Bad News and Good News

Dear Friends,

There is bad news and good news.  Bad news is that apparently the Development Control & Regulation decision cannot be ‘called in’ internally by Cumbria County Council

Good news is that all your fantastic emails and messages to councillors and others has resulted in Tim Farron MP requesting that the Secretary of State calls in this diabolic decision to give a green light to the first deep coal mine in the UK in decades.

We shall give an update on how we can best support this request for a call in by Tim Farron MP to the Secretary of State as soon as possible.

In the meantime – for those folk who were not able to get to the meeting, here are a few videos taken on the day (sorry I didn’t get all the speakers including myself!)   Grab a cuppa and watch the terrible drama unfold – and make no mistake this will make your toes curl.  It is significant that the proximity to Sellafield was not even brought up as an issue by the Council officers.  Sickeningly the members of the committee laughed their socks off when I pointed out that a liquefaction event had taken place in Barrow in the 1800’s – the ground at Sellafield is at high risk of liquefaction in the event of seismic activity.  The last thing we need is earthquake inducing deep mining and massive fresh water extraction to wash the coal (to be extracted from a fault near Whitehaven – they kept that freshwater extraction quiet!).

 

Part 1. Council Officials addressing the  Development Control and Regulation Committee of Cumbria County Council. The full council did not have a chance to debate this.  We heard Lib Dem Cllr and Chair of the meeting Geoff Cook clearly approve of the first deep coal mine in the UK in decades. Incredibly the close proximity (8km) to Sellafield was not discussed at all by councillors or by their officials.

 

 

Part 2 . Part 2. Official of Cumbria County Council outlining how adverse effects can be mitigated from the first deep coal mine in the UK in decades (really?)

 

Part 3. Dr Henry Adams of SLACCtt making a presentation to Cumbria County Council “SLACCtt most strongly objects to West Cumbria Mining’s application because the carbon emissions it would add are so huge that they would have very significant negative consequences that would far outweigh the benefits claimed.”

 

Part 4.  Dr Laurie Michaelis IPCC Emissions report author and coordinator of Living Witness.  making a breathtaking presentation to Cumbria County Council –

“Speaking to you feels like possibly the single most important thing I’ll do in my life.”

which they totally ignored.

 

Part 5. Sam of Radiation Free Lakeland/Keep Cumbrian Coal in the Hole exposes West Cumbria Mining’s false promises over jobs. “It would be truly difficult to find a bigger dead duck proposal than producing fossil fuels for a declining European steel industry. …Cumbria has had it’s fair share of dead and dying industries – old coal and now nuclear – we do not need another dead duck industry . . . Coal is not the future. It could perhaps be said of the WCM proposal that it was a well-intentioned attempt to bring employment to the area. It could equally be said that it was an unrealistic bubble from the start What we need are jobs that do have a future. Please look to the future stability of jobs in Cumbria and JUST SAY NO.”

 

Part 6.  Dr Stuart Parkinson, Executive Director of Scientists for Global Responsibility   “In summary, approving this application for a coal mine would be a huge step backwards for efforts to tackle climate change – and thus would increase the risks of extreme weather events such as storms and floods. Meanwhile, the economic case for the mine is flawed. Therefore, I strongly urge the planning committee to reject the application. ”   

Part 7. Mayor of Copeland, Mike Starkie tells councillors to Ignore the “sensationalist” claims of the objectors who have nothing to do with West Cumbria and the objectors views should carry no weight whatsoever (?! what a brass neck this Mayor has… many objectors are local to Whitehaven  and WCM is a dodgy company funded by who knows who from who knows where). Councillors agree entirely with the Mayor of Copeland (who makes the ‘Jaws’ Mayor look quite reasonable) and vote unanimously to approve the first deep coal mine in the UK in decades.  The Mayor points out that Sellafield are right behind this plan to mine deep holes in Cumbria.

 

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Will 3 Councillors Please Step Up to Protect Cumbria and the Planet??

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Mark Kirkbride CEO of West Cumbria Mining going into the Council Chamber. Photo credit Philip Gilligan of South Lakeland CND

Dear Friends,

We are shell shocked but regathering our resolve to challenge this outrageous decision taken by just a handful of Cumbria County Councillors.   There are legal actions we can take and are looking into but we feel the first course of action should be for CCC to have the chance to rethink this shameful decision.  We do not have much time to do this – just till early next week (we think – any advice welcome!)

There is a way to do this with an internal ‘call in’.

So it would be fantastic if folk could write to Cumbria County Councillors and ask for this decision to be ‘called in’.

The Councillors details are here…http://councilportal.cumbria.gov.uk/mgMemberIndex.aspx?bcr=1

An example letter is below but using your own words making these points would be really good.

