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 blog post is by What Lies Beneath Rattlechain Lagoon from 2017 and is reposted here with their kind permission. The article is a deep dive into the Marchon site and the Anhydrite Mine that West Cumbria Mining wanted to dewater in order to use as the route into the proposed coal mine under the Irish Sea. The Environment Agency objected to that plan of dewatering the Anhydrite mine into the Irish Sea as the mine water is extremely toxic. So WCM said they would go above the Anhydrite Mine drift tunnels instead of through to get around their dewatering problem. However WCM HAVE carried out extensive borehole explorations to test the hydrology and geology and who knows what impacts that has had on the honeycomb of mines below Whitehaven – including the acid producing Anhydrite mine. Although it is kept under wraps one of the biggest users of acids is the nuclear industry. The tanker of nitric acid that overturned last year on country roads was heading to Sellafield but not one mainstream media outlet shared that fact with the public.
Albright and Wilson’s stench extended beyond Oldbury in the West Midlands to up North in the coastal area of Whitehaven. The chemical firm Marchon Products Limited had been based in the town for many years producing raw materials for detergents, and then expanding onto a disused tar plant before “the Quakers” took over there in 1955 and made it a subsidiary producing the detergent raw material STTP- Sodium Tripolyphosphate. Solway Chemicals Limited, another subsidiary were also producing sulphuric acid from this year from a plant next to the Marchon site. Their main concerns were liquid fertilisers and sodium laurel sulphate- a toothpaste foaming agent.
STTP needed phosphoric acid as an essential agent, produced by “the wet process”. This method is outlined from a 1955 Albright and Wilson publication “The manufacture and uses of phosphorus.”
A £5 million sulphuric acid plant extension completed in 1967 made Albright and Wilson the producer of one tenth of the UK’s total sulphuric acid output. 1968 saw the start up of a new wet phosphoric acid plant at Marchon, replacing the two previous ones. Levels of chemcials produced at the site are reported to have been 350,000 tons per annum of Sulphuric acid, 350,000 tons of cement, 165,000 tons phosphoric acid and 170,000 of STTP.
Whitehaven harbour was utilised to deliver raw materials using specially built vessels, which finally ceased in 1992.
But around the late 1960’s with AW’s disastrous loss making Long Harbour venture, the rot appeared to begin to set in for Marchon works as a site. In particular the environmental issues associated with other Albright and Wilson sites began to show a familiar pattern.
Pollution grime
Pollution from this large site appeared like a sore pimple from an outpouring of froth associated with the phosphate manufacture into the Irish Sea. More dangerous were heavy metal laden effluent from the phosphate rock impurities. For many years it had been a source of constant complaint from residents yet Albright and Wilson batted these away as it always did with talk of “jobs being put at risk” and claims it met allowed consents- all the same bullshit they also used when complaints were made about their Oldbury activities.
One of the most infamous associations with this site is the ground breaking prosecution of the company by Greenpeace– at a time when they were a genuine pollution busting environmental charity and not devoted to the pet cause of a failed US presidential candidate.
In 1990 they successfully took Albright and Wilson to court, winning a private prosecution brought under the new Water Act 1989. Whitehaven magistrates fined them a poultry £2000 and greenpeace costs awarded of £20,000.
But Albright and Wilson were always a company in total denial about their disgusting environmental record and the following whinging, whining trite garbage is what they published in Albright World at the time, desperately attempting to convince their workforce that Greenpeace were in the wrong and that these environmental assassins were trying to close the plant down when they attempted to block the discharge pipe into the
The comments made by works director in this article are utterly delusional, “We believe the sample taken was not representative of our normal discharge” he wailed, with “profound knowledge” ,appearing to blindly believe that any transgression of the law should not apply to them. We also get those invented no/low risk “calculations” of theirs, which we have also recently seen offered by Rhodia in their defence of a white phosphorus/phosphine factory fire which were not accepted by the Health and Safety Executive.
We have a similar airbrushed version of events offered by Hugh Podger in his “Albright and Wilson The Last 50 years” and “Marchon The Whitehaven Chemical works by Alan Routledge.” The latter book is fine if you enjoy black and white photos of machinery and people standing in front of them viewed through rose tinted glasses, but the garish reality of long standing environmental pollution is not part of the colour scheme.
When Greenpeace later blocked the pipe discharging the grime into the sea, they were totally justified in doing so, and if I had been around then knowing what I do now about this firms activities, then I would have joined them to happily be arrested for taking a stand.
When challenged on their environmental record, Albright and Wilson and then Rhodia, basically the very same people, consistently were in denial about their activities being harmful and their blind arrogance as “scientists” believed they knew better than anyone else.
An excellent account of the general air pollution coming out of Whitehaven around this time is documented in a Guardian article from 1988, which is archived on the Fluoride Action Network website. It is entitled “a host of roasted daffodils” and details how plants were turned to dust by the factory emissions, as well as the longstanding human health risks which are still there and will be for many decades.
“Marchon is licensed by the North West Water Authority to pour 93 tonnes of uranium into the Irish Sea every year, as well as 27 tonnes of cadmium and 9.3 tonnes of arsenic. Tests carried out by Greenpeace show that the composition of radioactivity found in Whitehaven harbour precludes it being from Sellafield. For five years now, scientists have claimed that cadmium has been a cause of genetic damage. Large doses can destroy cell manufacture and repair.”
“In April over 100 parents and schoolchildren suffered nausea and coughing when a cloud of sulphur dioxide acid leaked from the factory and descended on them as they were leaving nearby Kells infant school. In July, 200 cars in the factory carpark were pitted and stripped of paint after a second acid leak.”
All of this appears to be of a very similar story to the anecdotes of residents living around the Langley area, and also the denials of an operator who appeared to care little about the health concerns associated with the toxic chemicals which it produced. That it “provides jobs for the area” that would otherwise not be there appears to be the standard political shillers comment for justifying appalling and blind eye turning health and safety faux pas.
Of the manner in which it treated its workforce:
“Only relatively recently, local people have become determined to know more about the effects the plant is having on their health. But employees are frightened to speak out for fear of losing their jobs in an area of high unemployment.
One former employee said he found that childhood asthma returned when he began working in the factory’s acid plant. He says the company never admitted that his work was the cause of his disease, but equally it did not insist he return to his job. The man, who still wishes to remain anonymous despite having left, interpreted this as a sign that the company knew it would be difficult to deny his work was the cause. But there are constant denials by the company when the plant is blamed for ill health.”
