Excellent “Call In” letter to James Brokenshire from West Cumbria FoE

St Bees

St Bees fragile “Heritage Coast” the scene of the first deep coal mine in the UK in decades?

Below is the call in letter sent to the Secretary of State James Brokenshire from West Cumbria Friends of the Earth.

YOU CAN SEND IN A REQUEST TOO!   The more individuals and groups asking the Secretary of State to call in Cumbria County Council’s outrageous decision to give the green light to the first deep coal mine in the UK in decades the better.

email: james.brokenshire@communities.gsi.gov.uk

The Rt Hon James Brokenshire MP,
Secretary of State for Housing, Communities & Local Government, Ministry of State for Housing, Communities & Local Government, 2 Marsham Street,
London SW1P 4DF

April 12th 2019

Dear Sir

re Planning Application ref 4/17/9007 Cumbria County Council

I am writing on behalf of West Cumbria & North Lakes Friends of the Earth to request that you as Secretary of State call in the above application for a Coal Mine on the Former Marchon Site, Pow Beck Valley and area from Marchon to St Bees Coast, Whitehaven, Cumbria. The applicant is West Cumbria Mining Ltd.

The application was considered by Cumbria County Council Development Control & Regulation Committee on March 19th 2019, and permission was granted subject to a Section 106 agreement.

Our request is based on the following:

1. Under-sea development: The development is part of a wider proposal for extraction of coal from under the Irish Sea. This is under the auspices of the Marine Management Organisation, but no proposal has been included, and the Environmental Impact Assessment (EIA) did not cover this wider proposal. Yet the cited economic and social benefits relate to the proposal as a whole and have not been separated within the application. The proposal is therefore not correctly balanced.

2. Climate change: The proposal plans to extract coal over a 50 year period, which conflicts with the UK’s target of a net-zero carbon economy by 2030.

No quantification of CO2 emissions has been offered other than to estimate ‘savings’ related to transportation of coking coal that would otherwise come from the USA. However, according to submissions at the Committee from objectors, these combustion emissions hugely outweigh the ‘savings’.
No attention has been paid to methane, N02 and particulate emissions other than a verbal assurance over methane given by the developer at the Committee meeting. Despite the mine’s objective to extract coal for making steel rather than generating energy, any mining operation on this scale and for this length of time conflicts with the aims of the Paris Agreement, the Climate Change Act 2008 and the National Policy Planning Framework.

3. Proximity to radioactive waste: The location of this under-sea mine is very close to the Sellafield nuclear waste site, just short of the jurisdiction of ONR. The risks related to seismicity and subsidence are potentially very serious. Such risks apply not only to the existing highly complex radioactive waste in such close proximity, but also to radioactive material on the sea bed due to historic discharges. These have not been considered and nor have the potential effects of other sea- bed pollutants arising from historic discharges from the former Marchon factory.

4. National Policy Planning Framework: The NPPF presumes that permission will not be granted for coal extraction for any purpose unless (a) the proposal is environmentally acceptable or (b) if not, then it provides national, local or community benefits which clearly outweigh its likely impacts.

However, the application failed to provide robust evidence of ‘need’ for coking coal in the UK steel industry. Estimates of the need for coking coal in the UK did not take into account the limited life of the Port Talbot plant and the precarious situation at the only other plant in Scunthorpe. Indeed the applicant proposes that 60-80% of the output will be exported to the EU. Yet national ‘need’, along with the benefit of jobs was given ‘considerable weight’.

The prospect of 500 local jobs for 50 years was enthusiastically embraced by Council members, understandably so given levels of poverty in South Whitehaven. But this estimate refers both to the proposal on land AND to the additional offshore proposal. Yet there was no EIA for the offshore proposal, so adverse impacts from this could not be balanced against the benefit.
Thus in relation to both benefits, the proposal has not been shown to provide benefits that clearly outweigh its likely impacts.

All these points indicate that the decision was not correctly taken and I trust you will therefore see the necessity to call it in.

Yours sincerely

Dr Ruth Balogh
Co-ordinator
West Cumbria & North Lakes Friends of the Earth

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Tweet of the Day! Stop the Cumbrian Coal Mine – Only Nesting Place of Black Guillemot in England

Dear Friends,

 

as you may know Keep Cumbrian Coal in the Hole is a small group, with a small reach so we need all of you to help and please sign the petition to the Secretary of State James Brokenshire asking him to CALL IN CUMBRIA COUNTY COUNCIL’s OUTRAGEOUS DECISION

You may not know that St Bees is the only place in England where the amazing black guillemot nests – this coal mine so close to Sellafield threatens us all, not just the black guillemot!

