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.

Aquifer beneath West Cumbria in the vicinity of WCM proposal

Image: BGS

 

 

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/