Postcards from Cumbria Expo

Postcards from Cumbria Expo is an online multi-media exhibition celebrating Cumbria’s life, geology, wildlife and much more through the distorting lens of past, present and ‘promised’ voids.

 

the sea cannot be depleted

We are delighted to be able to include this thought provoking and poignant work by Wallace Heim.

“the sea cannot be depleted” can be listened to here

Writer and Producer, Wallace Heim describes the project …….

An estuary is continual turbulence. The tidal forces of the open sea move hard against the higher regions of land, the regions from where maps are made. Those maps mark the two lands, split by the tides and softened by the imperative of rivers as they run to the sea. Maps can chart a channel, a changing sandbank, a buried ship, a danger zone. But they cannot show the restless pull of sea and wind. Or mark the intimacies between the life of the sea and the life of the land.

The tides of the Solway Firth are among the most turbulent around this island, a fast sweep from the Irish Sea into the soft sands of the rivers Esk, Eden and Nith. A line across the blank blue of a map etches the division between Scotland and England. The middle of that sea is not a place where humans can live, but we can find sanctuary in the unfolding of life in the tidal muds and in the migrations of the human imagination across the sea surface. The Latin word vastus described the immensity of the sea, its emptiness and its waste.

The UK Ministry of Defence fired at least 30 tonnes of artillery shells containing Depleted Uranium into the Solway Firth, to test those munitions on behalf of an unnamed ‘Customer’. The firings began in the 1980’s from the Kirkcudbright Training Range in Dumfries and Galloway, and on land at Eskmeals in Cumbria. The date of the latest confirmed firings is not certain, possibly 2011 or 2013, and the license to test fire may be continuing beyond that date. The MOD have justified this illegal dumping of radioactive waste into the sea as being ‘placements’. Attempts to retrieve the shells have failed. Their locations are unknown. MOD scientific reports declare that there is no hazard presented to human military or civil populations from this dumping, or from the misfires or contaminated materials on land.

The firings were a rehearsal and were hostile fire on a homeland, not only the infusion of nuclear waste into the wild sea. How can one understand the slow corrosion that remains? What does it mean for a place, a people, to cohere with the unseen objects of war? What is it to be a target? How do you make a life with, or disavow, the symptoms of the civil-military nuclear complex?

Outrage is a power. This arts project intends to transform those energies and make them work in other ways.

‘the sea cannot be depleted’ is not a continuation of the investigative journalism or activist research that brought this situation into the public domain. Instead, three fictional characters speak their thoughts, from both sides of the estuary. Too, this project sees the firings as episodes in the interlocked mesh of relations between the military, the nuclear industries, the arms corporations, capital, colonialism and political desires for international status. Uranium makes the situation timeless and without location. It casts a silence around the sea, and around the human place.

www.theseacannotbedepleted.net

The project is funded by Future’s Venture Foundation.

Voices

Camille Marmié, Vincent Friell, Lisa Howard

Composer & Sound Designer

Pippa Murphy

Writer & Producer

Wallace Heim

“Unprecedented Numbers of Representations” on Cumbrian Coal Mine Plan!!!

 

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PETITION 

STOP PRESS….

A message from Cumbria County Council …

“West Cumbria Mining Planning Application.

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 !!

WWF ASKS FOR ‘CALL IN’ – GREAT NEWS!

Sellafield from St Bees
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.

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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

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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

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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).

3 https://www.wwf.org.uk/sites/default/files/2018-11/NetZeroReportART.pdf
4 Teske S. Ed. “Achieving the Paris Climate Agreement Goals, Global and Regional 100% Renewable energy scenarios with Non-energy GHG pathways for +1.5C and +2C” https://link.springer.com/book/10.1007%2F978- 3-030-05843-2

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We object to this proposal and we believe that you should call it in. Yours,

GARETH REDMOND-KING Head of Climate Change

 

STOP THE COAL MINE IN CUMBRIA -PETITION

PLEASE SIGN THE PETITION –  LETS SEND CUMBRIA COUNTY COUNCIL THE MESSAGE 

STOP THE COAL MINE

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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!

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, safety (this is 8km from Sellafield) and well being of all Cumbrians. Send an email to development.control@cumbria.gov.uk –or if you have time to all the Development Control and Regulation Committee members  quoting the application reference number 4/17/9007 and including your name and address.

 

Keep Cumbrian Coal in the Hole say: Turn Down Dangerous Coal Mine Plan, For Cumbria and For the Planet

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 issues  we 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 the  CEO 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.
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Aquifer beneath West Cumbria in the vicinity of WCM proposal

Image: BGS

 

 

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The image above is from ESI retained by WCM for “hydrological and hydrogeological support”. 

The amended planning application gives no idea of exactly how much water  would 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.

………………………………………………………………………………………………………………………………………………….  

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”

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.  