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PLEASE SIGN HERE TO SAVE MY NESTING PLACE

 

Nightmare Coal Mine Near Sellafield – Ooops don’t mention Sellafield.

Many thanks to Real Media for posting a guest blog – the background story and info about the coal mine fiasco that you won’t see in the main stream media.  There is an updated version below…

 

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NIGHTMARE COAL MINE NEAR SELLAFIELD?
WHAT CAN WE DO ?

NIGHTMARE
Like one of those nasty nightmares that pulls the dreamer to an inevitable conclusion it is shocking that on March 19th in Kendal, Cumbria County Council approved the plan for the first deep coal mine in the UK in decades. Nevertheless it is rather suspicious that the Committee voted unanimously to give the green light to the diabolic plan. But then, there were no background noises of dissent in the years ahead of the planning decision that might have made the Committee think twice. Quite the opposite. There was almost universal silence from the national media.

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Protest staged by Keep Cumbrian Coal in the Hole after the Unanimous vote by the Development Control and Regulation Committee of Cumbria County Council on 19th March.  Photo credit: Philip Gilligan South Lakeland  CND

Silence, apart that is, from the occasional coverage which seemed to
come direct from the developer’s press releases. There were no outraged editorials or national campaigns by big NGOs. No mention from climate guru George Monbiot. This is despite the fact that the obscene coal mine plan was rumbling nightmarishly along for so many years. Only the blogosphere was raising the alarm. Including a very strong and early shout out from Jonathon Porritt.
SO DAMN NEAR SELLAFIELD
Radiation Free Lakeland are a civil society group concerned with nuclear safety. We started a dedicated campaign in 2017 to Keep Cumbrian Coal in the Hole because we could see that this plan was going massively under the radar and because it is so damn near Sellafield’s growing stockpiles of highly active and uniquely dangerous radioactive wastes. Our frustrations grew about the coal mine and the big silence from big hitters. As a voluntary group our public reach is small. We witnessed the aggressive PR and lobbying campaign by the developers. This lobbying by the developers included winning the hearts and minds of Green minded folk  MPs and Government Departments with the hugely deceitful mantra of we ‘need a massive new coking coal mine to make the steel for wind turbines’ and presenting to the public a homey image of West Cumbria Mining despite the major shareholder being a Cayman Island fund controlled via Singapore by managers based in Australia and HongKong. For ourselves we had a premonition about the way this was going and crowdfunded to enable us to continue to fight the plan with a Judicial Review should Cumbria County Council be led down the enticing garden path to the coal mine.
At the 11th hour it was such a relief to see some big hitters publicly putting their shoulders to the wheel to stop the mine. This included Scientists for Global Responsibility whose Director Dr Stuart Parkinson spoke at the Planning Meeting saying : “I have calculated that during the main production phase the mine would lead to emissions of over 9 million tonnes of carbon dioxide equivalent for every year it is in operation. This amount is similar to the annual emissions of over 1 million British citizens. ”

And Dr Laurie Michaelis who has “worked on climate-related issues for thirty five years, been a lead author for reports of the UN’s Intergovernmental Panel on Climate Change – the IPCC – and provided technology policy advice for the UK government, European Commission and UN climate negotiators.” Dr Michaelis went on to say that: “Speaking to you feels like possibly the single most important thing I’ll do in my life….Your officers have not obtained suitable expert advice to correct the misinformation…When coal is used to make steel, 99% of the carbon content ends up as CO2 in the atmosphere….Thousands could die early because of heatwaves, disease and other causes. You will share responsibility with WCM, steel manufacturers and final users. If you refuse, coal might be sourced elsewhere; that’s the kind of argument people often use to justify wrongdoing. You can prevent this coal from being used.”

While we have as a group been lobbying climate activists for years now to actively oppose the coal mine, we have also been campaigning on the uniquely dangerous environmental impacts of this coal mine. The close proximity to Sellafield’s stockpiles of highly active radioactive wastes could have catastrophic impacts not just for Cumbria but for the whole of Europe. The deaths resulting from a seismically induced catastrophe at Sellafield could be in the millions, not the thousands described by climate scientists as a result of climate impacts from the coal mine.

