumbria’s Statutory Development Plan (SDP)-Cumbria Minerals & Waste Local Plan; POLICY SP15 Environmental Assets. “Protect, maintaintain and enhance people’s overall quality of life and the natural, historic and other distinctive features that contribute to the environment of Cumbria and to the character of its landscapes and places”

 

 NOTE:

Cumbria County Council Minerals and Local Waste Policy DC13 15.16

“Planning applications for coal extraction will only be granted where; 

•  the proposal would not have any unacceptable social or environmental impacts; or, if not
  
• it 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.
  
• For underground coal mining, potential impacts to be considered and mitigated for will include the effects of subsidence including: the potential hazard of old mine workings; the treatment and pumping of underground water; monitoring and preventative measures for potential gas emissions; and the disposal of colliery spoil. Provision of sustainable transport will be encouraged, as will Coal Mine Methane capture and utilisation.”