Call in Request to the Secretary of State by Keep Cumbrian Coal in the Hole

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CEO of West Cumbria Mining , Mark Kirkbride (who interestingly also happens to be an expert in ‘geological disposal’ ) going into the Council Meeting past Protestors

Here is our letter to the Secretary of State.  Anyone can write requesting that the decision be called in and the more individuals and  groups that do this the better.

If you don’t have time to write a letter then there is a petition here 

(some folk may have already signed it – it has been updated – but the more shares the better!)

LETTER TO THE SECRETARY OF STATE

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 CO2 emitted). 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 

 

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WCM (with Cumbria County Council’s help) Puffed Up At the Planning Meeting Their Plan for “Recycling Water.” Get Real!! How Much Fresh Water Will You Use? From What Fault?.

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We have written asking under Freedom of Information about West Cumbria Mining’s fresh water use.  WCM have years ago (really!)  stopped answering any questions from us and Cumbria County Council told me over the telephone last week that they have no clue as to how much fresh water WCM plan to abstract from a fault near Whitehaven.
So we are forced to write and ask for this information under Freedom of Information This important information on fresh water should already be highlighted in the public domain and be easy for the public to access.   WCM have puffed themselves up mightily over “recycling surface water” and this was repeated at the planning meeting by Cumbria County Council officials as though WCM were some kind of super duper eco warriors.
The tiny percentage of ‘recycled standing water’ would be a drop in the vast ocean of fresh water necessary to wash the coal and other processes that WCM plan to do.
FREEDOM OF INFORMATION REQUEST TO THE ENVIRONMENT AGENCY
We have repeatedly asked the developers West Cumbria Mining and Cumbria County Council for detailed information on WCM’s projected water use .  WCM’s  PR makes much of the notion that WCM will “recycle” water, the public only heard briefly (and for myself for the first time)  about ‘abstraction from a fault’ at the planning meeting .
 We have recieved no reply to our questions either from WCM or from Cumbria County Council.
Under Freedom of Information, Radiation Free Lakeland ask the Environment Agency for sight of:
Fresh Water Abstraction From the Named Fault by West Cumbria Mining.
1. What is the name of the fault that WCM propose to use?
2. How much water per day do WCM propose to abstract from the fault?
3.  Has this proposed abstraction had an EIA from the EA?
4.  Does the fault proposed to be used by WCM have linkage with the Lake District Boundary Fault or is this unquantifiable?
Thank you
yours sincerely,
Marianne Birkby
Keep Cumbrian Coal in the Hole (a Radiation Free Lakeland campaign)

Bad News and Good News

Dear Friends,

There is bad news and good news.  Bad news is that apparently the Development Control & Regulation decision cannot be ‘called in’ internally by Cumbria County Council

Good news is that all your fantastic emails and messages to councillors and others has resulted in Tim Farron MP requesting that the Secretary of State calls in this diabolic decision to give a green light to the first deep coal mine in the UK in decades.

We shall give an update on how we can best support this request for a call in by Tim Farron MP to the Secretary of State as soon as possible.

In the meantime – for those folk who were not able to get to the meeting, here are a few videos taken on the day (sorry I didn’t get all the speakers including myself!)   Grab a cuppa and watch the terrible drama unfold – and make no mistake this will make your toes curl.  It is significant that the proximity to Sellafield was not even brought up as an issue by the Council officers.  Sickeningly the members of the committee laughed their socks off when I pointed out that a liquefaction event had taken place in Barrow in the 1800’s – the ground at Sellafield is at high risk of liquefaction in the event of seismic activity.  The last thing we need is earthquake inducing deep mining and massive fresh water extraction to wash the coal (to be extracted from a fault near Whitehaven – they kept that freshwater extraction quiet!).

 

Part 1. Council Officials addressing the  Development Control and Regulation Committee of Cumbria County Council. The full council did not have a chance to debate this.  We heard Lib Dem Cllr and Chair of the meeting Geoff Cook clearly approve of the first deep coal mine in the UK in decades. Incredibly the close proximity (8km) to Sellafield was not discussed at all by councillors or by their officials.

 

 

Part 2 . Part 2. Official of Cumbria County Council outlining how adverse effects can be mitigated from the first deep coal mine in the UK in decades (really?)

 

Part 3. Dr Henry Adams of SLACCtt making a presentation to Cumbria County Council “SLACCtt most strongly objects to West Cumbria Mining’s application because the carbon emissions it would add are so huge that they would have very significant negative consequences that would far outweigh the benefits claimed.”

 

Part 4.  Dr Laurie Michaelis IPCC Emissions report author and coordinator of Living Witness.  making a breathtaking presentation to Cumbria County Council –

“Speaking to you feels like possibly the single most important thing I’ll do in my life.”

which they totally ignored.

