Quaker Charity and IPCC Author Blast Coal Mine Plan

Quakers for Sustainability

Laurie  Michaelis was a Lead Author  on several Intergovernmental Panel on Climate Change (IPCC) reports, including the Special Report on Emission Scenarios.  He continues to serve as an Expert Reviewer for the IPCC, including the Special Report on Global Warming 1.5°C currently in development.

Laurie is the Quakers for Sustainability expert and he has written to Cumbria County Council outlining why they should turn down the coal mine plan. His letter and memo is reproduced in full below.

Dear Rachel Brophy

Planning Application 4/17/9007: Woodhouse Colliery

I am writing to comment on the above application and to ask to be allowed to speak at the Development Control Committee meeting on 7th March.   ( note this is now 18th April)

My comments centre on the climate change implications of the proposed mine and on the business case for the mine. As far as I can see these have not been addressed in any meaningful way by the applicant. There are several issues which need to be addressed for the Council to meet its obligations within the National Planning Policy Framework:

  1. Since every country in the world has signed the Paris Climate Agreement, we are all committed to limit global average temperature rise to well below 2°C and pursue efforts to limit the temperature rise to 1.5°C (see Annex). These limits are only possible with a rapid phase-out of fossil fuels to achieve zero net CO2 emissions around mid-century. WCM appears not to acknowledge this commitment or its implications in proposing a new coal mine with a ‘notional’ life of 50 years. In removing coal from underground and supplying it to steel manufacturers, the mine would be contributing to a continuation of CO2 emissions that would run counter to the Paris Agreement.

 

  1. UK Government policy does not yet reflect the Paris Agreement but is still working in the context of the 2008 Climate Change Act. The Committee on Climate Change (CCC), which has a statutory role guiding the government in implementing the Act, has advised that policies need strengthening to meet emission reduction goals in the coming 15 years[1]. Lord Deben, CCC chairman, has said[2] that the committee will not provide advice to the Government on meeting its Paris commitments until the Intergovernmental Panel on Climate Change Special Report on Global Warming of 1.5°C is finalised later this year. It is clear, however, from the bulk of the science and policy literature that has emerged in the last two years, that UK climate change policies will need considerable further strengthening.

 

  1. Through one assumed scenario in which its coal displaces coal from the US imported to Europe, WCM claims that the mine would reduce global CO2 emissions by about 40kg per tonne of coal produced by reducing shipping distances. However, the coal will generate 3100kg of CO2 per tonne[3], whether it is burned or used in steelmaking (in which carbon, the main constituent of the coal, reacts with the oxygen in iron oxide, the main constituent of iron ore, to produce iron and CO2).

 

  1. The whole system of iron ore extraction, shipping, smelting, manufacture and use needs to be, and probably will be, transformed in the coming decades. Many governments and at least parts of the steel industry are well aware of the need to rapidly decarbonise the sector and are working hard on being prepared for the future. Changes are likely to include reduction in the use of steel, so that most if not all demand can be met by recycling, and deployment of one or more of the ultra-low carbon methods of steelmaking currently being developed – whether based on biomass, hydrogen or electrolysis. Iron ore itself is shipped to the UK in larger quantities than the coal used to smelt it, from countries including Brazil and Canada. It would make more sense for any residual iron production from ore to be close to iron ore mines; some of the world’s largest iron ore producers (Brazil, China) also have the greatest potential for and commitment to renewable energy. The world does not need new coal mines.

 

  1. If this mine were to go ahead and the coal that is now safely underground in the custody of Cumbria County Council were to end up as CO2 in the atmosphere, there would be a serious risk of climate change impacts including some thousands of deaths extending long into the future (see Annex). The mine could also result in global loss of livelihoods and homes numbering many times greater than the jobs created in Cumbria. While within the UN Framework Convention on Climate Change the primary responsibility for reducing emissions falls on the country in which the emissions take place (in this case, use of the coal for steel making or as fuel), causal and moral responsibility for the emissions is shared by a) those involved in removing the coal from the ground, b) those involved in converting it to CO2 and releasing it to the atmosphere (the steel makers), and c) those involved in producing and consuming final products. If Cumbria County Council knowingly allows this mine to be developed, it bears at least a share of moral responsibility for those deaths and may in the future bear legal responsibility.

 

  1. The Planning Statement does not address the significant risk that the proposed mine would become a stranded asset and would need to be abandoned within ten to twenty years, along with the 500 jobs. The mine would divert people’s valuable time, energy and creativity from addressing the need for sustainable development in the region.

I have included a short bio outlining some of my relevant experience in the Annex.

Yours sincerely

 

Laurie Michaelis

[1] Committee on Climate Change: An independent assessment of the UK’s Clean Growth Strategy, January 2018.

[2] Lord Deben was responding to a question on 7th February at the Faith for the Climate Network Symposium, London.

[3] UK Government Emission Factors for Company Reporting, 2017

 

Annex

Mortality risk associated with CO2 emissions

The UK government, along with every other UN Member State, has signed the Paris Climate Agreement. Article 2.1(a) commits the signatories to:

‘Holding the increase in the global average temperature to well below 2 °C above pre-industrial levels and to pursue efforts to limit the temperature increase to 1.5 °C above pre-industrial levels, recognizing that this would significantly reduce the risks and impacts of climate change’.[4]

Global average warming currently stands at just over 1°C. Risks and impacts associated with 2°C and greater temperature increases have been set out in the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. The Synthesis Report Summary for Policymakers[5], approved by governments of IPCC Member States including the UK Government, states that:

“Continued emission of greenhouse gases will cause further warming and long-lasting changes in all components of the climate system, increasing the likelihood of severe, pervasive and irreversible impacts for people and ecosystems. Limiting climate change would require substantial and sustained reductions in greenhouse gas emissions which, together with adaptation, can limit climate change risks.”

