WWF ASKS FOR ‘CALL IN’ – GREAT NEWS!

Sellafield from St Bees
Sellafield – spitting distance from the proposed coal mine off St Bees  Head  (where the sheep are)

 

The World Wide Fund for Nature has asked for a “call in” of the planning decision due to be taken by Cumbria County Council.

This is Great News!

We shall also continue our  lobbying of the Secretary of State to intervene and stop  the plan for the first deep coal mine in the UK in decades.

The full “call in” letter from WWF can be read below.  It is very good but there is no reference at all to the close proximity of Sellafield, a burning but neglected issue which we at Keep Cumbrian Coal in the Hole will continue to flag up.

Rt Hon. Robert Jenrick MP
Secretary of State
Department for Communities and Local Government 2 Marsham Street
London
SW1P 4DF

Dear Secretary of State,

19th June, 2020

APPLICATION REFERENCE NUMBER 4/17/9007 – WEST CUMBRIA MINING

WWF-UK wrote to you in July 2019 to ask you to call in the previous application madeby West Cumbria Mining, which was approved by Cumbria County Council’sDevelopment Control and Regulation Committee; you declined to do so. The county council decided to grant planning permission and local campaigners commenced judicial review proceedings.

Following the grant of permission to proceed with the challenge, the developer filed an amended planning application to develop the coal mine. However, we consider the case for you to call in this application is strong, particularly in light of events occurring since we wrote to you last summer, and some of the information submitted by the developer in support of the amended application.

Caborn criteria
We consider that at least two of the Caborn criteria for call-in are met in this case. The first is that the proposal conflicts with national policy on important matters – in particular policy on mitigating climate change, the presumption against coal extraction in para. 211 of the National Planning Policy Framework, and duties to reduce CO2emissions under the Climate Change Act 2008 and under international law by the Paris Agreement. As we set out in our correspondence of last year, the development is in breach of policy adding to the global coal stock, assumes a long-term reliance on coking coal that is contrary to the trajectory indicated by UK and EU climate policy and legislation (informed by the Paris Agreement) and seeks to put in place new, long-term and environmentally invasive infrastructure.

Second, and again as per our letter last year, the proposal gives rise to national controversy; our previous letter provides evidence of this. Since our last letter, the application has been subject to judicial review proceedings and a wide cross section of groups have spoken out against it, including local campaigners, national NGOs (e.g.

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Green Alliance, WWF) and independent academics (e.g. Professor Ekin).

You will be aware that the application by Banks Mining for an open-cast coal mine at Highthorn, Northumbria was called in and remains undetermined. So far as administrative law imposes a duty to treat like cases alike, WWF suggests you must give careful consideration to treating Woodhouse Colliery in like manner, calling it in.

Detail
We see nothing in the revised planning application that negates our original three grounds for objecting to the proposed project (set out in more detail in our letter to you of 15th July, 2019). These are set out (in summary) below together with a number of new points in response to the amended application.

  • That government is committed to a net-zero greenhouse gas emissions target by 2050, under the Climate Change Act 2008 – a decision that theCommittee on Climate Change is clear “must be embedded and integratedacross all departments, at all levels of government, and in all major decisionsthat impact on emissions.” The iron and steel industries – the customers for coking coal produced from this proposed mine – are no exception to this.
  • The declining need for coal production of this nature over the short-term and over the 50-year proposed lifespan of the project, and the impact on greenhouse gas emissions of extracting it – in short, whether the benefits from the project outweigh its likely environmental impacts. The previous caseconcluded that industry’s need for metallurgical coal outweighed theenvironmental impacts, but with no sound evidence that coal from this proposed colliery would replace, rather than supplement, existing supplies, whether in the UK or in other markets.
  • The impact on the rights of children and future generations. A mine would generate significant carbon emissions over the course of the next 50 years and for at least 20 years after the UK is required to meet its net zero greenhouse gas emissions target in 2050. The consequences of those emissions (eg: in terms of their contribution to global heating) and the responsibility to offset them to meet the new 2050 target will fall disproportionately on the young, impacting on their human rights – including Article 8 of the European Convention of Human Rights in a manner which we believe cannot be justified at a time of climate crisis. The mine is also liable to generate significant air quality impacts and it is well established that air pollution disproportionately affects the young because their lungs are still developing1. As set out previously, the UN Convention on the Rights of the Child applies here (because the ECHR is in play) and requires decision makers to ensure that the best interests of children are a primary consideration and that the impacts of the decision on children are assessed and taken into account. There is no evidence that such an assessment has been undertaken in relation to the amended application, hence the flaw identified previously remains.New grounds

