Cracking Letter in the Westmorland Gazette …still no word from Mainstream Environmental Journos!

Keep Cumbrian Coal in the Hole

Another Cracking Letter from Anita in the Westmorland Gazette.  In a long running exchange this is a reply to Kent Brook’s letter about the “need” for coking coal to provide steel for WMD etc.  Whether or not you want nuclear WMD …there are other ways to make steel. To mine the coking coal you also need to mine the ‘middlings’ coal, off St Bees under the Irish Sea.

Here is Anita’s letter as it appeared in print

“MR KENT Brooks, (Letters, May 10, ‘Defence must be priority’) is, of course, entitled to his opinion about the proposed coal mine near Sellafield.

However, my opinion, having had a coal face worker in the family for many years, remains the same. Excavating a very deep coal mine beneath the Irish Sea, so close to Europe’s largest nuclear waste facility at Sellafield, is a risk too far.

Europe’s largest nuclear waste facility at Sellafield is a risk too far

In any case, we should not be mining coal at all, if we are serious about trying to mitigate climate change and rising sea levels.”

 

There is a petition to Keep Cumbrian Coal in the Hole

The Planning Meeting has been deferred again -Just How Long is This Piece of String and What is at the End of It…

Piece of String

Dear Friends,

The Planning meeting to determine the Coal Mine Plan has been deferred yet again – this is several times now….must be going for some kind of record.

Anyway the upshot is that the last deferrment of 30th May was to be deferred to July 11th but following our enquiries the latest message from Cumbria County Council is that they really don’t know.

Here is a message from the Democratic Services Manager

“At this stage I honestly don’t know when it will be all I can confirm at this
stage is that it won’t be 30 May.  I will try to get hold on the DCR
Manager for an update and come back to you as soon as I can with a more definite
update.   Really sorry I know it must be frustrating for you to try to
organise your plans around such a vague timetable. ”

Jackie Currie Senior Democratic Services Officer Legal &Democratic Services Cumbria

So there you have it.  Clear as mud.  I suppose it could be argued that it is a good thing that Cumbria County Council and others are not satisfied with the answers to further information that has been asked for.  It gives us more time to garner opposition too.

On the other hand in all this while, it allows West Cumbria Mining to get their feet firmly under the table in West Cumbria with money that has come from who knows where (for who knows what) to bribe and coerce the local population into thinking that deep mining in close proximity to Sellafield is a good thing.  There are a few reasons to be suspicious about the long running time of this planning proposal.

Will Let You Know As Soon As We Do.

If you hear anything perhaps you could let us know!!

Proximity to Sellafield and Earthquakes Good Letter !

Excellent letter in last weeks Westmorland Gazette in reply to previous  letter dismissing concerns about the coal mine plan.  Anita’s letter points out the close proximity of the proposed coal mine to Sellafield and the inconvenient truth that coal mining causes earthquakes.  Anita who wrote the letter tells us that the published letter  is much edited, nevertheless the main point about proximity to Sellafield comes across load and clear.

Coal Mine Poses Risk. WG April 19th 2018.jpg

Westmorland Gazette Letters April 19th 2018

Coal Mine Poses a Risk

“I dont find the ultimate paragraph of Do you need a gas-guzzler?  (Letters, March 29) in which the writer belittles the increased risk of seismic activity caused by coal mines, laughable at all.

Coal mining has been known to cause earthquakes, sinkholes and subsidence in the past.

Already there have been quite a number of earthquakes around the Sellafield area during my lifetime. In fact, Sellafield was built only half a mile away from a known geological fault line.

This coal mine proposal is a risk to our homes and properties we don’t need to take.

Anita Stirzaker

Lake District Boundary Fault.jpg
Lake District Boundary Fault runs alongside the Sellafield site (BGS Image)

Planning Meeting Cancelled Again! New Date 30th May

Dear Friends,

Just recieved word that the Planning Meeting has been cancelled again.  The new date is the 30th May.  Letter of notification from Cumbria County Council below…The more people and groups that register to speak at this meeting the better chance we have of stopping the plan!

“Planning Application 4/17/9007 – Woodhouse Quarry

I am writing to let you know that the West Cumbria Mining Application for Woodhouse Quarry has now been deferred from the 18 April meeting.  The aim is for it now to be considered at the DCR meeting on 30 May.  Apologies for any inconvenience this may cause you.

There is no need for you to register your request to speak at the 30 May committee again, as you have already indicated your intent for the earlier meeting.  However, please note that the deadline for your written information to be submitted to me will now be 23 May 2018.