“Climate change will amplify existing risks and create new risks for natural and human systems. Risks are unevenly distributed and are generally greater for disadvantaged people and communities in countries at all levels of development.”

Among other risks, a 2°C global average rise would expose significant populations to extreme weather events, jeopardise food security and increase the range of infectious diseases, and make some current centres of population uninhabitable with large scale loss of homes and livelihoods. The human consequences depend on how people respond, but mass migration and violent conflict are likely.

The World Health Organisation has assessed the implications of climate change for mortality associated with a limited range of health impacts (heat stress, child undernutrition and three diseases)[6]. It finds a total of approximately 240,000 deaths per year from these causes between 2030 and 2050. This is with a global temperature rise of approximately 1.5°C temperature rise, resulting from cumulative CO2 emissions of approximately 2 trillion tonnes since 1880[7]. The mortality resulting from these emissions can be expected to continue well into the future – on the order of a century. On the conservative assumption that mortality rises linearly with global temperature and with cumulative CO2 emissions, since 2 trillion tonnes of CO2 emissions results in at least 24 million deaths, the 500 million tonnes of CO2 that would result from using the coal from the proposed mine would cause at least 6000 deaths.

Mortality is likely to rise nonlinearly with global temperature rise, because people will become less able to adapt to local changes in climate; and other causes of death are likely to be significant, possibly much more so, than those included in the WHO assessment. Climate change with temperatures exceeding 2°C would pose a substantial and serious risk to global food security and health, which could potentially result in early deaths for a significant proportion of the world population. It is possible that the next 2 trillion tonnes of CO2 emissions could cause on the order of one billion early deaths. In this scenario the proposed mine would cause 250,000 deaths.

 

Laurie Michaelis: a short bio

Laurie Michaelis is the co-ordinator of Living Witness, a Quaker charity supporting engagement with sustainability and climate change. He has a degree in physics and a PhD in energy studies and has worked with a variety of approaches for evaluating the climate change impacts of products, services, processes, activities and lifestyles.

In the early 1990s he was part of a team in the Strategic Studies Department at the Energy Technology Support Unit, assessing long-term technology policy to reduce greenhouse gas emissions for UK government, European Commission and World Bank.

He went on to the International Energy Agency and the OECD where responsibilities included supporting the development of national reporting and review processes under the UN Framework Convention on Climate Change, preparing policy papers for climate negotiators, supervising staff of the Intergovernmental Panel on Climate Change National Greenhouse Gas Inventories Programme (then operated by OECD), and participating in ‘In-Depth Review’ teams evaluating national policies on energy and climate change in several countries.

He was a Lead Author or Convening Lead Author on several IPCC reports, including the Special Report on Emission Scenarios. He continues to serve as an Expert Reviewer for the IPCC, including the Special Report on Global Warming of 1.5°C, currently in development.

[4] The text of the agreement can be accessed at http://unfccc.int/paris_agreement/items/9485.php

[5] http://www.ipcc.ch/report/ar5/syr/

[6] World Health Organisation, 2014: Quantitative Risk Assessment of the Effects of Climate Change on Selected Causes of Death, 2030s and 2050s.WHO, Geneva.

[7] There are multiple mechanisms by which CO2 is removed from the atmosphere and these are changing as a consequence of climate change, so it is not possible to define a CO2 lifetime, but a first approximation is that global average warming is proportional to cumulative emissions.

 

FURTHER INFO Sent on 1st March

1st March 2018

Further to my letter of 12th February (attached for reference), I would like to raise a further matter in relation to the climate change implications of the proposed mine.

West Cumbria Mining hopes to export the coal from the proposed mine, so emissions resulting from its use, whether as a fuel or for iron smelting, would arise outside the UK. However greenhouse gas emissions from the mine itself, associated operations and inland transport of the coal would form part of the UK’s national inventory and would need to be accounted for within the budgets under the Climate Change Act 2008. Cumbria County Council has itself committed to play its part in meeting the national commitment by achieving emission reductions from residents, visitors and industry, in the Cumbria Climate Change Action Plan, 2009-2014 (I can find no record of an update to this).

The DEFRA Emission Factors for Company Reporting, 2017 give upstream emissions from coking coal supply as 442kg CO2e per tonne of coal. A large part of this will be associated with energy use and methane emissions from the mine. At a production rate of 2.8 Mt/year, the proposed mine would generate 1.24MtCO2e. The latest figure I can find for CO2 emissions in Cumbria was given in a presentation by Phil Davies, County Council Climate Change Officer, in 2010 and related to emissions in 2005. That figure was 7.4 Mt.

West Cumbria Mining has not given an assessment of the greenhouse gas emissions from its proposed project, but based on the above figures, it would constitute a significant increase in Cumbria’s greenhouse gas emissions. It would make it impossible for Cumbria County Council to meet its commitment, enabling the county to play its part in reducing national emissions by 80% by 2050.

 

Yours sincerely

Laurie Michaelis

 

TODAY’s EARTHQUAKE IN CUMBRIA – WHAT DOES IT MEAN FOR NEW COAL NEAR SELLAFIELD?