• Global footprint – the developer has failed to assess the carbon impacts of

use of the coal in steel foundries overseas. WWF considers that the exported

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emissions (must be assessed pursuant to the council’s duty to take account ofthe Paris Agreement following important new case law (Friends of the Earth v Secretary of State for Transport). Paris provides a temperature limit which is the shared responsibility of states to achieve. It is therefore unsustainable not to take into account the emissions arising abroad as a result of activities within the UK when the duty to achieve the temperature limits in the Paris Agreement are imposed collectively on all states. Further, WWF argues that thedeveloper’s approach either fails to comply with the EIA Directive or fails to enable the planning authority to take account of material consideration by failing to assess the likely scale of the impact of burning the coal abroad.

• High carbon development – the developer has wrongly categorised thedevelopment as “low carbon” because it has failed to assess the exported emissions as aforesaid. No consideration has been given to the likelihood that coal which may be edged out of use in European steel works by coal produced from the development would be burnt regardless leading to an overall increase in global greenhouse gas emissions. This fact flows both from the laxity of current commitments made by states under the Paris Agreement by way of Nationally Determined Contributions to date2 and the failure of many states (including the UK) to prohibit exported emissions in domestic legislation. Nor can the section 106 agreement proposed by the developer (to assess every 5 years whether the development continues to comply with carbon budgets) remedy the problem because carbon budgets do not build in exported emissions either. Far from being low carbon, the development is arguably high carbon, will add significantly to the emission of greenhouse gases (understood in a broader sense) and therefore conflicts with NPPF para 211. It must be called in.

• Net Zero – the net zero target was adopted before the original planning application was resolved to be granted by the County council. However, there is a suggestion in the amended planning application that this is not for the planning authority to take account of (because the duty in the Climate Change Act fastens on the Secretary of State). WWF is confident that the Secretary of State does not take such a view and he agrees with us that the target is a material consideration for the purposes of section 70 of the Town and Country Planning Act 1990. . However, to ensure the planning authority does not fall into error, WWF considers the safest route would be for the Secretary of State to call in.

  • Carbon plan – no consideration has been given to the fact that government has yet to adopt a carbon plan which sets out how the net-zero target will be met –nor has it yet explained how it will bring itself into compliance with carbon budgets from the mid-2020s onwards. By granting planning permission at this point for such a long-term, high carbon development, the council risks locking in high carbon infrastructure for many decades to come thereby pre-emptingimportant decisions about the UK’s pathway to net-zero which are pre- eminently for ministers to take. A decision to grant would be premature at this stage.
  • Equality – the council is subject to a duty in domestic law to have regard to the need to advance equality of opportunity as between people who have protected characteristics and those who do not (section 149 Equality Act 2010). As set

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out above, the development will impact disproportionately on the young yet no Public Sector Equality Duty assessment appears to have been undertaken. Should the failure continue, it leaves the application vulnerable to challenge.

We cannot decarbonise our economy at the speed and depth required to avert catastrophic impacts of climate change by substituting one source of fossil fuels for another.

WWF-UK has modelled an emissions reduction scenario for the UK to 2045 and to 2050 in a report with Vivid Economics, entitled Keeping It Cool3. This demonstrates the degree of decarbonisation needed in each sector, as well as the overall pathway. This makes clear that we will not need metallurgical coal for the next 45-50 years that this mine will be producing it. We do not need a new source of metallurgical coal in the short-term and it is spurious to argue that the emissions from this coal will be slightly lower than existing sources, when to achieve this would (a) add to the existing stock of metallurgical coal in the marketplace overall, (b) do so for far longer than any country can be relying on fossil fuels, and (c) do so in a way that generates new emissions from the construction, running and transport out of the country of the coal produced at the mine. It is clear that the need case in respect of the application is simply not made out.

Keeping global warming to 1.5°C requires that we stop using coal, as soon as possible, both for power generation and industry. Modelling by a group of 20 researchers indicates that keeping to 1.5°C without geoengineering requires the virtually complete elimination of fossil fuel emissions and fossil fuel infrastructure by 2050 and that global coal production must decline by 5886 million tonnes a year in 2015 to only 407 tonnes in 2050 – a reduction of around 93%4.

Given this and given the UK’s avowed global leadership on climate change – not least as holders next year of the presidency of the crucial UNFCCC Conference of the Parties (COP) 26 – allowing new coal production on its own shores would be perverse. Not only does it send a particularly unwelcome signal to the wider world about its commitment to climate action, but it adds to the already daunting scale of decarbonisation that would be required in other sectors in order to make net-zero possible by 2050.

