Now we need funds to continue the fight and STOP THIS COAL MINE. While the climate impacts of this mine have been much in the news, with the enormous carbon emissions over the lifetime of the mine, the nuclear impacts have been more taboo and were not even mentioned by the councillors in their deliberations.
The mine would be five miles from the world’s riskiest nuclear waste site –Sellafield Mass void removal as proposed by this coal mine is known to induce seismicity. As well as this certain seismic risk the mine would be directly below the radioactive sediments which have settled on the Irish Sea bed from decades of Sellafield discharges. The radioactive sediment estimated to include around 500kg of plutonium along with a cocktail of other radioactive isotopes ( the devastation of Nagasaki was caused by 1kg of plutonium) is named as the Cumbrian Mud Patch. In approving the plan the County Council acknowledged that seismicity and subsidence of the Irish Sea bed is likely but that it could be “mitigated” – with the developers self moderating impacts. Incredibly Sellafield is “in support” of the coal mine plan which lies below the decades worth of their radioactive waste discharge lying on the Irish Sea bed (the plan was to “dilute and disperse”).
Campaigners have also been lobbying the Secretary of State to call the decision in for a public inquiry. If a public inquiry were to be called we would use any donations to pay for expert advice and representation by Leigh Day.
With your help we can challenge this outrageous decision by Cumbria County Council. This coal mine would have impacts way beyond the sum of its parts.
With your help we can and we MUST STOP the Cumbrian Coal Mine
Note: All money goes directly to our Lawyers, Leigh Day who have already worked at well below commercial rates but we still need funds to cover legal fees and court costs should they arise. Already we have, with Leigh Day’s detailed legal work, delayed this plan now we need to stop the plan in its tracks.
We have permission to publish the following photo journal of a morning jog. The route is through the Whitehaven area past the proposed coal mine.
“It was a lovely morning for my run. The sun rises on another day. Two thirds of Copeland Borough are in the national park, a World Heritage Site. How disappointing that the remaining third has a coal mine; and a nuclear storage facility.
Our local MP Trudy Harrisons tells us that the mining company has a sound business plan. I think the Trojan Horse scenario is a strong possibility. A GDF is a little way off, plenty of time for a private company to invest in a coal mine and create a big cavern inshore. Coal mining and nuclear disposal advisory group in cahoots it seems.
My run takes me past the new housing estates opposite the mine site. I work with a couple of people here, they are not too bothered about the mine, both said that we need jobs. This is quite true, we need jobs but we are not unique, lots of areas are crying out for jobs. There are more people employed than unemployed in Whitehaven. If they build this mine I fear those new build houses won’t be such an investment, who wants to live next to a coal mine.
I cut across the old Marchon Chemical works to pick up the coastal path to take me to Whitehaven Harbour. Haig Pit is the HQ for West Cumbria Mining. Thay have taken over the mining museum, fascinating I have visited on three occasions before it closed a few years ago. You came away in awe of those miners. Did you know the pithead lift operator had to count the revolution on a clockwork wheel to control the descent of the lift cage. Mess it up and the cage and miners would be crushed as it hit the bottom. Every so often they had to recalibrate the wheel to compensate for the stretch in the steel cable. If it opens again pay a visit. Coal mining is our heritage not the future.
Down hill now towards our harbour and the candlestick vent chimney. The new coal mine vent, to be situated near Sandwith won’t be as elaborate. Perhaps just like the candlestick they will let it vent mine gases (methane).
The only thing I agree with in WCM’s new proposal is their acknowledgement that methane is the most potent greenhouse gas. They are quite happy to vent this into the atmosphere though and at a later date put some methane capture in place to use as an energy source; more pollution but still only less than 1% of the UK (England, Scotland, Wales & Northern Ireland; population 67,886,000) carbon budget.