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PRESS NOTICE
TODAY’s EARTHQUAKE IN CUMBRIA – WHAT DOES IT MEAN FOR NEW COAL NEAR SELLAFIELD?
The following letter has been sent to all Cumbrian Councillors on the Development Control and Regulation Committee . These councillors will be taking the decision in April whether or not to give a green light to the first deep coal mine in the UK …near to Sellafield.  The letter outlines concerns about induced seismic activity from coal mining and is especially pertinent to today’s earthquake.  There will always be earthquakes – but should there be developments near Sellafield that have the capacity to induce seismicity?  West Cumbria Mining have told campaigners that the plan is for coal to be mined up to five miles from Sellafield.
The Letter sent out today….
Dear Councillor …,
West Cumbria Mining – Planning Meeting Scheduled for the 18th April
Good Afternoon.   I am writing to you from the Keep Cumbrian Coal in the Hole campaign (a Radiation Free Lakeland campaign).
The timing of this morning’s earthquake is uncanny as the previous day we had sent a letter to Tim Farron on this very subject.  I am sure you would agree that increasing the risk of earthquakes in Cumbria should be avoided and yet there is a plan to mine for coal just five miles from Sellafield off the St Bees Coast.  Coal mining is known to induce seismicity – this also is the case with with heavy loading (Moorside/new nuclear would equal 100s of 1000s of tonnes of concrete) and injection (Preston New Road fracking site is 49 miles from Sellafield).
Over the last several decades Cumbria County Council has been minded to approve many developments at Sellafield including reprocessing which has led to a terrible accumulation of increasingly dangerous nuclear wastes. http://hansard.millbanksystems.com/commons/1976/nov/03/windscale-nuclear-reprocessing
I am sure you would agree that it is now incumbent on Cumbria County Council to ensure the safe stewardship of Sellafield. That safe stewardship must include shunning dangerous new developments nearby, whether they be nuclear, or coal.
Our letter to Tim Farron said:
“Dear Tim,
Last April we wrote to the HSE about the proposals to extract coal within five miles of Sellafield and fracking five miles from Springfields in Preston.  We did not recieve a reply.
Last week we sent (after trying to hand deliver..just think Hitch Hikers Guide to the Galaxy!) a petition of 1163 signatures (and growing) and a letter to the HSE asking that there should be a moratorium on the extraction of fossil fuel in such  close proximity to dangerous nuclear installations.
The Chief Inspector of Nuclear Installations carried out an assessment of seismic risk for nuclear installations following Fukushima.    However the report (Japanese earthquake and tsunami: Implications for the UK nuclear industry HM Chief Inspector of Nuclear Installations September 2011) makes no reference to the impact of new fossil fuel extraction near nuclear installations and does not include the real possibility of induced seismicity from that fossil fuel extraction.
This is the reason we have written to the HSE to ask for a moratorium on fossil fuel extraction which is currently proposed so close to Springfields, Lancashire (the front end of the nuclear cycle) and Sellafield, Cumbria ( the back end of the nuclear cycle) both sites are at risk of criticality following seismic events.
The full letter to the HSE is included below. We have not recieved an acknowledgment.  We would be very grateful if you could ensure that this letter is seen and acted upon by the HSE.”

In 2016 The Ecologist reported that: “Especially serious are the ~20 large holding tanks at Sellafield containing thousands of litres of extremely radiotoxic fission products.” Discussing these tanks, the previous management consortium, Nuclear Management Partners, stated in 2012: “There is a mass of very hazardous [nuclear] waste onsite in storage conditions that are extraordinarily vulnerable, and in facilities that are well past their designated life”The National Audit Office (NAO) stated these tanks pose “significant risks to people and the environment”.   One official review published in The Lancet concluded that, at worst, an explosive release from the tanks could kill two million Britons and require the evacuation of an area reaching from Glasgow to Liverpool.    This certainly would negate Cumbria County Council’s strategic objective of avoiding adverse impacts from developments ( Objective 2, Cumbria Minerals and Waste Local Plan 2.27)

Coal mining causes induced seismicity.  Please consider today’s earthquake when you make your decision on 18th April on the first deep coal mine in the UK for 30 years…..near Sellafield.
Yours sincerely
Marianne Birkby
on behalf of Keep Cumbrian Coal in the Hole
a Radiation Free Lakeland campaign

Letter to Tim Farron MP to ask that our Petition to the HSE is Heard and Acted On

cropped-sellafield-threatened-with-induced-seismicity.jpg
Dear Tim,
Last April we wrote to the HSE about the proposals to extract coal within five miles of Sellafield and fracking five miles from Springfields in Preston.  We did not recieve a reply.
Last week we sent (after trying to hand deliver..just think Hitch Hikers Guide to the Galaxy!) a petition of 1163 signatures (and growing) and a letter to the HSE asking that there should be a moratorium on the extraction of fossil fuel in such  close proximity to dangerous nuclear installations.
The Chief Inspector of Nuclear Installations carried out an assessment of seismic risk for nuclear installations following Fukushima.    However the report (Japanese earthquake and tsunami: Implications for the UK nuclear industry HM Chief Inspector of Nuclear Installations September 2011)
makes no reference to the impact of new fossil fuel extraction near nuclear installations and does not include the real possibility of induced seismicity from that fossil fuel extraction.
This is the reason we have written to the HSE to ask for a moratorium on fossil fuel extraction which is currently proposed so close to Springfields, Lancashire (the front end of the nuclear cycle) and Sellafield, Cumbria ( the back end of the nuclear cycle) both sites are at risk of criticality following seismic events.
The full letter to the HSE is included below. We have not recieved an acknowledgment.  We would be very grateful if you could ensure that this letter is seen and acted upon by the HSE.
with Many Thanks!

Fisheries and Conservation Authority Concerns: Irish Sea Subsidence and Resuspension of Radionuclides

 

Keep Cumbrian Coal in the Hole – Petition

There are many reasons to object to the plan for the first deep coal mine in the UK for 30 years.  The North Western Inshore Fisheries and Conservation Authority has voiced concerns. They highlight the following concern which is uniquely perilous to this area of the Irish Sea:

“Offshore Subsidence – resuspension and dispersal of radioactive contaminants. The documentation has confirmed to NWIFCA that a risk of subsidence exists and therefore there remains an overwhelming concern over the potential for disturbance and resuspension of radioactive contaminants and sediments.”