Additionally, it continues to pile the costs of delayed climate action, and of climate impacts, onto children and future generations.

This is most definitely a consideration for national government (owners of the legally- binding target for net-zero by 2050), for local government (who cannot simply abrogate their responsibility for additional emissions from projects such as these on the basis that they are but one small contributor), and for local people (who will bear the costs of growing climate impacts).

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

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

GARETH REDMOND-KING Head of Climate Change

 

STOP THE COAL MINE IN CUMBRIA -PETITION

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

STOP THE COAL MINE

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Nearly 4000 people, including Chris Packham have signed the petition to Stop the Coal Mine in Cumbria – Please keep sharing and signing.  As well as signing the petition – People can STILL WRITE individual letters to Cumbria County Councillors who will be making the decision on this to let them know STOP THE COAL MINE!

The main points to make are that this mine would fly in the face of the Council’s own climate commitments and its own stated commitments to protect the health, safety (this is 8km from Sellafield) and well being of all Cumbrians. Send an email to development.control@cumbria.gov.uk –or if you have time to all the Development Control and Regulation Committee members  quoting the application reference number 4/17/9007 and including your name and address.

 

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

Yesterday was the last ‘official’ date to send in objections to the new ‘amended’ planning application.  You can still send in letters of objection up to the Planning Meeting which is scheduled for the 8th July (if this goes by previous form the meeting will be rescheduled again and again).  Please do send in letters to members of the planning committee. (They have voted yes to this diabolic plan twice before,).

This is the Keep Cumbrian Coal in the Hole objection …

                                          15th June 2020

West Cumbria Mining: Planning Application Ref 4/17/9007: 

Woodhouse Colliery, High Road, Whitehaven

Dear Development Control and Regulation Committee,

I write on behalf of Keep Cumbrian Coal in the Hole, a campaign by Radiation Free Lakeland to ask that the County Council do not approve this amended planning application

We are a civil society group that aims to remove the risk of environmental damage both nationally and internationally that may arise from the presence of an extensive nuclear industry close (to the Lake District National Park, a World Heritage Site). 

On 19th March Cumbria County Council (CCC) granted conditional planning permission for a resumption of the long abandoned onshore coal mining at St Bees to West Cumbria Mining Limited (WCM). This would be followed by the ‘profit making’ offshore phase.   On 20 June 2019, our lawyers Leigh Day wrote to Cumbria County Council. The letter addressed a number of legal issues, including Cumbria County Council’s failures to consider:

  • Greenhouse gas (GHG) emissions of the mining operations
  • The need for, and GHG impacts of, Middlings Coal
  • The Government’s Net Zero target.

Despite being alerted to those concerns, Cumbria County Council ratified its decision on 31 October 2019. Mrs Justice Beverley Lang agreed that those legal issues  we raised were arguable and justified a public hearing.

In order it seems to circumvent the scrutiny afforded by Judicial Review and the criticisms levelled in the Green Alliance report the Developers have now submitted a new planning application.  This is despite the  CEO of West Cumbria Mining publicly stating that : “If you asked me to get planning for another one, I would say it would be impossible right now unless something significantly changed,”  Mark Kirkbride, British Tunnelling Society lecture reported in New Civil Engineer 26th February 2020    

The CEO of West Cumbria Mining went on to say:

“When we applied for planning it was a different set of planning rules. Now if you were to submit planning you’d have to try and do whole life greenhouse gas assessments.”  Given that steel can and should be produced without the use of coking coal – the additional GHG emissions arising from the use of coking coal from this mine to make steel should be taken into account . 

The amended planning application while attemping to address the original challenges we raised has compounded our concerns about the cumulative impacts of this mine. Regarding climate The use of coal from this mine will undermine the government’s net zero target, carbon budgets and policy to adhere to the Paris Agreement. 

NEW PROCESS TO TURN THERMAL/MIDDLINGS COAL INTO COKING COAL

The original big selling point of this mine proposal was that it would produce “premium” quality coking coal. In order to answer legitimate criticisms on the previous ‘by-product’ of middlings, the developers propose now to turn the 15% (or more) by-product of middlings/thermal coal into coking coal.  The details on this are sketchy. WCM say that in order to turn the thermal coal to coking coal there will be an additional process to enhance separation and removal of pyritic sulphur matter but then go on to claim optimistically that: 

“ Since this adjustment relates only to the internal process …. and no difference to external appearance …. it is not considered that it will give rise to any material effects of the proposal.”   This is clearly impossible – the removal of pyritic sulphur and the myriad other polluting imupurites from the middlings would leave an additional and unaddressed toxic footprint.  There would also be additional energy and freshwater usage.   In order to address the issue of the new and inferior quality of product, West Cumbria Mining propose a relaxation of the conditions that determine the specification for metallurgical coal.  The developer justifies a relaxation on the grounds that the original specification does not reflect the (now inferior) product that will be the final output from the Woodhouse Colliery, specifically with regard to ash and sulphur content.  WCM are also asking for removal of the condition that the product must be used only for steelmaking.  This is entirely understandable as once exported, WCM have no way of ensuring their coal is used solely for steel making (despite their considerable PR in this regard). 