 

Refs:

Cumbrian Campaign Group Granted Permission for Judicial Review https://www.leighday.co.uk/News/Press-releases-2020/February-2020/Cumbrian-campaign-group-granted-permission-for-jud

The Case Against New Coal Mines – Green Alliance https://www.green-alliance.org.uk/the_case_against_new_coal_mines_press_release.php

Cumbrian Coal Mine Could be ‘the last one’ in the UK – Tradelink Publications Ltd  https://mqworld.com/2020/02/26/cumbria-coal-mine-last-one-uk/

A more potent greenhouse gas than carbon dioxide, methane emissions will leap as Earth warms – Science Daily https://www.sciencedaily.com/releases/2014/03/140327111724.htm

Methane https://keepcumbriancoalinthehole.wordpress.com/2020/06/11/big-holes-in-mine-developers-plan/

UU Plans to Keep Drawing West Cumbria’s Water from Egremont Boreholes https://www.newsandstar.co.uk/news/17345135.united-utilities-plans-to-keep-drawing-west-cumbrias-water-from-egremont-boreholes/

Byerstead Fault – Marine Conservaton Zone https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/82717/mcz-i1-irish-seas-20121213.pdf

West Cumbria Aquifer https://www.bgs.ac.uk/research/groundwater/shaleGas/aquifersAndShales/maps/aquifers/CarboniferousLimestone.html

WCM have not demonstrated how much freshwater would be abstracted from the Byerstead Fault at peak production –  https://esi-consulting.co.uk/our-work/minerals-waste/hydrological-hydrogeological-support-proposed-metallurgical-coal-mine/?fbclid=IwAR2xvAcZjPly1AGS0nT8TLVHOuEAzKcciH_–G9NQv_m5kGFNznBdOOMc9s

Nightmare Coalmine Near Sellafield Approved. https://realmedia.press/sellafield-coal-mine/

Two Letters – Burning Questions

This letter was sent to the local and national press on 27th May – unpublished.  Can’t help thinking that the close proximity of this mine to Sellafield is a big taboo.

Dear Editor

The green light that Cumbria County Council unanimously gave for the first deep coal mine in 30 years has now turned back to amber. We now have a new opportunity to stop this outrageous plan in its tracks.  The developers West Cumbria Mining have submitted a revised planning application for their coking coal mine.  This revised plan seeks to answer the legal challenges which were to be brought by me in a Judicial Review, with the support of the group Keep Cumbrian Coal in the Hole and with the help of top lawyers, Leigh Day.

The developers are aiming it seems to sidestep our challenges regarding climate impacts and the ‘need’ for the “by-product” of “middlings coal”  This lower quality coal was to make up to15% of nearly 3 Million tonnes of coal to be mined from under the Irish Sea every year.  Now, say the developers, the plan is to ‘process’ the middlings coal and sell it on the already saturated world market as coking coal.

The bottom line is that there is no ‘need’ to open any new coal mines, anywhere.  We are living in strange times and it is really strange that the people who have been opposing this mine from the very beginning are nuclear safety campaigners.  The only thing worse than a new coal mine is a new undersea coal mine on the beautiful Heritage Coast at St Bees Head just five miles from the worlds riskiest nuclear waste site, Sellafield.

Please object to this new and cunning plan by West Cumbria Mining by writing to Cumbria County Council before June 15th. Planning Application Reference number 4/17/9007

Yours sincerely

Marianne Birkby

Keep Cumbrian Coal in the Hole (a Radiation Free Lakeland campaign)

Photo sent in with letter of St Bees Head – site of undersea coal mine 
St Bees Lighthouse
Good that there is a letter in this weeks press from Extinction Rebellion (note: XR ‘have no position on nuclear’ )

In March last year, Cumbria County Council (CCC) drew condemnation for its extraordinary decision to grant planning permission for the UK’s first new coal mine in 30 years, despite scientists warning we have just a few short years to avert climate catastrophe.

The developer, faced with the threat of a judicial review, has been forced to alter its planning application, meaning it must once again seek CCC approval.

If enough of us object, it’s possible our elected councillors will listen, but we must act quickly – the deadline is Monday June 15.

Please write to CCC before Monday using Application Ref No: 4/17/9007; either go to http://planning.cumbria.gov.uk/ and click on ‘Comment on this application’ or email development.control@cumbria.gov.uk quoting the Application Ref No. and including your name and address. Please also consider writing to your own councillor, which you can find on the council’s website.

A letter template is available here: https://www.xrsl.earth/.

Extinction Rebellion (XR) South Lakes Coordinators

Former Research Scientist with the National Coal Board Speaks Out Against Cumbrian Coal Mine

image
Logo of the National Coal Board – National Coal Board (NCB), former British public corporation, created on January 1, 1947, which operated previously private coal mines, manufactured coke and smokeless fuels, and distributed coal, heating instruments, and other supplies. It was renamed the British Coal Corporation in 1987. The British coal industry was privatized under the Coal Industry Act 1994, which also created a Coal Authority to license coal mining operations and to manage the environmental effects of past mining.   Info from Encyclopaedia Britannica

 

The following letter is reproduced here with kind permission of the author.

3 June 2020

Dear Sir

Woodhouse Colliery, Application Number 4/17/9007 West Cumbria Mining (WCM)

I wish to object to the application

Why I am writing this letter

I was educated at Kendal Grammar School and then graduated in economics from the London School of Economics.  My first job, from 1967 to 1973 was as an operational research scientist with the National Coal Board.  Most of my work was on improving the transport of coal from the coal face to the surface and also on the surface.  I then worked as a transport consultant with the Economist Intelligence Unit and as an industrial economist with an engineering consultancy in the Middle East.  For thirty years up to my retirement I worked in the management consultancy practice of KPMG.  At KPMG I was often involved in advising clients on the viability of investment projects.