Keep Cumbrian Coal in the Hole along with others have also highlighted this specific concern and would draw the Development Control and Regulation Committee’s attention to this photograph supplied to us by the Low Level Radiation Campaignsellapart04337.JPG

This is what radiation does to plastic

The centre of this image shows radiation tracks from a particle found near Sellafield. This is what radiation does to plastic. The Low Level Radiation Campaign tell us “it’s probably Plutonium, and about 1 micron diameter. Official reports since 1989 state that the Bristol Channel contains radioactivity from Sellafield. Since 1965 Hinkley Point also has discharged particles. Evidence that particles like this are present in the sediment has been covered up. When inhaled they are likely to be scavenged to lymph nodes. They deliver high doses of radiation to whatever body tissue they lodge in.”  Plutonium is found being washed up on West Cumbrian beaches from radioactive wastes discharged to the Irish Sea from Sellafield reprocessing.  Seabed subsidence would dramatically increase the “natural”  resuspension of Sellafield wastes from the seabed.

More from the North Western Inshore Fisheries and Conservation Authority below.

“The North Western Inshore Fisheries and Conservation Authority is the relevant body for the regulation of inshore sea fisheries within its District. It has a range of duties including sustainably managing the exploitation of sea fisheries resources and balancing the social and economic benefits of exploiting resources with the need to protect the marine environment.

Issues of concern to the NWIFCA regarding potential impacts on the coastal and marine environment relate to all marine and coastal areas located near to the project that could be impacted, not just Marine Protected Areas (MPAs) – Natura 2000 sites, SSSI and Marine Conservation Zones in this case. There are legal procedures for assessing risk and impacts on protected sites and obligations for minimising / mitigating against these risks. However NWIFCA would ask that assessments take a broader approach and consider any risk posed to all of the coastal / marine environment within the zone of effect.

Details of many of the aspects of the development are naturally currently relatively sketchy and it is therefore not possible to provide in-depth response. However at this stage there are areas of concern highlighted below.

Issues of particular concern are outlined as follows:

  1. Dewatering of mine and discharge – will require an environmental permit to discharge from the Environment Agency. The level of pre-discharge treatment that the water will require and the discharge limits are yet to be set, and require more detailed assessment of the chemistry of the water within the anhydrite mine. It is noted that West Cumbria Mining is also to carry out a series of modelling and assessments of impact of the water on the marine environment.The documentation states that “At this stage it is not possible to model how the discharged water will disperse, and therefore it is not possible to accurately predict what effect there might be on the local” … fish and invertebrate life.

    Until this data is obtained, firmer proposals are put forward and dispersal modelling has been completed the NWIFCA will continue to have serious concerns about the risk posed by contaminated water affecting coastal and marine environments and would request full continuing consultation and engagement with EA permitting over this aspect of the mine development.

    It is noted that WCM will conduct a wide-ranging marine environmental baseline monitoring study in support of the application to be made to the Environment Agency for a Permit to Discharge the mine water to sea. NWIFCA would request early sight of the study’s results to assist in our future responses.

    It is understood that the water taken from the anhydrite mine will be subject to continuous monitoring, to ensure that it continues to meet the water quality standard set by the Environment Agency. NWIFCA would request it is fully engaged in discussion over the nature of the monitoring subject to results of the water chemistry and assessed level of risk.

  2. Position of the discharge pipeline and diffuser – will be subject to an MMO Marine Licence application at which point NWIFCA will respond formally to an MMO consultation. Until more detailed particulars are decided for pipeline specification and position NWIFCA reserves concerns over impacts on coastal and intertidal habitats and species.At this stage NWIFCA would ask that the design ensures that all outfall pipeline discharge is below the lowest astronomical tide to prevent risk of impact on intertidal areas.
  3. Further potential impacts on coastal and marine systems could be impacted by the following during construction of the mine and its associated infrastructure:
    1. Physical mobilisation (such as soil erosion, run-off and sediment deposition);
    2. Disturbance of existing contaminated soils during earthworks or increased infiltration;
    3. Leaching once the soil is removed and areas of open excavations are exposed.

    The NWIFCA notes that construction works will be managed under a Construction Environment Management Plan (CEMP) that will be developed post-planning determination, and would request early sight of the plan once drafted. As above NWIFCA reserves concerns over the risk of contaminated water reaching the coastal and marine waters until further detail has been put forward.

  1. Storm water discharge – NWIFCA has learned from the documentation that during the operational phase, the anticipated discharge of excess storm water flows from the site into the sea via the existing outfall has the potential to provide a pathway for contaminants into the marine environment. These flows will be sporadic and unpredictable in nature. WCM state that drainage and water treatment infrastructure on-site will be designed to ensure that storm flows are passed through silt traps and oil interceptors and to enable flows to be discharged at a controlled rate to ensure that any significant influx of storm water into the marine environment does not occur.As a result WCM consider that the risk of the storm water discharge leading to adverse operational phase effects are considered be negligible. An Environmental Permit for this discharge will be required and NWIFCA deigns to Environment Agency advice on this point.
  2. Offshore Subsidence – impact on shoreline profile and wave heights. NWIFCA note that WCM propose a ‘no mine zone’ within Cumbria Coast MCZ and St Bees SSSI which we welcome. WCM state that “Given the small predicted seabed height changes, the slow rate of subsidence and the small changes in slope, combined with the fact that subsidence will not occur over the whole mined area it is likely that impacts on statutory protected areas in the vicinity of the development (i.e. the Cumbria Coast MCZ and the Solway Firth pSPA) will be negligible”.This does not dispel concerns over potential for subsidence of the seafloor outside of these Protected Areas which could have impacts on the benthos plus potential consequences to shoreline profile and wave heights, which could in turn result in unintended consequences that would affect these protected sites and elsewhere.