METHANE

The WCM report by Dr Neil Bristow says that “WCM is committed and obliged to install a methane capture and drainage system. …It will be put to use as an energy source of the mine with no atmospheric impact.”    This disingenously suggests the impossible namely that 100% of the methane emitted by the mine (continuously by the exposed and broken coal) would be “used” …”with no atmospheric impact.” In the first two decades after its release, methane is 84 times more potent than carbon dioxide Overall it is roughly 30 times more potent than CO2 as a GHG.   WCM propose to build the methane capture plant by year 5.  Calculations have been done independently which suggest that “ 13.9MCu m of methane could be produced and if the Capture system is not operational by then (year 5) it is possible that 38.75M cu m will be released before then. That is an equivalent effect on the atmosphere of 856486 T of Co2.  From year 5 the Methane capture plant will need to capture about 13.9Mcu m per year if there is to be ‘no atmospheric impact’. Where will it be stored? To put this volume into context the old style town gasometers held about 50000cu m. So WCM are planning to capture and store the equivalent of 5.3 gasometers per week, every week!!!   This is a substantive GHG impact on which the council needs information.

POLICY DC20 THE WATER ENVIRONMENT

Cumbria County Council’s Policy DC20 states “Proposals for developments should demonstrate that they would have no unacceptable quantitative or qualitative adverse effects on the water environment, both within the application site and its surroundings, including surface waters, coastal waters, private water supplies and groundwater resources. Proposals that minimise water use and include sustainable water management will be favoured.” 

FRESH WATER

Despite requests to them for information by us and other NGOs, West Cumbria Mining have not demonstrated what the impact on ground water will be.  There is no information in the public domain regarding the projected quantity of freshwater abstraction from the Byerstead Fault or potential hydrological impact.   This is an important issue in West Cumbria which is already suffering from fresh water stress.   WCM again use disingenous language to suggest that virtually all freshwater would be recycled suggesting that there would be minimal abstraction.  There is no indication of exactly how much water WCM expect to abstract per day from the Byerstead Fault – a named geological fault.  The Marine Conservation Zone documentation describes it thus.. “This site lies within the boundary of the rMCZ11 and is situated in Saltom Bay on the Cumbrian coast north of St Bees Head. The site includes an area known locally as Byerstead Fault, a recovering intertidal zone that is showing a return of species diversity..

“Water is heavily used in coal processing and would be obtained from the following sources: Groundwater (Byerstead Fault) “   

WCM presentation to CCC 19th March 2019

Cumbria County Council’s Minerals and Waste Local Plan states:

  • “16.36  Proposals will, therefore, be required to demonstrate that they do not have unacceptable adverse impacts on water resources. Any adverse impact should be avoided or, if unavoidable, suitable mitigation measures should be proposed. Unacceptable quantitative or qualitative impacts are those which are deemed so by the Environment Agency, as part of the planning application process.
  • 16.37  Sites proposed for development will need to be subject to site specific hydro- geological assessment, in order to determine their acceptability. Some factors influencing this process are the type of facility, the pollution control measures adopted, the potential impacts on groundwater resources and the groundwater vulnerability of the site.
  • 16.38  With respect to mineral applications, there is a requirement to establish the relationship that the development has with the water table. If the base of the excavation is near or below the anticipated water table, then there will be a requirement to establish an appropriate monitoring scheme. In some circumstances, the development may be considered unacceptable if it is carried out below the level of the water table”. 

Not only will WCM be abstracting fresh water from the Byerstead Fault but the development is in the region of the West Cumbria Aquifer – a water resource that is currently used to provide fresh water for much of West Cumbria.  A region that is heavily faulted and complex.