Dear..
On the 19th March The Development & Regulation Committee  voted unanimously in favour of the plan for the first deep coal mine in the UK in decades not far from Sellafield. This terrible plan hassuch damaging consequencesfor the planet and for Cumbria it should be discussed and debated by the whole council.   The Scrutiny and Overview committee decision can then be informed by the feeling of the whole council rather than by a handful of committee members.
It would just take 3 councillors step up to protect Cumbria and agree to a *call in* . If you are one of those councillors and would like to have a briefing to advise on wording for the call in then please urgently contact wastwater@protonmail.com
From CCCs website:  The *call in* requires three non-Cabinet members to email the Assistant Director- Corporate Governance, giving reasons and identifying a Lead Member.  The notice must specify which aspect or aspects of the decision the members wish to question or challenge.
Yours sincerely,
********

There is also a petition which we are keeping open can you help spread the word by forwarding the link below to your friends?

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

Many Thanks

Keep Cumbrian Coal in the Hole

Cumbria County Council would be responsible for “causing many thousands of climate deaths” should this Coal Mine plan be approved says Ecological Consultant

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You can still write to oppose this plan until the Planning Meeting on 19th March – email

Rachel.Brophy@cumbria.gov.uk

This is from South Lakes Action on Climate Change –     Bravo!

 

Dear Rachel Brophy,

Re: Application ref 4/17/9007 by West Cumbria Mining Ltd re proposed coal mine at Whitehaven

Last week’s High Court judgement: A pro-fossil fuel Paragraph in the 2018 NPPF is effectively illegal.

I am writing on behalf of South Lakes Action on Climate Change to make Planning Officers aware of a High Court Judgement which effectively makes illegal a paragraph in the ‘Oil, gas and coal exploration and extraction’ section of the 2018 NPPF, which has important implications as regards how climate change impacts should be considered as a planning consideration at local government level. We at SLACCtt most strongly advise that this ruling and their implications are given urgent and priority attention by the Planning Officers involved in producing their report to the Development Control Committee on WCM’s coal mine application.

The attached letter is an addition to our letter of objection dated 18/2/18 and covers the above key addition as well as important implications of IPCC’s Special Report for 1.5 degrees, WCM’s carbon emissions and the many thousands of consequential climate deaths, and also a critique of WCM’s claims as regards emissions from shipping coal.

The attached letter was written just before I heard that the Planning Officers have produced their report to the committee on WCM’s application. We regard the implications of the High Court Judgement of sufficient importance, together with the implications of the IPCC SR1.5 report, and the consequent many thousands of deaths that the WCM project will cause, that the report should be withdrawn and revised.

The Court judgement means that Project Officers can no longer work on the basis that the NPPF, the Planning System, and indeed Written Ministerial Statements, are necessarily legally correct in facilitating or providing loop-holes for, the extraction of more fossil fuels. Fossil fuel extraction is now being legally challenged.

This means that the Cumbria County Council, its Planning Officers and Councillor Committee members, can no longer use an excuse that they have to follow government statements or policies that are pro-fossil fuel extraction, when they recommend or decide on fossil applications such as from the WCM.

This also means that any officers who advise councillors to accept WCM’s application, and likewise any councillors who vote in favour, will share responsibility for causing the many thousands of climate deaths and air pollution deaths that will very likely result from their decision.

Yours sincerely Dr Henry Adams (Ecological Consultant)

 

Dear Ms Brophy,

http://www.slacc.org.uk

12th March 2019

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Re: Application ref 4/17/9007 by West Cumbria Mining Ltd for Development of an existing surface mine entrance for a new underground metallurgical coal mine and associated surface development including: […] at the former Marchon site (High Road) Whitehaven […] off Mirehouse Road, Pow Beck valley and area from, Marchon Site to St Bees Coast

This letter adds to SLACCtt’s 18/2/18 letter of objection to WCM’s proposal, which is appended here.

Both letters are also separately online, at bit.ly/SLACCttNOtoCOAL1 and bit.ly/SLACCttNOtoCOAL2 in date order.Key additions to 18/2/18 letter: High Court judgement on NPPF and its implications, IPCC SR1.5, WCM

emissions and consequential climate deaths, critique of WCM shipping emissions claims.

1. A High Court judgement last week has in effect made illegal a paragraph in the ‘Oil, gas and coal exploration and extraction’ section of the 2018 NPPF, which has important implications as regards how climate change impacts should be considered as a planning consideration at local government level. We at SLACCtt most strongly advise that this ruling and their implications are given urgent and priority attention by the Planning Officers involved in producing their report to the DevelopmentControl Committee on WCM’s coal mine application.

2. The High Court Judge ruled on 6th March that the Government was acting illegally to ignore recent scientific papers on climate science and fossil fuel extraction, when it copied across a 2015 Written Ministerial Statement into Paragraph 209a of the 2018 Revised NPPF, despite having received a report showing that the 2015 WMS was not scientifically valid. Although Paragraph 209a concerns onshore oiland gas extraction, nonetheless the High Court ruling has wider implications as regards all ‘Oil, gas and coal exploration and extraction’ in chapter 17 on minerals, including Paragraph 211 on coal, and also on government planning policies in general – where fossil fuels and climate change are involved.