I am writing because I was astonished to see a proposal to open a deep coal mine in a coalfield which had high costs of production and at a time when the climate emergency demands the phasing out of coal.      

The market envisaged by WCM

WCM propose to sell coking quality coal to steel producers who use the blast furnace/basic oxygen furnace process in the UK and Europe.  This market is currently served mainly by coal from the United States.  WCM argue that their product would have a competitive advantage in Europe because of shorter transport distances and lower transport costs.  WCM argues that this leads to an advantage in terms of greenhouse gas emissions because of less fuel used in shipping.

There are other steel processes which do not require coking coal.  The scrap-based electric arc furnace process accounts for about 40% of EU production.  The direct reduction process usually uses natural gas and is widely used in the Middle East.

Getting finance for the project

WCM have already raised funding for project development (exploratory drilling, initial design and obtaining planning permission).  The company would next need to find investors willing to commit much greater sums to:

  • develop the access drifts to coal seam level;
  • equip the ventilation system; 
  • equip mine drainage systems;
  • equip the underground transport systems for coal extraction, and taking in workers and supplies;
  • provide the coal cutting and loading equipment;
  • build the coal preparation plant and other surface installations. 

This would be a major project.  The investors would spend several years paying out money in capital investment before there was any income from sales of coal.  The last big drift mine project in the UK was the Selby complex where development took four years before any coal was produced.  Deep mining has always been financially risky because, although you may have borehole information, you do not know for certain what lies underground.  

 In this case there are major market risks.  What will be the market for metallurgical coal in Europe when this project comes on stream, perhaps in the mid to late 2020s and, over the long operating life that WCM envisages?  Investors would do due diligence on:

  • potential customers in the United Kingdom and Europe (customers being steel producers using the blast furnace process) ;
  • competition for the market in Europe, and in particular steel imports from elsewhere (China, Russia, Turkey);
  • the impact of the coronavirus recession on steel demand;
  • technology in the steel industry;
  • environmental regulation in the UK and the European Union.  Investment institutions are increasingly concerned that climate change could undermine what now appear to be profitable activities and are under pressure to avoid investments in fossil fuels.

Investors would have to look very carefully at all these risks.  Would any serious investor put money into the WCM project?

Overall steel production in the Europe Union (EU28)

I refer to market conditions before the coronavirus pandemic.  The market prospects for most major industrial investments will be worse post-pandemic.

The Statistical Yearbook of the World Steel Association shows that steel production in the EU(28) fell at the time of the 2008 financial crisis and has not fully recovered.  Crude steel production was 199 million tonnes in 2008 and was down to 168 million tonnes in 2017.  This is not a growing market.  

Within this overall total UK crude steel output fell steeply from 13.5 million tonnes in 2008 to 7.5 million tonnes in 2017.  The major producing countries in the EU are Germany, followed by Italy, France and Spain.

The USA has taken anti-dumping action against imports of steel from China.  EU countries have not taken anti-dumping action.  The policy argument has been won by those who say that the benefits of cheap steel for steel-using industries outweigh any gains from protecting the domestic steel industry.  The UK, when a member of the EU, was against anti-dumping action.  So the steel industry is unlikely to be sheltered by protectionist policies.

Potential customers for coking coal in the UK

The UK has two steelworks with blast furnaces, at Scunthorpe and Port Talbot.  Until 2016 both were owned by Tata Steel of India.  In March 2016 Tata, facing financial losses, proposed to sell all or part of its UK steel assets.  The Scunthorpe plant and units making “long products” were sold for £1 to a private equity company Greybull Capital which renamed the business “British Steel”.  After the sale Tata  underwent a change of management and a change of heart.  In December 2016 Tata agreed to invest in Port Talbot and continue to operate blast furnaces there for five years.

In May 2019 British Steel went into insolvency.  The business was kept going by the Official Receiver until it was sold in March 2020 to a Chinese company, Jingye Group.  Commentators have suggested that the attractive part of the business with a longer-term future is not the blast furnace operation but the well-equipped rolling mills. The rolling mills could keep working using semi-finished steel brought in from elsewhere.

Tata Steel continued to make losses.  In January 2020 Nataranjan Chandrasekaran, Chairman of Tata Sons Group told the Sunday Times that “the company can’t have a situation where India keeps funding losses” at Port Talbot.  In April 2020 the BBC reported that Tata was seeking £500 millions in government support for the Port Talbot operations.

Both UK blast furnace operations were in a financially precarious state even before the coronavirus recession.  Jingye and Tata Steel are likely to need to restructure, possibly by ceasing the blast furnace operations and concentrating on downstream processing of semi-finished steel from elsewhere.  No potential investor in Woodhouse Colliery could safely assume that they would be customers for coking coal by the time the mine opened.  The mine operator would need to seek customers in mainland Europe.  

The documents submitted by WCM envisage hauling some of the output by rail to Teesside for shipment.  This might still have cost advantages over US coal, but these would be less profitable than for the UK market because of port-related costs and costs of shipping coal to European ports.

The market in the EU – Environmental policy issues

In December 2019 the incoming European Commission published “The European Green Deal” which sets out a broad strategy for accelerating progress towards meeting a target of no net emissions of greenhouse gases by 2050.  It proposes increasing the EU’s climate ambition for 2030.  It describes a range of policy measures which can be used to achieve this, including:

  • the emissions trading system (ETS) which raises the financial costs of activities which emit greenhouse gases;
  • an emphasis on recycling, the “circular economy”;
  • co-ordinated action with other countries;
  • a “carbon border adjustment mechanism” which would penalize those who simply move polluting activity offshore to places with lax regulation;
  • the use of the EU budget to promote the reduction of emissions, including specifically “research and innovation on low-carbon steelmaking”.