WCM have revealed so litte detail about their fresh water usage that there can be no proper scrutiny or oversight by Cumbria County Council or the public.
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Aquifer beneath West Cumbria in the vicinity of WCM proposal

Image: BGS

 

 

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

The amended planning application gives no idea of exactly how much water  would be abstracted from the Byerstead Fault (see above) at peak production of the mine – or of the damage likely to be caused by this abstraction

HAZARDOUS INSTALLATIONS – COAL AND NUCLEAR WASTE AT SELLAFIELD (and DRIGG)

When preparing Local Plans, local planning authorities are required to have regard to the prevention of major accidents and limiting their consequences. They must also consider the long-term need for appropriate distances between hazardous establishments and population or environmentally sensitive areas. They must also consider whether additional measures for existing establishments are required so that risks to people in the area are not increased.

Cumbria County Council are no exception and the Minerals and Waste Local Plan states that:

  • 5.102. “Permission should not be given for the extraction of coal unless the proposal is environmentally acceptable, or can be made so by planning conditions or obligations; or if not, it provides national, local or community benefits which clearly outweigh the likely impacts to justify the grant of planning permission”. 

and…

13.23  In some cases, a proposed development may itself have multiple environmental impacts that would be acceptable on their own, but which may exacerbate adverse impacts caused by other developments. Such cumulative environmental impacts can derive either from a number of developments with similar impacts being operational at the same time in an area, or from a number of concurrent developments in an area with different impacts or from a succession of similar developments over time. They can include the impacts of noise or traffic, and impacts on local communities, the landscape, water resources or wildlife habitats.

  • 13.24  Local Plan policy needs to take account of the extent to which a particular locality, community, environment or wider area can reasonably be expected to tolerate such adverse cumulative impacts. This may involve mitigation of impacts or the timing of permissions and phasing of operations to make a proposal acceptable. Where cumulative impact presents a potential issue, applicants should be able to demonstrate that this has been adequately assessed and addressed in a planning application.

The Office for Nuclear Regulation’s official remit to consult on planning applications is 7.4 km from Sellafield. The coal mine extends to 8km from Sellafield i.e. 600 metres difference. In the absence of any detailed regard to cumulative impacts by either the developers or Cumbria County Council or the regulators we have commissioned a Briefing Paper on the radiological implications of West Cumbria Mining’s plan.

The author of the paper, Tim Deere-Jones is an Independent & non-aligned Marine Pollution Researcher & Consultant whose clients include: WWF, The UK Wildlife Trusts, European Climate Foundation, Greenpeace International, European Coastal Local Authorities and many others.

This comprehensive report concludes that the plan by West Cumbria Mining should be abandoned.

The introduction and Major Conclusions are reproduced below…..

Introduction:                                                                                                                                                        This Briefing offers a review of the possible seabed morphological changes and marine pollution implications of the sub-sea coal mining venture proposed by West Cumbria Mining (WCM) at their Woodhouse Colliery site near St Bees Head.

WCM have designated and identified a sub-sea mining zone of the Irish Sea lying to the west of St Bees Head and extending at least 8kms offshore and southwards to within about 8km of the Sellafield site.

The WCM extraction proposals, using continuous mining methods, predict the extraction of approximately 3 million tonnes of coal per year over a 50 year period. This extraction rate will eventually generate a huge subterranean void space of approximately 136 million cubic metres (a volume greater than that of Wastwater Lake).

This briefing considers the impact of the creation of such a sub-sea void space on the possibility of sea bed subsidence in the area of the WCM designated sub-sea mining zone, and the subsequent potential for marine radiological pollution as a result of the subsidence induced re-suspension of the heavily radioactively contaminated sea bed sediments of the Cumbrian Mud Patch and surrounding sea bed areas.

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

Major Conclusions

It is noted that there is a lack of data about the status of the existing historical galleries and workings of the West Cumbrian Coalfield. 

It is noted that there is a lack of accurate data about the history and status of any subsidence seismicity in the coalfield.  

It is noted that the BGS have concluded that the coalfield is heavily faulted and has a long history of subsidence and that it appears that there are no plans to monitor for any subsidence prior to, during the operational phase or in the post operational phase of the Woodhouse Colliery.  

It is noted that sub-sea monitoring equipment is available and could be deployed in the region in order to monitor for any subsidence effects arising as a result of the proposed Woodhouse Colliery “mass removal” extraction.

It is concluded that there is a real potential for subsidence to occur as a result of the “mass removal” and the creation of extensive sub-sea void spaces, and it is noted that such subsidence could generate earthquake and liquefaction effects which may extend onshore as far as the Sellafield/Moorside sites.

It is concluded that any seabed subsidence in the WCM designated sub-sea mining zone would generate re-suspension of Cumbrian Mud Patch heavily radioactive seabed sediments. It is noted that such an event would generate elevated doses of man-made radioactivity to coastal zone populations and sea users along both the Cumbrian coast and at “downstream” regions further afield.