 

Part 5. Sam of Radiation Free Lakeland/Keep Cumbrian Coal in the Hole exposes West Cumbria Mining’s false promises over jobs. “It would be truly difficult to find a bigger dead duck proposal than producing fossil fuels for a declining European steel industry. …Cumbria has had it’s fair share of dead and dying industries – old coal and now nuclear – we do not need another dead duck industry . . . Coal is not the future. It could perhaps be said of the WCM proposal that it was a well-intentioned attempt to bring employment to the area. It could equally be said that it was an unrealistic bubble from the start What we need are jobs that do have a future. Please look to the future stability of jobs in Cumbria and JUST SAY NO.”

 

Part 6.  Dr Stuart Parkinson, Executive Director of Scientists for Global Responsibility   “In summary, approving this application for a coal mine would be a huge step backwards for efforts to tackle climate change – and thus would increase the risks of extreme weather events such as storms and floods. Meanwhile, the economic case for the mine is flawed. Therefore, I strongly urge the planning committee to reject the application. ”   

Part 7. Mayor of Copeland, Mike Starkie tells councillors to Ignore the “sensationalist” claims of the objectors who have nothing to do with West Cumbria and the objectors views should carry no weight whatsoever (?! what a brass neck this Mayor has… many objectors are local to Whitehaven  and WCM is a dodgy company funded by who knows who from who knows where). Councillors agree entirely with the Mayor of Copeland (who makes the ‘Jaws’ Mayor look quite reasonable) and vote unanimously to approve the first deep coal mine in the UK in decades.  The Mayor points out that Sellafield are right behind this plan to mine deep holes in Cumbria.

 

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Will 3 Councillors Please Step Up to Protect Cumbria and the Planet??

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Mark Kirkbride CEO of West Cumbria Mining going into the Council Chamber. Photo credit Philip Gilligan of South Lakeland CND

Dear Friends,

We are shell shocked but regathering our resolve to challenge this outrageous decision taken by just a handful of Cumbria County Councillors.   There are legal actions we can take and are looking into but we feel the first course of action should be for CCC to have the chance to rethink this shameful decision.  We do not have much time to do this – just till early next week (we think – any advice welcome!)

There is a way to do this with an internal ‘call in’.

So it would be fantastic if folk could write to Cumbria County Councillors and ask for this decision to be ‘called in’.

The Councillors details are here…http://councilportal.cumbria.gov.uk/mgMemberIndex.aspx?bcr=1

An example letter is below but using your own words making these points would be really good.

Dear..
On the 19th March The Development & Regulation Committee  voted unanimously in favour of the plan for the first deep coal mine in the UK in decades not far from Sellafield. This terrible plan hassuch damaging consequencesfor the planet and for Cumbria it should be discussed and debated by the whole council.   The Scrutiny and Overview committee decision can then be informed by the feeling of the whole council rather than by a handful of committee members.
It would just take 3 councillors step up to protect Cumbria and agree to a *call in* . If you are one of those councillors and would like to have a briefing to advise on wording for the call in then please urgently contact wastwater@protonmail.com
From CCCs website:  The *call in* requires three non-Cabinet members to email the Assistant Director- Corporate Governance, giving reasons and identifying a Lead Member.  The notice must specify which aspect or aspects of the decision the members wish to question or challenge.
Yours sincerely,
********

There is also a petition which we are keeping open can you help spread the word by forwarding the link below to your friends?

https://you.38degrees.org.uk/petitions/keep-cumbrian-coal-in-the-hole-its-too-near-sellafield

Many Thanks

Keep Cumbrian Coal in the Hole

COAL? Nr Sellafield? What the Objectors Said..

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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.  Photo credit: Philip Gilligan South Lakeland  CND

Summary of speaking notes from objectors to the proposed new Cumbrian coal mine.

Cumbria County Council’s Development Control and Regulation Committee met on March 19th 2019 to consider the application from West Cumbria Mining [WCM] for a new mine at Whitehaven.

The planning documents can be found at https://planning.cumbria.gov.uk/Planning/Display/4/17/9007 

Providing a submission to the Committee or registering to speak at the meeting was open to any member of the public.  Some of those of us who spoke on the day had not met one another before.  We tried to cover different areas of objection so as many points as possible could be raised.  Objectors were given 5 minutes each to speak.  These are the speaking notes from the 7 people speaking to object.  We have all offered our notes to be shared.  We spoke in alphabetical order – so the notes are in that order.

The speakers are   

Dr Henry Adams, South Lakes Action on Climate Change 

Dr Ruth Balogh, West Cumbria & North Lakes Friend of the Earth

Marianne Birkby, Keep Cumbrian Coal in the Hole, Radiation Free Lakeland

Maggie Mason, Planning expertise and experience

Dr Laurie Michaelis, IPCC author and advisor,  Living Witness

Sam Moisha, Radiation Free Lakeland

Dr Stuart Parkinson, Scientists for Global Responsibility

Contact details are listed with each presentation.