Round the harbour, the water is looking really clean now that they have introduced a floating rubbish collector. Past the mermaid, she is my favourite and I stop a moment to watch a couple of coast to coast cyclists dip their bike wheels. Their route will take them across the head of the Pow Beck Valley, location of the train loading facility. It is peaceful and green now, an uninterrupted view down the valley with St,Bees Priory standing proud, It’s a lovely view from the cycle track.
The coast to coast proper drops into Pow Beck They are to build an underpass for walkers. I can’t see the appeal of seeing dozens of coal wagons in this green valley, Not all the coal mine is to be built on an old industrial site. So this is how Cumbria protects its tourist assets, lets dig coal, Shameful.
The run takes a turn for the worse, back to my starting point at Seacliffe. It’s all uphill now, those steps are so steep they could be ladders. “
A local resident has sent the following letter to Cumbria County Council – it exposes many of the massive holes in West Cumbria Mining’s amended planning application. Please use this as inspiration to write your own letters of objection to ask that this mine is NOT GIVEN APPROVAL
A quick reading of the WCM proposals leads me to believe that they have been made in response to the Green Alliance Report and were intended to negate the proposed Judicial Review.
Basically WCM are no longer producing the contentious thermal coal and are also planning to control the output of methane. They are also placing great emphasis on how the mine will reduce GHG in America and in reduced transport.
1.1 In more than one section WCM say that there will be an additional process to enhance separation and removal of pyritic sulphur matter.
“ 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”
1.2 This cannot be the case.As it is a new process it may have implications that Cumbria CC may wish to consider. Some processes for removing pyritic sulphur can involve hydrochloric acid.
1.3“ The vol of reject material to be returned underground remains the same”
This cannot be the case if the new process is producing more waste. This in turn will go through the paste plant and result in more cement being used.(see my letter of the 24/1/19)
2.0 Methane Capture and Utilisation
2.1In their submission to Cumbria CC WCM use several phrases to describe their proposals.
“During the ramp up phase to full production a detailed design of a methane capture and utilisation plant will begin once viable volumes are available. It is assumed it will be operating from 5th year of production”
“ Methane capture and drainage system will reduce and mitigate release of methane and…. will have no atmospheric impact”
Bristow report – “ 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”
These three quotes show that WCM have no real plan at the moment and are making assumptions about when it will start.‘Reduce and mitigate’ are not the same as ‘ no atmospheric impact’
2.2 Twice in the above quotes WCM say ‘ no atmospheric impact’so this implies that 100% of the methane will be captured.To get an idea of the scale of the task I have produced the attached Methane table. (Table 1)This shows that in year 5 13.9MCu m of methane could be produced and if the Capture system is not operational by then 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.
2.3From 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!!!
2.4 Methane in the mine ventilation system will be very diluted with air so will be very difficult to extract.By drilling boreholes into the coal faces before working an area the methane may be captured when the area is worked. Overall it is very doubtful if the plant will extract any more than 75% .
2.5 Even with the capture plant it is likely that of the 13.9MCum produced each year from Year 5 only 10.425MCum will be captured. I would not call the 3.5Mcum /yrremaining as having‘no atmospheric impact’ as WCM claim.
2.6Even though WCM are placing great emphasis on the Capture and Utilisation plant to enhance their ‘green’ credentialsI am surprised that they are so vague about details.They have no design yet, no details of how much methane will be captured , no storage details , and no utilisation details.
2.7It is difficult to see how the capture plant and storage system could be housed in the present structure that is proposed.
2.8Even if my estimated figures for methane capture are 50% out , the fact remains that WCM intend to store large quantities of methane on site , near residentialestates.
2.9WCMsay they will utilise methane to generate electricity for their own use.If this utilisation is less than the capture how do they envisage that the surplus will be stored ?
3.0WCM coal v USA coal
3.1 WCM say that ‘ the substitution of US coal with Cumbrian coal … is not likely to result in an increase in GHG emissions’ alsothey say ‘It is reasonable to assume that coal mined in the UK will contribute less GHG emissions than an equivalent operation in the USA.’