Sellafield from St Bees

Sellafield viewed from St Bees

Despite this the Office for Nuclear Regulation has washed its hands of any responsibility and has provided the County Council with an excuse to be nonchalant about the close proximity of the mine to Sellafield . The ONR’s official remit to consult on planning applications is 7.4 km from Sellafield. The coal mine extends to 8km from Sellafield ie 600 metres difference.

 

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It has not gone unnoticed by Radiation Free Lakeland that the coal mine plan extends to right up to the area under the Irish Sea that is has been earmarked as ‘suitable’ as a possible site

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Image based on West Cumbria Mining’s own map

for the geological disposal of the decades of nuclear wastes resulting from the nuclear civil military industrial complex.

Nor has it gone unnoticed that there is a revolving door between the government body tasked with “facilitating geological disposal” and West Cumbria Mining. Mark Kirkbride West Cumbria Mining’s CEO has a portfolio which includes “deep geological disposal investigations” while Steve Reece formerly Operations Director of West Cumbria Mining is now Head of Site Evaluation at the government body Radioactive Waste Management who are tasked with ‘delivery’ of a Geological Disposal Facility for high level nuclear wastes.  There may be nothing suspicious in this revolving door but we have to say that the silence over this diabolic new coal mine has been almost deliberate, almost like a Defence Advisory notice or something along similar lines has been issued on this coal mine plan. A coal mine which has, ironically the full support of the nearby nuclear industry!  The Guardian’s Adam Vaughan told us in all seriousness that the paper’s editors have said they would ‘report on the plan when a decision has been made.’ That kind of Orwellian journalistic policy was guaranteed to keep the public in the dark. When the coal mine was approved what they and other media outlets did not report in their crocodile tears of mock shock and horror was that the folk who have been actively campaigning against the plan from the beginning are nuclear safety campaigners.  This not been mentioned anywhere in the National press neither has the close proximity to Sellafield, with one exception – the German Newspaper, Taz.

This coal mine should have been stopped as a result of public outcry on climate grounds alone, but it wasn’t because the public have effectively been kept in the dark about it. We are wondering Why?  

ACTION! ASK THE SECRETARY OF STATE TO CALL IN CRAZY COAL MINE DECISION

We have already delivered a petition of 1527 signatures to the Secretary of State James Brokenshire. We are however keeping the petition open to show the strength of feeling against the coal mine.  PLEASE SIGN AND OR SEND James Brokenshire a letter urging him to call in the decision (see below).

Westmorland and Lonsdale MP, Tim Farron has written asking for the decision to be called in and he has been vehemently condemned for this by the Mayor of Copeland, Mike Starkie who was reported in the local press as saying that Farron should “Butt Out of West Cumbria” Tim Farron has pointed out that Climate impacts from the mine won’t stop at Scafell. We agree and would also point out that neither would Nuclear impacts.

We believe that the more people and groups that write and request that the Secretary of State calls in the decision made by Cumbria County Council the better as a show of force will 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 can be found here – even a paragraph would be good to send to the Secretary of State– the main point to make is that West Cumbria Mining has not given figures on CO2 Emissions. There are no independent assessments. There has been no detailed scrutiny or debate on the close proximity of deep mining to Sellafield’s high level radioactive wastes.

Marianne Birkby
Founder of Radiation Free Lakeland
Keep Cumbrian Coal in the Hole is a RaFL campaign

 

 

Local Elections and the Coal Mine

Who put their hands up for a coal mine just five miles from Sellafield?  Remember this when you vote – these councillors listened to the Mayor of Copeland who told them to ignore locals (from Whitehaven to Kendal) and experts who told them that this would be putting the ducks in line for a catastrophe and not just for Cumbria.

These councillors voted for a coal mine just five miles from Sellafield.