5 minute oral presentation by Dr Henry Adams on behalf of SLACCtt – 13mar19 draft for 19mar19 CumbriaCC hearing on WCM Whitehaven coal mine application

Dr Henry Adams (Ecological Consultant)   Home phone: 01539 722158      Mobile: 07421 309453 

Link to objection letters by Henry for SLACCtt: www.bit.ly/SLACCttNOtoCOALcov 

Hi my name is Henry Adams and I’m speaking on behalf of South Lakes Action on Climate Change – SLACCtt for short, which has 40 paid up members and 160 newsletter subscribers.

SLACCtt most strongly objects to West Cumbria Mining’s application because the carbon emissions it would add are so huge that they would have very significant negative consequences that would far outweigh the benefits claimed.

We’ve calculated that these emissions would be over 9 million tonnes of CO2 equivalents per year after year 4, amounting to 500 million tonnes CO2e over 50 years.

Over 1 million tonnes CO2e per year of these emissions would be within Cumbria.

This would totally undermine Cumbria’s chances of declaring a meaningful Climate Emergency to reach zero carbon emissions by 2030. This target is what all the UK must do, as a wealthy nation, for the world to be on track to at least halve carbon emissions by 2030, and means immediately and rapidly reducing emissions.

This target is vital for us to have any good chance of keeping global average temperatures below plus 1.5 degrees, and is what we’ve been strongly advised to aim for, by last October’s Special Report for 1.5 by the Intergovernmental Panel on Climate Change.

   

Please note that the project extends 40 years beyond 2030 when the UK must be net zero.

Rapid and urgent reduction of our carbon emissions is essential – yet West Cumbria Mining and Cumbria CC are pushing us to do the opposite, while claiming that the mine will actually result in CO2 “savings” from shorter shipping routes! 

WCM - chart cf'ing emissions types 3 with text.JPG

 This chart combines WCMs “savings” figure with government conversion data for upstream and combustion emissions:

You’ll see that WCM’s “savings” of CO2 emissions (the blue column) are relatively minute, in fact just 1.4% of the combustion emissions of the same quantity of coking coal (in the grey column), and only about 10% of the size of emissions within the UK at Whitehaven (in orange).

Also bear in mind, that some of the combustion emissions in grey are likely to be burnt in UK blast furnaces before the latter close down, in possibly just a few years.

WCM’s claim assumes that at least 99% of the current source of coal from elsewhere abroad will be left in the ground.  Yet it’s obvious that if a new source of a coal is added to the global market this will add to the total, and also add to global carbon emissions. 

There is no global cap for either coking coal, or their emissions, that would ensure a new source will fully replace an existing source. Additions of coking coal would also result in a downward pressure on global prices. This would impact on the economic viability of much lower carbon new methods being developed to get steel from iron ore, and also existing lower carbon alternatives – such as electric arc furnaces powered by renewable electricity to recycle old into new steel. 

——-

Earlier this month, a High Court judge ruled that the government had acted illegally when it ignored the latest climate science when it added a paragraph in the 2018 NPPF that stated that exploiting UK shale gas would be beneficial towards a low carbon economy.

The Committee Report also failed to consider the latest climate science, and contrary to its conclusion, the proposal would produce unacceptable emissions both within the county, and at national and global levels. It could thus also be illegal as a result of the High Court precedent.

——

Laurie Michaelis calculated that many thousands of climate deaths would result from the CO2e emitted over 50 years. This corresponds to a minimum of tens of deaths, to many hundreds of deaths per job.      

Also there’d be additional harms that would include loss and damage to habitats, species, crop-growing areas and liveable areas.

Last Friday the “Kendal School Strike for the Climate” assembled outside this building insisting that the coal mine does not go ahead. It is their lives that will be damaged, and the lives of thousands abroad in the global South ||| who contribute so much lower emissions per person than us.

||| = I was timed out totally at this point, so couldn’t add my optional extra paragraph in the box below.

=====================

On 2nd May the Committee for Climate Change report for 1.5 will be published. It will most certainly not advise for NPPF updates to allow more coal mining. If the NPPF is updated to follow the advice the mine will become a stranded asset.

 

Cumbria County Council Planning Committee Meeting Application: 4/17/9007 – Marchon Woodhouse Colliery

Friends of the Earth England Wales & Northern Ireland

foe-wcumbria@hotmail.co.uk

https://friendsoftheearth.uk/groups/westcumbria

Introduction

I am Dr. Ruth Balogh (West Cumbria & North Lakes FoE), also author of several research papers on the health & social impacts of flooding, an important climate change issue. Thank you for this opportunity.

FoE EWNI regret being unable to appear in person. They objected three times since 2017 but were not formally notified of the committee hearing.  

  1. Concerns over Committee hearing notification and CCC’s duties under the Aarhus Convention

Fair public participation in decision-making is enshrined in the Aarhus Convention, especially for EIA applications. Cumbria CC should have notified all respondents  – previously standard procedure here; standard procedure throughout the sector, and therefore expected by us. At least we should have been warned of this change in policy. “Lack of resources” was cited but there is a planning performance agreement in place with the developer. Other objectors may have also been denied this right. This is not in the spirit of planning systems, nor Aarhus.

