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.

The project is funded by Future’s Venture Foundation.


Camille Marmié, Vincent Friell, Lisa Howard

Composer & Sound Designer

Pippa Murphy

Writer & Producer

Wallace Heim

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. 


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). 


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.


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.” 


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.

Aquifer beneath West Cumbria in the vicinity of WCM proposal

Image: BGS




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


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”. 


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


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.  



Cumbrian Campaign Group Granted Permission for Judicial Review

The Case Against New Coal Mines – Green Alliance

Cumbrian Coal Mine Could be ‘the last one’ in the UK – Tradelink Publications Ltd

A more potent greenhouse gas than carbon dioxide, methane emissions will leap as Earth warms – Science Daily


UU Plans to Keep Drawing West Cumbria’s Water from Egremont Boreholes

Byerstead Fault – Marine Conservaton Zone

West Cumbria Aquifer

WCM have not demonstrated how much freshwater would be abstracted from the Byerstead Fault at peak production ––G9NQv_m5kGFNznBdOOMc9s

Nightmare Coalmine Near Sellafield Approved.

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

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

“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).

Information was correct at time of publishing. See terms and conditions for further details.

Great News! Green Light for Coal Mine is Now Amber, Thanks to You!

Whitehaven to St Bees

Image: Wild honeysuckle and Irish Sea 

There is great news!

The unanimous green light that Cumbria County Council had given the developers, West Cumbria Mining,  has now effectively turned back to amber.   Cumbria County Council has confirmed that it will no longer rely on the resolution decision that we were challenging.

This turn around would not have happened without youramazing support for the Judicial Review (which had been granted full approval to go ahead and challenge the County Council’s decision). 

West Cumbria Mining has now submitted a revised planning application to Cumbria County Council.  This revised plan seeks to answer the legal challenges which were to be brought by us in the Judicial Review.

We believe the true reason why West Cumbria Mining has submitted a revised planning application is to try to defeat our legal challenge.

For example the middlings coal will now, say West Cumbria Mining, with this new plan be magically transformed into coking coal!

Our brilliant lawyers at Leigh Day will now seek costs from Cumbria County Council and WCM, because we have in effect achieved what we set out to do, which was to overturn the council’s unanimous decision to approve the coal mine.

We are seeking legal costs in order to keep our fighting fund for another day.  This is should we need the fighting fund after the council’s planning meeting to decide whether or not to approve WCM’s new and improved cunning plan!
So, there is now an opportunity to firstly lobby the council so they do not, yet again, say yes to this revised planning application for the first deep coal mine in the UK in decades.

Should Cumbria County Council say yes again, Keep Cumbrian Coal in the Hole will challenge that, again!

But first things first – the revised plan can be seen Online via the County Council’s website at:   Application Ref No: 4/17/9007

Even if you have written in opposition to the plan before please do write again…this is in effect a new plan.

I will send out info soon to help people challenge this revised planning application with your own letters of opposition to Cumbria County Council.   We have not got long – the (first) official deadline is June 15th. 

We can Keep Cumbrian Coal in the Hole !! 

“Magical Coal Mine” Demo Outside County Offices Kendal, 31st Oct from 8.30am till the meeting starts at 10am

Bloody Magical Coal Mine I am!  .jpg


The presentation below has been sent to the Development Control & Regulation Committee.  I will read a shortened version of it out on behalf of Keep Cumbrian Coal in the Hole at the meeting on the 31st in the County Offices, Kendal.

There will be a demonstration ahead of the meeting from 8.30 for people to make their views known about this outrageous plan. Bring Banners – bring yourselves!

You can send your own letter of objection in before 31st (do it quick) doesn’t need to be loads just a few lines of why Cumbria County Council is wrong to be ratifying this outrageous decision.  They even say this coal mine would be “carbon neutral” and make “carbon savings” this is incredible magical thinking.  Phone, Write to

01539 713 548

Keep Cumbrian Coal in the Hole –

Presentation to Development Control and Regulation Committee 31st oct

Application ref no 4/17/9007


Keep Cumbrian Coal the Hole is a campaign by civil society group Radiation Free Lakeland.  We were first alerted to this coal mine as it would extend to within 5 miles of Sellafield. The risks are multiple and are on a planetary scale.

Carbon Neutral?

The overriding and often repeated message from the council’s reply to Leigh Day’s questions is that the mine would be “broadly carbon neutral”.  This assumption is crucial; yet, neither the addendum report, nor in fact any of the underlying application documents,  provide the evidence to support it.