Emissions from steel making are about 6% – 7% of total EU CO2 emissions, so the industry is a target for regulatory change.  The Commission published with “The European Green Deal” a brief related document entitled “Sustainable Industry” which has a highlighted statement “The Commission will make a proposal to support zero-carbon steel making by 2030.”  

There is ambiguity about whether this means the Commission means steel making to be actually zero-carbon by 2030, or whether by 2030  the Commission means to have a set of programmes to get to zero-carbon steelmaking.  Probably the latter because it would be unrealistic to make such rapid changes to production processes.  However, the EU steelmakers need to take this objective seriously, and potential investors would realise that a new investment in coking coal production would be swimming against the regulatory tide.

The major users of coking coal in the EU

 I have reviewed the climate change strategies of the three biggest steel producers in the EU (Arcelormittal, ThyssenKrupp and Tata Steel).  It is clear that they take seriously the need to reduce greenhouse gas emissions in line with internationally agreed targets.  Arcelormittal says “Our most substantial climate related policy risk is the EU ETS which applies to all our European plants.”  EU policy is pushing the producers to cut greenhouse gas emissions.  Arcelormittal stresses that the EU needs also to help the producers towards this objective by introducing a carbon border adjustment mechanism.  

Improved steelmaking technology can help. In recent years producers have made efficiencies by improving the tensile strength of steel, so that less steel is needed to achieve a given result (and therefore less coke needed).

The steel producers have participated in research and development projects partly funded by the EU.  Technologies proposed by the steel producers include:

  • in the short term modifying blast furnaces by injecting hydrogen as a reducing agent.  This would reduce the tonnage of coke required and reduce the CO2 emissions.  Arcelormittal has plants in operation;
  • Arcelormittal’s Torero progammme using waste carbon (for example, wood waste that would be unsuitable for burning in other circumstances) as a reducing agent.  A demonstration plant is being built in Belgium;
  • Modifications to the blast furnace process to produce an exhaust gas which is purer CO2.  This might be transformed into syngas and recycled into the furnace, reducing the need for coke.  Alternatively the purer  exhaust gas might be captured, pumped into underground reservoirs where these are available;
  • The use of hydrogen (rather than a hydrogen/carbon monoxide mix) as a reducing agent in a direct reduction plant.  Arcelormittal proposes to build a test installation in Hamburg;
  • Tata Steel has built pilot plants to test the Hlsarna concept.  This is a furnace operating at very high temperatures fueled by coal rather than coke;
  • In the longer term there are schemes for producing steel by electrolysis, similar to the way that aluminium has been produced since the nineteenth century. 

Hydrogen can be produced by electrolysis of water.  Improvements which require “green” hydrogen depend on the greater availability of electricity from solar or wind power.  These power sources are developing fast but it will take years before there is regular surplus electric power available for large scale electrolysis plants.  

There are few quick easy wins, but regulatory pressure will tend to reduce the demand for coke.

An example of a plant in transformation to lower carbon technology

The ILVA plant in Taranto, Italy, claimed to be the biggest iron and steel plant in the EU with a capacity of over 10 million tonnes of steel per year (though for some years it appears to have operated at well below full capacity).  There were concerns that emissions of dioxins were the cause of a high incidence of cancer in the area.  In 2012 there was an official investigation of environmental crimes.  The coke making plant has been blamed for the toxic emissions.  At one stage court ordered the blast furnaces to be closed down.  Government commissioners took over the plant from the private owners.  There are political tensions between local people concerned about health and those concerned about jobs.

The government sought a private company to take a lease on the plant and operate it.  Arcelormittal was selected as the operator.  The deal has still not been finalised because Arcelormittal will not take responsibility for lawsuits arising from the legacy operations.  In March 2020 Reuters reported that negotiations had progressed and there was a conditional agreement for Arcelormittal to take over and invest in steel production using direct reduction/electric arc furnace technology.  If this agreement is finalized there will no longer be a requirement for coal.

The impact of the coronavirus recession

The financial crisis of 2008 resulted in a reduction in steel output in Europe. Some steel producers are in a weak financial position.  The signs are that the coronovirus recession will be deeper and long lasting.  Marginal steel plants could close.

Potential investors in WCM may therefore hesitate until the outcome is clearer.  

Observations on methane drainage

I note that WCM’s consultants, AECOM, estimate that methane emissions from the mine would constitute 74% of the local greenhouse gas emissions.  In some comments there has been an assumption that methane drainage would solve this problem.  I also note that AECOM make no assumption about a reduction as a result of methane drainage.

When I worked for the National Coal Board fifty years ago the risks of climate change and the problems of methane in the atmosphere were not widely understood.  Mine operators were, however, very concerned about the risk of methane explosions underground. When coal is exposed it leaks methane. The NCB used methane drainage in a few particularly gassy mines in order to reduce the risk of underground explosions.  The technique involved drilling holes into the pillars of coal which were left to support the strata alongside access tunnels.  The holes were connected to pipework and the methane sucked out and used as fuel at the surface.

