It has taken a while to properly ponder this letter recieved via Tim Farron MP for Westmorland and Furness, from Andrew Bowie, Minister for Nuclear. In it the Minister for Nuclear accuses me of “harassment” of the CEO of West Cumbria Mining – this harassment amounts to four and a half letters worth written every year since 2020 regarding the alarming and continuing appointment of the coal mine CEO to advise Government on their Delivery of a Geological Disposal Facility for heat generating nuclear wastes. The letters and petition are largely to the Dept for Business, Energy and Industrial Strategy, now the Dept for Energy Security and Net Zero and ask for the removal of the Coal Boss from the Committee on Radioactive Waste Management – the UK Government’s expert voice on geological disposal of nuclear wastes.
The letter and petition of almost 2000 signatures can be seen here.
The reply from Andrew Bowie Minister for Nuclear and Renewables is below with some of my comments in red.
So far the media and it has to be said NGOs have barely raised an eyebrow about this preferring to focus on climate/steel/jobs aspects of the earthquake inducing coal mine just a few miles from what is likely to be the biggest pile of plutonium in the world (the plutonium is not earmarked for a deep geological disposal facility – that would be likely to stay right where it is on the Lake District coast)
The following letter was published in last weeks Whitehaven News
Dear Editor,
It’s such bad form to blow your own trumpet but I believe I was the first person in the world to set up a campaign to oppose the first deep coal mine in the UK in over 30 years (Cumbrian Climate Activists in London by Ollie Rawlinson Nov 2nd 2023). Back in 2017 at the outset of the campaign “Keep Cumbrian Coal in the Hole (and Nuclear Waste Out)” I remember well how utterly painful and frustrating it was trying to encourage climate activists and climate authors to oppose the mine. Invariably the answer was we “don’t have time” or “know enough” to oppose the earthquake inducing coking coal mine just a few miles from Sellafield.
The nuclear aspects of the coal mine, its guarantee of inducing earthquakes in close proximity to Sellafield, were totally airbrushed out of the mainstream narrative when climate activists did get involved. When the coal mine was approved by Cumbria County Council in 2019 the CEO of West Cumbria Mining told me at the planning meeting to “get a conscience Marianne!”
I could not have imagined in my worst nightmares that just a week later, the coal mine CEO Mark Kirkbride, would be appointed to the Committee on Radioactive Waste Management to advise the UK Government on “investigation techniques, costings and construction” of a very deep, very hot and very radioactive nuclear dump adjacent to his coal mine. This hair raising scandal has been ignored for so many years and continues to be ignored.
While climate activists shout for “action” and “clean energy,” the nuclear industry and our nuclear obsessed government are only too keen to oblige. With nuclear power now calling itself “clean” and the means to brush extremely hot (literally upwards of 100 degrees c) radioactive nuclear wastes under the carpet, or in this case, the Lake District coast and the Irish Sea. It is scary that ‘climate activists’ in Cumbria repeatedly fail to oppose the nuclear industry (which is one of the North Wests biggest users of fossil fuel) and fail to challenge the industry’s Orwellian claim on the word “clean.”
Cumbria is being pushed ever closer to an ever more toxic nuclear future that could return us to a time when the planet was too radioactive for life. Coal and nuclear are now hand in glove in Cumbria but only nuclear has the brass neck to claim it is “clean”. 55,000 people have signed a petition against coal boss Mark Kirkbride’s advice on “investigation techniques” for a nuclear dump which has seen devastating seismic blasting with “unusal” deaths of harbour porpoises, dolphins, pilot whale and more https://www.change.org/p/save-the-whale-and-the-snail-stop-nuclear-waste-services-blasting-the-irish-sea. Hundreds have signed a petition to reclaim the word “clean” from the nuclear industry Petition: Stop calling uranium mined fuels “clean energy”. Will climate activists widen their gaze in Cumbria? To continue to ignore the very hot and very radioactive nuclear elephant in the room (held up as a “solution”) is to guarantee extinction.
The facebook group Pit Crack West Cumbria is featuring poems promoting West Cumbria Mining (at any cost it seems) and ridiculing Keep Cumbrian Coal in the Hole and ‘Green Marianne’ hey ho.
Any way here is a little poem in reply to Pit Crack Cumbria I’ve just tried to post on the facebook group but it was blocked. Here it is.
Pit Cracked Cumbria
The Cavalry is Here
Its West Cumbria Mining
Currently Focussed on Coal
But thats Just a Blinding
The Big Money’s on Nuclear
The Hole would be Deep
Deeper than Scafell is high
n’ Fifteen Miles Square Peeps
with Artificial Intelligence
Giant Moles Underground
Creep Creep Creep
Who Cares if the Water’s Acid Orange
In the Harbour -“Give us New Coal”
Is the Nostalgic Clamour.
Dripping with Memories of Days
Long Ago Where the Axe and the Blast
Will No Longer Go. Now it is Massive
Tunnel Boring Machines Giant Moles
Massive Dust and Damage Aglow
Its all climate friendly and clean clean CLEAN dontcha know
The following letter has just been sent to the Coal Mine Planning Inspector Mr Stephen Normington following a letter from the Rt Hon Greg Hands, Minister of State for Energy, Clean Growth and Climate Change (this Govnt department appointed the coal mine boss as “invaluable” nuclear dump advisor).