It seems that this “carbon neutral” claim is simply based on vague assumptions that “coal production at Whitehaven would substitute for coal production elsewhere.”   Really?

Clearly, the consideration of the likely emissions output from this development is absolutely key for any decision made by this committee. The Committee must come to a reasonable conclusion on the expected level of greenhouse gas emissions that will be produced over the next 50 years.  It must do so, so that it can decide how much weight to give to that factor in the planning balance. The Applicant has simply failed to provide the Committee with sufficient information to carry out this task – this was a key point highlighted in the Leigh Day letter and it has not been addressed by the addendum report – which merely reiterates assertions about how the market might respond to the increased output in Whitehaven.

  1. With respect, the addendum report has raised more questions than it has answered. Notably, it states at para 4.4 of the addendum report, that the original Committee Report attached “moderate weight” to the “CO2 emissions from the extraction and processing of the coal and their impact upon climate change” which weighed against the proposal.  That must have been based on an understanding that the mine would produce CO2 emissions (as undoubtedly is the case).  Somewhat oddly, the Addendum Report now seeks to clarify that this should have said that “greenhouse gas emissions globally as a result of the extract and processing of coal would be broadly in balance”.  It refers to other paragraphs of the original report (6.47 and 6.406) where the import-substitution point was made – however, the import-substitution point concerns emissions from reduced transportation.  It does not support the argument that the coal produced further afield will stop being produced at all.  So it cannot be relied upon to factor out the additional emissions associated with bringing a new coal mine into operation.  
  1. On the emissions expected from exports of coal from the mine, we must emphasise that the vast majority of output is expected to be exported. The proposed amount of coking coal for export to Europe and beyond would be a staggering 2 million tonnes annually.  Whereas the amount earmarked for UK use would be a more modest 360,000 tonnes. So most of the coking coal produced is destined to travel abroad.  In relation to this, the addendum report relies on assumptions that this will all be exported to “Europe” and will replace alternative sources of coking coal from further afield.  Yet there is absolutely no restriction on where the coal would be exported to.  Nothing prevents it from travelling further afield.  And, if it does, all the assumptions on emissions savings through import substitution fall on their face. 

Has the Committee properly considered this? Where is the evidence for this idea of “substitution”?  Do the councillors really believe that a mine elsewhere will stop producing coal because a mine in Cumbria has opened up under the Irish Sea, five miles from Sellafield? More importantly, do they have before them sufficient evidence to support such claims.  In our view, they clearly do not.

Demand for Coking Coal for Steel

You acknowledge that the demand for coking coal is led by the demand for steel.  However there is no acknowledgment in your report that technology and politics has moved on with the Department for Business, Energy & Industrial Strategy (BEIS) announcing in August,  new measures to “enable a pathway to lower carbon steel production and support broader efforts to decarbonise industry”.  

Nor is there any recognition of the possibility that greater supply of coking coal might impact on worldwide prices, with a real chance that demand will increase (for both the coking coal, itself, and for steel) due to reductions in the price.

Middlings Coal

The middlings coal you say would be up to 15% of coking coal extraction.  To describe up to 15% of production as a “by-product” is disingenous. It is a significant amount of production, in and of itself, and members should not be distracted by this type of terminology.  The level of middlings coal produced could easily be a development in itself, so the impacts of it need to be fully considered.

You say that an assessment of CO2 emissions “would not be a reasonable requirement.”   Given that the UK government has just signed up to a Climate Emergency we say that a full and comprehensive assessment including the various scenarios of transport exports to near Europe, far Europe and beyond, of the CO2 emissions from both coking and middlings coal is an entirely reasonable requirement.

At paragraph 6.71 of the original report, it stated in relation to middlings coal production that “There are valid arguments made in respect of climate change, but we consider these issues could be better managed by applying regulatory controls at the point of use.” The addendum report now seeks to clarify, at para 4.14, that the mere reference to there being “valid arguments made in respect of climate change” meant that the issue was weighed in the planning balance but was not considered of sufficient weight as to justify the refusal of permission, or to require a condition requiring disposal of the middlings coal.  That is not how we read the original report.  It is not clear at all what the “valid arguments in respect of climate change” referred to were and by reference to other regulatory controls, it was clear that the officer did not factor emissions from middlings coal production into her assessment.

Interestingly, the addendum report now recognizes that the burning of middlings coal would “undoubtedly” result in the generation of CO2 but argues that it would not be a “reasonable requirement” to expect the decision-maker to assess possible emissions associated with it.  This is a fundamental failing in a case where the officers are nonetheless arguing that the “greenhouse gas emissions of the mining operations would be broadly carbon neutral” and the “greenhouse gas emissions globally as a result of this extraction and processing of coal would be broadly in balance”.  