What one can also take from this is the not uncommon observation concerning how Albright and Wilson treated its community with contempt from a resident who states in the article
“The medical profession has not been remarkably active in trying to identify the source of high asthma, foetal mortality, and genetic abnormality rates which have been found in and around the town. During the past five years rare syndromes have been found in babies born in Whitehaven and nearby Mirehouse. These diseases have led to either mental disorders, cleft palates, cysts, or facial abnormalities. There are also abnormal levels of severe spasticity, premature births, the transposition of body vessels, poor speech, and acute myloid leukaemia…..
….Sheila Smith, who runs the family advice centre in nearby Monkwray, said: ‘It’s the accountability which in some ways concerns me more than the pollution. The thing we have found quite amazing is that Albright and Wilson is a totally closed organisation.
‘Trying to get the company involved in the community is impossible. You just meet with closed doors. As a result, there’s an awful feeling of apathy and despair. The health authority also turns a blind eye, even though this part of the town has the highest death rate from heart disease among women in the northern region, and is among the worst for general health.’
One can perhaps see why after the Greenpeace incident and concerns like this, Albright and Wilson attempted a charm PR offensive with “open days“, which of course, were more like an advertisement for what they made than a factory tour of any real benefit to the put upon polluted.
Political grime.
As at their Oldbury headquarters in the West Midlands, it is apparent that Albright and Wilson at Whitehaven were well represented in political circles. The May/June 1986 edition of Albright World reported that the new mayor of Copeland- the borough in which the works sat, was an employee, and not only that but boasted that he was the fourth employee mayor of that pocket borough to hold the title!
There may well have been others that followed him, but how can anyone really believe that having top councillors onside- especially in matters relating to planning and environmental concerns was not likely to be a very beneficial arrangement for all concerned- with protecting the company polluter?
And then there is the former MP – John Cunningham- now “Baron Cunningham of Felling”. Between 1970-1983 he was MP for the Whitehaven constituency, which then became the Copeland constituency where he would serve another 22 years as the elected representative. He deserves a special mention in how a political friend “who never worked for the company” was actually working for it for many years.
The following article appeared in Albright World, where the then fledgling Labourite was joined on a factory tour of the works by the useless former Prime Minister Jim Callaghan who held talks with union officials and managers- Orwell’s “man to pig and pig to man” comes to mind here .
“He told them that Dr Cunningham, who was his Parliamentary Private Secretary during Mr Callaghan’s government, was “constantly preaching about A+W’s virtues and is a very good advertisement for you”
With this type of ear to the top man, one wonders what the good doctor was actually diagnosing him with about the wretched company, but it is plain to see in the subsequent years that he persisted in this “advertisement” shillery for AW.
“Bottom’s up” champagne socialist
In 1980, he would go on to become a paid “industrial policy adviser” for Albright and Wilson, a title he held throughout his time as shadow environment secretary until he became Minister for Agriculture, fisheries and food under the odious Blair administration. So back to pouring “advertisements” into the ear of the premier. Of course this would be short lived, as Albright and Wilson by now were in terminal decline, so his advice cannot have been of much use in the 80’s
AFTERMATH
With takeover assured, Rhodia did not waste much time in flogging off the Whitehaven site to “Huntsman”- another metamorphosising pillock of a chemical manufacturer. In June 2005, time was called on the entire site, as it shut down for good, with Rhodia diverting its operations abroad.
There are some interesting footnotes to the fallen polluting behemoth of Whitehaven available on the internet.
An excellent urban exploration of the way in which Albright and Wilson/Rhodia and its associates left the site before demolition, almost as though it was Chenobyl can be found HERE. Another on the excellent 28 days later website gives a ghostly tour of the abandoned factory.
from 28 days later- a discarded map of the AW Whitehaven site
It is clear that this post apocalyptic scenario is one very familiar with Albright and Wilson and the manner in which it operated as a company- especially at its demise into the French hands of Rhodia.
Uncharacterised chemicals of all types and colours appear to be scattered everywhere mixing freely with mould alongside office equipment and personal identification tags serving as wafers in the toxic cream. How little the company must have valued the personal data protection of its staff to leave the site such as this!
Clearly the Environment agency will be monitoring this area for many years to come this, one of the many Albright’s bastards.
From the perspective of an ex worker at the site there is a rather whimsical ditty concerning the demise of the works at Whitehaven which can be found below, but it is somewhat unusual for the usually brainwashed ex workers of an Albright and Wilson company to be somewhat critical of both the employer and the union facilitating the destruction of the operation. It is quite clear that longstanding Marchon workers resent Albright and Wilson and Rhodia’s control of operations, as it began to unravel. Ultimately, with the type of chemicals that it made and which will no doubt persist for several decades, what one “couldn’t believe what they’d done” is how they managed to get away with it for so long.
And so to the inevitable talk of “regeneration” from toxic crap. We have this document entitled “West Whitehaven Draft Supplementary Planning Document (SPD) February 2012″, which can be read at the link below.
So when politicians are no longer able to spin their PR about jobs being vital from polluting industry, thus they like to play lego land and still pretend that the toxic legacy does not appear by wanting to build “quality homes” on or near to contaminated land. We do however get the truth of the past in this document about this dirty polluting shambles of a chemical site too late from this self serving council, now that its chemical factory paymasters are no longer there in situ.
“The public perception of the area locally is often poor due to the recent history of the industrial / chemical activities of the Marchon plant. The environmental impacts of the production processes resulted in unpleasant odours, gas clouds, and residue deposits on cars and gardens, as well as ground water contamination leading to foam licks and radioactive deposits in the sea. Visual impacts, noise and lighting pollution affected local residential amenity as did the heavy road traffic generated by the many tanker trips taking raw materials to the site from the harbour.”
Now when did Jack Cunningham and co ever admit to any of this at the time?
There is a parliamentary by-election in the Copeland constituency looming with the departure of Cunningham’s successor as MP there Jamie Reed who is taking up the position of “head of development and community relations” at the Sellafield Nuclear plant in the area. One could strongly argue that this former PR man for the company never left the job during his time as an MP. Perhaps voters should look very closely at the cv’s of the candidates for any grimy links with longstanding pollution.
Memorandum attached to our Evidence to the Public Inquiry.
5/5/21 Memorandum from Radiation Free Lakeland
Applicant’s name: West Cumbria Mining Ltd
Call-in reference: APP/H0900/V/21/3271069
BYERSTEAD FAULT
We would like to make it clear regarding the Byerstead Fault that County Councillors were, as far as we can see, not properly appraised of West Cumbria Mining’s profligate need for fresh water and what the likely impacts of such a huge, ongoing withdrawal of groundwater from the area would be.