3.2These statements may well be true but nowhere do WCM give any figures to show how they have arrived at these conclusions.
3.3 WCM admit that they are not sure how much methane /ton of coal will be produced in their mine. They say 2 to 6 Cum /T .No where do they say what they have estimated for the USA mines.It is guess work and supposition.Withoutany evidence they are assuming that the USA coal gives off more methane.
3.4In order to get some handle on the truth of their statements I have produced Table 2.I have used a figure of 5cu m /T for Cumbria and 2.5 cu m /T for the USA.Who is to say that these figures are right or wrong ?
3.5From Table 2 it can be seen that WCM produce twice the methane of the USA in the first 5 years.It is only when the Capture plant becomes operational in year 6 that WCMmethane levels fall below the USA.Even after 10 years the total that WCM could potentially emit over that 10 year period is still higher than the USA.
3.6 Importantly any methane that would have been emitted in the USA will now be emitted in the UK
3.7WCM assertion that their mine will emit less GHG than a mine in the USA is not based upon any facts that they have produced.
4.0 New Technologies
4.1In their response to the Green Alliance ReportWCM give details ofnew technologies that may negate or reduce the use of metallurgical coal. They say they do not envisage any viable technologies in the next couple of decades.
4.2Technologicalchange may be quicker than this, spurred on by legislationin European countries.Who 20 yrs ago could have seen the development of wind turbines on the present scale.
5.0 Labour and Hours of Work
5.1 I was interested to see the table of potential salaries paid by WCM.
5.2 The local Mayor and several local politicians have been supporting the mine on the basis that it will bring well paid jobs. They may be disappointed.
5.3To me they do not seem to be well paid. In fact in Dr Bristow’s report for WCM which discussesthe economics of the mine, he says ‘ salaries for miners (UK)are lower than for other countries’
6.0 Cumbria CC Emergency Planning
6.1I was surprised that in their response to this latest proposalthey basically said ‘no comment’
6.2This is very surprising considering the nature of the methane capture plant and that methane will be storednear residential properties.
6.3They should look at the proposal again.!
7.0Scale of Operations
7.1In my previous correspondenceI have expressed surprise at the scale of paste pumping operations that WCM propose.
7.2 I have also previously pointed out that WCM are proposing a peak of coal production that exceeds the maximum peak that was ever achieved by all the combined mines of West Cumbria. The history of the West Cumbria coal field has been one of geological faults and methane.
8.1WCM do not describe their new pyrittic sulphur removal plant. What chemicals are involved.? Contrary to what they say extra waste will be produced .
8.2 Methane is not captured for the first 5 years. 38.75M Cu m may be released in that time.
8.3 To have ‘no atmosptheric impact’ the methane capture plant will need to capture 100% which seems unlikely.
8.4 It is likely that the ‘utilisation’ of the methane will be less than the capture so large volumes will be stored.
8.5 Contrary to local belief salaries in the mine will not be well paid.
8.6 WCMhave not produced data to back up their assertion that their mine will be cleaner than a USA mine
9.1 WCM have made many generalised statements about GHGs without any backup data.
9.2WCMshould produce data to show how much methane they envisage being released in the first five years.
9.3 WCM should be asked to back up their assertion that their mine will be cleaner than a USA mine
9.4 Statements such as ‘no atmospheric impact’ are based upon the 100% success of a plant that will not be designed for 4 years.WCM should produce an indicative design now.By the nature of methane in a mine is not possible for methane capture to be 100%.What percentage do WCM envisage in reality?
9.5 Data showing envisaged volumes of methane , capture, utilisation and storage should be produced.
9.6Information on how and where the methane will be stored is needed especially as the mine is close to residential estates.
9.7 From the contents of this letter I hope you can see that Cumbria CC should not take WCM general statements on face value without backup data or more questions.
9.8If the mine opens then it is important that Cumbria CC has some form of audit system to verify that what WCM say will happenregardingcontrol of methane, does actually happen!