Given the potential for such a radiological effect and the delivery of increased doses of radioactivity to relevant coastal zone communities, some of which have already been identified by the authorities as Coastal Critical Groups, the Woodhouse Colliery proposal (especially in the absence of any precautionary mandatory subsidence monitoring) is strongly contra-indicated and should be abandoned”

The full report is attached as a pdf

CONCLUSION

The weight of evidence is overwhelmingly clear that this application should be unequivocally refused.  We urge Cumbria County Council to take eagerly with both hands this new opportunity, via the amended planning application, to turn down this dangerous coal mine plan, for Whitehaven, for Cumbria, and for the Planet.  

 

Refs:

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

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

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

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

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

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

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

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

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

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

Support our Legal Fight Against a New Coal Mine in Cumbria

SUPPORT OUR LEGAL FIGHT AGAINST A NEW COAL MINE IN CUMBRIA

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Keep Cumbrian Coal in the Hole – demonstration back in 2017

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Many groups including KCCH and individuals demonstrating outside Cumbria County Council offices on the day of ratification 31st October 2019

NEW – LEGAL CHALLENGE – We need your help. 

Check out the CrowdJustice page here – we have donated £50 already but- we need £5000 to take forward the Legal Challenge.  If you cannot donate then please do share and get the message out that this fight against the first deep coal mine in the UK in decades is far from over.

Thank you to Lawyers Leigh Day who have already put so much work into paving the way and ensuring a legal challenge is possible.

UPDATE: What a rollercoaster!  Firstly on 31st October we had an amazing demonstration of opposition outside Cumbria County Council offices with many groups and individuals taking part to show the strength of feeling against this coal mine.  This was despite the fact that we only found out last minute by accident about the ‘ratification’ meeting for the first deep coal mine in the UK in decades.  As you will have heard the committee again voted unanimously to pass the plans…shocking!  Then on the same day as the much publicised announcement on the halt to fracking there was a much more subdued announcement that the Secretary of State will not call in Cumbria County Council’s outrageous decision on the coal mine for a public inquiry.

Thank you so much for the donations so many of you have already made for the initial advice from top lawyers Leigh Day.  This has been of such enormous value and has paved the way for a legal challenge so we can continue to fight this terrible plan..

A new crowd justice fundraiser is now live and can be found here.  We now need to up the ante and raise enough funds to cover the costs of a full legal challenge. We can’t do it without your help.  If you can share the page or donate no matter how small the donation then please do.

If this coal mine is not stopped the carbon emissions alone would be likely to result over its lifetime to one full year of UK national emissions.  This is crazy given that the UK government has declared a climate emergency.

Not only would this coal mine produce 9 million tonnes of CO2 emissions every year (not including methane, radon etc)  but the plan is to extend mining activity under the Irish Sea to within 5 miles of Sellafield.

The results of induced seismic events of any magnitude at the worlds riskiest nuclear waste site could be catastrophic on a planetary scale.

There are so many reasons to oppose this coal mine plan from climate catastrophe to nuclear catastrophe.  That is why we are  campaigning hard to stop the plan.

Please check out the CrowdJustice Page  and PLEASE continue to Keep Cumbrian Coal in the Hole!   All donations made will go direct to the legal challenge!

With Many Thanks!!!

Marianne

Keep Cumbrian Coal in the Hole – a Radiation Free Lakeland campaign

New Partner – Javelin Global Commodities “aims to ramp up its coal trading”

This is PLANNED Under the Irish Sea just five miles from Sellafield – what could go wrong? We need to STOP THIS! 

New partner for West Cumbria Mining. London-based Javelin launched in 2015 and is 34 percent owned by U.S. coal miner Murray Energy, 28 percent owned by German utility E.ON and 38 percent owned by its principal traders, some of whom were previously at Goldman Sachs…
WCM have just published this here:
“West Cumbria Mining is pleased to announce that it has entered into an exclusive marketing and offtake agreement with Javelin Global Commodities.

This agreement represents a major milestone in the development of WCM’s flagship Woodhouse Colliery project and is a key step towards a world class underground metallurgical coal mine. It also demonstrates the confidence that Javelin has in a premium UK source of steelmaking coal and the long-term market demand for this sector critical product.

The agreement will see Javelin purchasing 100% of WCM’s production output and selling this to steelmaking customers in the UK and Europe, on terms which will reduce the payment time for coal deliveries from weeks to days. The structure will free up several million pounds of working capital facility on WCM’s balance sheet, providing significant assistance during the early years of the mine’s production.