We note that the developer’s “Project Description” predicts water usage at 261m3/h. Rather conveniently the water ‘available’( largely from the Byerstead Fault and newly mined voids) is stated as being 262 m3/h. This is an enormous amount of water and would inevitably impact groundwater and geology. This was not discussed at all by councillors who were satisfied with the developer’s assurances that 98 m3/h of the water would be “recycled.” We believe the councillors have been deliberately misled into believing that 98% of the total water would be recycled.
The water that West Cumbria Mining envisage obtaining due to ingress from the Byerstead Fault is 136m3/h. This is far higher than the threshold above which an abstraction licence from the Environment Agency is required, and the Officers’ Report for 19 March 2019 notes at para.6.329 that “the removal of water from the mine would require an abstraction licence”. The Environment Agency have told us there are no applications for abstraction. There is no indication in Environmental Statement Ch.5 of how water will be obtained if the mines experience lower levels of water ingress than predicted (Public Supply? Sharing Sellafield’s Supply?).
IMPACTS
Historically “Mine pumping in the Cumbrian Coalfield has abstracted up to about 20% of the reliable yield, dominating the flow pattern, and drawing in sea water to pollute the aquifers. Chemical analyses of mine drainage water reflect the infiltrated sea water, but suggest that normal groundwater is probably a sodium sulphate type with subordinate amounts of chloride. Mine workings in the Northumberland and Durham Coalfield were extensively interconnected and pumping maintained a water table at about 150 m below the ground surface. With the end of mining activity, groundwater levels are rising.” http://earthwise.bgs.ac.uk/index.php/Hydrogeology_and_water_supply,_geology_and_man,_Northern_England
We note that the County Council’s Minerals and Waste Local Plan states:
16.38 With respect to mineral applications, there is a requirement to establish the relationship that the development has with the water table. If the base of the excavation is near or below the anticipated water table, then there will be a requirement to establish an appropriate monitoring scheme. In some circumstances, the development may be considered unacceptable if it is carried out below the level of the water table.
16.39 The current licensing exemption on dewatering is likely to be removed in 2017, subject to Ministerial approval, after which, dewatering activities will be brought into regulation by the Environment Agency.
ENHANCED SEISMICITY DUE TO MINE DEWATERING “human activity – like water extraction – can cause the stress to be released quickly, rather than dissipating slowly over time. “It’s not just that you’re advancing an earthquake that would have happened anyway. It’s that you’re creating more or larger earthquakes,” https://www.newscientist.com/article/dn22403-thirst-for-groundwater-caused-fatal-earthquake/#ixzz6tzBoSKIO Given the common knowledge that the activities of mining and dewatering can induce seismicity it is puzzling as to why Cumbria County Council have not demanded bullet proof evidence from the regulators that this mine would be safe. This mine is not just anywhere it is 8km from Selalfield. A recent paper explains that the Sellafield site area is at high risk of liquefaction. https://pygs.lyellcollection.org/content/62/2/116/tab-figures-data The lack of scrutiny on impacts is especially troubling as the County Council has a key role to play in the new regulatory requirements demanded by the Outlying Planning Zone of 50km from Sellafield “Cumbria County Council has accepted the report at a meeting of the cabinet, which was chaired by Cllr Stewart Young. “It demonstrates the role of the county council in the nuclear industry,” he said. “This new concept of an Outlying Planning Zone is new. The zone is determined by kilometres from the centre of the Sellafield site. It takes you way beyond the boundaries of Copeland, showing that other areas of Cumbria would also be affected by a serious incident. “It includes BAE and the docks at Barrow. So, the implications of an accident are so significant for the whole county. It is a responsibility that sits then with Cumbria County Council as well as Barrow, Copeland and Allerdale. This is an important piece of work.” https://www.in-cumbria.com/news/18753183.sellafield-nuclear-disaster-spread-across-cumbria—new-map-shows/https://www.cumbria.gov.uk/elibrary/Content/Internet/533/561/44148123654.pdf We reiterate our request to the Planning Inquiry that Water and Nuclear Impacts are not only included but that they are central to the considerations of the Inquiry. These issues are important (not just to Cumbria) and we feel strongly that they must not be smothered under the blanket of climate concern. yours sincerely Marianne Bennett (aka Birkby) on behalf of Radiation Free Lakeland
Thank you for writing to Robert Jenrick Secretary of State for Communities and Local Government regarding the proposed Woodhouse Colliery in West Cumbria and exposing the fact that opening this coal mine would mean that the 6th Carbon Budget would not be achieved by the UK.
We ask that you also write to your parent Dept, the Department of Business, Energy and Industrial Strategy who bizarrely are responsible for the Coal Authority as well as the Committee on Climate Change. The Coal Authority (sanctioned by BEIS) issued conditional Coal Authority Licences to the developers West Cumbria Mining in 2013/14. The licences were issued above the heads of local councillors and the public. These licences have lapsed and West Cumbria Mining have applied for an extension/renewal. We ask that you write to the Secretary of State for BEIS Kwasi Kwarteng urging him to ensure that new Coal Authority licences are not issued for the coal mine in Cumbria. We also ask that you write to the Coal Authority urging them not to issue renewal of licences for West Cumbria Mining. It is a scandal that the original licences were issued quietly 8 years ago. Even more of a scandal now given that we now know the full implications of this coal mine which would be under the decades of Sellafield’s radioactive wastes on the Irish Sea bed and just five miles from the worlds riskiest nuclear waste site. The reasons not to issue licences are overwhelming. Please follow up your excellent letter to Robert Jenrick by writing to BEIS and the Coal Authority and ensure Game Over for the most contraversial and dangerous coal mine ever to be proposed in the UK.
Thank You
Marianne Birkby founder of Radiation Free Lakeland a nuclear safety group who have been running the Keep Cumbrian Coal in the Hole campaign since 2017
Campaign group, Keep Cumbrian Coal in the Hole has sent in a Call In request to the Secretary of State Robert Jenrick MP.
The World Wide Fund for Nature have already sent in a call in request to the Secretary of State. KCCH say they agree with the points WWF make but have advised the Secretary of State of ” further overwhelming reasons for this development to be called in”
These reasons include:
1. West Cumbria Mining are asking for conditions to be relaxed in order to facilitate the addition of lower quality middlings coal to the development
( previously middlings coal was to be a “by product” of this “premium” coal mine ).
2. West Cumbria Mining propose mitigating against subsidence by backfilling 25% of the mined area with cement paste ( the below land area and also close to the Marine Conservation Zone). However 75% of the proposed void which includes the area beneath the Cumbrian Mud Patch would not be backfilled. There is potential for marine radiological pollution as a result of the subsidence induced re-suspension of the heavily radioactively contaminated sea bed sediments of the Cumbrian Mud Patch and surrounding sea bed areas.