 

  1. Key objections

FoE EWNI maintains 3 key objections to the application and is disappointed with officer recommendation to approve:

  1. impact on climate change
  • The UK is bound by the Climate Change Act 2008 to reduce greenhouse gas emissions by at least 80% on 1990 levels by 2050.
  • NPPF para 148 aims for the planning system to “shape places in ways that contribute to radical reductions in greenhouse gas emissions”.  
  • The 2015 Paris Agreement committed the UK to limiting temperature increase to 1.5°C.

Coal has the highest carbon intensity of all fossil fuels and so its extraction and combustion must be minimised. Despite the objective of steel-making, mining on this scale for 40+ years conflicts with these instruments.

Mining 2.8 million tonnes a year for 40 years represents 175 million tonnes of C02 . Climate impact will increase through additional fugitive methane release, CO2, NO2 and particulate emissions from operations/plant/transport. The UK’s binding Carbon Budgets also apply to methane and other greenhouse gases – which this mine will emit. Have the impacts of methane leakages over 40 years had proper consideration?

A Mine Gas Capture Management scheme is a condition. But this could be varied and watered down over time. And there is no guarantee the coal will be used for steel. The apportioning of “moderate weight” to climate change impacts is therefore underestimated.

  1. Compatibility with the Cumbria Minerals and Waste Plan (2017) and NPPF approach to coal  

This proposal gives ‘considerable weight’ to a “national need” for indigenous metallurgical coal and local benefit from 500+ well-paid jobs, thus outweighing environmental impacts.

The “national need” for metallurgical coal is weak. It appears to be based purely on coal being listed in Annex 2 of the NPPF and steel demand projections – hardly robust research. Have any British steel manufacturers been consulted?  What if steel manufacturing further diminished in future? This “considerable weight” is based on a lot of assumptions.

The purported benefits of fulfilling ‘a national need’ fail to outweigh the clear environmental harms, and regional employment benefits could adversely affect jobs in tourism and leisure.

  1. Incompatibility with government announcements on coal phase-out

In 2018, Claire Perry said: We’re proud to be leading the world when it comes to getting rid of [coal], well ahead of our 2025 target.

The NPPF’s new approach makes it clear that the days of coal mining are very limited. The sheer scale of extraction, including 335,000 tonnes of middlings coal remains incompatible with these government approaches.

 This application should be refused. The environmental impacts will not be outweighed by employment benefits and “need”, making legal challenge likely.

 

KEEP CUMBRIAN COAL IN THE HOLE
PRESENTATION FOR DC&R Committee 19:3.19 

Marianne Birkby  wastwater@protonmail.com

https://www.facebook.com/groups/radiationfreelakeland/

https://mariannewildart.wordpress.com/ 

I am Marianne Birkby speaking on behalf of Keep Cumbrian Coal in the Hole.  This is a Radiation Free Lakeland campaign set up following the proposal by WCM. People have asked why would a nuclear safety group be campaigning against coal. 

The answer to that can be seen in our petition which I present to you today.   

The petition headline says:  Keep Cumbrian Coal in the Hole – it is too close to Sellafield.  (1,154 signatures and growing)  

West Cumbria Mining say our petition objections have been answered.  Not true.  Our objections stand and are escalating the more we find out about the plan.  

Others will speak forcibly today of the terrible climate impacts. I would like to concentrate on seismic  and water impacts. 

SEISMIC  

At 8km from Sellafield the extent of the mine lies 600 metres from the Office for Nuclear Regulation’s legal remit to consult. The ONR say therefore that they do not need to be consulted by CCC. 

For the ONR to completely wash its hands of any real scrutiny regarding this unprecedented deep mining so close to Sellafield’s 140 tons of plutonium is scandalous.  The Precautionary Principle is enshrined in UK laws that CCC are bound by and we would urge Councillors to ask the ONR for full consultation and scrutiny before making a decision.  That scrutiny should include a recent paper published last September by the Yorkshire Geological Society. The paper outlines the high risk of liquefaction at the Sellafield and Moorside sites. (1) 

Barrow is the only place in the UK ever to have experienced liquefaction from a much smaller seismic event than that outlined in the recent paper. 

A liquefaction event at Sellafield caused by coal mining induced earth movements would be disastrous not just for Cumbria but for Europe too.  The Precautionary Principle in this instance must be applied. 

WATER 

Coal, like nuclear, is a water intensive industry, leaving long lasting carcinogenic products .  For every ton of coal, two and a half tons of water are required to wash that coal.  West Cumbria Mining propose to ‘recycle’ the water pumped from the voids and ‘surface’ water.  Only today have we been told that water would also be extracted from a geological fault – water extraction on a big scale also causes seismic activity..    I have asked for scrutiny from CCC and WCM on fresh water usage but have not received any answers.  My calculations from WCM’s coal production figures is that the  mine would need to use 3 million litres of water a day to wash the coal before transportation. 