I understand from the WCM submissions that the coal will be worked by a partial extraction method, which involves leaving a high proportion of coal in pillars to support the roof.  Methane drainage could reduce leakage from these pillars.  I have never heard of it being used at the coalface where the coal is being broken up by coal cutting machinery (and thus emitting most).  Nor could it stop emissions from the broken coal being transported to the surface and onward to the customer.  Methane drainage would only be a partial solution to atmospheric pollution.

Local implications of a project that failed

I understand the need for jobs.  But job creation efforts should be directed towards projects with a better potential for success.  In my career I have seen too many cases where local authority efforts and money have been sucked into promoting ill-conceived projects. 

I would like to speak at the planning meeting.

Yours sincerely

Robert Wharton

Letter of Objection from Local Resident – Please Write, Write Write and Say NO! to the First Deep Coal Mine in Decades

Pow Beck photo

Here is an excellent letter of objection from Martin – a resident living close to the proposed coal mine and associated infrastructure.

Please use Martin’s letter below as inspiration for your own letters of objection to Cumbria County Council (write before the 15th June) – also ask to speak at the meeting on 8th July  – There is  more information here.

PLANNING REFERENCE: 4/17/9007

I object to the building of the Wood House Colliery and the Train Load Facility (TLF), Pow Beck. 

Cumbria’s Statutory Development Plan (SDP)-Cumbria Minerals & Waste Local Plan; POLICY SP15 Environmental Assets. “Protect, maintaintain and enhance people’s overall quality of life and the natural, historic and other distinctive features that contribute to the environment of Cumbria and to the character of its landscapes and places

The leading paragraph of the same SDP reads “…It will always work proactively with applicants to find solutions that mean that proposals can be approved wherever possible, and to secure development that improves economic, social and environmental conditions in the area.

In my opinion the new mine does not meet those three criteria. The mine won’t be successful; environmental pressures will increase; coke is going to be replaced; other coking coal producers from Russia and Poland are already supplying Europe’s steel industry. As a result there are no economic or social gains. Pollution (air, water, noise, light, environmental) to the local area will be significant and as a consequence our quality of life will be affected.

With regard to greenhouse gasses (GHG), West Cumbria Mining (WCM) made it clear they dig out the coal. The GHG created from exporting the coal and the burning of the coal has nothing to do with them.  Another fossil fuel company that absolves itself from responsibility. Yet when it comes to creating an argument they are more than willing to express the saving in GHG from bulk cargo ships from across the Atlantic and the train miles of American coal to make comparisons with their own small coal mine. 

In your own policy DC13 criteria for Energy minerals, part c. “the impacts of the development have been considered in relation to impact on climate change;

In WCM planning statement (5.3.6) “The determination as to whether an impact is `unacceptable` inevitably involves a degree of judgement on the part of the decision maker”  It is my opinion,  the  environmental impact of this Cumbrian coal  is unacceptable in today’s global warming crisis and should and can be rejected in compliance with your own planning documents, particularly the impact Cumbrian coal will have on the environment.

May I also draw your attention to matters which could be of specific interest to committee.

  • Presently we have the peaceful enjoyment of our home here in High Walton, near St Bees. The air is clean, the valley beautiful and quiet. I have the pleasure of enjoying the first small section of Wainwright’s coast to coast on my doorstep. A tourist asset that you should protect. I am appalled that Cumbria County Council (CCC) has allowed this green space in Pow Beck to come under threat with a large coal yard. 
  • West Cumbria Mining’s preferred  freight operator does use some modern trains in its fleet, trains that will pull 21 coal wagons using diesel engine power. The facts are; a train over 400 metres long; carrying +1500 tonnes; emitting 25.3g CO2e per tonne km (1). Those wagons will need shunting to sidings. When diesel engines apply pulling power they emit plumes of diesel smoke. What are those pollution levels for six daily trains + 126 coal wagons when Frieghtliner begins shunting wagons here in Pow Beck?

 

  • The building may be high tech and aesthetic; but in my opinion still noisy in the quiet areas of Pow Beck and Seacliffe. I can’t imagine the Fan House being too quiet. 126 Coal wagons on sidings are hardly inconspicuous in our green landscape. More rhetoric at the expense of local residents. Our environmental assets will change for the worse.
  • Methane capture during coal crushing processing to provide gas energy (5.4.54).  Does the mine capture all this methane and utilize it? 

Methane is “…reduced and mitigated…”  “…with no atmospheric impact…” (P9: Para 29). Burning Methane produces C02; but this won’t happen until the fifth year of operation when the methane capture plant comes on line apparently. WCM planning statement (page 8-S18) “…methane and utilisation plant will potentially eliminate the majority of fugitive methane emissions”. Also, GHG surveyor remarks about methane capture with a statement that reads “…potentially eliminate fugitive emissions…” (P59: para 9.4). So WCM doesn’t actually know how much Methane will vent into the atmosphere, a number between 2m3 and 6m3 per tonne of coal. That seems quite a difference. 