The original selling point of this mine was that it would produce “premium quality” coking coal for steel manufacture. West Cumbria Mining in attempting to address the challenge from Keep Cumbrian Coal in the Hole regarding “middlings coal” as a “by-product” have made this proposed development even more absurd by adding a new onsite process to render the extracted thermal/middlings coal into coking coal.
The relaxing of conditions necessary to facilitate this inclusion of lower grade coal are applied for in this new amended application and detailed in West Cumbria Mining’s Planning Statement R20 – page 51.
STEEL MANUFACTURE?
Condition 3 – This condition relates to the coal being for use in steel manufacture only. As this stands it appears that the developers are asking that this condition be removed to refer to authorisation of the “extraction of Metallurgical Coal” – rather than specifying the end use.
QUALITY – ASH AND SULPHUR CONTENT
Condition 76 – This condition relates to the quality of the end product. The quality of the product is to be further reduced from the already generous allowance of 8% Ash content and 1.2% Sulphur content to 9% Ash content and 2% Sulphur content.
AND
A new paper has been written on the radiological impacts of the coal mine. Tim Deere-Jones is an Independent & non-aligned Marine Pollution Researcher & Consultant whose clients include: WWF, The UK Wildlife Trusts, European Climate Foundation, Greenpeace International, European Coastal Local Authorities and many others.
This comprehensive report concludes that the plan by West Cumbria Mining should be abandoned.
It is concluded that there is a real potential for subsidence to occur as a result of the “mass removal” and the creation of extensive sub-sea void spaces, and it is noted that such subsidence could generate earthquake and liquefaction effects which may extend onshore as far as the Sellafield/Moorside sites.
Full Letter can be read below
Rt Hon. Robert Jenrick MP
Secretary of State
Department for Communities and Local Government 2 Marsham Street
London
SW1P 4DF
1st July, 2020
Dear Secretary of State,
APPLICATION REFERENCE NUMBER 4/17/9007 – WEST CUMBRIA MINING
Dear Secretary of State,
You may remember that on 29th October 2019 Tim Farron MP delivered a petition to you in Parliament on behalf of 1,852 people asking that the Secretary of State call in the application by West Cumbria Mining for the first new deep coal mine in decades which was approved by Cumbria County Council in March 2019 and ratified on 19th October 2019.
Now, the Developers have applied for amendments to that original planning application.The Council (whose decision was to be challenged through Judicial Review) are not relying on their original twice approved planning decision but will look at
the amendments as a new application.
We are writing to support the World Wildlife Fund for Nature’s call in of the amended planning application. We agree with the points they make but would like to add further overwhelming reasons for this development to be called in for your consideration.
Previous letters and the petition to you are included for your consideration alongside the new evidence below.
WCM ASK CUMBRIA COUNTY COUNCIL FOR RELAXATION OF CONDITIONS
The original selling point of this mine was that it would produce “premium quality” coking coal for steel manufacture. West Cumbria Mining in attempting to address the challenge from Keep Cumbrian Coal in the Hole regarding “middlings coal” as a “by-product” have made this proposed development even more absurd by adding a new onsite process to render the extracted thermal/middlings coal into coking coal.
The relaxing of conditions necessary to facilitate this inclusion of lower grade coal are applied for in this new amended application and detailed in West Cumbria Mining’s Planning Statement R20 – page 51.
STEEL MANUFACTURE?
Condition 3 – This condition relates to the coal being for use in steel manufacture only.As this stands it appears that the developers are asking that this condition be removed to refer to authorisation of the “extraction of Metallurgical Coal” – rather than specifying the end use.
QUALITY – ASH AND SULPHUR CONTENT
Condition 76 – This condition relates to the quality of the end product. The quality of the product is to be further reduced from the already generous allowance of 8% Ash content and 1.2% Sulphur content to 9% Ash content and 2% Sulphur content.
This is NOT by industry standard a premium metallurgical coal product. By contrast the Global Platts Metallurgical Specifications 2020 guide for Australian Premium Coking Coal is Sulphur no more than 0.05% while Hard Coking Coal is no more than 0.06% Sulphur content. Which makes the Woodhouse product look positively shoddy. No wonder the developers appear to want the condition erased that the end use should be for steel manufacture only.
3 – The permission hereby granted authorises the Winning and Working of Metallurgical Coal for use in steel manufacture only.
Reason: This permission authorises the development for the extraction of Metallurgical Coal. For the avoidance of doubt, Middlings Coal is also produced as a by-product during the processing of Metallurgical Coal.
Reason: This permission authorises the development for the extraction of Metallurgical Coal.
The reason needs to be amended because middlings coal will no longer be produced.
76 – Metallurgical Coal (definition)
Coal with particular physical and chemical characteristics that makes it suitable for use in the production of steel and separated from industrial/ Middlings Coal and reject material during processing at the Coal Handling and Processing Plant. For the avoidance of doubt ‘Metallurgical Coal’ shall be defined as having a maximum ash content of 8% and a maximum sulphur content of 1.25%.
Metallurgical Coal (definition)
Coal with particular physical and chemical characteristics that makes it suitable for use
in the production of steel and separated
from reject material during processing at the Coal Handling and Processing Plant. For the avoidance of doubt ‘Metallurgical Coal’ shall be defined as having a maximum ash content of 9% a maximum sulphur content of 2%.
The original maxima as stated do not reflect the product which will be produced by Woodhouse Colliery
Page 51 – WCM Planning Statement R20
CLOSE PROXIMITY TO SELLAFIELD AND THE CUMBRIAN MUD PATCH
Image and Text from : RADIOLOGICAL IMPLICATIONS of POTENTIAL SEABED SUBSIDENCE SEISMICITY & “FAULT RE-ACTIVATION” beneath The CUMBRIAN MUD PATCH: INDUCED BY “MASS REMOVAL”, RAPID EXTRACTION & VOID SPACE CREATION – Briefing Paper by Tim Deere Jones for Keep Cumbrian Coal in the Hole
A new paper has been written on the radiological impacts of the coal mine. Tim Deere-Jones is an Independent & non-aligned Marine Pollution Researcher & Consultant whose clients include: WWF, The UK Wildlife Trusts, European Climate Foundation, Greenpeace International, European Coastal Local Authorities and many others.
This comprehensive report concludes that the plan by West Cumbria Mining should be abandoned. The introduction and Major Conclusions are reproduced below…..