Dear Planning Inquiry Inspector Mr Stephen Normington,
Happy New Year to you and yours.
We, Radiation Free Lakeland (who run the Keep Cumbrian Coal in the Hole campaign) are aware that you will shortly be making a recommendation to the Secretary of State on West Cumbria Mining’s coal mine plan.
We would like to draw your attention to a letter (attached) we have received from the Rt Hon Greg Hands, Minister of State for Energy, Clean Growth and Climate Change. The reply is to our letter requesting that, should the coal mine be approved by government, then a seismic Traffic Light System at least as stringent as that for the oil and gas industry should be part of the conditions imposed. The empirical evidence (presented by Radiation Free Lakeland at the Planning Inquiry) is unequivocal in its findings that coal mining produces earthquakes of far greater magnitude and frequency than that of fracking. Despite this Greg Hands MP states that there will be no Traffic Light System for the coal mine.
In tandem with the absence of a seismic Traffic Light System is the outrageous allowance of 6mm/s Peak Particle Velocity as agreed by the Inquiry’s Rule 6 Parties and Developer for ground movements as a result of the deep mining proposed. As you will be aware the PPV at which “receptors” will make complaints is 1mm/s.
An observer of the bulk of the Planning Inquiry would have had no idea of the uniquely dangerous sense of place regarding the planned coal mine. If this same coal mine was anywhere in the world the climate impacts would be the same. But this coal mine is not anywhere in the world. It is five miles from Sellafield, the worlds riskiest nuclear waste site, under the arguably most radioactively contaminated sea in the world and directly beneath the radioactively contaminated Cumbrian Mud Patch.
You will see In his reply to us the Minister answers a question we did not ask – namely the use of the coal mine as a nuclear dump – no one in their right mind would think of using a coal mine as a nuclear dump, our concerns lay with the undeniable connections/cronyism between the coal mine and the proposed Geological Disposal Facility.
The Government’s refusal to consider a seismic Traffic Light System for the earthquake inducing coal mine is a case in point.
Mark Kirkbride the CEO of West Cumbria Mining was appointed in 2019 as an “invaluable” adviser to the Government (Committee on Radioactive Waste Management) on the digging of big holes for a Geological Disposal Facility for Heat Generating Nuclear Wastes and for shallower Near Surface Disposal of Low and Intermediate Level Nuclear Wastes.
We are painfully aware, as no doubt is government nuclear dump advisor Mark Kirkbride, that a seismic Traffic Light System for an earthquake inducing deep undersea coal mine would also impact negatively on the facilitation of an even deeper hole for a GDF. The Irish Sea area adjacent to the coal mine is in the frame for a GDF.
We urge you to take all these related issues into consideration and emphatically advise refusal for the deep coal mine which is far more than the sum of its (more widely reported) climate/jobs parts. Should this coal mine go ahead the people and environment of Cumbria and the planet WILL be exposed to deep radiological, immediate and irreversible impacts that will make the more widely reported and not to be sneezed at climate impacts pale into insignificance.
The whole thing feels like a massive stitch up in which the climate issues have been used as a smoke screen to hide the nuclear impacts of this coal mine. If Leonardo DiCaprio (of “Don’t Look Up” fame) thinks climate campaigners have it bad he should walk a mile in the shoes of nuclear safety campaigners!
Please ensure the safety of Cumbria and the planet by emphatically advising refusal for this out of control deep coal mine five miles from Sellafield.
Thank You.
Yours sincerely,
Marianne Birkby Radiation Free Lakeland who run the Keep Cumbrian Coal in the Hole campaign
Both West Cumbria Mining and Radioactive Waste Management (who are advised by one Mark Kirkbride, coal mine CEO) are keen to deflect any attention from the direct connections between the coal mine and the GDF (of which the CEO of WCM has already given the government “invaluable” advice on the digging of the big hole).
If the coal mine is the route whereby the GDF is reached both physically and by design then there is a direct connection. If the coal boss is advising RWM there is a direct connection (he is). If the same companies are being promoted by the coal boss to deliver the GDF as are on the WCM supplier list there is a direct connecton (they are). If the area in the frame for GDF is directly adjacent to the coal mine meaning that the same access tunnels could be used there is a direct connection (it is). If the voids made by the coal mine could be used for GDF rock spoil there is a connection (they could). If the borehole research for the coal mine is in the same area as the GDF there is a direct connection (it is). In the light of the COP26 discussions, in which Australia opposed the phasing out of coal, (bringing tears to Alok Sharma’s eyes), the role of the Australian, EMR Capital, via WCM, in this whole dodgy business is just the icing on the orchestrated mess which ends in Cumbria being lined up for a GDF directly alongside a coal mine.
This screenshot below is from RWM’s website – see how they avoid the question! Of course there is a connection – everyone can see it. Of course no one in their right mind would put nuclear waste in (or near) a coal mine (although they already tried at Keekle Head). All the connections of cronyism and use of the coal mine to facilitate the infrastructure for a GDF are undeniable and Radioactive Waste Management have not attempted to deny any of them. All they do is repeat the diversionary mantra that the two are “unconnected” in that heat generating waste will not be directly shovelled into the coal mine – OK so what about all the other questions ? Tell us the truth for once.