    Data and understanding are limited at the present time and in order to address this, WCM will commission surveys and a numerical modelling study to more accurately predict the potential impacts, if any, of subsidence on the intertidal and marine environments, to be completed prior to commencement of works.

    “Data will also be gathered regarding subtidal communities to determine the distribution, extent and likely responses of any potential sensitive receivers. In addition, a Marine Monitoring Plan will be implemented to monitor the bathymetry of the seabed and surficial sediments properties (including benthic communities) overlying the extraction zones using the data collected in 2016-17 as a baseline”.

    NWIFCA would ask who the regulator for subsidence risk is and stress the need for further dialogue and engagement over this issue once predictions of potential impacts have been produced.

  3. Offshore Subsidence – resuspension and dispersal of radioactive contaminants. The documentation has confirmed to NWIFCA that a risk of subsidence exists and therefore there remains an overwhelming concern over the potential for disturbance and resuspension of radioactive contaminants and sediments.

 

COAL MINE DECISION DEFERRED…AGAIN!

The Planning Meeting has been deferred yet again.  This will be the fourth date.

The NEW DATE is the 18th April 2018 – 10 am at Cumbria County Council Offices, Kendal.

This gives us more time to object.  The more people and groups who object the better chance we have of stopping this diabolic plan.

 To Object please write to Rachel.Brophy@cumbria.gov.uk

Quote: Planning Application 4/17/9007 – Woodhouse Quarry

If you or your group would like to register your intent to speak at the 18 April committee please contact  Jackie.Currie@cumbria.gov.uk before the 12 April 2018

 

 

Excellent Objection – Please Feel Free to Use in your own Letters to Cumbria County Council

 

Men_of_the_Mine-_Life_at_the_Coal_Face,_Britain,_1942_D8263.jpg

There is Nostalgia for the good old days of Coking Coal in West Cumbria

The Following is an excellent objection to the coal mine plan.  Please feel free to use this for ideas or as a starting point for your own research and letter to Cumbria County Council.

NOTE the date of the planning meeting has now been deferred again (this is the fourth date!) until the middle of April.  This gives us more time to build up a momentum against this diabolic plan to mine for coal under the Irish Sea.

Email:   Rachel.Brophy@cumbria.gov.uk

To Rachel Brophy, Development Control Team, Cumbria County Council

Feb 6th 2018

Woodhouse Colliery, Application Number 4/17/9007

West Cumbria Mining [WCM]

I am writing with particular concerns about the economic sustainability and the employment claims in the application.   I wish to object to the application.

The general NPPF guidance regarding coal extraction is very clear

Para 149. ‘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.’

The many consultation responses received from statutory bodies make it abundantly clear that the proposal is not environmentally acceptable on a very broad range of issues. This is well documented.   WCM have been requested on two occasions via regulation 22 to provide additional information on environmental aspects of the proposal. It is now becoming obvious to all that the application is not and cannot be environmentally acceptable.

There are no planning conditions or obligations which can alter the basic fact that the carbon in the coal would end up almost entirely in CO2, whether it is burned or used in steel making and therefore fails all criteria for low carbon, sustainable development. [1]

The WCM application claims that it provides local community benefits by way of creating employment. As these claims relate to the creation, or otherwise, of a sustainable economy – they form a material consideration. These employment claims need to be challenged.

Economic challenges to jobs/community benefit

 The production of coal for the European steel market can only be as viable as that market itself.   The international steel market has been notoriously unstable in recent years. China, India and Korea are emerging as major steel producers – there have been dramatic declines in European steel production. Steel plants have been closed. There is reducing production globally. In 2016 European production declined to 10% of global production. Competition is fierce with new markets emerging. [2]

The production of steel is closely tied to the automobile and construction industries. With financial difficulties, austerity and cautious consumer spending the future of steel production in Europe is in a precarious place.

However much coal WCM may wish to produce the global market situation means there can be no guarantee of ready customers.

October 2017 article from the Financial Times – ‘Our current [global] overcapacity issue is bad,” said John Ferriola, chief executive of US group Nucor, speaking at the World Steel Association’s annual general meeting in Brussels earlier this month. “[It] results in a high level of exports that in some cases are illegally subsidised and dumped in other nations.” The problem of overcapacity has dogged the industry for years. When mills are underused, they use raw materials less efficiently and producers are forced to reduce prices in the scramble to win orders and cover their high fixed operating costs. But there is a new political urgency, with accusations of unfair trading practices that have caused protectionist measures in number of countries. A steep rise in exports, especially from China, contributed to a collapse in the price of steel two years ago. That hit earnings hard at companies such as ArcelorMittal, South Korea’s Posco and US Steel, triggering major job losses and raising questions about the industry’s future in some developed countries.’ [3]

There are also the implications of Brexit and the uncertainties about whether the UK will remain in the European Single Market.

Carbon challenges to jobs/community benefit

 Building on the commitments of the Paris Agreement all signatory nations are now moving into ever tighter carbon budgets with increasing regulatory measures. There is a race on to develop processes of steel making which do not involve the burning of fossil fuels. Sweden seems to be at the forefront [4]. It is also likely that recycling will play a greater part in the steel industry.

Investment challenges to jobs/community benefits

While the application is in the name of West Cumbria Mining it appears that the proposal is backed by EMR Capital.[5] who describe themselves as follows – ‘We are a specialist resources private equity manager whose team has a proven track record in the three dimensions critical to achieving superior returns’

EMR Capital has offices in Melbourne, Sydney, Cayman Island and networks across the globe. They specialise in –

  1. Successful development, over 30 years, of resources projects and companies across a wide range of commodities and countries, advancing early stage projects through the development stages into high quality producing mines;
  2. Achievement of superior investment returns in the resources sector; and
  3. Building successful partnerships, joint ventures and linkages in Asia, emerging markets and new frontiers for resources, with investors, resources companies, commodity end users and government in those markets, who are the key drivers of global commodity markets and prices, and key buyers of resource assets.