“Introduction:This Briefing offers a review of the possible seabed morphological changes and marine pollution implications of the sub-sea coal mining venture proposed by West Cumbria Mining (WCM) at their Woodhouse Colliery site near St Bees Head.
WCM have designated and identified a sub-sea mining zone of the Irish Sea lying to the west of St Bees Head and extending at least 8kms offshore and southwards to within about 8km of the Sellafield site.
The WCM extraction proposals, using continuous mining methods, predict the extraction of approximately 3 million tonnes of coal per year over a 50 year period. This extraction rate will eventually generate a huge subterranean void space of approximately 136 million cubic metres (a volume greater than that of Wastwater Lake).
This briefing considers the impact of the creation of such a sub-sea void space on the possibility of sea bed subsidence in the area of the WCM designated sub-sea mining zone, and the subsequent potential for marine radiological pollution as a result of the subsidence induced re-suspension of the heavily radioactively contaminated sea bed sediments of the Cumbrian Mud Patch and surrounding sea bed areas.
Major Conclusions
It is noted that there is a lack of data about the status of the existing historical galleries and workings of the West Cumbrian Coalfield. It is noted that there is a lack of accurate data about the history and status of any subsidence seismicity in the coalfield.It is noted that the BGS have concluded that the coalfield is heavily faulted and has a long history of subsidence and that it appears that there are no plans to monitor for any subsidence prior to, during the operational phase or in the post operational phase of the Woodhouse Colliery.It is noted that sub-sea monitoring equipment is available and could be deployed in the region in order to monitor for any subsidence effects arising as a result of the proposed Woodhouse Colliery “mass removal” extraction.
It is concluded that there is a real potential for subsidence to occur as a result of the “mass removal” and the creation of extensive sub-sea void spaces, and it is noted that such subsidence could generate earthquake and liquefaction effects which may extend onshore as far as the Sellafield/Moorside sites.
It is concluded that any seabed subsidence in the WCM designated sub-sea mining zone would generate re-suspension of Cumbrian Mud Patch heavily radioactive seabed sediments. It is noted that such an event would generate elevated doses of man-made radioactivity to coastal zone populations and sea users along both the Cumbrian coast and at “downstream” regions further afield.
Given the potential for such a radiological effect and the delivery of increased doses of radioactivity to relevant coastal zone communities, some of which have already been identified by the authorities as Coastal Critical Groups, the Woodhouse Colliery proposal (especially in the absence of any precautionary mandatory subsidence monitoring) is strongly contra-indicated and should be abandoned.”
Keep Cumbrian Coal in the Hole have been raising awareness about the climate and radiological impacts of this proposed development since 2017. If not now – when will this plan be deemed too dangerous to continue with? Please call in this amended planning application for this deep coal mine development which if allowed to continue on its disastrous trajectory will impact locally, nationally and internationally.
Tomorrow is too late.
Yours sincerely,
Marianne Birkby
on behalf of Keep Cumbrian Coal in the Hole.(a Radiation Free Lakeland campaign)
Due to unprecedented numbers of representations being received on this application, including some received after the Consultation deadline and some that have contained new evidence, the Council has decided to postpone taking this application to the Development Control and Regulation Committee for a decision on 8th July in order to properly consider all representations and documentation received. The Council will now look to provide an alternative date. Please check our website on www.cumbria.gov.uk for further information”
Well Done to Everyone who has written into Cumbria County Council opposing this plan – It is NOT A DONE DEAL !!
Sellafield – spitting distance from the proposed coal mine off St Bees Head (where the sheep are)
The World Wide Fund for Nature has asked for a “call in” of the planning decision due to be taken by Cumbria County Council.
This is Great News!
We shall also continue our lobbying of the Secretary of State to intervene and stop the plan for the first deep coal mine in the UK in decades.
The full “call in” letter from WWF can be read below. It is very good but there is no reference at all to the close proximity of Sellafield, a burning but neglected issue which we at Keep Cumbrian Coal in the Hole will continue to flag up.
Rt Hon. Robert Jenrick MP
Secretary of State
Department for Communities and Local Government 2 Marsham Street
London
SW1P 4DF
Dear Secretary of State,
19th June, 2020
APPLICATION REFERENCE NUMBER 4/17/9007 – WEST CUMBRIA MINING
WWF-UK wrote to you in July 2019 to ask you to call in the previous application madeby West Cumbria Mining, which was approved by Cumbria County Council’sDevelopment Control and Regulation Committee; you declined to do so. The county council decided to grant planning permission and local campaigners commenced judicial review proceedings.
Following the grant of permission to proceed with the challenge, the developer filed an amended planning application to develop the coal mine. However, we consider the case for you to call in this application is strong, particularly in light of events occurring since we wrote to you last summer, and some of the information submitted by the developer in support of the amended application.
Caborn criteria
We consider that at least two of the Caborn criteria for call-in are met in this case. The first is that the proposal conflicts with national policy on important matters – in particular policy on mitigating climate change, the presumption against coal extraction in para. 211 of the National Planning Policy Framework, and duties to reduce CO2emissions under the Climate Change Act 2008 and under international law by the Paris Agreement. As we set out in our correspondence of last year, the development is in breach of policy adding to the global coal stock, assumes a long-term reliance on coking coal that is contrary to the trajectory indicated by UK and EU climate policy and legislation (informed by the Paris Agreement) and seeks to put in place new, long-term and environmentally invasive infrastructure.
Second, and again as per our letter last year, the proposal gives rise to national controversy; our previous letter provides evidence of this. Since our last letter, the application has been subject to judicial review proceedings and a wide cross section of groups have spoken out against it, including local campaigners, national NGOs (e.g.
Green Alliance, WWF) and independent academics (e.g. Professor Ekin).
You will be aware that the application by Banks Mining for an open-cast coal mine at Highthorn, Northumbria was called in and remains undetermined. So far as administrative law imposes a duty to treat like cases alike, WWF suggests you must give careful consideration to treating Woodhouse Colliery in like manner, calling it in.
Detail
We see nothing in the revised planning application that negates our original three grounds for objecting to the proposed project (set out in more detail in our letter to you of 15th July, 2019). These are set out (in summary) below together with a number of new points in response to the amended application.
That government is committed to a net-zero greenhouse gas emissions target by 2050, under the Climate Change Act 2008 – a decision that theCommittee on Climate Change is clear “must be embedded and integratedacross all departments, at all levels of government, and in all major decisionsthat impact on emissions.” The iron and steel industries – the customers for coking coal produced from this proposed mine – are no exception to this.