West Cumbria Mining CEO, Mark Kirkbride, commented; ‘I am delighted to be able to announce this exclusive agreement with Javelin, following on from extensive dialogue and a very clear joint objective to ensure that Cumbrian steelmaking coal is supplied into the UK and European steel industry via a world class, highly respected specialist commodity trader. This is a key step for the project, and my team and I are looking forward to working collaboratively with Javelin to demonstrate real value and innovation to our customers.’

Peter Bradley, CEO of Javelin Global Commodities, (formerly MD of Goldman Sachs) commented; ‘Javelin is very pleased to be partnering with such an outstanding mining project and with a group of management and investors that have a history of delivering world class mining operations.

I am particularly excited to introduce this strong steel making coal to the domestic UK and European export markets at a time where competitively priced feedstock is needed to support the industry in its efforts to compete with low cost imports of steel. I am confident the project will get the final funding it needs, and Javelin looks forward to supporting West Cumbria throughout the development.”

SUPERFICIALLY this is being given a most shiny PR SPIN.   But there is a lot for sceptics to take notice of.
One of our Keep Cumbrian Coal in the Hole colleagues has made the observations that:
“Firstly, Javelin has been going less time than WCM has.  Founded in 2015 it has a complex control and accounting structure but it is essentially a couple of city blokes backed by a German finance company and a US coal company.  Secondly, you can see from both Kirkbride’s and Bradley’s comments that they are having difficulties getting funding and for why that might be you only need to research Sirius Mineralsover in the NYMNP.  Thirdly, Javelin has picked bad’uns before, see here.  Finally, Murray Energy, the coal company, are the main backers of Javelin and they are in deep trouble.  All in all they can spin it up but this looks like desperation from both of them.”

Nightmare Coal Mine Near Sellafield – Ooops don’t mention Sellafield.

Many thanks to Real Media for posting a guest blog – the background story and info about the coal mine fiasco that you won’t see in the main stream media.  There is an updated version below…

 

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NIGHTMARE COAL MINE NEAR SELLAFIELD?
WHAT CAN WE DO ?

NIGHTMARE
Like one of those nasty nightmares that pulls the dreamer to an inevitable conclusion it is shocking that on March 19th in Kendal, Cumbria County Council approved the plan for the first deep coal mine in the UK in decades. Nevertheless it is rather suspicious that the Committee voted unanimously to give the green light to the diabolic plan. But then, there were no background noises of dissent in the years ahead of the planning decision that might have made the Committee think twice. Quite the opposite. There was almost universal silence from the national media.

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Protest staged by Keep Cumbrian Coal in the Hole after the Unanimous vote by the Development Control and Regulation Committee of Cumbria County Council on 19th March.  Photo credit: Philip Gilligan South Lakeland  CND

Silence, apart that is, from the occasional coverage which seemed to
come direct from the developer’s press releases. There were no outraged editorials or national campaigns by big NGOs. No mention from climate guru George Monbiot. This is despite the fact that the obscene coal mine plan was rumbling nightmarishly along for so many years. Only the blogosphere was raising the alarm. Including a very strong and early shout out from Jonathon Porritt.
SO DAMN NEAR SELLAFIELD
Radiation Free Lakeland are a civil society group concerned with nuclear safety. We started a dedicated campaign in 2017 to Keep Cumbrian Coal in the Hole because we could see that this plan was going massively under the radar and because it is so damn near Sellafield’s growing stockpiles of highly active and uniquely dangerous radioactive wastes. Our frustrations grew about the coal mine and the big silence from big hitters. As a voluntary group our public reach is small. We witnessed the aggressive PR and lobbying campaign by the developers. This lobbying by the developers included winning the hearts and minds of Green minded folk  MPs and Government Departments with the hugely deceitful mantra of we ‘need a massive new coking coal mine to make the steel for wind turbines’ and presenting to the public a homey image of West Cumbria Mining despite the major shareholder being a Cayman Island fund controlled via Singapore by managers based in Australia and HongKong. For ourselves we had a premonition about the way this was going and crowdfunded to enable us to continue to fight the plan with a Judicial Review should Cumbria County Council be led down the enticing garden path to the coal mine.
At the 11th hour it was such a relief to see some big hitters publicly putting their shoulders to the wheel to stop the mine. This included Scientists for Global Responsibility whose Director Dr Stuart Parkinson spoke at the Planning Meeting saying : “I have calculated that during the main production phase the mine would lead to emissions of over 9 million tonnes of carbon dioxide equivalent for every year it is in operation. This amount is similar to the annual emissions of over 1 million British citizens. ”

And Dr Laurie Michaelis who has “worked on climate-related issues for thirty five years, been a lead author for reports of the UN’s Intergovernmental Panel on Climate Change – the IPCC – and provided technology policy advice for the UK government, European Commission and UN climate negotiators.” Dr Michaelis went on to say that: “Speaking to you feels like possibly the single most important thing I’ll do in my life….Your officers have not obtained suitable expert advice to correct the misinformation…When coal is used to make steel, 99% of the carbon content ends up as CO2 in the atmosphere….Thousands could die early because of heatwaves, disease and other causes. You will share responsibility with WCM, steel manufacturers and final users. If you refuse, coal might be sourced elsewhere; that’s the kind of argument people often use to justify wrongdoing. You can prevent this coal from being used.”