3. Put simply, the ruling implies more widely that other paragraphs in the NPPF, and the wider planning structure put in place by central government where it concerns fossil fuels, need to be re-examined and updated with regards recent additions to climate science. The judge also appeared to accept that it is valid for campaigners and local government to treat climate impacts as a planning consideration at a local level (instead of leaving this consideration to central government policy under pressure from above). These 2 points are of vital relevance to WCM’s very high carbon application.

4. It is essential for CumbriaCC to look ahead at such implications regarding future inevitable changes in policy including to the NPPF, to avoid decisions that result in future stranded assets (If WCM’sproject is wrongly given the go-ahead, it will have to be closed down in a few years).

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How does this apply to coal, WCM and CumbriaCC?5. 2018 Revised NPPF: Quotes from p.61:

Oil, gas and coal exploration and extraction

209. Minerals planning authorities should:
a) recognise the benefits of on-shore oil and gas development, including unconventional hydrocarbons, for the security of energy supplies and supporting the transition to a low-carbon economy; and put in place policies to facilitate their exploration and extraction;

211. Planning permission should not be granted for the extraction of coal unless: a) the proposal is environmentally acceptable, or can be made so by planning conditions or obligations; or b) if it is not environmentally acceptable, then it provides national, local or community benefits which clearly outweigh its likely impacts (taking all relevant matters into account, including any residual environmental impacts).

6. So 209.a is now illegal (or at least – the process that put it there). We reckon this should apply in a wider sense also to 211 – which persists with loop-holes for the most climate-damaging (and health- damaging) big fossil fuel. 211 should have banned all coal mining. For advocates of metallurgical coal aka coking coal being an exception – there is no carbon budget scope now for any new coking coal mines in the UK.

7. We have known for years that the NPPF does not accord with climate science as regards the emissions reductions required, and the 2018 Revised NPPF failed to plug the loopholes (Ref:bit.ly/growth-cc-nppf). Furthermore, legislation including even the 2008 Climate Change Act, failed to plug the other over-used loophole that allows fossil fuel advocates (including the UK government) to frequently claim “climate benefits”, or “climate savings”, for fossil fuel projects by confining attention to just UK territorial emissions (as shown by Paragraph 209a), and ignoring additions to global emissions. Claims of “displacing” possibly higher carbon imports actually mean adding to global emissions if the displaced fuel is burnt abroad. Such claims – if they are to comply with climate science, should be considered invalid if they fail also to apply to global emissions (to stop the hypocrisy of“gaming the [international carbon-accounting] system”). WCM provides an example:*

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* 8. The “climate savings” from shipping coal that WCM wishes to divert us to, are only about 1% of the size of its combustion emissions, and are only realizable as regards global emissions reductions if another nation –WCM points to the US – is willing enough to leave in the ground at least 99% of the same quantity of coal that WCM wishes to extract. We doubt if the US would oblige by even 1%!

WCM would be adding its coal and all associated emissions to the global total without any mechanism to ensure any replacement of other coal sources. Increased supply would have an influence towards lowering the global price of coking coal, which would have a detrimental influence on the economics of lower carbon methods of producing steel such as using renewable-powered electric arc with steel from recycling, or new innovative methods under development for iron ore.

My spreadsheet calculations are or soon will be online here: http://www.bit.ly/SLACCttNOtoCOAL5

9. These loopholes have kept the door open to Banks Group to pursue new open-cast mining applications, and WCM the present project. All these coal projects are incompatible with the UK being on track for the 2015 Paris temperature goals, and even more so for keeping below +1.5 degrees, the latter now requiring the world to halve emissions by 2030, which for wealthy countries means the UK being carbon net zero by 2030.

10. Very obviously, the 8 million tonnes of CO2 per year that WCM coal would emit if combusted, canin no way fit with such a rapid and immediate emissions reduction requirement, and that’s beforeadding the significant within-UK upstream emissions from the project, and other GHGs such as methane. Such emissions would be very high in relation to Cumbria’s carbon budget. The emissions would undermine the possibility of Cumbria meeting a 1.5 degrees emissions reduction path, i.e. of reaching net zero carbon by 2030, and thus the aim for Cumbria County Council to declare a Climate Emergency to assist putting those targets in place. Also as Laurie Michaelis points out: “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.”

11. Climate-related deaths equivalent to WCM carbon emissions
I have calculated from WCM production figures that the combustion emissions from the 133 million tonnes of

coal they hope to extract over 50 years to be 400 million tonnes CO2e

Both Laurie Michaelis and SLACCtt (myself) have separately calculated climate deaths from a subset of climate health impacts (from a WHO report) and we produced figures of similar magnitude of thousands of deaths from the subset category alone. It would be significantly higher if other categories of coal-products-related deaths are added. I have calculated a minimum of 1 climate death per year in the subset category from 1 year of WCM emissions. x50x100 gives a minimum of around 5,000+ deaths over 100 years from 50 years mining, which relates to over ten deaths per job. A more-than linear relationship (which is more likely according to LM), could hugely amplify these figures (NB: see LM’s submissions for details as well as what they mean and imply).