West Cumbria’s fresh water situation is already stressed with many people in the Copeland area suffering health impacts from having to drink a mix of 80/20 borehole 

water.   Borehole water can be very good but not from a complex geologically faulted area which has been heavily mined in the past.   

To impose another water intensive, dirty and geologically damaging industry on West Cumbria is an attack on the most basic of human rights, the right to fresh water. 

 

Text for DC&R Cttee: 19.3.19:  4/17/9007: Maggie Mason: Kendal 

My name is Maggie Mason. I have an Architecture Degree and Post Graduate Diploma in Town Planning and was a senior Minerals and Waste planner in Kendal for 10 years to December 2015. 

I object to this planning application because the development would significantly increase Greenhouse Gas Emissions and damage our climate and planetary home. 

I think that this Committee Report has misrepresented: 

  1. the climate change impacts; 
  2. the UK need for metallurgical coal; 
  3. the national, local and community benefits, and therefore
  4. the overall planning balance 
              1. Climate change impacts
  1. The Committee Report says there are NO Climate Change impacts because the “moderate” benefits of reduced GHG from transportation balance the TOTAL adverse impacts of non-combustion emissions ( construction, extraction, AND transportation). Logically these cannot balance – as SLACCtt demonstrate in their diagram. One is a fraction of a fraction of the total. They cannot be the same.
  2. Even if combustion emissions are disregarded, an adverse impact from an increase in emissions as a result of the proposed mine’s construction and operation is acknowledged in the Committee Report but not carried through into the planning balance. 
              1. UK Need for metallurgical coal : 
  1. The Committee Report claims “it is reasonable to assume that demand for steel and coking coal will continue to exist both within the UK and EU for the foreseeable future”.  A graph of soaring scenarios from an industry/consultant source is presented with the comment “I have no doubt to conclude these are reasonable” . 
  2. This optimistic and “business as usual prediction” conflicts with official Government reports and easily available information. The Port Talbot steel plant is only “guaranteed” until 2022, and the only other UK steel plant at Scunthorpe , which was bought by an Investment Bank for a £1 announced the loss of 400 jobs in November2018 . 
  3. If the UK steel industry is dying as the Financial Times explained in January 2019, and the UK Government has offered warm words but no subsidies, there is little national or local economic benefit in the proposed coal mine. The coal will travel further or not be sold, the transportation emissions “savings” disappear and the West Coast is left with another derelict industry, this time leaking methane emissions.
              1. National, local and community benefits
  1. The Committee Report “weighs up” combined “UK and EU” need or economic benefit, but translates this into “potential..national benefits ..of considerable weight” when applying NPPF paragraph 211. Benefits to the EU are not relevant to the NPPF, and should be omitted.
  2. The Report implies 500 jobs for 50 years, without clarifying that only benefits due to the (onshore) planning application are a material planning consideration. If multi-generational jobs” from the combined proposals DO influence Members decision, THEN so should adverse impacts from the offshore proposals (such as subsidence that mobilises contaminants and radioactive particles from the sea bed, and earthquakes from pumping liquidised waste into mine voids).

In Conclusion 

  • I agree with CCC that the proposal is not environmentally acceptable even without the climate change impacts,
  • but in addition, there are significant Climate Change impacts that increase the total likely impacts, even if end use/ combustion is ignored.
  • significant national economic benefit has NOT been demonstrated in considering the second test of NPPF Paragraph 211, and
  • local and community benefits (mainly jobs) are medium to short term only, not multigenerational as promised in the proposal.

When a more reasonable and evidence based assessment is applied to Paragraph 211, the impacts increase, and the benefits decrease. 

Therefore the proposal has not been shown to “provide benefits that clearly outweigh its likely impacts”; NPPF paragraph 211 test fails; the presumption against coal extraction stands; and the application should be refused.

I respect this Committee, and know that refusing consent against officers’ advice takes courage, but the report’s flaws and its disregard of current climate science make a legal challenge likely. Please refuse this planning application.

 

West Cumbria Mining proposal – issues related to climate change

Speaking points from Dr Laurie Michaelis, Living Witness

https://www.livingwitness.org.uk/ 

I’m Laurie Michaelis. I’ve 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. 

Speaking to you feels like possibly the single most important thing I’ll do in my life. 

I work now with Quaker charity Living Witness helping communities face up to climate change and find sustainable ways forward. 

Climate change is already wrecking lives. Last year’s IPCC report made clear that global warming beyond 1.5°C could be catastrophic for humanity and other life including in Cumbria. For instance global warming of 1.5 to 2°C could bring long term sea level rise of 6-9m. To prevent that, global carbon emissions must fall to zero by about 2050.