With respect, you cannot reach a conclusion that operations are carbon neutral if you have failed to estimate the emissions associated with 15% of production.

If you are going to assess the net carbon output of a development, then you have to assess the whole of it.  To do otherwise is irrational.

Finally, on middlings coal, we can still see no reasoning as to why the level of output has been limited by condition to 15%? Why not 10% or 25%? What evidence or understanding rationalises this conclusion and how has it been shown to be necessary, relevant to planning, relevant to the development to be permitted, or reasonable in all other respects?

Net Zero

The addendum report concludes that whilst the new net zero target makes the Climate Change Act 2008 target more challenging, it does not change the original report’s assessment on the impact on climate change and efforts to reduce CO2 emissions, which were both treated as key considerations in that report.

With respect the addendum report fails to appreciate the substantive change brought about by the new net zero target.  By 2050 there needs to be a 100% reduction in emissions as compared to 1990 levels.  That means that all emissions need to be offset, or somehow compensated for, so as to produce a “net zero” emissions output level overall.

This development will result in significant emissions far beyond 2050.  If consent were to be granted next year, the permission would last until 2070.  Even if the Committee were to accept – what we say are the incorrect – assumptions that the production of coking coal will be carbon neutral, it now seems accepted by officers that the production of middlings coal will result in unquantified levels of emissions.  That – at the very least – needs to be properly factored in.

The Committee must have due regard to the emissions output that any permission will grant consent for beyond 2050 and what will be needed to offset this.  This is clearly a material consideration in light of the legally binding net zero target.

And, it only supports the need for the Committee to obtain robust evidence from the Applicant on what exactly the likely emissions output will be.  To reiterate, we do not consider the Committee has sufficient information at present.

Carbon Savings?

Finally and without any supporting evidence at all the report claims that “whilst greenhouse gas emissions of the mining operations are very likely to be carbon neutral, it is still considrered that some carbon savings must exist  from reduced transportation distances.” (4.6)  Incredible!  So this massive coal mine which proposes to operate over 50 years would actually result in carbon savings from reduced transport with this ‘home grown’ coking coal-?   Even though the plan is to export the majority of coal to Europe and beyond. 

We ask that the Council do not ratify this disastrous and planetary damaging application for the first deep mine in the UK in 30 years extending to within 5 miles of Sellafield.  There is no supporting evidence at all to back up the false claims of the mine being “carbon neutral” and making “carbon savings.” 

COAL!! BBC & Magical Thinking

ash background beautiful blaze
Ashes and Dust

The BBC’s latest Christmas Cracker is to promote the first deep coal mine in the UK in 30 years like there is no tomorrow.

Yesterday’s Radio 4 PM programme treated listeners to the most highly sweetened, sickening concoction of greenwash promoting a coal mine.  The plan for Woodhouse Colliery under the Irish Sea extending over 50 years towards Sellafield  seems to be enjoying the most magical of magical thinking.

It is an enigma wrapped up in coal dust.  Where is George Monbiot?  Where is David Attenborough?   Where is the Extreme Energy Network?  Where are Extinction Rebellion? Where is Everyone?  What is the BBC’s Game?


I was interested to hear the PM broadcast about the proposed first deep coal mine in over 30 years. We heard from the mining developers, the Mayor of Copeland and former miners, all of whom expressed delight with the proposal. There were no dissenting voices. The reporter’s questions were superficial and too easily satisfied by the developers cynical reassurances that the steel would be used for wind turbines. This is nonsense to hoodwink the public, they could just as well have pointed out that the biggest steel structure in the world is nuclear related -over Chernobyl. This bias from PM is shocking given that the West Cumbrian coal mine is the most methane rich in the country. Despite false assurances from the developers on the programme, it proposes to produce middlings, (thermal coal) as well as coking coal, the majority of which is for export. The DEFRA Emission Factors for Company Reporting, 2017 give upstream emissions from coking coal supply as 442kg CO2e per tonne of coal. The mine will extend closer to Sellafield than ever before with the attendant risk of earthquake from such huge abstraction of coal. I expected to hear from at least one of those opposing the mine to point out the cumulative dangers, but the programme ended in a congratulatory tone. This is shocking bias from the BBC given that this is a development which is due to go before Cumbria County Council maybe as soon as February.

Complaint to the BBC Woodhouse Colliery 27,12,18