Companies House lists 12 Directors for WCM five of whom live in Australia, one in France and one in Scotland. The registered address is in Surrey.

It would seem that despite the local sounding name of ‘West Cumbria Mining’ this application represents a speculation of global capital. The investors and recipients of any profit from the mine are likely to be in Asia or Australia.

Despite the interest of EMR Capital however – there is a powerful global movement of divestment from fossil fuel industries and any such investment will become increasingly risky.

From a June 2015 article in the Guardian – ‘ . . . . the UN has lent its “moral authority” to the divestment campaign, while Desmond Tutu has said that “people of conscience need to break their ties with corporations financing the injustice of climate change. Second is the financial argument, which rests on the premise that if international agreements on climate change are met, the investments will become worthless. The theory that these “stranded assets” are creating a trillion dollar “carbon bubble” that could plunge the world into another economic crisis is now the subject of an investigation by the Bank of England, after Governor Mark Carney said publicly that “the vast majority of reserves are unburnable.   The World Bank has come out in support of the financial argument for divestment, with president Jim Yong Kim stating that: “every company, investor and bank that screens new and existing investments for climate risk is simply being pragmatic.’ [6]

Safety challenges to jobs/community benefits

 We know that the coal mining industry has a long and sad history of fatalities.   Some miners still remain where they died under the sea off Whitehaven. Any accident at the mine reaching out 5 miles under the sea would have serious consequences for continuing production/jobs as well as for the bereaved and injured themselves.

Additionally – any minor induced seismicity or earth tremor that affected the Sellafield location would have catastrophic consequences in the potential release of radioactivity and would undoubtedly need to result in the immediate closure of the mine.

The nature of potential earth tremors is in that very potential. They are unknown. An application, such as this, which increases the possibility and potential of induced seismicity/earth tremors is simply too dangerous to be approved.

It is of critical importance that the Coal Authority has formally objected to the application on safety grounds

Conclusion

The application from WCM assumes employment prospects/community benefits based on a steady demand for the coal produced. This is clearly a nonsense given the instabilities of the global steel and investment markets; coal phase – out; the increasing regulatory controls on the burning of fossil fuels and the many safety threats at the mine including methane, subsidence and seismicity.

There can be no guarantee whatever of the employment WCM may prove able to provide.   There are simply too many complex global factors which are outwith the control of the company.

The NPPF statement on achieving sustainable development states –

‘International and national bodies have set out broad principles of sustainable development. Resolution 42/187 of the United Nations General Assembly defined sustainable development as meeting the needs of the present without compromising the ability of future generations to meet their own needs. The UK Sustainable Development Strategy Securing the Future set out five ‘guiding

principles’ of sustainable development: living within the planet’s environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy; promoting good governance; and using sound science responsibly.’

In addition to failing to provide a sustainable environment – the WCM application clearly fails to provide both a sustainable economy or sustainable employment.   There can be no jobs, economic growth or prosperity when the fossil fuel products are no longer viable.

The people of West Cumbria do most certainly need greater employment opportunities – these need to be sustainable in all senses – both economically and in terms of low carbon. This is a very real challenge to create future sustainable employment that creates decent local jobs and honours both the people and the landscapes of West Cumbria.

One model for the creation of sustainable local economies is that of CLES which is gaining great interest – and action – among various Local Authorities in the North West and beyond. ‘ CLES is the UK’s leading, independent think and do tank realising progressive economics for people and place. Our aim is to achieve social justice, good local economies and effective public services for everyone, everywhere.’ [7] [8]

It could perhaps be said of the WCM proposal that it was a well-intentioned attempt to bring employment to the area. It could equally be said that it was an unrealistic bubble from the start – despite the detailed information on proposed shift patterns for miners.

Despite being on the far west seaward side of Europe – West Cumbria cannot extract itself from global market, investment and environmental realities. Cumbrians deserve decent, local, stable, sustainable jobs.

Sam Moisha

Member of Radiation Free Lakeland

 

 

 

 

 

 

South Lakes Action on Climate Change Object to the Coal Mine

South Lakes Action on Climate Change
Dear Ms Brophy,
Re: Application ref 4/17/9007 by West Cumbria Mining Ltd for
Development of an existing surface
mine entrance for a new underground metallurgical coal mine and associated surface development
including: at the former Marchon site (High Road) Whitehaven […] off Mirehouse Road, Pow Beck valley and area from, Marchon Site to St Bees Coast
1. South Lakes Action on Climate Change towards transition (SLACCtt) objects to the above coal mining application because the quantity of greenhouse gases it will release over its projected years of operation would be totally incompatible with the urgent and steep reduction in carbon emissions that climate scientists state we will need to ensure,
in order to have any good chance of meeting the temperature goals of the Paris Climate Agreement that the UK and almost all other nations have signed up to.

FOSSIL FUELLED EARTHQUAKES? NO THANKS! ( BUT ARE THE HSE LISTENING?)

Come On! Fossil Fuel Extraction Near Nuclear ..Are the HSE Going to ACT?

PRESS NOTICE

22nd February 2018

FOSSIL FUELLED EARTHQUAKES? NO THANKS! ( BUT ARE THE HEALTH AND SAFETY EXECUTIVE LISTENING?)

Fracking and Nuclear Activists have joined forces to call for increased Nuclear Safety for the UK. NGOs including Radiation Free Lakeland, Close Capenhurst, People Against Wylfa B, Residents Against Fylde Fracking, CND Cymru, South Wales Anti-Nuclear Alliance, Natur- Nature not Nuclear Wales and Stop Hinkley have called upon the UK Health and Safety Executive to effect an immediate ban on the extraction of fossil fuel near nuclear installations.