This means that Officers writing the report, and Committee members making the final decision – will be deciding the fate of many thousands of lives – and would need to use their own ethical and moral judgements. The High Court ruling means that an equivalent of “just following orders” (which I have seen too much in hearings by other committees) would have even less ethical weight now than before the ruling.

We must no longer discount or externalize impacts outside of application localities in space and over time.My spreadsheet calculations for emissions and deaths are, or soon will be, online here: http://www.bit.ly/SLACCttNOtoCOAL4

12. SLACCtt thus recommends that CumbriaCC now has a legal precedent as well as an ethical and moral duty to regard Paragraph 211 as legally suspect, and in urgent need of updating to accord with up-to-date climate science. This would mean looking forward to how policy including the NPPF will have to change in the future, and assuming that there should be no more coal mining in the UK. Cumbria CC should take into account the following:

13. On 2 May the Committee on Climate Change (CCCuk) will publish it’s “Report: Advice on the UK’slong-term climate change targets: In light of the Paris Agreement, and the IPCC’s recent special reporton global warming of 1.5°C, the Committee on Climate Change will provide new advice to theGovernment and the devolved administrations on the UK’s long-term climate change targets.” If thisreport takes care to avoid loopholes or ambiguities, and has regard for UK impacts on global as well as UK territorial emissions, then it is likely to state or imply that the UK must stop mining for coal, and urge other changes to the NPPF and planning. Please anticipate this.

14. The CCCuk informed Government that its policies are not on track for meeting UK’s carbon budgets over this coming decade. These budgets are to meet the “at least 80% of 1990 levels by 2050”emissions reduction target of the 2008 Climate Change Act. It is important to realize that climatescientists now agree that the “80% by 2050” target is now inadequate to meet its original target of +2 degrees or “a little above 2 degrees”. This means that current government policies head not just

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slightly above 2 degrees, but a lot above 2 degrees, which means that big changes in policies will have to urgently be implemented – and should include the NPPF.

15. The temperature goals of 2015 The Paris Agreement are to keep “the increase in the global average temperature to well below 20C above pre-industrial levels and to pursue efforts to limit the temperature increase to 1.50C above pre-industrial levels”. Government emission reduction policies are thus totally inadequate for the goals the UK signed up to. Furthermore – CCCuk’s remit enshrinedin the 2008CCA have yet to be both updated to comply with the Paris temperature goals. Ref:https://henryadamsblog.wordpress.com/2018/07/02/how-the-ccc-is-not-paris-compliant/

16. The IPCC’s Special Report for 1.5 degrees has shown much more clearly, by assessing the climate impacts at 1.5 degrees and 2 degrees in comparison, that the impacts of 1.5 degrees are bad enough, that 2 degrees is much worse than 1.5, and that the 2 degrees target is now considered much worse than thought in the last decade (except by low-lying/island nations), and that the 1.5 degrees target should be the one to aim for rather than 2 degrees. Yet UK policies are still nearer +3 degrees than 1.5.

17. To stay below 1.5 degrees we need to do more than just greatly change UK policies, and I’vesummarized and collated relevant studies and their implications here: http://www.bit.ly/growth-cc andwww.bit.ly/growth-cc-nppf (on behalf of SLACCtt. Main target readers: local government officers and cllrs).

18. Furthermore, a significant number of climate scientists reckon IPCC’s SR1.5 is over-conservative, gives inadequate consideration of potential climate tipping points in its summary report, and that 1.5 degrees may be exceeded by 2030.

19. I hope by now you are fully convinced that Paragraph 211 should be regarded as incompatible withUK’s climate commitments, and that WCM’s application can be rejected on climate grounds alone (aswell as on other important issues summarized by FoE and other groups).

20. It is heartening to see that Councillors used climate impacts as a planning consideration against the high emissions application by IGas at Ellesmere Port, and climate scientist Professor Kevin Anderson gave evidence on the GHG impact: https://drillordrop.com/2019/01/22/live-news-updates-day-5-of-inquiry- into-igas-test-plans-for-ellesmere-port-well/ Fossil fuel applications must be challenged. The case for doing so is strong, and is now helped by the High Court precedent for challenging the NPPF.

21. As to priorities: It is important to view “jobs and growth” as what is possible within a framework of climate and environment – without going beyond ‘planetary boundaries’ (Kate Raworth 2017‘Doughnut Economics’). Acting on climate will require many jobs (e.g. house insulation).

22. CONCLUDING RECOMMENDATIONS

In light of the above, SLACCtt most strongly recommends that CumbriaCC does not shy from making climate impacts a key planning consideration, and to incorporate up-to-date climate science and itsimplications in both the Planning Officers report for the Committee and the Councillor members’reasons for the final decision. The pro-fossil parts of both NPPF and applications should be challenged.