Why are the seismic and subsidence issues being ignored by NGOs and media? That is for them to answer. Whatever the reason the ongoing silence it is putting us all at immediate danger of an unlivable radioactively contaminated environment.
This is the latest in the extensive evidence on earthquakes caused by deep coal mining …
Different from the shallow coal seam, in deep mining, the dynamic response of overlying rock has changed significantly due to the high in-situ stresses and complex geological conditions. The frequent occurrence of strong mine earthquakes seriously restricts the safe and efficient mining of deep coal resources. This paper investigates the distribution and evolution of strong mining earthquakes during the process of deep coal seam mining in Dongtan coal mine of China by means of the microseismic monitoring and surface subsidence monitoring technologies. Results show that strong mine earthquakes occurring in the 1st square of the single goaf in each working face take the largest proportion. Most of the mine earthquakes are basically concentrated in the lower hard rock layer in the early mining stage. As the working face advances, mine earthquakes primarily rise straightly to the far-field hard layers. In the early stage of coal mining, the frequency of earthquakes is significantly high. After the mine earthquake goes into the higher hard strata, the frequency of strong mine earthquakes in lower layers decreases. The strong mine earthquake occurs with higher probability when the surface subsidence rate changes rapidly. When multiple layers of hard rock exist, the overburden fracture behaviors become complicated. A large energy mine earthquake in far-field overlying hard strata during deep coal mining is generally caused by the coordinated fracture of multi-strata, which can be reflected by the waveform of mine earthquakes.
Article highlights
The distribution and evolution of strong mine earthquakes during the process of deep coal seam mining are investigated.
As the working face advances, mine earthquakes primarily rise straightly from low field hard strata to the far field.
The strong mine earthquake wave characteristics and surface subsidence behaviors when the earthquake occurs are also investigated.
Not to mention the Subsidence and the Radioactive Mud Patch
This is our response to West Cumbria Mining and the Council’s agreement on conditions should the Secretary of State rubberstamp WCM’s coal mine.
We vehemently disagree with the conditions on seismicity and subsidence as agreed by WCM, the Rule 6 parties and Cumbria County Council. We ask for evidence of justification from WCM for the generous conditions on subsidence and seismicity. The very small concession to monitor all seismicity is meaningless when the limits set at which actions would be taken are generous and the outcome is not to halt operations but for WCM to merely deliver a report.
We are devastated to have been sent the report by (WCM) planning advisors, IC Planning, that: “The Rule 6 parties, Friends of the earth and SLACC, have both confirmed that they have no issuewith the subsidence and seismic activity condition as they are currently drafted. Both parties have provided extensive commentary on a wide range of other conditions and aspects of the proposals, but have not chosen to do so in relation to these specific conditions.” (Note: SLACC have contacted me saying they “do not agree” with the conditions on seismicity and subsidence – lets hope that disagreement from SLACC is voiced in the final conditions).
We agree with the former UK climate envoy John Ashton who has said: “It is morally incoherent” to focus on climate without looking at subsidence of the contaminated Irish Sea bed and induced seismic impacts on the Sellafield site. It will be interesting to see how this all plays out given that the coal boss Mark Kirkbride is employed by Government to advise on nuclear waste plans, his expertise is, after all, in digging very big holes https://www.lakesagainstnucleardump.com/post/government-take-advice-from-coal-mine-boss-over-deep-nuclear-dump-plans .
“WCM can approach these parties and request access to monitor using their electricity and wifi but cannot guarantee permission will be granted.”
RFL Response: WCM must be responsible for providing power and wifi for equipment used in seismic monitoring at high vibration- sensitive and high hazard consequence onshore receptors in the region such as i) West Cumberland Hospital ii) South Egremont boreholes utilised for public drinking water and Sellafield. The receptors should not be responsible for providing electricity and monitoring for WCM.
Unless seismic activity is taking the very long route by road, the shortest distance from the nearest point of the coal mine’s subsea area identified by WCM’s location maps is South Egremont under 4 miles and Sellafield, five miles. Unless WCM can prove otherwise their disingenous claims on distance between the nearest point of the subsea coal mine and the highly vulnerable receptors, should be struck out of official records.
Images – Distances from WCM’s mining interests to receptors, taken from the “as the crow flies” distance calculator http://www.tjpeiffer.com/crowflies.html and WCM’s location map with RaFL additions.
67 Seismic Activity – Investigation
WCM Response
“1mm/s threshold is unreasonable and impractical, – suggest retaining 6mm/s as per original condition.”
RFL Response
What evidence is there that the 1mm/s peak particle velocity threshold agreed by the Planning Inspector during RFL’s contribution to conditions is unreasonable and impractical?
WCM’s 6mm/s PPV is the threshold used for blasting and 1mm/s is the point at which residents will complain of vibrations.
WCM Response
“This is not a fracking project”
RFL Response
If this was a fracking project a stringent Traffic Light System would by legal requirement be put in place – as Cuadrilla have said: “It should be noted that the Traffic Light System required for hydraulic fracturing in the UK is significantly more stringent than the maximum ‘allowed’ induced seismic event for other hydrocarbon industries in the UK such as coal mining where magnitude >3.0ML events have been observed”. Cuadrilla Environmental Statement Appendix 1. Induced Seismicity May 2014 Preston New Road.
WCM Response
“Unreasonable to stop if cause not known. Outside body not defined.”