Refusing this mine could save thousands of lives and help build momentum to cut carbon but I’m worried you don’t have enough information to decide safely. The applicant has made wrong and misleading statements about climate impacts of the development, the steel industry and policy context. Your officers have not obtained suitable expert advice to correct the misinformation. For instance:

Unrealistic expectations of future coking coal demand

The IPCC says demand for raw steel and coking coal must fall to limit warming to 1.5°C. The UK Government and European Commission have published decarbonisation pathways for iron and steel to 2050 which include using biomass or hydrogen instead of coke. 

Misinformation about climate impact

Over 50 years, this development’s climate impact would be equivalent to about 450 million tonnes CO2, the same as the total UK greenhouse gas emissions in 2017. 

When coal is used to make steel, 99% of the carbon content ends up as CO2 in the atmosphere. 

Just the methane emissions in the mine ventilation air and from the coal could add over a million tonnes a year of CO2 to Cumbria’s climate footprint – that’s about 15% – and its ten times bigger than the reduction claimed from international shipping.

Moral responsibility

If you consent, the resulting emissions could mean tens of thousands of people losing homes or livelihoods. 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.

Legal responsibility

Cumbria County Council has promised to play its part in meeting national climate goals which are likely to be tightened in light of the IPCC report following advice to the Government from the Climate Change Committee, due in May.

The High Court just ruled that the National Planning Policy Framework did not take climate change properly into account and the Government must revise it. More court cases like this are being brought around the world.

A positive strategy for Cumbria

As an outsider, I can’t tell you what sustainable development here should look like but the vision and action plan must come from the local community, NOT from fossil fuel industries parachuting in.

 

My name is Sam Moisha  

I wish to object strongly to the application.  

Para 211 of the government’s National Planning Policy Framework  regarding coal extraction is totally clear 

 ‘Permission should not be given for the extraction of coal unless the proposal is 

A] environmentally acceptable, or can be made so by planning conditions or obligations;

  – or if not, . . . . 

B] it provides national, local or community benefits which clearly outweigh the likely impacts 

The CCC report has stated that     a] the application is not environmentally acceptable                yet it gives  ‘considerable weight’  to community benefits with regard to jobs/employment. [6.515]

I am challenging this ‘community benefit’ aspect with regards to jobs and employment.   

What happens to the proposed jobs when – 

  • Volatile market forces in the global steel industry close further UK and European steel plants –  as China, Korea and Australia increase steel production and global overcapacity? 
  • WCM  may become non viable commercially  as a result of global markets  – a potential clearly identified in the committee  report – with regard to bonds and securities for remediation work as and when the mine may close early.
  • The UN declaration of our climate emergency accelerates the carbon budget limits on all co2 emissions  – and the burning of any fossil fuel in steel making or otherwise?   
  • The climate emergency accelerates new technologies of steel production that do not use coal?
  • Production at the mine may be stopped due to accidents – including methane, subsidence and seismicity – which has currently stopped production at Preston New Road fracking site?

 

  • Global divestment from fossil fuel industries makes all fossil fuel investments  increasingly risky  – and likely to become stranded assets?
  • If the major investors in China withdraw funding in the face of Brexit uncertainties?   
  • If  Brexit  makes export to eurpoean steel producers un economic? 

SUMMARY

WCM simply do not have control over global steel markets, overcapacity or Brexit and  so cannot guarantee any sales at all of any coal produced.  

Or any jobs depending on this.

It would be truly difficult to find a bigger dead duck proposal than producing fossil fuels for a declining European steel industry.

The Lancashire fossil fuel experience – 

In Lancashire officers recommended approval of the fracking site at Preston New Road.

Lancashire County Councillors rejected the application.  They said NO.

This should have ended here – but as we know central government overturned the local democratic decision and we have seen years of protest, judicial review, court cases, arrests and massive policing costs  . . . . fracking at PNR has now ground to a halt.

Conclusion – request

Cumbria has had it’s fair share of dead and dying industries – old coal and now nuclear – we do not need another dead duck industry . . . Coal is not the future.

It could perhaps be said of the WCM proposal that it was a well-intentioned attempt to bring employment to the area.  

It could equally be said that it was an unrealistic bubble from the start 

What we need are jobs that do have a future. 

Please look to the future stability of jobs in Cumbria and JUST SAY NO.

Thank you.

 

Planning Application 4/17/9007: Woodhouse Colliery

Spoken submission by Dr Stuart Parkinson, Scientists for Global Responsibility

Stuart Parkinson  

http://www.sgr.org.uk/ 

I am speaking in opposition to the application from West Cumbria Mining Ltd.