 

Mr A Bowness, Bothel and Wharrels, Conservative

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Mrs HF Carrick, Penrith North, Conservative, Deputy Leader of the Conservative Group

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Mr F Cassidy, Walney South, Labour

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Mr N Cotton, Sedbergh and Kirkby Lonsdale, Liberal Democrat

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Mrs BC Gray, Kendal South, Liberal Democrat

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Mr D English, Dalton South, Conservative

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Mr LN Fisher, Brampton, Conservative

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Mr KR Hamilton, Risedale, Labour

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Mr GD Cook (Chair), Kendal Highgate, Liberal Democrat

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Mr AJ Markley, Solway Coast, Conservative

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Mr W McEwan, Ormsgill, Labour

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Mr FI Morgan, Cleator Moor West, Labour

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What a shower….and then there is the Mayor of Copeland who told those in West Cumbria and those outside West Cumbria to ‘Butt Out’ if they don’t like a coal mine just five miles from Sellafield.  Don’t you get it Mr Mayor?  Fission Wastes from Nuclear Crapola wings its way through the whole of Cumbria to Sellafield almost on a daily basis – and you have agitated and puffed for a mega coal mine next door to those growing wastes.

Here he is with the Mayor of Fukushima – I kid you not…

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from the Elected Mayor of Copeland’s facebook page.

“21st March ….I (sic) was my pleasure to welcome Mayor Endo and his colleagues to Copeland Council yesterday.

Mr Endo, the Mayor of Hirono, met with me as part of his visit to West Cumbria in which he is focusing on education and revitalisation.

His community houses Fukushima and Mr Endo is particularly proud of the fact that around 90 per cent of the original population has returned to his town since the evacuation.

Mr Endo and his colleagues are keen to develop relationships with communities that have some similarities in terms of rurality and the creation of new opportunities. He also visited the Energy Coast UTC, West Cumbria Sites Stakeholders Group and The Beacon Museum, Whitehavenduring his stay.”

The only national paper to report on Delivery of our Protest and Petition to the Secretary of State was Le Monde.

Le Monde 15th April 2019

Translated with Google..

Le Monde

“Despite growing concerns over global warming, the UK is about to open an underwater coal mine. The first in thirty years, in the north-west of the country, on the coast of the depopulated county of Cumbria. A group of local opponents sent the government Wednesday, April 10 a petition signed by 1,500 people.  This called for a stay of Cumbria County Council’s decision and the opening of a public inquiry, in which “all aspects of the mine would be examined in detail”.
On March 19th, all-party members of the county council voted unanimously in favor of this offshore submarine mine project led by West Cumbria Mining Limited. In the Irish Sea, a few hundred meters from the coast of Whitehaven (25 000 inhabitants), the exploitation of the ore nested at a depth of 350 meters should begin within two years, according to the company. The mining company is still required to obtain an operating license from the Marine Management Organization (an independent body responsible for the management of marine protected areas) to be able to dig under the sea.
Access will be from the mainland, then through underground galleries. “For the miners who work there, it does not change a conventional underground mine,” says the director of risks in the Bureau of Geological and Mining Research (BRGM), Karim Ben Slimane.

“Desperately need these jobs”
Objective of the “Woodhouse Colliery”, name of the future mine: the extraction of 3.1 million tons of annual coking coal for the European steel industry, for fifty years. And above all, 500 jobs, of which the company guarantees “80% to the inhabitants of the zone”. “The mine will boost the local economy and create well-paying jobs,” said Mike Starkie, Mayor of Copeland District, whose capital is Whitehaven. It is fantastic to see the coal industry return to western Cumbria. ”
The coal has long been part of the industrial landscape of this region, “one of the most disadvantaged in the north of England,” he says. In 1986, the closure of a first underwater mine left 3 500 people on the road. Then in Whitehaven, in the popular neighborhood adjoining the land where the mine offices are already located, the prospect of a salary goes well before the rest. …”

The rest of the article is behind a paywall

Delivering the Petition to Call In the Crazy Coal Mine Plan to the Home Office

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Outside the Home Office, Kevin  the West Cumbrian Mining Canary has that sinking feeling! 

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Yesterday in the cold sunshine a couple of intrepid Cumbrians and a naked yellow ‘coal mine canary’ called Kevin made the journey to London.

We were delivering a petition signed by 1527 folk (now risen to 1582) who are asking the Secretary of State James Brokenshire MP to call in the outrageous decision for a new deep undersea coal mine.

We will keep the petition open to demonstrate the strength of feeling against this plan which so many people living nearby are opposed to.