“Scientists have been vastly underestimating the amount of methane humans are emitting into the atmosphere through fossil fuels, according to research.
Analysis published in the journal Nature shows methane emissions from fossil fuels owing to human activity is around 25 percent to 40 percent higher than thought.
But researchers believe their findings offer hope, saying stricter regulations to curb methane emissions could help reduce future global warming to “a larger extent than previously thought”.
Benjamin Hmiel, a professor of earth and environmental science at the University of Rochester and one of the study authors, said: “I don’t want to get too hopeless on this because my data does have a positive implication: most of the methane emissions are anthropogenic, so we have more control.
“If we can reduce our emissions, it’s going to have more of an impact.”
The Cumbrian Coal deposits under the Irish Sea off St Bees are methane rich. West Cumbria Mining’s proposed development has already released an unknown quantity of methane from beneath the Irish Sea bed when it hit a methane gas pocket whilst carrying out exploration back in 2017: ” drilling operations from a jack-up barge had struck a gas pocket approximately one nautical mile from St Bee’s Head. The drilling is part of a programme of exploration work to support a new coal mining project in west Cumbria…Local authorities, fire rescue, police and the Environment Agency were all informed.”
Now in 2019 West Cumbria Mining have been given the green light by Cumbria County Council to continue their release of methane which is currently safely contained deep beneath the Irish Sea bed.
It was due to this area’s methane rich status that the famous safety Davy Lamp was tested out right here in West Cumbria!
Today’s Guardian reports that : “Methane emissions from coalmines could stoke climate crisis…Millions of tonnes belched into atmosphere as bad as shipping and aviation emissions combined, researchers find”
“Dave Jones, an analyst at the climate thinktank Sandbag, said the report proves the global coal industry “is even more polluting than we thought” and should face tougher regulation.”
“It found that deeper coal seams tend to contain more methane than shallower seams, while older seams have higher methane content than younger seams. The findings were applied across all countries with coalmines to estimate the global scourge of coalmine methane.”
“In 1816, the Cumberland Pacquet reported a demonstration of the Davy lamp at William Pit, Whitehaven. Placed in a blower “… the effect was grand beyond description. At first a blue flame was seen to cap the flame of the lamp, – then succeeded a lambent flame, playing in the cylinder; and shortly after, the flame of the firedamp expanded, so as to completely fill the wire gauze. For some time, the flame of the lamp was seen through that of the firedamp, which became ultimately extinguished without explosion. Results more satisfactory were not to be wished…” Another correspondent to the paper commented “The Lamp offers absolute security to the miner… With the excellent ventilation of the Whitehaven Collieries and the application of Sir HUMPHRY’s valuable instrument, the accidents from the explosion of’ (carburetted) ‘hydrogene which have occurred (although comparatively few for such extensive works) will by this happy invention be avoided”.
Unfortunately, this prediction was not fulfilled: in the next thirty years, firedamp explosions in Whitehaven pits cost 137 lives.:139 More generally, the Select Committee on Accidents in Mines reported in 1835 that the introduction of the Davy lamp had led to an increase in mine accidents;:130 the lamp encouraged the working of mines and parts of mines that had previously been closed for safety reasons.”
Check out the CrowdJustice page here – we have donated £50 already but- we need £5000 to take forward the Legal Challenge. If you cannot donate then please do share and get the message out that this fight against the first deep coal mine in the UK in decades is far from over.
Thank you to Lawyers Leigh Day who have already put so much work into paving the way and ensuring a legal challenge is possible.
UPDATE: What a rollercoaster! Firstly on 31st October we had an amazing demonstration of opposition outside Cumbria County Council offices with many groups and individuals taking part to show the strength of feeling against this coal mine. This was despite the fact that we only found out last minute by accident about the ‘ratification’ meeting for the first deep coal mine in the UK in decades. As you will have heard the committee again voted unanimously to pass the plans…shocking! Then on the same day as the much publicised announcement on the halt to fracking there was a much more subdued announcement that the Secretary of State will not call in Cumbria County Council’s outrageous decision on the coal mine for a public inquiry.