RFL Response
If the cause is not known operations should be halted until the cause is known. The “Outside body” refers to the appropriate regulatory authority.
68 Seismic Activity – Mitigation
WCM Response
“Suggest the WCM TLS =
C66 – continuous monitoring (Green)
C67 – investigation if PPV > 6mm/s (Amber)
C68 – mitigation if investigation demonstrates WCM at fault (Red) Although a case could be made from the references later to increase the threshold, WCM have not pursued this”
RFL Response – WCM TLS applies only to PPV not to Magnitude of earthquake
C66 – continous monitoring (GreenP
C67 – investigation if PPV > 1mm/s (Amber)
CC8 – halt to operations if investigation demonstrates WCM at fault (Red)
Magnitude TLS Green light a seismic event up to 0.0 occurs operations continue normally.
Amber light: A seismic event between 0 and 0.5ML occurs during mining within the operational boundary (a specified geographical area). Operations continue with caution unless this coincides with a peak particle velocity of 1mm/s and then operations should halt.
Red light A seismic event of 0.5ML or greater occurs within the operational boundary or within the near region up to 5 miles.
69 Subsidence Monitoring
WCM Response
“Prawn fishing in the mud patch and weather conditions are more likely to have an influence.”
RFL Response
What evidence does WCM have that “prawn fishing” and “weather” are more likely to have an influence on resuspending radioactive silts from the Cumbrian Mud Patch than subsidence and climate impacts ?
We have searched for referenced academic research studies of the volume/mass of seabed sediment re-suspension following prawn trawling in, or near, the unique seabed fine sediment feature known as the Cumbrian Mud Patch. We have found no reference to any such studies.
We challenge WCM to provide the referenced academic research data on which they base their claim that sediment re-suspension generated by shrimp trawling and weather factors will generate a greater degree of sediment re-suspension than sub-seabed mining subsidence.
Unless WCM can produce copy of the relevant, fully referenced academic data we urge the Inquiry to regard the WCM statement/claim as spurious and un-substantiated, to disregard it, and to ensure that it is struck out of any record of official proceedings.
If WCM can produce copy of the relevant, fully referenced academic data, we request that the material be regarded as late submitted evidence and that we be granted an extension period in which we can review, consider and respond to this late submitted evidence. If such a time extension is not available or not permitted we formally request that the late submitted evidence be withdrawn and that any reference to the WCM claim be struck out of the record of of official proceedings.
We note that the North Western Inshore Fisheries and Conservation Authority provided an early submission to Cumbria County Council on Subsidence saying:
“impact on shoreline profile and wave heights. NWIFCA note that WCM propose a ‘no mine zone’ within Cumbria Coast MCZ and St Bees SSSI which we welcome. WCM state that “Given the small predicted seabed height changes, the slow rate of subsidence and the small changes in slope, combined with the fact that subsidence will not occur over the whole mined area it is likely that impacts on statutory protected areas in the vicinity of the development (i.e. the Cumbria Coast MCZ and the Solway Firth pSPA) will be negligible”.
This does not dispel concerns over potential for subsidence of the seafloor outside of these Protected Areas which could have impacts on the benthos plus potential consequences to shoreline profile and wave heights, which could in turn result in unintended consequences that would affect these protected sites and elsewhere.Data and understanding are limited at the present time and in order to address this, WCM will commission surveys and a numerical modelling study to more accurately predict the potential impacts, if any, of subsidence on the intertidal and marine environments, to be completed prior to commencement of works.
“Data will also be gathered regarding subtidal communities to determine the distribution, extent and likely responses of any potential sensitive receivers. In addition, a Marine Monitoring Plan will be implemented to monitor the bathymetry of the seabed and surficial sediments properties (including benthic communities) overlying the extraction zones using the data collected in 2016-17 as a baseline”.
NWIFCA would ask who the regulator for subsidence risk is and stress the need for further dialogue and engagement over this issue once predictions of potential impacts have been produced.
The NWIFCA have said that they “will respond formally to an MMO consultation”.
70 Subsidence – Investigation and reporting
WCM response
“Chapter 17 and the HRA did not come to a conclusion that this would occur. CCC have considered this 3 times and have not sought such a condition”
RFL response
It was assumed by the NWIFCA, the County Council and NGOs that the subsea impacts of this coal mine would be scrutinised by a Marine Management Organisation consultation. The onshore impacts from subsea mining induced seismicity and subsidence ( including radiological impacts and the question of who is liable should the “expected subsidence” result in resuspension of Sellafield’s wastes from the mud patch) would be one of the issues given scrutiny in a public consultation by the MMO. However, WCM have said that they “may not need” a MMO licence. What is the evidence for this statement? Has a pre- licence application been submitted behind closed doors ?
71 Subsidence – Mitigation
See above.
Refs North Western Inshore Fisheries and Conservation Authority Ref No: 4/17/9007 RE: Consultation on Further Information submitted in relation to a Mineral County Matter Application for Planning Permission accompanied by an Environmental Statement 29th January 2018 – full document attached“Offshore Subsidence – resuspension and dispersal of radioactive contaminants. The documentation has confirmed to NWIFCA that a risk of subsidence exists and therefore there remains an overwhelming concern over the potential for disturbance and resuspension of radioactive contaminants and sediments.”