  • My understanding is that the fan house sucks out air/gases from the mine and as a result clean air is drawn into the mine, diluting gases to safe non-combustible levels within the mine. What is not clear to me is where those gases are vented and captured.  Mined coal constantly gives off methane does it not.
  • GHG reports say the mine operation pollution is less than 1% of the UK’s carbon budget. So this small mine will emit less than 1% of the whole of England, Scotland, Wales and Northern Ireland with all its cities, transport, power generation and people, just to put in some perspective. This tiny spot in Cumbria will add less than 1% to the UKs carbon budget(CB). According to the Government’s own advisory body the UK is not going to meet its targets for the next two CB (2), The implication is that the 2032 budget will have to be even more stringent and the government more decisive to keep on track for 2050 net zero. Indeed the GHG report states (Para 7,13) “Emissions from this Proposed Development are therefore likely to become significant without an emissions reduction strategy” The GHC report mentions (para 9,4) the assumed operation of methane capture & utilisation plant in 5th year of operation. so obviously under development. Is the technology, the burning of methane and offsetting going to be good enough to keep the mines emissions below 1%? 
  • WCM states that “This substitution of imported coal will result in significant carbon dioxide emissions savings from the shipping…” (Para 4.2.13) At maximum mine production, how many bulk cargo ships will it need to bring the equivalent 2.78million tonnes of coking coal to Europe from America per annum? Seven maybe each carrying 400,000 tonnes? 

Dr. Neil Bristow’s letter says “WCM’s place in the global market is small”. Conversely the emission saved by importing from abroad (America) will also be small. In my opinion the saving of seven Atlantic crossings is small in comparisons to the 300 millions tonnes globally. Lets not forget also that Europe uses coking coal from Russia and Poland. The Polish coal news article was an interesting read (3). European steel may source more coking coal from there.

  • WCM planning application did not give examples of companies using hydrogen for greening steel. In Germany they closed all their deep coal mines and import coking coal. Their economy and steel industry is much larger than the UKs. Already the Germans (Austrian and Swedish also ) have invested in hydrogen plants to produce the gas in abundance and replace coal; most notably ThyssenKrupp(4) and Voestalpine(5) . Clearly these two companies will be producing greener steel in the not too distant future and unburden themselves of coking coal dependency. Spending £65 million creating their hydrogen plant sounds like a pretty serious investment to me.
  • I am not convinced by WCM’s argument on weathering either. The coal suppliers and steel makers have been dealing with weathering for years. I doubt there is little advantage to having another small supplier nearby? WCM coal, like all the other coal heading for Rotterdam, will be piled on the quayside along with American, Russian, Polish, Australian and whoever else, ready to be distributed to Steelworks. Sure the coal has a `shelf life`, but this little coal mine won’t keep the furnaces of Europe going for long. 
  • WCM talks about the coal quality degrading once mined and transported yet In their new application it seems they are requesting a “relaxation” (Welsh Mining Forum-GB, 13th May 2020 @ 05:41pm)(6) to their metallurgical coal definition, , in effect manufacturing a slightly lower quality coal. Also (Planning Statement page 51) Why the removal of a condition that states “the coal is to be used for steel manufacturing only” This smacks of hypocrisy from WCM in my opinion or is that typo error there?
  • In my first letter of objection last year I asked you to refuse this planning application. I am asking again to turn down this coal mine. Coal is not an asset anymore, the planet is warming up and the weather system is more extreme. Fossils fuels have to stay in the ground if the countries that signed up to the Paris Agreement want to meet those global warming targets,
  • In your previous planning application the committee were under the impression that the mine is broadly carbon neutral. A fact denied by WCM and not substantiated by CCC. The mine is not broadly carbon neutral, you are misleading the general public. Therefore, I do not believe the rhetoric from the mine company or their expert; who can’t get his sums right  (page 25, para 8)  2.78mt is not 0.26% of 300mt. 

Local people’s environment is not enhanced in any way. Cumbrian people living beside the mine and the roads and railway that are used by the mine are in for big changes to their environment; There will be more pollution from diesel engines and the mine itself. The roads will be busier at rush hour; More light and noise pollution, and just because it is within regulation limits, it will still be intrusive.

 

  • I read this recently and it has many interesting points.

…Rapidly phasing out fossil fuels is critical to address the climate crisis because fossil fuels are the biggest driver of the climate crisis. Reports from the Intergovernmental Panel on Climate Change based on the work of thousands of scientists have confirmed there are no scenarios in which we both keep digging out fossil fuels and keep the world from a climate disaster. We must act now, and decisively, to switch to alternative sources of energy”. NEW York Times” (7).

  • Global warming does not stop at Scafell Pike(8), Keep the coal in the ground and do Whitehaven, Cumbria and the planet a favour. Turn down this coal mine by putting your own policy in action and stand by your policy statement SP15 Environmental Assets.

I am happy to attend your committee meeting, Wednesday 8th July 2020 to elaborate on any of the issues I have raised. Please email me, in the first instance if you would like me to attend.

Yours sincerely,

Martin J Kendall

REFERENCES

 

OBJECT!!! To the New Plan for the Coal Mine Before 15th June

Dear Friends,

Thanks to our continued challenges the Developers of the first deep coal mine in the UK in decades have put forward an amended planning application.  The difference with this plan is that the developers propose to make the lower quality middlings coal (previously called a “by product”) into coking coal.

Even if  you have written previously to oppose the plan PLEASE PLEASE write and object again BEFORE 15th June – and ALSO ask to speak at the planning meeting (July 8th).

We have prepared a list of potential issues that you can object to – (this is not an exhaustive list – there are plenty more arguments you can make against this diabolic plan)

So please do use this as inspiration for your own letters of objection.  Even it you can write just a line or two saying that you strongly oppose this plan. – it is all valid and it all helps!!