  • My name is Dr Stuart Parkinson. I am executive director of Scientists for Global Responsibility, a UK organisation whose membership includes 600 science, design and technology professionals. I am an environmentalist scientist, with nearly 30 years’ experience of research and advocacy work on climate change and energy issues. My professional background also includes: a PhD in climate change science from Lancaster University; five years as a post-doctoral research fellow in climate and energy policy at Surrey University; and a year as an expert reviewer for the UN advisory body on climate change, the IPCC. I have also worked in and with UK industry, including carrying out research for the energy industry.
  • The main grounds on which I object to the planning application is that it would make a large contribution to global climate change. The coal mine, if approved, would significantly undermine local, national and international efforts to reduce carbon pollution – as agreed in policy documents including the 2015 Paris Climate Agreement, the 2008 UK Climate Change Act, and Cumbria County Council’s climate change strategy. These efforts are essential to help reduce the risk of extreme storm and flood events similar to those which Cumbria has experienced in recent years.
  • The most recent report of the IPCC highlighted our vulnerabilities even to relatively modest levels of climate change. The report showed that efforts to reduce carbon pollution need to be stepped up rapidly, with approximately one decade left for the world to take transformative action. This action would need to include major changes in the iron, steel and cement industries.
  • Coal is a highly polluting fuel, especially in terms of carbon pollution. Based on the figures for estimated coal production provided in the planning application, and additional data from technical sources, 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. This estimate includes both direct emissions from coal use in the steel-making process and indirect emissions from, for example, transportation. 
  • Coal mines emit significant levels of methane, a powerful greenhouse gas which further exacerbates climate change. This coal mine would be no different. Such emissions are very hard to control, despite claims made in the application. 
  • Because it is planned to export much of the coal, most of the emissions would appear in the ‘environmental accounts’ of other countries, not the UK – but they would still be subject to the Paris Climate Agreement – and the UK, and Cumbria in particular, would arguably bear ethical responsibility. 
  • The steel-making industry has been slowly moving to less carbon intensive production processes. Such processes include electric arc furnaces which have particular environmental benefits over coal-fired blast furnaces, if the source of electricity is lower carbon, as in the UK. This new mine would do nothing to help the low carbon transition – indeed it would slow down the process.
  • Claims that coal from this mine would ‘save’ some carbon pollution because it could, for example, offset US coal are speculative and probably misleading. By increasing international supply, this mine would help depress coal prices – and thus it would actually be more likely to increase coal use internationally in the short term. In any case, the transportation emissions are a tiny proportion of the emissions released during coal use in steel-making.
  • In line with international trends, the UK is phasing-out coal for electricity generation by 2025. Other uses of coal will also need to be rapidly reduced to tackle climate change – and the IPCC and others have recommended ways in which this could happen. Hence, this mine is highly unlikely to be economically viable for anything close to its claimed 50-year lifespan – thus becoming a ‘stranded asset’. Cumbrian authorities would therefore do better to encourage economic activities with a more promising future, for example, renewable energy, forestry or tourism.
  • The UK government has repeatedly been criticised by its advisory body, the Committee on Climate Change, for not taking adequate action to meet its carbon pollution targets. The Committee itself has yet to update its assessments in light of the latest IPCC report, meaning that the government’s policies are even further behind scientific evidence of the climate threat. Yet the failings of central government should not be an excuse for Cumbria County Council to ignore the scientific evidence of the major threat that this coal mine poses to our shared climate. 

In summary, approving this application for a coal mine would be a huge step backwards for efforts to tackle climate change – and thus would increase the risks of extreme weather events such as storms and floods. Meanwhile, the economic case for the mine is flawed. Therefore, I strongly urge the planning committee to reject the application. 

Demo Tomorrow Kendal County Offices 8.45 to 10 am: Keep Cumbrian Coal in the Hole

Keep Cumbrian Coal in the Hole.jpg

Please join us tomorrow outside Cumbria County Council Offices in Kendal (Busher Walk).

We will gather at 8.45 to greet the Development Control and Regulation Committee who will be taking a decision on whether or not to allow the first deep coal mine in the UK in 30 years.  Bring Banners, Music, Bring Yourselves to show OPPOSITION to this beyond crazy plan.

Speakers in opposition to this plan include Dr Laurie Michaelis who has been a lead author for several reports of the Intergovernmental Panel on Climate Change and provided analysis and policy advice for the UK government, European Commission, OECD environment ministers and the UN climate negotiators.

He  will introduce his detailed presentation to the committee by saying  “Speaking to you feels like possibly the single most important thing I’ll do in my life. I know climate change mostly feels abstract and distant, but it is real and it is already wrecking the lives of real people. Your decision not to go ahead could save thousands of lives and help build effective action to prevent catastrophic climate change.”

Just this evening we have recieved a letter from Tim Farron MP saying “I am pleased to confirm that I have written to the Chief Executive of the Office for Nuclear Regulation to ask them to reconsider this decision not to provide detailed feedback, especially given recent concerns raised by bodies, such (published by) as the Yorkshire Geological Society which outlines the high risk of liquefaction at the Sellafield and Moorside sites.”

Tim Farron - Written to ONR.jpg

We only have five minutes each to speak – below is my presentation on behalf of Keep Cumbrian Coal in the Hole.  You can still sign the petition here .