Yours sincerely,

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Chris Rowley / –

Dr Henry Adams on behalf of SLACCtt

 

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The above includes the first author’s interpretation of how the Judge’s High Court ruling should be regarded – in a way that looks forward in the direction to future such legal steps and policy changes to hopefully follow climate science (and hopefully not too far behind). I have appended copies of write-ups by Leigh Day and others below – so that you can form your own interpretation, which I hope will view the direction of travel that law and planning will have to take to catch up with climate science – and how this will apply to long-term high carbon applications (like that by WCM) that could if not stopped, become stranded assets.

References

I can provide further references for above statements if requested henryadams@dragonfly1.plus.comI have appended a copy of SLACCtt’s first submission to CumbriaCC objecting to WCM’s application.

I most strongly recommend everyone reads the objection letters by Laurie Michaelis – who has had much experience in climate science, and by by Maggie Mason – who has had years of very relevant experience in planning. I also recommend as regards climate impacts letters by FoE and Stuart Parkinson (Director of Scientists for Global Responsibility).

6mar19 Government’s fracking policy ruled unlawful – Leigh Day
The High Court has today ruled that key elements of the government’s national fracking policy are unlawful.https://www.leighday.co.uk/News/2019/March-2019/Governments-fracking-policy-ruled-unlawful

6mar29 TALK FRACKING WIN COURT CASE AS GOVERNMENT’S FRACKING PLANNING POLICY ISDECLARED UNLAWFUL – Claire Stephenson – Talk Frackinghttp://www.talkfracking.org/slider-3/talk-fracking-win-fracking-court-case-against-goverment/

2018 ECONOMIC GROWTH and CLIMATE CHANGE – annex re NPPF
The 2018 revised NPPF and the planning system in relation to ‘economic growth’ and climate change- Dr Henry Adams – draft towards a several-document potential SLACCtt publication, now online atwww.bit.ly/growth-cc-nppf

6mar19 Breaking: Campaigners win court challenge over government support for fracking – RUTH HAYHURST https://drillordrop.com/2019/03/06/breaking-campaigners-win-court-challenge-over-government- support-for-fracking/

6mar19 High court rules government’s fracking guidelines ‘unlawful’ – Court finds government failed to consider scientific evidence against fracking – Fiona Harvey, Environment Correspondenthttps://www.theguardian.com/environment/2019/mar/06/high-court-rules-governments-fracking-guidelines- unlawful

6mar19 Government fracking policy declared unlawful by High Court

‘It is clear what the government must now do, namely hold a full review of its policy support for fracking’- Josh GabbatissScience Correspondent @josh_gabbatiss https://www.independent.co.uk/news/uk/home- news/fracking-policy-high-court-ruling-government-unlawful-housing-energy-a8810101.html

6mar19 Fracking: Government guidance ‘unlawful’ rules High Court – By Dulcie LeeBBC Newshttps://www.bbc.co.uk/news/science-environment-47472732

BBC Northwest Tonight: High Court decision on planning rules for fracking

Kate Raworth (2017) ‘Doughnut Economics’ (book) – summary re climate in http://www.bit.ly/growth-cc

 

FULL LETTER AND FULL REFERENCES CAN BE FOUND HERE

Excellent Letter from Maggie Mason

 

Here is an excellent letter from Mrs Maggie Mason reproduced with her kind permission.

It would be really good if folk could write to Cumbria County Council before 13th March saying that they fully support Mrs Maggie Mason’s letter.  Perhaps making some of your own points too.

Please email: nicola.harrison@cumbria.gov.uk.

 

To:

Mrs Rachel Brophy County Offices Busher Walk Kendal

Cumbria LA9 4RQ

 

Dear Mrs Brophy

 

Planning Application: 4/17/9007 West Cumbria Mining

 

I am writing to express my objection to the West Cumbria Mining’s planning application number 4/17/9007. Having considered the revised submissions I consider that the application should be refused because it does not conform to policies the following policies in Cumbria County Council’s Minerals and Waste Local Plan:

SP1 Presumption in favour of sustainable development

SP13  Climate change mitigation and adaptation

SP14  Economic benefit

SP15  Environmental assets

SP17 Section 106 planning obligations

DC2 General criteria

DC6 Cumulative environmental impacts

DC13 Criteria for energy minerals

DC22 Restoration and aftercare

I note that the Environment Agency, the Coal Authority and the Royal Society for the Protection of Birds continue to maintain that insufficient evidence has been provided to approve this planning application and I hope that the officer’s report will recommend that the Development Control and Regulation Committee refuse the application.

REASONS FOR REFUSAL

I consider that the disbenefits of the development outweigh the benefits, which makes the proposal fail to meet many of the policies above. This is the case whether we take into account just the onshore development (where CCC is the Planning Authority), or the total development including off shore fossil fuel extraction (where the Marine Management Organisation (MMO) is the decision maker).

It is clearly wrong to include benefits of the offshore activity without the adverse impacts.

 

Due to my recent bereavement I cannot fully develop the case I wish to make into formal reasons for refusal on each policy, but I request permission to speak at the planning committee on the 19th March.

The following section explains the three core problems with this proposal as I see them, which cut across all the policies above.