Thank you so much for the donations so many of you have already made for the initial advice from top lawyers Leigh Day. This has been of such enormous value and has paved the way for a legal challenge so we can continue to fight this terrible plan..
A new crowd justice fundraiser is now live and can be found here. We now need to up the ante and raise enough funds to cover the costs of a full legal challenge. We can’t do it without your help. If you can share the page or donate no matter how small the donation then please do.
Not only would this coal mine produce 9 million tonnes of CO2 emissions every year (not including methane, radon etc) but the plan is to extend mining activity under the Irish Sea to within 5 miles of Sellafield.
The results of induced seismic events of any magnitude at the worlds riskiest nuclear waste site could be catastrophic on a planetary scale.
There are so many reasons to oppose this coal mine plan from climate catastrophe to nuclear catastrophe. That is why we are campaigning hard to stop the plan.
Many thanks to our MP Tim Farron for presenting our petition yesterday in the House of Commons to the Secretary of State. Since presenting the petition the signatures have gone up..and continue to go up calling on the Secretary of State to call in the dodgy decision made by Cumbria County Council.
I present a petition on behalf of 1,852 residents of Cumbria who oppose the proposed West Cumbrian coal mine, believing, as I do, that in the fight to prevent climate catastrophe, it is vital that we keep fossil fuels in the ground. The petitioners request that the Secretary of State call in the application for his own determination at the earliest opportunity and that he rule against the opening of the mine.
Following is the full text of the petition:
[The petition of people of the United Kingdom,
Declares that a local petition has been collected against the proposed west Cumbria coal mine which should not be opened on account of the impact on the climate.
The petitioners therefore request that the House of Commons urges the Government to call this application in for its own determination at the earliest opportunity and that it rules against the opening of the mine.
Murray Energy, once a symbol of American mining prowess, has become the eighth coal company in a year to file for bankruptcy protection. The move on Tuesday is the latest sign that market forces are throttling the Trump administration’s bid to save the industry.
The collapse of the Ohio-based company had long been expected as coal-fired power plants close across the country.
Its chief executive, Robert E. Murray, has been an outspoken supporter and adviser of President Trump. He had lobbied extensively for Washington to support coal-fired power plants.
Mr. Murray gave up his position as chief executive and was replaced on Tuesday by Robert Moore, the former chief financial officer. Mr. Murray, who will remain chairman, expressed optimism that the company would survive with a lighter debt load.
“Although a bankruptcy filing is not an easy decision, it became necessary to access liquidity,” he said in a statement, “and best position Murray Energy and its affiliates for the future of our employees and customers and our long-term success.”
Murray, the nation’s largest privately held coal company, has nearly 7,000 employees and operates 17 mines in six states across Appalachia and the South as well as two mines in Colombia. It produces more than 70 million tons of coal annually.
But with utilities quickly switching to cheap natural gas and renewable sources like wind and solar power, Murray and other coal companies have been shutting down mines and laying off workers. Murray’s bankruptcy follows those of industry stalwarts like Cloud Peak Energy, Cambrian Coal and Blackjewel.
Murray was most closely identified with Trump administration promises to reverse the industry’s fortunes.
Mr. Murray contributed $300,000 to Mr. Trump’s inauguration. Shortly after, he wrote Mr. Trump a confidential memo with his wish list for the industry, including shaving regulations on greenhouse gas emissions and ozone and mine safety, along with cutting the staff at the Environmental Protection Agency by at least 50 percent. Several of the suggestions were adopted.
The presentation below has been sent to the Development Control & Regulation Committee. I will read a shortened version of it out on behalf of Keep Cumbrian Coal in the Hole at the meeting on the 31st in the County Offices, Kendal.
There will be a demonstration ahead of the meeting from 8.30 for people to make their views known about this outrageous plan. Bring Banners – bring yourselves!