Many thanks

Jackie Currie

Senior Democratic Services Officer

Legal & Democratic Services

Cumbria County Council| Cumbria House

Botchergate|Carlisle|Cumbria CA1 1RD

Tel: 01228 221030 Mobile 0788 1250007

Email jackie.currie@cumbria.gov.uk    “

 

Easter Greetings!

Black Guillemot – St Bees is the last nesting place in England!

Dear Friends,

Easter Greetings!  Many thanks to all who have been sharing, talking and campaigning to stop the first deep coal mine in the UK for 30 years.

The planning decision date has been cancelled 3 times now. The new date for the planning meeting in Kendal is 18th April.

We continue to campaign against this plan with letters to press and actions on the streets.

Opposition letters continue to be sent to Cumbria County Council including from Scientists for Global Responsibility who have said: ”

  • ..combustion of the coal from this mine will lead to emissions of about 8.3 million tonnes of CO2 each year during the main production phase. This is about the same as the annual emissions of about 900,000 British citizens. However, because it is planned to export much of the coal, these emissions will appear in the ‘environmental accounts’ of other countries, not the UK – although the UK would arguably bear ethical responsibility.
  • Coal mines emit significant levels of methane, a powerful greenhouse gas which further exacerbates climate change. This coal mine will be no different. Such emissions are hard to control. And, of course, there will be additional carbon emissions from the fossil fuels used to produce energy for the mining process itself. Again using figures from Defra, I estimate that this will add approximately 1.2 million tonnes to the figure above, making a total of 9.5 million tonnes of CO2 each year – equivalent to over 1,000,000 UK citizens….”

Please do join Scientists for Global Responsibility and write a few lines (or more!!) opposing this plan to the Development Control Committee via DC Officer Rachel Brophy   quoting:  Planning Application 4/17/9007: Woodhouse Colliery

email: Rachel.Brophy@cumbria.gov.uk

Many thanks

Marianne

Keep Cumbrian Coal in the Hole

Letters in the Westmorland Gazette – For and Against the first deep coal mine in the UK for 30 years

Th Guardian

From this month’s Guardian (whose lack of critical coverage of the first deep coal mine in the UK for 30 years is viewed with growing alarm)

A couple of weeks ago there was a letter in the Westmorland Gazette (based in Kendal) from Kent Brooks.  The letter was critical of opposition to the coal mine plan and advocating nostalgic support for the first deep coal mine in the UK for 30 years.  The same week a Kent Brooks from Kendal also had a letter in the Sunday Times advocating strong opposition to “the most environmentally damaging of energy sources”  coal mining while plugging the “need” for new nuclear.  Quite a feat that, having two opposing views printed in the press in the same week!

Following Kent Brooks letter there have been other letters of support for the coal mine in the Westmorland Gazette but these have been overwhelmed by letters of opposition!

Kent Brooks in the Sunday Times two weeks ago speaking of Angela Merkel“After the disaster at Fukushima she closed down the German nuclear power stations, to the delight of the Greens, although these installations were not threatened by earthquakes and tsunamis.  To plug the gap there has been a massive upsurge in the burning of coal, the most environmentally damaging of energy sources:  a blunder that has worldwide consequences.”

Kent Brooks, Kendal, Cumbria.

Kent Brooks Letter to the Westmorland Gazette “A Long History of Mining” (1st March 2018)  “this mine is part of a proud tradition”

Kent Brooks March 1st 2018

In Support of the view that there should be a nostalgic return to coal mining in Cumbria :

“I fully support the views of Kent Brooks…he is quite right when he says it is an indigenous industry and would be of great benefit to the area”  R Quirk

In Opposition :

“In coking coals heyday … Sellafield was a farming hamlet. Now it is a sprawling nuclear site reprocessing spent nuclear fuel….As well as subsidence risk  on the Irish Sea bed it is well documented that extraction of fossil fuels causes earthquakes.”   Marianne Birkby (Keep Cumbrian Coal in the Hole – edited out)

“Anyone who has children and wants them to grow up in a safe world should be demanding that the plan for new deep coal mining in western Cumbria must not be allowed to go ahead”  Andy Mason

“Coal mining is a backward step and one of the technologies that threatens the viability of our planet. Far better, and more responsible for Cumbria, would be to move with the times..”  Dr Ruth Balogh West Cumbria and North Lakes Friends of the Earth.

Westmorland Gazette Letters March 15th 2018

 

 

 

 

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?

Untitled.jpg
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.