Send your letters of objection to

developmentcontrol@cumbria.gov.uk

If you have time to write to all the members of the committee then the details are here 

You can tweet Cumbria County Council here ..  @CumbriaCC 

Please include:  West Cumbria Mining – amendment to Application Reference No. 4/17/9007. 

 

OPPOSITION LETTER TO THE COAL MINE

                              

Application Reference No. 4/17/9007. 

Proposal: Development of a new underground metallurgical coal mine and associated development including: the refurbishment of two existing drifts leading to two new underground drifts; coal storage and processing buildings; office and change building; access road; ventilation, power and water infrastructure; security fencing; lighting; outfall to sea; surface water management system and landscaping at the former Marchon site (High Road) Whitehaven; 

  • a new coal loading facility and railway sidings linked to the Cumbrian Coast Railway Line with adjoining office / welfare facilities; extension of railway underpass; security fencing; lighting; landscaping; construction of a temporary development compound, and associated permanent access on land off Mirehouse Road, Pow Beck Valley, south of Whitehaven; and
  • – a new underground coal conveyor to connect the coal processing buildings with the coal loading facility.

West Cumbria Mining have resubmitted this previously unanimously approved appliction with the change that high quality coking coal would now comprise up to 15% of middlings coal processed on site to render it into coking coal.   

OPPOSITION ON THE GROUNDS OF:

Cumbria County Council Minerals and Local Waste Policy DC13 15.16

This proposal will have unacceptable social and environmental impacts which cannot be mitigated against and would fly in the face of Cumbria County’s own Policy DC13   

a. Loss of Ancient Woodland and degradation of remaining woodland area by the proposed rail conveyor  to cut through two areas of woodland.West Cumbria Mining Rail Conveyor

b. Large Coal Yard Sidings and Trains Local residents are opposed to Pow Beck Valley hosting  a large coal yard with six daily coal trains “The facts are; a train over 400 metres long; weighing +1500 tonnes; emitting 25.3g CO2e per tonne km” “126 Coal wagons in their sidings are hardly inconspicuous in our green landscape. More WCM rhetoric at the expense of local residents”.  Local Resident.

c.  Methane Rich coal seams are now safely contained under the Irish Sea. Methane is a potent greenhouse gas.  The developers consultant AECOM has estimated that 74% of the on-site emissions would be the methane emitted from the exposed coal in the mine.  The developers say that “The installation of a methane capture and utilisation plant will potentially eliminate the majority of fugitive methane emissions.”

Methane would continue to be emitted from the broken up coal up till and including the point of use at a steel works.  Methane drainage would potentially only remove a small fraction of total methane.
d.  Zero Carbon Britain – The developers state If the emissions are less than 1% of the relevant carbon budget, the level of significance is considered to be minor adverse”.   In the context of this long lived coal mine this is nonsensical.  The coal mine is set to continue over 70 years.  By peak production the wildly optimistic 1% of UK carbon emissions from this coal mine would be 5%, 10%  – 20% or even more of an otherwise decarbonised Britain.  In June 2019 the UK became the first major economy to pass net zero emissions law.  The new target will require the UK to bring all greenhouse gas emissions to net zero by 2050.

e. Carbon Neutral.  Cumbria County Council declared a climate emergency in September 2019 and says it is committed to becoming carbon neutral.  West Cumbria Mining have stated in their amended planning applicationand in response to theGreen Alliance Report, that the Coal Mine would NOT be carbon neutral (despite having previously led people including Cumbria County Council to believe that it would be).  In their amended planning statement West Cumbria Mining propose that they have ongoing monitoring requirements on the Development (from 2033 onwards) in order to stop operations past this date if the coal mine compromises the UK’s ability to meet its emissions targets.  This is disingenous.  Cumbria County Council should be brave enough to call a halt to this coal mine sooner rather than later.  

f.  Subsidence and Cement Paste.  The developers propose to fill the voids left by mining with a cement paste in an effort to avoid subsidence of the vulnerable Irish Sea bed and onshore area.  They say the cement backfill :  “will be primarily targeted to sensitive areas including all onshore panels and selected panels close to the Marine Conservation Zone.”  

The planned annual production after 5 years will reach a steady state and is estimated at 2,780,000 tonnes of metallurgical coal, and 

pastedGraphic.png

150,000 tonnes of reject. The reject will be blended with water and a binder (e.g. cement) and the resultant paste material will be pumped back underground and placed directly behind a working panel as it is mined. When used, the paste will fill an estimated 65 % of the void space behind a worked panel. The use of the paste backfill will significantly increase the stability of mined-out areas and subsidence over backfilled panels will be reduced by at least 65 %. This applies to both single panels and to groups of panels. For example, for a single panel with 65 % backfill the maximum vertical displacement will be reduced from 21 cm to 9 cm. There will be sufficient paste produced each year to fill two of the eight panels mined each year, i.e. 25 % of panels will be backfilled. Backfill will be primarily targeted to sensitive areas includ- ing all onshore panels and selected panels close to the MCZ.