You can send your own letter of objection in before 31st (do it quick) doesn’t need to be loads just a few lines of why Cumbria County Council is wrong to be ratifying this outrageous decision. They even say this coal mine would be “carbon neutral” and make “carbon savings” this is incredible magical thinking. Phone, Write to
Presentation to Development Control and Regulation Committee 31st oct
Application ref no 4/17/9007
Keep Cumbrian Coal the Hole is a campaign by civil society group Radiation Free Lakeland.We were first alerted to this coal mine as it would extend to within 5 miles of Sellafield. The risks are multiple and are on a planetary scale.
The overriding and often repeated message from the council’s reply to Leigh Day’s questions is that the mine would be “broadly carbon neutral”.This assumption is crucial; yet, neither the addendum report, nor in fact any of the underlying application documents,provide the evidence to support it.
It seems that this “carbon neutral” claim is simply based on vague assumptions that “coal production at Whitehaven would substitute for coal production elsewhere.” Really?
Clearly, the consideration of the likely emissions output from this development is absolutely key for any decision made by this committee. The Committee must come to a reasonable conclusion on the expected level of greenhouse gas emissions that will be produced over the next 50 years.It must do so, so that it can decide how much weight to give to that factor in the planning balance. The Applicant has simply failed to provide the Committee with sufficient information to carry out this task – this was a key point highlighted in the Leigh Day letter and it has not been addressed by the addendum report – which merely reiterates assertions about how the market might respond to the increased output in Whitehaven.
With respect, the addendum report has raised more questions than it has answered. Notably, it states at para 4.4 of the addendum report, that the original Committee Report attached “moderate weight” to the “CO2 emissions from the extraction and processing of the coal and their impact upon climate change” which weighed against the proposal.That must have been based on an understanding that the mine would produce CO2 emissions (as undoubtedly is the case).Somewhat oddly, the Addendum Report now seeks to clarify that this should have said that “greenhouse gas emissions globally as a result of the extract and processing of coal would be broadly in balance”.It refers to other paragraphs of the original report (6.47 and 6.406) where the import-substitution point was made – however, the import-substitution point concerns emissions from reduced transportation.It does not support the argument that the coal produced further afield will stop being produced at all.So it cannot be relied upon to factor out the additional emissions associated with bringing a new coal mine into operation.
On the emissions expected from exports of coal from the mine, we must emphasise that the vast majority of output is expected to be exported. The proposed amount of coking coal for export to Europe and beyond would be a staggering 2 million tonnes annually.Whereas the amount earmarked for UK use would be a more modest 360,000 tonnes. So most of the coking coal produced is destined to travel abroad.In relation to this, the addendum report relies on assumptions that this will all be exported to “Europe” and will replace alternative sources of coking coal from further afield.Yet there is absolutely no restriction on where the coal would be exported to.Nothing prevents it from travelling further afield.And, if it does, all the assumptions on emissions savings through import substitution fall on their face.
Has the Committee properly considered this? Where is the evidence for this idea of “substitution”?Do the councillors really believe that a mine elsewhere will stop producing coal because a mine in Cumbria has opened up under the Irish Sea, five miles from Sellafield? More importantly, do they have before them sufficient evidence to support such claims.In our view, they clearly do not.
Demand for Coking Coal for Steel
You acknowledge that the demand for coking coal is led by the demand for steel.However there is no acknowledgment in your report that technology and politics has moved on with the Department for Business, Energy & Industrial Strategy (BEIS) announcing in August,new measures to “enable a pathway to lower carbon steel production and support broader efforts to decarbonise industry”.
Nor is there any recognition of the possibility that greater supply of coking coal might impact on worldwide prices, with a real chance that demand will increase (for both the coking coal, itself, and for steel) due to reductions in the price.