The result of this would be that the seismic and subsidence issues having not been addressed by Rule 6 Parties in the Planning Inquiry will also not receive any scrutiny in a public consultation from the Marine Management Organisation. The Mineral Planning Authority of Cumbria County Council has the responsibility to manage conditions for any onshore effects and harms resulting from Woodhouse Colliery should Michael Gove approve the mine. But if their source of origin is subsea, the local planning regime outsources responsibility to the UK government’s Marine Management Organisation, from whom the developers clearly expect a rubber stamp.
If a rubber stamp is to be issued by Government (who employ the coal boss as a nuclear waste ‘disposal’ advisor at the Committee on Radioactive Waste Management https://www.gov.uk/government/people/mark-kirkbridg) it is imperative that a seismic Traffic Light System for the Woodhouse Colliery is implemented. The TLS should be at least as stringent as that for fracking.
“MORALLY INCOHERENT” In his statement to the Planning Inspector, the independent speaker and writer, formerly UK climate envoy 2006-12 John Ashton CBE included the following points. https://www.itv.com/news/border/2021-09-08/cumbria-coal-mine-inquiry-evidence-from-day-two : “it is also dysfunctional that the terrestrial and marine dimensions are being considered separately. I understand the procedural reasons. But it is the consequences of the project as a whole that will shape the lives of those in the firing line. It is both intellectually and morally incoherent, as well as administratively inefficient, to subdivide those consequences: to consider the climate implications, for example, without looking at the risks arising from the destabilization through subsidence and seismicity of Sellafield waste on the seabed above the mine.” Although the former UK Climate Envoys’ statement was widely reported the points he made on seismicity and subidence never made it into the headlines.
Pundits a-plenty are asking if Boris will bolster his climate credentials by scrapping the £160m coal mine. The CEO of West Cumbria Mining must be having a little smile. He has much bigger and much more dangerous fish to fry. When the question of the coal mine comes up at the G7 it can be guaranteed that Boris will make some climate noises but will keep entirely schtum about the fact that his government has asked the coal boss to come up with costings for the biggest and most dangerous deep pit in UK (not to mention world) history.
The deep pit in question is the hole for a deep nuclear dump to “dispose” of heat generating nuclear wastes. The coal boss has advised government use the same company as his coal mine for its giant Tunnel Boring Machines. These expensive machines usually have to be abandoned underground so having a new job to move onto (in the same place under the Irish Sea) could be lucrative for someone?
The estimated cost however at £1.7 billion for a big deep nuclear pit (thats just the cost for the hole not anything else) is way more expensive than for Mark Kirkbride’s coal mine at £160 million.
The heat generating wastes planned to go in the deep pit are the most lethal material on the planet. The plan is to dump them, leave them without supervision, without cooling and without repackaging. It is guaranteed that they will continue to heat up underground, under the Irish Sea or the land. The planetary destroying wastes then would breach the supposed safety barriers and there would be no way to stop them entering the biosphere.
This issue is being ignored by media and NGOs, but hey ho the circus is in town.
We have called upon Tim Farron MP to ask that Government scrap the farcical Public Inquiry and puts an immediate Block on the Secretive WCM Coal Authority Licences.
Dear Tim,
As the only MP in the County strongly opposing the coal mine you will no doubt share Radiation Free Lakeland’s delight that the County Council has withdrawn its support for the mine and will not now provide any witnesses or evidence to the public inquiry (scheduled for September).
As nuclear safety campaigners we have long held the belief that we had far more likelihood of persuading the Council to overturn their approval than government who have such vested interests in West Cumbria Mining’s expertise with regards the Critical National Infrastructure project of deep ‘disposal’ of heat generating nuclear wastes.
We now know the public inquiry is a farce. A farce because the County Council’s decision to approve the mine no longer exists. A farce because government have appointed the existing coal mine CEO and former Head of Operations to the Delivery of Geological Disposal of Heat Generating Nuclear Wastes with the Irish Sea area adjacent to the coal mine being in the frame. A farce because the government could stop its virtue signalling and actually scrap the coal mine tomorrow by blocking the developer’s application for new Coal Authority licences. New secretive licences which the public are being refused sight of and have no idea what they contain.
It is now more clear than ever that the enormous expense of a public inquiry could be spared. The Secretary of State for Business, Energy and Industrial Strategy, Kwasi Kwarteng MP could put his ‘coal mine should be blocked’ words into action and put the kaibosh on renewal of the developer’s licence to drill. The letter below asking for an immediate block on the licence to drill has been signed by organisations as diverse as the Ethical Consumer Research Association, CND and the Sea Horse Trust. Leading academics have also signed along with Whitehaven locals who are concerned amongst other things about the enormous ground water withdrawal that this mine would abstract from a named geological fault. Our letter recieved no media attention (in contrast to blanket coverage of the letter from organisations focussing narrowly on climate), this disparity is we believe because our letter “outs” the Government’s vested interests in West Cumbria Mining and exposes the scandalous recklessness and cronyism regarding nuclear safety. Asking the public to pay for an expensive inquiry into a coal mine whose CEO is employed by Government as a nuclear waste advisor, a coal mine which is guaranteed to flout climate and nuclear safety and would end up being a stranded asset (ready to morph into an entirely different asset?) at a time of austerity is scandalous. The mine could be stopped today.