(MCZ referee to Marine Conservation Zone – quote above from WCM Process Change_R10) 

image
Marine Conservation Zone Areas – Map by North Western Inshore Fisheries and Conservation

 

Where is West Cumbria Mining's Plan
This is the area of West Cumbria Mining’s Plan

Cement Paste Backfill (of the “panels” – the voids left by the mining process)   is a relatively new and unstable process.  “many factors such as sulfate presence, geothermal factors, and rock pressure in a mine water context have significant effects on the properties of Cement Paste Backfill.”   The last thing needed near the Sellafield nuclear waste plant is a new coal mine with unstable ‘cement paste backfill.’

The Colourful Coast Partnership has noted that : “The impact of any level of subsidence upon the terrestrial or marine hertiage assets and designated sites and landscapes could be significant and permanent, therefore having a detrimental impact…the history of contamination of watercourses in the area raises concerns…”

The Irish Sea bed has been in reciept of Sellafield’s reprocessing wastes for many decades and any resuspension of those radioactive and chemical wastesis to be avoided.

Local planning authorities such as Cumbria County Council 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.   Sellafield is less than five miles from the area of mining proposed in the WCM development.  We have seen no detailed risk assessments for this.

g.  “Water is heavily used in coal processing”   Exactly how much Groundwater would the mine abstract daily from the Byerstead Fault at full peak production ?  West Cumbria Mining have not given any indication of fresh water abstraction. No research has been done on the hydrological and geological impact of this abstraction from the Byerstead Fault?   

“Water is heavily used in coal processing and would be obtained from the following sources:

    • Groundwater (Byerstead Fault)
    • Recycled from the CHPP
    • Mine water ingress
    • Moisture in the coal
    • Harvested rain-water “

(WCM presentation to CCC 19th March 2019)

h.  Blight from Construction and operation.  West Cumbria Mining’s own Environmental Assessement says “the construction and operational activities of the proposals ‘have the potential to generate a number of land contamination related adverse impacts on identified receptors.’ And that “the significance of residual effects related to potential geological and contamination related impacts associated with the Proposal during the construction and operation phases are likely to be minor or moderate adverse, and therefore not significant.”  The blight for  people living near the proposal would be Very Significant. The would experience the coal mine blight of toxic mine tailings, coal dust, chemical pollution,  rail wagons,  and associated noise.  The beginning of the first section of Wainwright’s Coast to Coast walk would be impacted by the noise and disturbance of the coal mine’s rail loading facility.  Should Cumbria County Council approve this plan they would be in contravention of Cumbria’s Statutory Development Plan (SDP)-Cumbria Minerals & Waste Local Plan; POLICY SP15 Environmental Assets. “Protect, maintaintain and enhance people’s overall quality of life and the natural, historic and other distinctive features that contribute to the environment of Cumbria and to the character of its landscapes and places

 

 NOTE:

Cumbria County Council Minerals and Local Waste Policy DC13 15.16

“Planning applications for coal extraction will only be granted where; 

  •  the proposal would not have any unacceptable social or environmental impacts; or, if not
  • it 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.
  • For underground coal mining, potential impacts to be considered and mitigated for will include the effects of subsidence including: the potential hazard of old mine workings; the treatment and pumping of underground water; monitoring and preventative measures for potential gas emissions; and the disposal of colliery spoil. Provision of sustainable transport will be encouraged, as will Coal Mine Methane capture and utilisation.”

 

“Vindication for campaigner fighting plan for deep coal mine in West Cumbria”

On Leigh Days Website

A campaigner, who issued a legal case against a proposed deep coal mine in West Cumbria on grounds that the climate change impact had not been properly taken into account, says she has been vindicated by the latest development in plans for the scheme.

20 May 2020

Earlier this year, campaigner Marianne Bennett, with support from the Keep Cumbrian Coal in the Hole (KCCH) group was granted permission for a judicial review of Cumbria County Council’s decision to allow the first deep coal mine in the UK for 30 years to be built by West Cumbria Mining (WCM) in Whitehaven.

However, since the ruling in February, WCM has submitted a revised planning application to only process premium metallurgical coal in a simplified, cheaper-to-construct mine proposed for the site of the former Marchon Chemical Works. The previous application would have resulted in 15 per cent of the mined produce being a type of non-metallurgical coal, known as “middlings” coal.

As a result, Cumbria County Council has now confirmed that it will no longer rely on the resolution decision being challenged in the judicial review proceedings.

However, Ms Bennett’s legal team at Leigh Day solicitors believes that WCM has submitted the revised planning application to defeat the legal challenge.

They have agreed with Cumbria County Council and WCM that the claim will be withdrawn. They will now seek costs on behalf of Ms Bennett from Cumbria County Council and WCM.

Ms Bennett said:

“We have in effect achieved what we first set out to do, which was to overturn the council’s unanimous decision to approve the coal mine.

“We will be seeking legal costs so that we can keep our fighting fund for another day. We will now be encouraging our supporters to lobby the council so they do not say yes to this revised planning application for the first deep coal mine in the UK in decades.”

Rowan Smith, of Leigh Day solicitors, said:

“We believe that this revised application by WCM is an attempt to defeat the legal challenge which would have been brought at the High Court in Manchester later this year.

“Our client will be studying the new plan carefully and considering further action because she firmly believes that the changes proposed do not resolve the climate change issue with the project and this was the principal reason she took her brave legal action at the start of this process.”

Ms Bennett is also represented by David Wolfe QC (Matrix) and Merrow Golden (Francis Taylor Buildings).

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