Containers of Uranium Hexaflouride- Springfields, Preston.jpgContainers of Uranium Hexaflouride at Springfields, Preston. Five miles from PNR fracking site.

Featured Image -- 12987St Bees, where a new undersea Coal mine is planned just 5 miles from Sellafield (seen here from St Bees)

Earthquakes? – We Don’t Want Your Concerns, Your Petition or your Letter Say HSE.  

Marianne Birkby of Radiation Free Lakeland said “ It is well known that fossil fuel…

View original post 965 more words

URGENT – KEEP CUMBRIAN COAL IN THE HOLE

An Urgent Request from Keep Cumbrian Coal in the Hole

– Please Send Objections into Cumbria County Council to Make Sure we STOP the First Deep Coal Mine in the UK for 30 years. Below is an objection from Keep Cumbrian Coal in the Hole.   Please feel free to amend, adapt or just generally use as a starting point for your own objection. It doesn’t need to be long – just a sentence or two would do to let Cumbria County Council know that you oppose the plan.  Every letter of objection is a step nearer to stopping the plan!

Send Emails to

Rachel.Brophy@cumbria.gov.uk   in the Subject put : Wood House Colliery 4/17/9007

If you have time please do also tell the Development Control Committee how you feel too! They will be making the decision on March 7th in Kendal  http://councilportal.cumbria.gov.uk/mgCommitteeDetails.aspx?ID=124

Letters to be in before 19th February to stand a good chance of being included in the report to Council – but you can object up until the planning meeting on the 7th March

 

To Rachel Brophy,

Development Control Team, Cumbria County Council

Woodhouse Colliery, Application Number 4/17/9007

West Cumbria Mining [WCM]

KEEP CUMBRIAN COAL IN THE HOLE

On July 2nd 2017 Radiation Free Lakeland wrote to the Leader of Cumbria County Council to vehemently oppose the plan for the first deep coal mine in the UK in 30 years.

I am writing again on behalf of Keep Cumbrian Coal in the Hole which is a Radiation Free Lakeland campaign, to add further comments, and also ask to be allowed to speak on behalf of Keep Cumbrian Coal in the Hole.

Reasons to Refuse this application include:

  • Proximity to Sellafield
  • Hydrology Impact
  • Wildlife Impact
  • Seabed Subsidence
  • Methane Emissions
  • Carbon Emissions
  • Health Impacts

PROXIMITY TO SELLAFIELD

SellafieldPondajpg.jpg

The B30 pond showing a full loading of spent fuel rods

A recent article in The Ecologist magazine highlighted the proposed mine’s close proximity to this dangerous stockpile of plutonium:

“The potential for earth tremors and quakes resulting from mining is well known. Even if the tremors were small that is too big a risk to take in the vicinity of Sellafield.”  High intensity and liquefaction phenomena like that experienced at Christchurch in New Zealand are usually associated only with relatively large magnitude earthquakes. An earthquake in 1865 in the northwest of England (Rampside) suggests that a sufficiently shallow small event can also produce liquefaction. The Ecologist reported that: “Especially serious are the ~20 large holding tanks at Sellafield containing thousands of litres of extremely radiotoxic fission products.” Discussing these tanks, the previous management consortium, Nuclear Management Partners, stated in 2012: “There is a mass of very hazardous [nuclear] waste onsite in storage conditions that are extraordinarily vulnerable, and in facilities that are well past their designated life”The National Audit Office (NAO) stated these tanks pose “significant risks to people and the environment”.

One official review published in The Lancet concluded that, at worst, an explosive release from the tanks could kill two million Britons and require the evacuation of an area reaching from Glasgow to Liverpool. This would negate Cumbria County Council’s strategic objective of avoiding adverse impacts from developments (Objective 2, Cumbria Minerals and Waste Local Plan 2.27)

HYDROLOGY

the-beautiful-river-ehen-about-to-be-nuclearised.jpg

The River Ehen runs alongside the Irish Sea

West Cumbria’s domestic fresh water supplies are already stressed with the halting of abstraction from Ennerdale to protect the river Ehen (Sellafield will continue to abstract from the Ehen for cooling and processes).

People in West Cumbria have experienced problems with borehole water being added to their supply. The vast discharge of water required to dewater the old existing and newly opened mines would inevitably impact on West Cumbria’s fresh water supply.   “The history of contamination of watercourses in the areas raises concerns for some local residents in relation to the impact of the development on the complex hydrology of the area.” Colourful Coast Partnership. This flies in the face of NPPF and Cumbria County Council’s own Minerals and Waste Plan to have regard for provide for public health (2.25).

WILDLIFE IMPACT

RSPB - St Bees Black guillemot.jpg

“We are particularly concerned in regard to the potential impact upon the wider marine and coastal environment of the discharge of water into the sea, which has been pumped from the flooded anhydrite mine.” National Trust

“ The application site is in proximity (Solway Firth 1.5km) to a European designated site (also commonly referred to as Natura 2000 sites), and therefore has the potential to affect its interest features.”Natural England

“The impact of any level of subsidence upon the terrestrial or marine heritage assets and designated sites and landscapes could be significant and permanent, therefore having a detrimental impact ..The history of contamination of watercourses in the areas raises concerns for some local residents in relation to the impact of the development on the complex hydrology of the area.” Colourful Coast Partnership

Our position is to object to the proposed development on the grounds of the adverse impact on groundwater, surface water and biodiversity.”Environment Agency

St Bees “supports England’s only breeding black guillemot – which are small in number and already vulnerable to stochastic events.” “The development has the potential to have an adverse effect upon the St Bees Head SSSI through disturbance to breeding birds during excavations and coal processing.”   RSPB