The public inquiry is a farce and should be halted with the immediate blocking of Coal Authority licences for West Cumbria Mining. If this does not happen Government should come clean on its vested nuclear waste interests regarding West Cumbria Mining’s expertise.
Correspondence below with BEIS indicates deliberate obfuscation by Government over their role in protecting WCM interests at the expense of any social licence for the development or public scrutiny. Thank you for your continued opposition to the coal mine which is far more dangerous than the sum of its parts.
We would like to ask that Government now scraps the farcical Public Inquiry and puts an immediate Block on the Secret WCM Coal Authority Licences. Any help you can give us in achieving this “Big Ask” would be so very much appreciated.
Yours Sincerely
Marianne Birkby on behalf of Radiation Free Lakeland
Letter
29.3.21
To the Rt Hon Kwasi Kwarteng Secretary of State for BEIS
BLOCK THE CUMBRIA COAL MINE’S LICENCE TO DRILL
I am writing to you again on behalf of nuclear safety group Radiation Free Lakeland. We were the first to call out the proposed coal mine development in Cumbria and remain unequivocally opposed to the plan on both climate and nuclear safety grounds so we were delighted to hear your statement that there are “very compelling reasons” to block the mine.
BEIS ARE RESPONSIBLE FOR THE COAL AUTHORITY
The position of Secretary of State grants the wherewithal to put these words into action and to actually block the coal mine by ordering the Coal Authority (who report to BEIS) not to renew or extend existing conditional licenses or grant new unconditional licences to the developers West Cumbria Mining whose licence to drill has now lapsed.
BLOCK THE COAL MINE, SAVE THE PUBLIC PURSE EXPENSIVE PUBLIC INQUIRY
This would save the public purse the huge expense of a public inquiry and send a strong message to the UK and our international neighbours that BEIS is committed to both climate and nuclear safety.
THIS IS NOT “ANYWHERE” IT WOULD BE FIVE MILES FROM SELLAFIELD
While the significant climate impacts of this coal mine would be exactly the same anywhere else in the UK, this coal mine is not just anywhere in the UK. The mine would be largely subsea off the West Coast of Cumbria, would extend to within five miles of the world’s riskiest nuclear waste site and be directly under a massive nuclear waste dump known as the Sellafield Mud Patch. Sellafield has been pumping eight million litres of “low level” radioactive discharges into the Irish Sea every day. It been doing that for decades and nuclear wastes still continue to arrive in West Cumbria. The nuclear waste discharge pipeline out to the Irish Sea is in constant use. The coal mine developers say there would be “expected subsidence” of the Irish Sea bed. Recent reports (attached) have indicated this would most likely result in the resuspension of decades worth of Sellafield’s radioactive wastes now largely immobilised in the Irish Sea bed. Radioactive wastes including plutonium would be resuspended back into the water column, to ours and to neighbouring shores. The one thing not to do with a radioactive waste dump is disturb it.
EIGHT YEARS SINCE THE COAL AUTHORITY/BEIS RUBBERSTAMPED ORIGINAL CONDITIONAL LICENCE TO DRILL EXPLORATORY BOREHOLES. NEW EVIDENCE
The world has changed since the Coal Authority issued West Cumbria Mining with conditional licences 8 years ago. Eight years ago there was no public scrutiny as the Coal Authority was permitted to issue licences above the heads of the public and Cumbrian councillors. Eight years on and many miles of subsea ‘exploratory’ mining boreholes and core samples later, questions of climate and nuclear safety are being asked about this coal mine. Despite the controversy the Coal Authority have replied directly to us saying that there would be no public consultation into issuing West Cumbria Mining with new licences to drill, this is outrageous.
APPOINTMENT OF COAL BOSS TO GOVERNMENT ADVISOR ON NUCLEAR DUMP
As well as being under decades of Sellafield’s discharged nuclear wastes the mine itself would be adjacent to the area being promoted as a possible Geological Disposal Facility for heat generating nuclear wastes under the Irish Sea. BEIS’s wide ranging responsibilities include the provision of and management of the Committee on Radioactive Waste Management (CoRWM). The CEO of the coal mine Mark Kirkbride has been appointed by BEIS to CoRWM (Nov 2019) to advise government on ‘Delivery” of a Geological Disposal Facility (GDF). The proposed coal mine would make a void of 136 Million square metres. What destabilising impact would this have on the laterally neighbouring rocks Radioactive Waste Management (advised by CoRWM) tell us are “Possible” for a GDF
PUBLIC INQUIRY WOULD LIKELY BE LIMITED IN SCOPE – THERE ARE QUESTIONS SUCH AS COAL AUTHORITY/BEIS INVOLVEMENT IN HANDING OVER OF HAIG COLLIERY FOR £1 TO COAL MINE DEVELOPERS
These questions (and more) should, but are not likely to be within the remit of a forthcoming public inquiry focussing on planning rather than issues of governance and nuclear safety. The public have already paid out £millions for this coal mine, to be precise, £2.5 Million in Heritage Lottery Funds for the Haig Colliery Museum which was then handed over to the developers for £1 (courtesy of the Coal Authority handing the developers a pre-emption right).
As Secretary of State responsible for the Coal Authority you could ensure that the public do not have to foot the bill yet again, this time for a public inquiry into a coal mine that should have been scrapped yesterday. Tomorrow would be a good day to order the Coal Authority not to issue West Cumbria Mining with licence to drill. By taking this action the coal mine would be blocked and the expense of a public inquiry prevented.