The middlings coal you say would be up to 15% of coking coal extraction.To describe up to 15% of production as a “by-product” is disingenous. It is a significant amount of production, in and of itself, and members should not be distracted by this type of terminology.The level of middlings coal produced could easily be a development in itself, so the impacts of it need to be fully considered.
You say that an assessment of CO2 emissions “would not be a reasonable requirement.” Given that the UK government has just signed up to a Climate Emergency we say that a full and comprehensive assessment including the various scenarios of transport exports to near Europe, far Europe and beyond, of the CO2 emissions from both coking and middlings coal is an entirely reasonable requirement.
At paragraph 6.71 of the original report, it stated in relation to middlings coal production that “There are valid arguments made in respect of climate change, but we consider these issues could be better managed by applying regulatory controls at the point of use.” The addendum report now seeks to clarify, at para 4.14, that the mere reference to there being “valid arguments made in respect of climate change” meant that the issue was weighed in the planning balance but was not considered of sufficient weight as to justify the refusal of permission, or to require a condition requiring disposal of the middlings coal.That is not how we read the original report.It is not clear at all what the “valid arguments in respect of climate change” referred to were and by reference to other regulatory controls, it was clear that the officer did not factor emissions from middlings coal production into her assessment.
Interestingly, the addendum report now recognizes that the burning of middlings coal would “undoubtedly” result in the generation of CO2 but argues that it would not be a “reasonable requirement” to expect the decision-maker to assess possible emissions associated with it.This is a fundamental failing in a case where the officers are nonetheless arguing that the “greenhouse gas emissions of the mining operations would be broadly carbon neutral” and the “greenhouse gas emissions globally as a result of this extraction and processing of coal would be broadly in balance”.
With respect, you cannot reach a conclusion that operations are carbon neutral if you have failed to estimate the emissions associated with 15% of production.
If you are going to assess the net carbon output of a development, then you have to assess the whole of it.To do otherwise is irrational.
Finally, on middlings coal, we can still see no reasoning as to why the level of output has been limited by condition to 15%? Why not 10% or 25%? What evidence or understanding rationalises this conclusion and how has it been shown to be necessary, relevant to planning, relevant to the development to be permitted, or reasonable in all other respects?
The addendum report concludes that whilst the new net zero target makes the Climate Change Act 2008 target more challenging, it does not change the original report’s assessment on the impact on climate change and efforts to reduce CO2 emissions, which were both treated as key considerations in that report.
With respect the addendum report fails to appreciate the substantive change brought about by the new net zero target.By 2050 there needs to be a 100% reduction in emissions as compared to 1990 levels.That means that all emissions need to be offset, or somehow compensated for, so as to produce a “net zero” emissions output level overall.
This development will result in significant emissions far beyond 2050.If consent were to be granted next year, the permission would last until 2070.Even if the Committee were to accept – what we say are the incorrect – assumptions that the production of coking coal will be carbon neutral, it now seems accepted by officers that the production of middlings coal will result in unquantified levels of emissions.That – at the very least – needs to be properly factored in.
The Committee must have due regard to the emissions output that any permission will grant consent for beyond 2050 and what will be needed to offset this.This is clearly a material consideration in light of the legally binding net zero target.
And, it only supports the need for the Committee to obtain robust evidence from the Applicant on what exactly the likely emissions output will be.To reiterate, we do not consider the Committee has sufficient information at present.
Finally and without any supporting evidence at all the report claims that “whilst greenhouse gas emissions of the mining operations are very likely to be carbon neutral, it is still considrered that some carbon savings must existfrom reduced transportation distances.” (4.6)Incredible! So this massive coal mine which proposes to operate over 50 years would actually result in carbon savings from reduced transport with this ‘home grown’ coking coal-? Even though the plan is to export the majority of coal to Europe and beyond.
We ask that the Council do not ratify this disastrous and planetary damaging application for the first deep mine in the UK in 30 years extending to within 5 miles of Sellafield.There is no supporting evidence at all to back up the false claims of the mine being “carbon neutral” and making “carbon savings.”