1. This is a proposal for additional fossil fuel extraction at a time when the world faces a totally unprecedented environmental, human catastrophe if urgent action is not taken to leave fossil fuels in the ground.

 

a. Although the development is for coking coal for use in the steel industry, a significant volume of high emissions “middlings” coal will be produced. There can be no watertight, enforceable way of guaranteeing it will only be used in processes which capture the worst emissions from that coal (as per the assurances the applicant has made).

 

b. In any case, the use suggested, is itself a huge contribution to dangerous climate change. The “carbon” assessment assuming that this coal extraction would not be additional to the current US source of coking coal, but that the difference in miles travelled constitutes carbon reduction has been fully considered and minimised is oversimplified and unrealistic . It ignores the reduction in price due to additional supply which will enable more to be sold, and burnt. Hence I consider that a significant proportion of the carbon emissions arising from the coal to be extracted should be included in the carbon assessment.

c. The applicant states that this coal will support the UK steel industry, whose future has now been secured. This is not the case, Port Talbot is supported only until 2022. The European Steel Industry is also under severe threat from China, and the UK. The likely outcome is either: that the demand for this coal will drop sharply, OR that it will be transported longer distances.

 

2. There are significant risks of subsidence offshore, where there are known to be layers of chemical and radioactive pollution on the sea bed. The application addresses this by extracting only a significant distance off shore, and pumping mining waste back into the voids which it is claimed will reduce the subsidence risk.

a. Toxic substances disturbed by subsidence would move freely through the marine environment and there could be no way of preventing adverse impacts in protected areas, and to fish and other marine organisms. One impact which can bring the reality of the risk home to us, is that the percentage of multi-wintering salmon returning to Cumbrian rivers has reduced from 25% to 2-3%. All the rest die at sea. Our river salmon populations are plummeting, and have been described as an extinction event, and it is due to changes in the marine ecology and environment.

 

b. No credible evidence seems to have been offered to the claim that pumping waste back into the mine will reduce subsidence. Pumping waste water back into shale gas wells has been shown to be the main cause of earthquakes in shale producing regions of the world. Inadequate seismicity testing is referred to in the Coal Authority response to the revised EIA, but note that they are only considering the onshore development. It must be even more concerning off shore.

3. It is tempting to think that this development will enable the detoxification and restoration of the Marchon site, that has been a problem for Whitehaven, and Copeland Borough Council for many years. It also appears to bring more jobs and prosperity to the town. However, this is very likely to bring more problems than benefits in the long term.

a. There are jobs during the development phase, but the application emphasises a long term future, with well paid jobs. These are related to the offshore extraction, and should not be weighed in the balance unless the potential, and unknown impacts of the offshore extraction is known.

b. An earlier application/proposal by the same backers but a different company name proposed initial coal extraction, followed by Underground Coal Gasification (UCG). This has never been done successfully in the UK, but is included in the Coal Authority Licence. The dangers of UCG, to both excess fugitive emissions, earthquakes and further subsidence would be controlled by the MMO, with no input from Cumbria County Council, as it could potentially be achieved with a minimal onshore planning permission.

c. It is perhaps more likely that UCG would be refused by the MMO , in which case this mine will close, leaving us with fugitive methane gas emissions (as in the N Cumbria Coal Bed Methane applications) and a restoration problem somewhat like Keekle Head. The finance/ownership of this mine is from Australian and other international mining corporations. S106 agreements or deposited bonds would be very difficult to pursue, and even if funds are allocated, both Scottish and Cumbrian experience shows it is never enough to cover restoration.

Yours sincerely
Mrs Maggie Mason : BA(Arch) Dip TP

Polar Bear Urges Freeze on Coal Mine Plan

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Last Friday 22nd February the Keep Cumbrian Coal in the Hole ‘Polar Bear’ highlighted the Beyond Crazy plan to mine for coal under the Irish Sea.  A photographer from the Whitehaven News met us at the train station in the town to walk up to the Haig Pit.

Everyone in the town we spoke to was opposed to the mine, some of the comments we heard were: “its a backward step”  “its too near Sellafield, too dangerous”.  This was all witnessed by the photographer from the Whitehaven News and shows the distance between the truth and the enthusiastic PR we have seen from West Cumbria Mining and those with an unaccountable (?) vested interest in seeing deep mining become ‘a thing’ once again in West Cumbria.  We also spoke to folk who live opposite the Haig Pit and their view is : “We don’t want it.”

The Whitehaven News reported : “The ‘polar bear’ was actually Sam Morris who, along with Marianne Birkby of the Keep Cumbrian Coal in the Hole campaign, was protesting against West Cumbria Mining’s plans to extract coking coal off the coast of St Bees.

“The pair tore up a copy of the Paris Agreement – a global agreement to tackle climate change – outside the developer’s Whitehaven office.

They believe the application goes against the agreement and Cumbria County Council’s Carbon Reduction Plan and Climate Local programme and that the mine’s proximity to Sellafield would increase the risk of earth tremors. They also claim mining under the Irish Sea could re-suspend radioactive particles from decades of Sellafield reprocessing and argue that there are other ways to produce steel.”