LEADING CUMBRIAN COUNCILLORS HAD ALREADY CHANGED THEIR MINDS AND VOTED NO. A NEW APPRAISAL BY COUNCIL IS NOW SUPERCEDED BY PUBLIC INQUIRY
Leading Cumbrian Councillors had already reassessed their former support for the mine and voted “no.” Through this No vote they have voiced their opposition alongside leading academics, scientists, politicians, the public and many organisations. We urge you to honour the wishes of leading Cumbrian councillors and the millions of people represented by this letter and block this coal mine. The reasons for doing so are not just “compelling” they are overwhelming.
The mine could be stopped tomorrow and the buck stops with BEIS.
Yours sincerely,
Marianne Birkby, founder of Radiation Free Lakeland Keep Cumbrian Coal in the Hole – a RaFL campaign Brian Jones, Vice Chair, CND Cymru Jo Smoldon on Behalf of Stop Hinkley Jonathon Porritt, Rebecca Heaton Cooper, The Heaton cooper studio, Grasmere Terry Bennett, Emeritus Professor, Nottingham University Kate Hudson, General Secretary, Campaign for Nuclear Disarmament Anita Stirzaker, Bowness business owner Alison Denwood, George and Dragon Public House, Harrington, West Cumbria Harry Doloughan, Whitehaven Simon Burdis, Northern England, family carer Philip Gilligan, South Lakeland and Lancaster District CND Dave Webb, Chair, Campaign for Nuclear Disarmament David Smythe, Emeritus Professor of Geophysics, University of Glasgow Dr Paul Dorfman, UCL Energy Institute Dr Rachel Western Postcards from Cumbria – artists collectiveDavid and Una Hatton, Wigton, Cumbria, Sarah J Darby BSc DPhil Associate Professor, Environmental Change Institute, University of Oxford Samagita Moisha, Lancaster. Concerns for nuclear safety presented to Cumbria CC at both committee hearings Tim Deere-Jones, Marine Research & Consultancy Joan West, Cumbria and Lancashire Area CND Martin Kendall, Resident High Walton, Near Whitehaven Oliver Tickell, journalist and campaigner Irene Sanderson, North Cumbria Campaign for Nuclear Disarmament Walter Bennett, I am 90 years of age, born in Frizington, Cumberland, son of a coal miner, (former Director responsible for Technology in an International Company) Dr Carl Iwan Clowes OBE, Fellow Royal College of Physicians Faculty of Public Health, Honorary Fellow of the Royal College of General Practitioners Mag Richards, WANA, the Welsh Anti-Nuclear Alliance Ian Ralls, Anti-Nuclear Campaigner Neil Wilson, Life Long Conservationist, Hodbarrow Mine Action to the Royal Courts of Justice London Greenpeace, Core Participant within Undercover Policing Public Inquiry (Spycops) Richard Bramhall, Low Level Radiation Campaign David Penney, Coordinator, Cumbria and Lancashire Area CND Martyn Lowe, Close Capenhurst Campaign Andrew Warren, former special advisor to the House of Commons environment select committee. Neil Garrick-Maidment FBNA, Executive Director and Founder, The Seahorse Trust Christine Gibson, Keep it Green, Northern Ireland
Mark Jennings, West Cumbria Water (Save our water services} David Dane, Veteran Campaigner
Rob Harrison, Ethical Consumer Research Association.
References
BEIS Ministerial Responsibility for the Coal Authority
“Ministerial responsibility 11. The Secretary of State for Business, Energy and Industrial Strategy is accountable to Parliament for the activities and performance of the Authority and it is proposed that any new Minister with responsibility for the Authority will carry out a visit to the Authority within six months of taking up appointment to learn about the role of the Authority and its functions. Typically, we would expect the chair and chief executive to meet with the minister at least annually. 12. Specific responsibilities include: approving the Authority’s overall strategic objectives and the policy and performance frameworkwithin which the Authority operates (as set out in this framework document and associated documents keeping Parliament informed about the Authority’s performance approving the amount of grant-in-aid/grant/other funds to be paid to the Authority, and securing Parliamentary approval carrying out responsibilities specified in the Act including appointments to the board, determining the terms and conditions of board members, consenting to the appointment of the, approval of terms and conditions of staff (Including pay) in accordance with the latest pay guidance laying of the annual report and accounts before Parliament”
Sellafield Radioactive Discharge on the Irish Sea Bed directly beneath the coal mine plan and question of ‘Who is Responsible for Safety of the Discharged Nuclear Wastes?’ is subject to complaint being dealt with by the Information Commissioner https://www.whatdotheyknow.com/request/responsibility_for_discharged_ra
Letter from the Coal Authority (who are a BEIS authority) to Radiation Free Lakeland
.”This site currently has 3 conditional licences which have been in place since 2013/14. A conditional licence allows coal exploration and would need to be replaced by a full licence in order for coaling to begin. On 18th January 2021 date West Cumbria Mining Ltd applied to extend the end dates of 2 of these conditional licences (UND/0184 & UND/0177). They were due to expire on 24th January 2021 but they will remain in place until the application to extend them has been determined. No exploratory works will be undertaken during this time. The application will take approximately 3 months to determine. If the conditional licences were extended the operator would still need to apply for one or more full coaling licences before coaling can begin. When the conditional licence extension application has been determined the outcome will be posted on our website: https://www.gov.uk/government/publications/coal-mining-licenceapplications.
note: the Coal Authority later confirmed there would be no public consultation or scrutiny over the issuing of new licences to drill for West Cumbria Mining. The public are not being allowed sight of the new licence appliations from West Cumbria Mining
Coal Mine developers, West Cumbria Mining have asked the *Coal Authority for new licences. Do Not Rubber Stamp the Developer’s Licence to Drill.