 

KEEP CUMBRIAN COAL IN THE HOLE
PRESENTATION FOR DC&R Committee 19:3.19

I am Marianne Birkby speaking on behalf of Keep Cumbrian Coal in the Hole.  This is a Radiation Free Lakeland campaign set up following the proposal by WCM People have asked why would a nuclear safety group be campaigning against coal.

The answer to that can be seen in our petition which I present to you today.  

The petition headline says:  Keep Cumbrian Coal in the Hole – it is too close to Sellafield.  (1,154 signatures) 

West Cumbria Mining say our petition objections have been answered.  Not true.  Our objections stand and are escalating the more we find out about the plan. 

Others will speak forcibly today of the terrible climate impacts. I would like to concentrate on seismic  and water impacts.

SEISMIC 

At 8km from Sellafield the extent of the mine lies 600 metres from the Office for Nuclear Regulation’s legal remit to consult. The ONR say therefore that they do not need to be consulted by CCC.

For the ONR to completely wash its hands of any real scrutiny regarding this unprecedented deep mining so close to Sellafield’s 140 tons of plutonium is scandalous.  The Precautionary Principle is enshrined in UK laws that CCC are bound by and we would urge Councillors to ask the ONR for full consultation and scrutiny before making a decision.  That scrutiny should include a recent paper published last September by the Yorkshire Geological Society. The paper outlines the high risk of liquefaction at the Sellafield and Moorside sites. (1)

Barrow is the only place in the UK ever to have experienced liquefaction from a much smaller seismic event than that outlined in the recent paper.

A liquefaction event at Sellafield caused by coal mining induced earth movements would be disastrous not just for Cumbria but for Europe too.  The Precautionary Principle in this instance must be applied.

WATER

Coal, like nuclear is a water intensive industry, leaving long lasting carcinogenic products .  For every ton of coal, two and a half tons of water are required to wash that coal.  West Cumbria Mining propose to ‘recycle’ the water pumped from the voids and ‘surface’ water, this involves a series of lagoons to allow  toxic products to settle.  WCM’s proposal is to only use mains water the offices.  This is not credible. I have asked for scrutiny on fresh water usage but have not recieved any answers.  My calculations from WCM’s coal production figures is that the the mine would need to use 3 million litres of water a day to wash the coal before transportation.

West Cumbria’s fresh water situation is already stressed with many people in the Copeland area  suffering health impacts from having to drink a mix of 80/20 borehole

water.   Borehole water can be very good but not from a complex geologically faulted area which has been heavily mined in the past.  

To impose another water intensive, dirty and geologically damaging industry on West Cumbria is an attack on the most basic of human rights, the right to fresh water.

Notes:

Tim Farron has written to the ONR asking that they reconsider the decision not to provide detailed feedback given the recent concerns raised over risk of liquefaction at Sellafield and Moorside. 

Reply to CCC from the ONR: 

“ONR ask to be consulted on developments within the off-site emergency planning area around the Sellafield site, which extends approximately 6.1 – 7.4 km from the site centrepoint.  We would not expect Cumbria County Council to consult us regarding developments outside this zone..”

The susceptibility of glacigenic deposits to liquefaction under seismic loading conditions: case study relating to nuclear site characterization in West Cumbria Authors: Martin Cross1*, Anass Attya2 & David J. A. Evans3   “The results of the assessments indicated a potential high risk for liquefaction for both horizontal ground acceleration events. Due to the variation of the ground and groundwater conditions across the sequence investigated, differences in excess pore-water pressure dissipation can be expected. In such circumstances large differential settlement and ground deformation are highly probable during a seismic event of magnitude (M)=6.0.”  Published by the Yorkshire Geological Society, September 2018

The Barrow-in-Furness Earthquake of 15 February 1865: Liquefaction from a Very Small Magnitude Event

  • R. M. W. Musson

“High intensity and liquefaction phenomena are usually associated only with relatively large magnitude earthquakes. An earthquake in 1865 in the northwest of England suggests that a sufficiently shallow small event can also produce liquefaction. The effects are well-documented in historical sources and include sand fountaining. Modern investigation is confined to documentary evidence owing to the tidal environment of the area where liquefaction occurred. Analysis shows that the felt area of the earthquake was probably only about 200 km2; however, heavy damage occurred in the village of Rampside and the maximum intensity is assessed at 8. Liquefaction is not uncommon at this intensity, but such a high intensity is not usually produced by such small erathquakes. The magnitude was probably in the range 2.5–3.5 M L .”    https://www.researchgate.net/publication/226374518_The_Barrow-in-Furness_Earthquake_of_15_February_1865_Liquefaction_from_a_Very_Small_Magnitude_Event

Assessing Water Issues in China’s Coal Industry by Hope Inman Advanced Science News:  April 30th 2014; “On average, for one tonne of prepared coal 2.5 tonnes  of water  is used”

https://www.advancedsciencenews.com/assessing-water-issues-in-chinas-coal-industry/