In response to our protest the developers replied to the local press that : 

“The WCM planning submission clearly sets out and responds to all of the questions raised by external parties over the last three years and provides clear scientific evidence based responses to all of these points, clearly demonstrating that there are no risks or significant impacts from the scheme.”   

Really?  The fact that this must be the most deferred planning application to go before Cumbria County Council ever, rather belies this statement.  The reason for the delays are that the Council, and the regulators are not happy with the content of WCM’s application and require further clarification and answers from the developers.

What can be clarified is that this development is Beyond Crazy while the rest of the world looks Beyond Coal.   A recent document handed to Keep Cumbrian Coal in the Hole (below) gives some insight into the climate impacts and the deaths that would result from opening up this deep coal mine.

52611734_2495185493842080_7478466973567811584_n.jpg

Meanwhile, the impacts on Sellafield are of course unquantifiable – an increase in seismicity in the area housing such a vast stockpile of the world’s most dangerous radioactive wastes is unthinkable.

There is a Petition To Sign Here – Please Sign and Share and lets give Cumbria County Council the message that this dangerous coal mine is not wanted

How To Write to Cumbria County Council and tell them to Keep Cumbrian Coal in the Hole

white and black moon with black skies and body of water photography during night time
Irish Sea – the scene of the first deep coal mine in the UK in 30 years?   (Photo by GEORGE DESIPRIS on Pexels.com)

The consultation period ends on January 28th,  Cumbria County Council will still accept letters after this time but the sooner you write the better.

Send your email now to Cumbria County Council at developmentcontrol@cumbria.gov.uk.

Please also ask if you can speak at the meeting on the 22nd February – the more folk who write, speak and make a noise against this plan the better chance we have of stopping it.

Please remember to include the planning application reference number PL\1689\05 (4/17/9007) and your postcode in the subject.

The main points to make are

  • This  coal mine proposal flies in the face of Cumbria County Council’s Carbon Reduction Plan and Climate Local programme.
  • The mine workings would extend to within 8km of Sellafield, this would increase the risk of earth tremors and worse.
  • Collapse of the sea bed as a consequence of mining under the Irish Sea would resuspend radioactive particles from decades of Sellafield reprocessing.

 

Here below is an excellent letter from Sam who is a member of Radiation Free Lakeland.  Feel free to use this as inspiration to write your own letter of objection.  It doesn’t need to be long – just a sentence or a paragraph or two.

To Rachel Brophy, Development Control, Cumbria County Council

Jan 8th 2019

WOODHOUSE COLLIERY, APPLICATION 4/17/9007

In response to the current consultation I wish to make the following comments regarding the revised Environmental Statement from West Cumbria Mining [WCM]. This letter is additional to my submission of Feb 6th 2018.

I am writing to raise serious concerns concerning climate change, subsidence, earth tremors and the potential to trigger a major nuclear emergency at Sellafield.

I wish to OBJECT to the application.

I wish to raise four major grounds on which this application must be firmly rejected.

  1. The 2008 Climate Change Act

The revised Environmental Statement fails completely to address the UK Government’s commitments to carbon reduction within the 2008 Climate Change Act and the increasingly stringent restrictions regarding the extraction and burning of fossil fuels.

WCM state that at full annual production the mine will extract: 2.43 million tonnes of metallurgical coal; 350,000 tonnes of lower grade ‘middlings’ coal; and 150,000 tonnes of rock overburden (reject).    (annually!)

WCM continue to refer to ‘metallurgical’ coal as if this is in no way related to the coal used in energy generation.   The simple facts of physics are that all coal produces CO2 when burned for whatever purpose.

WCM seem to be completely unaware of the global urgency of reducing carbon emissions. The proposal to open a new coal mine in our current precarious climate change situation is completely counter to Government policy.

  1. Subsidence, earth tremors and nuclear accident/emergency.

I have written to The Office for Nuclear Regulation [ONR] regarding the application.   In response to my letter they state –

‘ONR ask to be consulted on developments within the off-site emergency planning area around the Sellafield site, which extends approximately 6.1 – 7.4 km from the site centrepoint (see http://www.onr.org.uk/depz.htm for further details).  We would not expect Cumbria County Council to consult us regarding developments outside this zone, and I can confirm that we have not been consulted.’

map WCm.jpg

This ONR map shows the offsite emergency planning zone around Sellafield.   This shows the area where planning consultation with ONR is required.

The ONR state that Woodhouse Colliery would be approx. 10 km from Sellafield. WCM state the mine would reach within 8km of Sellafield. Which is correct? Surely it is essential to know exactly what the distance may be.

Even more crucially – this is not a mere surface development – the WCM application concerns undersea mining in an area known to be heavily faulted.

The nature of underground earth tremors and minor quakes is that they travel in unpredictable ways through the rock. Earth tremors have no regard for the 7.4 km exclusion zone drawn on the map.