*The Coal Authority report to the Dept of Business, Energy and Industrial Strategy. Kwasi Kwarteng MP is the Secretary of State
Why is this important?
BLOCK WEST CUMBRIA MINING’S LICENCE TO DRILL
Leading Cumbrian Councillors had already reassessed their previous unanimous support for the first deep coal mine in decades in the UK and voted “No.” Through this No vote they have voiced their opposition alongside leading academics, scientists, politicians, the public and many organisations.
The reasons for saying No to new licences for West Cumbria Mining are not just “compelling” as Secretary of State Kwasi Kwarteng MP has stated, they are overwhelming.
There is zero need for a public inquiry at the expense of the public purse. The mine could be stopped tomorrow. All it would take is for the Coal Authority to block the developers new applications for a Licence to Drill. It is shocking that details of the new licence applications are being kept secret and from public scrutiny despite Freedom of Information requests from nuclear safety group Radiation Free Lakeland.
CLIMATE AND NUCLEAR SAFETY …OR RECKLESSNESS?
A block on the developer’s new applications for a Licence to Drill would not only save the public purse the huge expense of a public inquiry it would also send a strong message to the UK and our international neighbours that the Department of Business, Energy and Industrial Strategy, who are responsible for the Coal Authority, are committed to both climate and nuclear safety.
While the significant climate impacts of this coal mine would be EXACTLY the same if this development had been proposed anywhere else in the UK, this coal mine is NOT JUST ANYWHERE in the UK. The mine would be largely subsea off the West Coast of Cumbria, would extend to within five miles of the WORLD”S RISKIEST NUCLEAR WASTE SITE and be directly under a massive nuclear waste dump known as the Sellafield Mud Patch.
COAL MINE UNDER AN EXISTING NUCLEAR WASTE DUMP?
Sellafield has been pumping eight million litres of “low level” radioactive discharges into the Irish Sea every day. It been doing that for decades and nuclear wastes (military and ‘civil’) still continue to arrive in West Cumbria. The nuclear waste discharge pipeline out to the Irish Sea is in constant use. The coal mine developers say there would be “EXPECTED SUBSIDENCE” of the Irish Sea bed. Recent reports have indicated this would most likely result in the resuspension of decades worth of Sellafield’s radioactive wastes now largely (but not completely) immobilised in the Irish Sea bed. Radioactive wastes including plutonium would be resuspended back into the water column, to ours and to neighbouring shores. The one thing not to do with a radioactive waste dump is disturb it.
COAL MINE ADJACENT TO A NEW HIGH LEVEL NUCLEAR WASTE DUMP?
The mine itself would be adjacent to the area being promoted as a “possible” Geological Disposal Facility for heat generating nuclear wastes under the Irish Sea. The CEO of the coal mine Mark Kirkbride has been appointed to the Committee on Radioactive Waste Management to advise government on “Delivery” of a Geological Disposal Facility (GDF). The proposed coal mine would make a void of 136 million square metres. Would this handy hole be used to dump mountains of rock spoil excavated for a GDF from neighboring rocks? What destabilising impact would this have on the neighbouring rocks? Is there a massive unresolvable conflict of interest at the heart of the forthcoming coal mine public inquiry? The final decision about the climate and nuclear dump-wrecking mine will rest with the government – the same government who have appointed the coal mine boss to position of top government nuclear dump advisor (for highly active wastes).
FARCICAL PUBLIC INQUIRY?
These questions (and more) should, but are not likely to be within the remit of a forthcoming public inquiry focussing on planning rather than key issues of governance and nuclear safety.
PUBLIC MONEY
The public have already paid out £millions for this coal mine, to be precise, £2.5 Million in Heritage Lottery Funds for the Haig Colliery Museum which was then handed over to the developers for £1.
This is a coal mine that the public would keep paying for in more than money and climate impacts – the many headed hydra of both a slow burn and immediate nuclear catastrophe are overwhelming.
There is no credible case for this mine either on the basis of Finance (no market ), Climate (flies in face of COP26) or arguably the most serious concern, Nuclear safety (the mine would be under decades of “low level” nuclear waste, also undermining the geology near the world’s riskiest high level nuclear waste site Sellafield).
BLOCK WEST CUMBRIA MINING’S LICENCE TO DRILL!
DO IT NOW
References
BEIS Ministerial Responsibility for the Coal Authority
“Ministerial responsibility 11. The Secretary of State for Business, Energy and Industrial Strategy is accountable to Parliament for the activities and performance of the (Coal) Authority …
Sellafield Radioactive Discharge on the Irish Sea Bed directly beneath the coal mine plan and question of ‘Who is Responsible for Safety of the Discharged Nuclear Wastes?’ is subject to complaint being dealt with by the Information Commissioner
Keep Cumbrian Coal in the Hole 
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