On the same day that we were delivering the petition the Mayor of Copeland sent an extraordinary letter to the Secretary of State. In his letter the Mayor, Mike Starkie restates the view he expressed to Cumbria County Councillors.  The Mayor urges the Secretary of State to ignore the high level expert advice which has described the damage that this plan would do to our planet’s climate,  and to ignore the very real concerns of nuclear safety campaigners who fear this plan would increase the already intolerable and overwhelming radioactive risks from Sellafield to Cumbria and beyond.

West Cumbria Mining have spent £millions on promoting this plan with lobbyists wooing local MPs and government ministers many of whom have been lured by the entirely faux ‘environmental’ reassurances.

The Mayor of Copeland repeats the mantra that this plan has overwhelming support from ordinary West Cumbrians.  We would like to invite the Mayor of Copeland to take a walk with us, in the presence of a journalist to act as a witness, and to ask those we meet in the streets of Workington, Egremont, Whitehaven and Kells what their view is of West Cumbria Mining’s plan.

 

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The Mayor of Copeland and WCM keep on repeating the mantra that this mine is wanted by local folk.  It is true that West Cumbria is desperately in need of jobs and investment. What West Cumbria is not in need of is yet another dead duck and expensive (in more ways than one) industry to suck the remaining life out it.

Here are some excerpts of what locals are saying…

 

This was the view of everyone we chatted to in Workington (except one)

What are folk saying who live even nearer the proposed mine?

This is an extract from a letter sent by local folk to Cumbria County Council (it may be available on the CCC website  – although our letters of objection from Keep Cumbrian Coal in the Hole are not on!!)

“Pow Beck has the railway and a couple of wind turbines but in the main it is a tranquil, fairly secluded and pretty place. In our opinion the Railway Loading Facility will affect our environment with emission, dust, noise and light, and detrimental to the ecology here. The facility will impact the peaceful enjoyment of our home, St. Bees village and Pow Beck wildlife.

The building is large and railway sidings extensive. The facility will be visually overbearing and no amount of tree planting or timber clad buildings will soften its appearance on the landscape. They have planned technically advanced building to keep the dust, noise and emissions to regulation levels, but the Loading Facility will still be a noisy, dusty and bright facility in our quiet, dark valley.

By its very nature mining is a messy business and we are not convinced by the marketing and bright coloured CGI animations used to demonstrate how this MODERN mine will operate. The animation makes it looks so clean but we have the opinion that is far from the facts. It does not show the shunting of wagons to the sidings, the plumes of dust as each wagon is loaded; We read somewhere 4 trains’ daily transporting coal to Redcar. These quieter modern trains can pull at least 21 large covered coal wagons, not the 7/8 shown on the CGI.

In our estimate that must be a train over 200m long. The CGI does not show those large trains trundling past homes through Mirehouse, Parton or Harrington to name a few. Pow Beck is going to be a very different place at all times of the day and night. We thought the United Nations and EU have in place regulations to reduce carbon emissions to meet climate targets, yet here we are in Cumbria giving consideration to digging out millions of tonnes of coal. We would have thought political policy would have put the kibosh on mining in this country, indeed in March of this year our government rejected an open cast mine in Northumberland saying the environmental impact outweighs economic benefits.

In Wales, only last month, they have reached the decisions no new mining unless under exceptional circumstances. WCM say 80% will be exported. We produce the coal and let someone else burn it. What a legacy, will we ever learn? Mining coal is a retrograde step, Apologies to all those miners past and present, We don’t wish to be ungrateful for their legacy, but we should not be thinking of building a new mine, burning coal is never going to be clean enough and that’s the facts.

Since 2014 WCM Ltd have marketed the mines with the creation of jobs for a lot of people over a very long time, benefits for the economy; an investment for West Cumbria. It is our belief that the environmental costs and environmental risk are too high a price for all that. The coal is not an asset anymore, the burning of fossil fuel is a liability that our children will be paying for. Therefore, we ask that Cumbria County Council refuse this planning application and keep Copeland coal, and other pollutants locked beneath the sandstone out of harm’s way.”

That last line from folk living near this proposal is worth repeating

..”we ask that Cumbria County Council refuse this planning application and keep Copeland coal, and other pollutants locked beneath the sandstone out of harm’s way.”

These are the locals that the Mayor Mike Starkie wants the Secretary of State to ignore – having sucessfully urged the County Council to ignore them!    Is this what a Mayor is for?

 

CALL IN THE CRAZY CUMBRIAN COAL MINE DECISION! DEMO and PETITION HAND OVER – 10th APRIL in LONDON

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