The declining need for coal production of this nature over the short-term and over the 50-year proposed lifespan of the project, and the impact on greenhouse gas emissions of extracting it – in short, whether the benefits from the project outweigh its likely environmental impacts. The previous caseconcluded that industry’s need for metallurgical coal outweighed theenvironmental impacts, but with no sound evidence that coal from this proposed colliery would replace, rather than supplement, existing supplies, whether in the UK or in other markets.
The impact on the rights of children and future generations. A mine would generate significant carbon emissions over the course of the next 50 years and for at least 20 years after the UK is required to meet its net zero greenhouse gas emissions target in 2050. The consequences of those emissions (eg: in terms of their contribution to global heating) and the responsibility to offset them to meet the new 2050 target will fall disproportionately on the young, impacting on their human rights – including Article 8 of the European Convention of Human Rights in a manner which we believe cannot be justified at a time of climate crisis. The mine is also liable to generate significant air quality impacts and it is well established that air pollution disproportionately affects the young because their lungs are still developing1. As set out previously, the UN Convention on the Rights of the Child applies here (because the ECHR is in play) and requires decision makers to ensure that the best interests of children are a primary consideration and that the impacts of the decision on children are assessed and taken into account. There is no evidence that such an assessment has been undertaken in relation to the amended application, hence the flaw identified previously remains.New grounds
• Global footprint – the developer has failed to assess the carbon impacts of
use of the coal in steel foundries overseas. WWF considers that the exported
emissions (must be assessed pursuant to the council’s duty to take account ofthe Paris Agreement following important new case law (Friends of the Earth v Secretary of State for Transport). Paris provides a temperature limit which is the shared responsibility of states to achieve. It is therefore unsustainable not to take into account the emissions arising abroad as a result of activities within the UK when the duty to achieve the temperature limits in the Paris Agreement are imposed collectively on all states. Further, WWF argues that thedeveloper’s approach either fails to comply with the EIA Directive or fails to enable the planning authority to take account of material consideration by failing to assess the likely scale of the impact of burning the coal abroad.
• High carbon development – the developer has wrongly categorised thedevelopment as “low carbon” because it has failed to assess the exported emissions as aforesaid. No consideration has been given to the likelihood that coal which may be edged out of use in European steel works by coal produced from the development would be burnt regardless leading to an overall increase in global greenhouse gas emissions. This fact flows both from the laxity of current commitments made by states under the Paris Agreement by way of Nationally Determined Contributions to date2 and the failure of many states (including the UK) to prohibit exported emissions in domestic legislation. Nor can the section 106 agreement proposed by the developer (to assess every 5 years whether the development continues to comply with carbon budgets) remedy the problem because carbon budgets do not build in exported emissions either. Far from being low carbon, the development is arguably high carbon, will add significantly to the emission of greenhouse gases (understood in a broader sense) and therefore conflicts with NPPF para 211. It must be called in.
• Net Zero – the net zero target was adopted before the original planning application was resolved to be granted by the County council. However, there is a suggestion in the amended planning application that this is not for the planning authority to take account of (because the duty in the Climate Change Act fastens on the Secretary of State). WWF is confident that the Secretary of State does not take such a view and he agrees with us that the target is a material consideration for the purposes of section 70 of the Town and Country Planning Act 1990. . However, to ensure the planning authority does not fall into error, WWF considers the safest route would be for the Secretary of State to call in.
Carbon plan – no consideration has been given to the fact that government has yet to adopt a carbon plan which sets out how the net-zero target will be met –nor has it yet explained how it will bring itself into compliance with carbon budgets from the mid-2020s onwards. By granting planning permission at this point for such a long-term, high carbon development, the council risks locking in high carbon infrastructure for many decades to come thereby pre-emptingimportant decisions about the UK’s pathway to net-zero which are pre- eminently for ministers to take. A decision to grant would be premature at this stage.
Equality – the council is subject to a duty in domestic law to have regard to the need to advance equality of opportunity as between people who have protected characteristics and those who do not (section 149 Equality Act 2010). As set
out above, the development will impact disproportionately on the young yet no Public Sector Equality Duty assessment appears to have been undertaken. Should the failure continue, it leaves the application vulnerable to challenge.
We cannot decarbonise our economy at the speed and depth required to avert catastrophic impacts of climate change by substituting one source of fossil fuels for another.
WWF-UK has modelled an emissions reduction scenario for the UK to 2045 and to 2050 in a report with Vivid Economics, entitled Keeping It Cool3. This demonstrates the degree of decarbonisation needed in each sector, as well as the overall pathway. This makes clear that we will not need metallurgical coal for the next 45-50 years that this mine will be producing it. We do not need a new source of metallurgical coal in the short-term and it is spurious to argue that the emissions from this coal will be slightly lower than existing sources, when to achieve this would (a) add to the existing stock of metallurgical coal in the marketplace overall, (b) do so for far longer than any country can be relying on fossil fuels, and (c) do so in a way that generates new emissions from the construction, running and transport out of the country of the coal produced at the mine. It is clear that the need case in respect of the application is simply not made out.
Keeping global warming to 1.5°C requires that we stop using coal, as soon as possible, both for power generation and industry. Modelling by a group of 20 researchers indicates that keeping to 1.5°C without geoengineering requires the virtually complete elimination of fossil fuel emissions and fossil fuel infrastructure by 2050 and that global coal production must decline by 5886 million tonnes a year in 2015 to only 407 tonnes in 2050 – a reduction of around 93%4.
Given this and given the UK’s avowed global leadership on climate change – not least as holders next year of the presidency of the crucial UNFCCC Conference of the Parties (COP) 26 – allowing new coal production on its own shores would be perverse. Not only does it send a particularly unwelcome signal to the wider world about its commitment to climate action, but it adds to the already daunting scale of decarbonisation that would be required in other sectors in order to make net-zero possible by 2050.
Additionally, it continues to pile the costs of delayed climate action, and of climate impacts, onto children and future generations.
This is most definitely a consideration for national government (owners of the legally- binding target for net-zero by 2050), for local government (who cannot simply abrogate their responsibility for additional emissions from projects such as these on the basis that they are but one small contributor), and for local people (who will bear the costs of growing climate impacts).
Nearly 4000 people, including Chris Packham have signed the petition to Stop the Coal Mine in Cumbria – Please keep sharing and signing. As well as signing the petition – People can STILL WRITE individual letters to Cumbria County Councillors who will be making the decision on this to let them know STOP THE COAL MINE!