It is clear from objections by the Colourful Coast Partnership and those quoted above (this is just a selection, there are many more) that Biodiversity would be adversely impacted on by this development. This runs counter to NPPF policies and Cumbria County Councils own Minerals and Waste Local Plan (2.25)

SEABED SUBSIDENCE

As previously noted seabed subsidence is an issue that would have environmental consequences anywhere. Close to Sellafield the environmental consequences of seabed subsidence have far wider implications. This includes the possible resuspension of many decades worth of radionuclides that are currently on the Irish Sea bed as a result of Sellafield reprocessing. Long-lived radionuclides (like plutonium or americium 241 nuclides) are still accumulating in the mud at the bottom’ of the Irish Sea. Events like storm surges or seabed subsidence churn this up. Resuspended particles make their way to the beaches of Cumbria and beyond. This is intolerable and is already an issue for beaches in West Cumbria with radioactive particles being routinely found by the industry’s own beach monitoring system (which stops in the school holidays).

ArgocatFinds.jpg

Monitoring West Cumbrian beaches for radioactive particles – thousands are found and ‘retrieved’…

Knowingly creating the conditions for seabed subsidence from undersea coal mining runs counter to Cumbria County Council’s own policy of “risk reduction” regarding radioactive wastes.   The Irish Sea Bed should be treated with care as it acts as a saucer like container for the many decades worth of radioactive wastes which are best left undisturbed.

METHANE EMISSIONS

The fossil fuel industry’s methane emissions are far higher than previously thought. The famous landmark “candlestick” in Whitehaven is an air vent for the “most fiery pit in the kingdom.”   “Fiery” because this area is methane rich. Last year the applicants West Cumbria Mining accidently hit a methane seam off St Bees and just five miles from Sellafield while carrying out exploratory drilling. “Local authorities, fire rescue, police and the Environment Agency were all informed.”  An explosion was averted this time. Cumbria County Council have a duty of care to make sure there is no next time.

WCM drilling rig off Fleswick bay.jpg

WCM Drilling Rig off Fleswick Bay

CARBON EMISSIONS

Cumbria County Council are the custodians of hundreds of millions of tonnes of CO2 currently safety bound up in this coal under the Irish Sea. The developers are pushing the “need” to mine this coal for steel making. Why? There is a race on to develop ever more processes of steel making which do not involve the burning of fossil fuels. Sweden seems to be at the forefront

Worldwide the steel industry is well aware of the need to rapidly decarbonise. This is already happening with ever more steel recycling. For new steel production there are ultra-low carbon methods of steelmaking in development and soon to be deployed whether this is based on biomass, hydrogen or electrolysis.

This is happening now with some of the world’s largest iron ore producers (Brazil, China) also having the greatest potential for and commitment to renewable energy. There is no case for opening a new coal mine in Cumbria.   Cumbria County Council will have a case to answer should they facilitate the opening of this the first deep coal mine in the UK for 30 years.

Sellafield from St Bees - a stones throw!.jpg

Sellafield viewed from St Bees…a stones throw!

 

HEALTH

The old Marchon Chemical plant and Anhydrite mine that fed it feature in the WCM application. We note that the anhydrite mine would need to be dewatered. This would be reckless given that previous operations are still having a “significant” impact. “There is also a significant radiological impact due to the legacy of past discharges of radionuclides from non-nuclear industrial activity that also occur naturally in the environment. This includes radionuclides discharged from the former phosphate processing plant at Whitehaven, and so monitoring is carried out near this site.” Radioactivity in Food and the Environment 2016.(  https://www.food.gov.uk/sites/default/files/report2016_0.pdf )

This direct assault on health is additional to well documented climate change health impacts and the intolerable danger that this mine would represent to the safe stewardship of Sellafield

We urge Cumbria County Council to turn down this application, which presents a danger to us all on many different levels.

 

Yours sincerely,

Marianne Birkby

On behalf of Keep Cumbrian Coal in the Hole

A Radiation Free Lakeland campaign

https://keepcumbriancoalinthehole.wordpress.com/

 

 

PETITION to Keep Cumbrian Coal in the Hole

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

 

 

Campaigners Shocked At ‘What Coal Mine?’ Survey Response

Local Radio Stations have reported on our survey.  Many thanks to The Bay and Lakeland Radio .

From the Bay Radio…

Campaigners Shocked At ‘What Coal Mine?’ Survey Response

Tuesday, February 6th, 2018 5:00am

Campaigners say they’re surprised that plans for a deep coal mine off the Cumbrian coast don’t seem to be common knowledge.

A survey in Kendal last week found that 100% of the respondents knew about the Thirlmere zip wire plans – but none had heard about the mine proposals, just 30 miles from Kendal – under the Irish Sea at St Bees.

Both applications will be heard on March 7th, in Kendal, by the Lake District National Park Authority and Cumbria County Council respectively.

Marianne Birkby from Radiation Free Lakeland said: “Of these two developments, the plan that will, beyond any shadow of a doubt have the most damaging and long lasting impacts on Cumbria and our neighbours is the coal mine.

“But this is the plan that campaigners Keep Cumbrian Coal in the Hole say is ‘going way under the radar’.

“Everyone questioned in the survey was astonished that there is a plan to open a new coal mine which would extend under the Irish Sea from St Bees.”

The developers, West Cumbria Mining, have told campaigners that mining could take place five miles from Sellafield but that ‘seismic activity as a result of mining would not be a problem.’

Opponents say it’s not a risk worth taking.

In September, campaigners met in Bowness to ask people to sign their petition against the plans, calling for them to “show resistance” to the first new deep coal mine in the UK for more than 30 years.

 

 

PETITION: KEEP CUMBRIAN COAL IN THE HOLE (IT’S TOO NEAR SELLAFIELD)