The geology that WCM plans to mine is completely connected to the geology underneath Sellafield. That the mine would be outside the formal ONR planning zone by up to 4km is completely irrelevant given the unpredictable nature of earth movements.

Any earth tremor caused by mining or subsidence would have catastrophic effects in terms of a nuclear emergency bringing massive danger to life over a vast area.

  1. Potential collapse of the mine.

The ONR state – ‘The nature of the proposed mine (pillar and room) is one that is not designed to collapse at any point in the future, unlike for example long wall mining.   Even in the highly unlikely event of a collapse, the nature of any ensuing earth tremors would be limited to very low levels.  These levels would not be felt by persons on the Sellafield site and would not disrupt structures, systems and components important to safety on the site. ‘

This is a very worrying response. Firstly ONR states that they believe that the mine is not designed to collapse – then they state that if it did so it would not affect nuclear safety.

IMG_3707.png

‘Pillar and Room’ mines can and do collapse.

Crandall Canyon Accident Investigation
Summary and Conclusions On August 6, 2007, six miners were killed in a catastrophic coal outburst when roof-supporting pillars failed and violently ejected coal over a half-mile area. Ten days later, two mine employees and an MSHA inspector perished in a coal outburst during rescue efforts.

https://miningawareness.wordpress.com/2018/12/30/murray-energys-crandall-canyon-coal-mine-disaster-9-deaths/?fbclid=IwAR3O7nI2ICJCp9qFoMNvPTF3noiDeGly_rGtL6XaRmsJLVt0gXmEiqCc_BA

In the event of a mine collapse at Woodhouse the potential for injury and death would reach well beyond the mine shaft itself. Radioactive accidents at Sellafield could affect much of the UK and neighbouring nations.

There is a major inconsistency here as the ONR believe the mining process to be ‘pillar and room’ while the WCM website states –

‘Run-out and Pocket extraction will be the chosen mining method as this is a proven, highly versatile coal mining method that takes advantage of advancements in mining technology to mitigate risks associated with the Cumbrian Coal fields.’

How can this application possibly be agreed given that WCM and the ONR are clearly not operating on the same basis regarding the basic mining method and associated risks?

It is telling that WCM themselves are acknowledging the very real risks of the Cumbrian coal fields and are seeking to ‘mitigate’ them.

This is a glaring inconsistency and indicative of the wrong footed nature of this entire application.

What Nuclear Emergency Plans are in place by the County Council should tremors damage the containment vessels at Sellafield?

  1. Formal assessments of likely subsidence damage have proved to be very wrong

There are big lessons to be learned from the fracking industry at home and abroad.

Groningen in the Netherlands is Europe’s biggest gas field. The Netherlands Government has recently decided to close it down leaving billions of euros of gas in the ground. So far 80,000 homes have been damaged, families are living in sheds and schools are closed.

In the UK the Governments Oil and Gas Authority [OGA] has allowed fracking in Lancashire to proceed with the ‘traffic light’ system of monitoring tremors. Since fracking recommenced in autumn 2018 there have been over 30 Lancashire quakes recorded by the British Geological Society.     Many of these quakes causing shut down of production.   The UK OGA has said – ‘it is rare for damages, even cosmetic ones, to occur at magnitudes of less than 4.’

The truly frightening aspect of this is that ALL of the Groningen quakes measured less than 4. The Netherlands Government had insisted that they were harmless, yet the damage stands at 8 billion euros so far and the closure of the industry.

Groningen had few geological faults or earth tremors before the extraction began.   West Cumbria has a history of both faults and of tremors.

https://www.channel4.com/news/why-the-dutch-are-ditching-gas-extraction

 

CONCLUSION

The nature of subsidence and earth tremors is by nature unpredictable.

What is certain is that this constitutes a very real potential.

The damage caused in the Netherlands by allegedly ‘safe’ levels of tremor would result in radioactive mayhem were such tremors to occur in West Cumbria where we have Europe’s largest collection of deadly nuclear waste.

This potential risk of a nuclear accident/emergency is simply too great a risk.

There is no way that Cumbria County Council can possibly assure the public safety of this proposed mine and the application must be firmly rejected.

 

Sam Moisha

Member of Radiation Free Lakeland

STOP PRESS – COAL MINE PLANNING DECISION DELAYED AGAIN! TILL AUTUMN

Sellafield from St Bees

St Bees looking across to Sellafield

We have just heard that the planning meeting for the first deep coal mine in the UK  that was due to be heard on August 23rd in Kendal has been delayed yet again.

We have lost count of the deferments – it must be some kind of record.  We have to ask why hasn’t this dangerous mad bad plan been knocked on the head already?  Is it to embed West Cumbria Mining into Cumbrian society with its largesse and promises of jobs?   It it to soften West Cumbria up for deep mining of an altogether different plan, concerning nuclear wastes?  That may be way off course but it is a thought that has crossed many a Cumbrian mind.

So the new date – as far as we know is the autumn.

We shall continue to fight this plan and welcome all hands to the deck until the plan for the first deep coal mine in the UK in 30 years is stopped once and for all.