Yesterday was the last ‘official’ date to send in objections to the new ‘amended’ planning application. You can still send in letters of objection up to the Planning Meeting which is scheduled for the 8th July (if this goes by previous form the meeting will be rescheduled again and again). Please do send in letters to members of the planning committee.(They have voted yes to this diabolic plan twice before,).
This is the Keep Cumbrian Coal in the Hole objection …
15th June 2020
West Cumbria Mining: Planning Application Ref 4/17/9007:
Woodhouse Colliery, High Road, Whitehaven
Dear Development Control and Regulation Committee,
I write on behalf of Keep Cumbrian Coal in the Hole, a campaign by Radiation Free Lakeland to ask that the County Council do not approve this amended planning application
We are a civil society group that aims to remove the risk of environmental damage both nationally and internationally that may arise from the presence of an extensive nuclear industry close (to the Lake District National Park, a World Heritage Site).
On 19th March Cumbria County Council (CCC) granted conditional planning permission for a resumption of the long abandoned onshore coal mining at St Bees to West Cumbria Mining Limited (WCM). This would be followed by the ‘profit making’ offshore phase. On 20 June 2019, our lawyers Leigh Day wrote to Cumbria County Council. The letter addressed a number of legal issues, including Cumbria County Council’s failures to consider:
Greenhouse gas (GHG) emissions of the mining operations
The need for, and GHG impacts of, Middlings Coal
The Government’s Net Zero target.
Despite being alerted to those concerns, Cumbria County Council ratified its decision on 31 October 2019. Mrs Justice Beverley Lang agreed that those legal issueswe raised were arguable and justified a public hearing.
In order it seems to circumvent the scrutiny afforded by Judicial Review and the criticisms levelled in the Green Alliance report the Developers have now submitted a new planning application.This is despite theCEO of West Cumbria Mining publicly stating that : “If you asked me to get planning for another one, I would say it would be impossible right now unless something significantly changed,”Mark Kirkbride, British Tunnelling Society lecture reported in New Civil Engineer 26th February 2020
The CEO of West Cumbria Mining went on to say:
“When we applied for planning it was a different set of planning rules. Now if you were to submit planning you’d have to try and do whole life greenhouse gas assessments.”Given that steel can and should be produced without the use of coking coal – the additional GHG emissions arising from the use of coking coal from this mine to make steel should be taken into account .
The amended planning application while attemping to address the original challenges we raised has compounded our concerns about the cumulative impacts of this mine. Regarding climate The use of coal from this mine will undermine the government’s net zero target, carbon budgets and policy to adhere to the Paris Agreement.
NEW PROCESS TO TURN THERMAL/MIDDLINGS COAL INTO COKING COAL
The original big selling point of this mine proposal was that it would produce “premium” quality coking coal. In order to answer legitimate criticisms on the previous ‘by-product’ of middlings, the developers propose now to turn the 15% (or more) by-product of middlings/thermal coal into coking coal.The details on this are sketchy. WCM say that in order to turn the thermal coal to coking coal there will be an additional process to enhance separation and removal of pyritic sulphur matter but then go on to claim optimistically that:
“ Since this adjustment relates only to the internal process …. and no difference to external appearance …. it is not considered that it will give rise to any material effects of the proposal.” This is clearly impossible – the removal of pyritic sulphur and the myriad other polluting imupurites from the middlings would leave an additional and unaddressed toxic footprint.There would also be additional energy and freshwater usage. In order to address the issue of the new and inferior quality of product, West Cumbria Mining propose a relaxation of the conditions that determine the specification for metallurgical coal. The developer justifies a relaxation on the grounds that the original specification does not reflect the (now inferior) product that will be the final output from the Woodhouse Colliery, specifically with regard to ash and sulphur content. WCM are also asking for removal of the condition that the product must be used only for steelmaking.This is entirely understandable as once exported, WCM have no way of ensuring their coal is used solely for steel making (despite their considerable PR in this regard).
METHANE
The WCM report by Dr Neil Bristow says that “WCM is committed and obliged to install a methane capture and drainage system. …It will be put to use as an energy source of the mine with no atmospheric impact.”This disingenously suggests the impossible namely that 100% of the methane emitted by the mine (continuously by the exposed and broken coal) would be “used” …”with no atmospheric impact.” In the first two decades after its release, methane is 84 times more potent than carbon dioxide Overall it is roughly 30 times more potent than CO2 as a GHG. WCM propose to build the methane capture plant by year 5.Calculations have been done independently which suggest that “ 13.9MCu m of methane could be produced and if the Capture system is not operational by then (year 5) it is possible that 38.75M cu m will be released before then. That is an equivalent effect on the atmosphere of 856486 T of Co2.From year 5 the Methane capture plant will need to capture about 13.9Mcu m per year if there is to be ‘no atmospheric impact’. Where will it be stored? To put this volume into context the old style town gasometers held about 50000cu m. So WCM are planning to capture and store the equivalent of 5.3 gasometers per week, every week!!!This is a substantive GHG impact on which the council needs information.
POLICY DC20 THE WATER ENVIRONMENT
Cumbria County Council’s Policy DC20 states “Proposals for developments should demonstrate that they would have no unacceptable quantitative or qualitative adverse effects on the water environment, both within the application site and its surroundings, including surface waters, coastal waters, private water supplies and groundwater resources. Proposals that minimise water use and include sustainable water management will be favoured.”
FRESH WATER
Despite requests to them for information by us and other NGOs, West Cumbria Mining have not demonstrated what the impact on ground water will be.There is no information in the public domain regarding the projected quantity of freshwater abstraction from the Byerstead Fault or potential hydrological impact. This is an important issue in West Cumbria which is already suffering from fresh water stress. WCM again use disingenous language to suggest that virtually all freshwater would be recycled suggesting that there would be minimal abstraction.There is no indication of exactly how much water WCM expect to abstract per day from the Byerstead Fault – a named geological fault.The Marine Conservation Zone documentation describes it thus.. “This site lies within the boundary of the rMCZ11 and is situated in Saltom Bay on the Cumbrian coast north of St Bees Head. The site includes an area known locally as Byerstead Fault, a recovering intertidal zone that is showing a return of species diversity..”
“Water is heavily used in coal processing and would be obtained from the following sources: Groundwater (Byerstead Fault) “
WCM presentation to CCC 19th March 2019
Cumbria County Council’s Minerals and Waste Local Plan states:
“16.36 Proposals will, therefore, be required to demonstrate that they do not have unacceptable adverse impacts on water resources. Any adverse impact should be avoided or, if unavoidable, suitable mitigation measures should be proposed. Unacceptable quantitative or qualitative impacts are those which are deemed so by the Environment Agency, as part of the planning application process.
16.37 Sites proposed for development will need to be subject to site specific hydro- geological assessment, in order to determine their acceptability. Some factors influencing this process are the type of facility, the pollution control measures adopted, the potential impacts on groundwater resources and the groundwater vulnerability of the site.
16.38 With respect to mineral applications, there is a requirement to establish the relationship that the development has with the water table. If the base of the excavation is near or below the anticipated water table, then there will be a requirement to establish an appropriate monitoring scheme. In some circumstances, the development may be considered unacceptable if it is carried out below the level of the water table”.
Not only will WCM be abstracting fresh water from the Byerstead Fault but the development is in the region of the West Cumbria Aquifer – a water resource that is currently used to provide fresh water for much of West Cumbria.A region that is heavily faulted and complex.
WCM have revealed so litte detail about their fresh water usage that there can be no proper scrutiny or oversight by Cumbria County Council or the public.
The amended planning application gives no idea of exactly how much waterwould be abstracted from the Byerstead Fault (see above) at peak production of the mine – or of the damage likely to be caused by this abstraction
HAZARDOUS INSTALLATIONS – COAL AND NUCLEAR WASTE AT SELLAFIELD (and DRIGG)
When preparing Local Plans, local planning authorities are required to have regard to the prevention of major accidents and limiting their consequences. They must also consider the long-term need for appropriate distances between hazardous establishments and population or environmentally sensitive areas. They must also consider whether additional measures for existing establishments are required so that risks to people in the area are not increased.
Cumbria County Council are no exception and the Minerals and Waste Local Plan states that:
5.102. “Permission should not be given for the extraction of coal unless the proposal is environmentally acceptable, or can be made so by planning conditions or obligations; or if not, it provides national, local or community benefits which clearly outweigh the likely impacts to justify the grant of planning permission”.
and…
13.23 In some cases, a proposed development may itself have multiple environmental impacts that would be acceptable on their own, but which may exacerbate adverse impacts caused by other developments. Such cumulative environmental impacts can derive either from a number of developments with similar impacts being operational at the same time in an area, or from a number of concurrent developments in an area with different impacts or from a succession of similar developments over time. They can include the impacts of noise or traffic, and impacts on local communities, the landscape, water resources or wildlife habitats.
13.24 Local Plan policy needs to take account of the extent to which a particular locality, community, environment or wider area can reasonably be expected to tolerate such adverse cumulative impacts. This may involve mitigation of impacts or the timing of permissions and phasing of operations to make a proposal acceptable. Where cumulative impact presents a potential issue, applicants should be able to demonstrate that this has been adequately assessed and addressed in a planning application.
The Office for Nuclear Regulation’s official remit to consult on planning applications is 7.4 km from Sellafield. The coal mine extends to 8km from Sellafield i.e. 600 metres difference. In the absence of any detailed regard to cumulative impacts by either the developers or Cumbria County Council or the regulators we have commissioned a Briefing Paper on the radiological implications of West Cumbria Mining’s plan.
The author of the paper, Tim Deere-Jones is an Independent & non-aligned Marine Pollution Researcher & Consultant whose clients include: WWF, The UK Wildlife Trusts, European Climate Foundation, Greenpeace International, European Coastal Local Authorities and many others.
This comprehensive report concludes that the plan by West Cumbria Mining should be abandoned.
The introduction and Major Conclusions are reproduced below…..
Introduction:This Briefing offers a review of the possible seabed morphological changes and marine pollution implications of the sub-sea coal mining venture proposed by West Cumbria Mining (WCM) at their Woodhouse Colliery site near St Bees Head.
WCM have designated and identified a sub-sea mining zone of the Irish Sea lying to the west of St Bees Head and extending at least 8kms offshore and southwards to within about 8km of the Sellafield site.
The WCM extraction proposals, using continuous mining methods, predict the extraction of approximately 3 million tonnes of coal per year over a 50 year period. This extraction rate will eventually generate a huge subterranean void space of approximately 136 million cubic metres (a volume greater than that of Wastwater Lake).
This briefing considers the impact of the creation of such a sub-sea void space on the possibility of sea bed subsidence in the area of the WCM designated sub-sea mining zone, and the subsequent potential for marine radiological pollution as a result of the subsidence induced re-suspension of the heavily radioactively contaminated sea bed sediments of the Cumbrian Mud Patch and surrounding sea bed areas.
It is noted that there is a lack of data about the status of the existing historical galleries and workings of the West Cumbrian Coalfield.
It is noted that there is a lack of accurate data about the history and status of any subsidence seismicity in the coalfield.
It is noted that the BGS have concluded that the coalfield is heavily faulted and has a long history of subsidence and that it appears that there are no plans to monitor for any subsidence prior to, during the operational phase or in the post operational phase of the Woodhouse Colliery.
It is noted that sub-sea monitoring equipment is available and could be deployed in the region in order to monitor for any subsidence effects arising as a result of the proposed Woodhouse Colliery “mass removal” extraction.
It is concluded that there is a real potential for subsidence to occur as a result of the “mass removal” and the creation of extensive sub-sea void spaces, and it is noted that such subsidence could generate earthquake and liquefaction effects which may extend onshore as far as the Sellafield/Moorside sites.
It is concluded that any seabed subsidence in the WCM designated sub-sea mining zone would generate re-suspension of Cumbrian Mud Patch heavily radioactive seabed sediments. It is noted that such an event would generate elevated doses of man-made radioactivity to coastal zone populations and sea users along both the Cumbrian coast and at “downstream” regions further afield.
Given the potential for such a radiological effect and the delivery of increased doses of radioactivity to relevant coastal zone communities, some of which have already been identified by the authorities as Coastal Critical Groups, the Woodhouse Colliery proposal (especially in the absence of any precautionary mandatory subsidence monitoring) is strongly contra-indicated and should be abandoned”
The full report is attached as a pdf
CONCLUSION
The weight of evidence is overwhelmingly clear that this application should be unequivocally refused.We urge Cumbria County Council to take eagerly with both hands this new opportunity, via the amended planning application, to turn down this dangerous coal mine plan, for Whitehaven, for Cumbria, and for the Planet.
If you have time please write to Cumbria County Council and tell them to scrap this terrible plan (even if you have written before please drop them a line again).
The main points to make are that this mine would fly in the face of the Council’s own climate commitments and its own stated commitments to protect the health and well being of all Cumbrians….AND the IMPACTS of this mine would extend far BEYOND Cumbria. Send an email to development.control@cumbria.gov.uk – quoting the application reference number 4/17/9007 and including your name and address.
Keep Cumbrian Coal in the Hole 