While we have as a group been lobbying climate activists for years now to actively oppose the coal mine, we have also been campaigning on the uniquely dangerous environmental impacts of this coal mine. The close proximity to Sellafield’s stockpiles of highly active radioactive wastes could have catastrophic impacts not just for Cumbria but for the whole of Europe. The deaths resulting from a seismically induced catastrophe at Sellafield could be in the millions, not the thousands described by climate scientists as a result of climate impacts from the coal mine.

Sellafield from St Bees

Sellafield viewed from St Bees

Despite this the Office for Nuclear Regulation has washed its hands of any responsibility and has provided the County Council with an excuse to be nonchalant about the close proximity of the mine to Sellafield . The ONR’s official remit to consult on planning applications is 7.4 km from Sellafield. The coal mine extends to 8km from Sellafield ie 600 metres difference.

 

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It has not gone unnoticed by Radiation Free Lakeland that the coal mine plan extends to right up to the area under the Irish Sea that is has been earmarked as ‘suitable’ as a possible site

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Image based on West Cumbria Mining’s own map

for the geological disposal of the decades of nuclear wastes resulting from the nuclear civil military industrial complex.

Nor has it gone unnoticed that there is a revolving door between the government body tasked with “facilitating geological disposal” and West Cumbria Mining. Mark Kirkbride West Cumbria Mining’s CEO has a portfolio which includes “deep geological disposal investigations” while Steve Reece formerly Operations Director of West Cumbria Mining is now Head of Site Evaluation at the government body Radioactive Waste Management who are tasked with ‘delivery’ of a Geological Disposal Facility for high level nuclear wastes.  There may be nothing suspicious in this revolving door but we have to say that the silence over this diabolic new coal mine has been almost deliberate, almost like a Defence Advisory notice or something along similar lines has been issued on this coal mine plan. A coal mine which has, ironically the full support of the nearby nuclear industry!  The Guardian’s Adam Vaughan told us in all seriousness that the paper’s editors have said they would ‘report on the plan when a decision has been made.’ That kind of Orwellian journalistic policy was guaranteed to keep the public in the dark. When the coal mine was approved what they and other media outlets did not report in their crocodile tears of mock shock and horror was that the folk who have been actively campaigning against the plan from the beginning are nuclear safety campaigners.  This not been mentioned anywhere in the National press neither has the close proximity to Sellafield, with one exception – the German Newspaper, Taz.

This coal mine should have been stopped as a result of public outcry on climate grounds alone, but it wasn’t because the public have effectively been kept in the dark about it. We are wondering Why?  

ACTION! ASK THE SECRETARY OF STATE TO CALL IN CRAZY COAL MINE DECISION

We have already delivered a petition of 1527 signatures to the Secretary of State James Brokenshire. We are however keeping the petition open to show the strength of feeling against the coal mine.  PLEASE SIGN AND OR SEND James Brokenshire a letter urging him to call in the decision (see below).

Westmorland and Lonsdale MP, Tim Farron has written asking for the decision to be called in and he has been vehemently condemned for this by the Mayor of Copeland, Mike Starkie who was reported in the local press as saying that Farron should “Butt Out of West Cumbria” Tim Farron has pointed out that Climate impacts from the mine won’t stop at Scafell. We agree and would also point out that neither would Nuclear impacts.

We believe that the more people and groups that write and request that the Secretary of State calls in the decision made by Cumbria County Council the better as a show of force will demonstrate the strength of feeling against the mine.

The letter should be addressed to James Brokenshire MP, the Secretary of State. james.brokenshire@communities.gsi.gov.uk.
Re: Application Reference No. 4/17/9007 – Former Marchon Site, Pow Beck Valley and area from Marchon Site to St Bees Coast, Whitehaven, Cumbria

Our full letter can be found here – even a paragraph would be good to send to the Secretary of State– the main point to make is that West Cumbria Mining has not given figures on CO2 Emissions. There are no independent assessments. There has been no detailed scrutiny or debate on the close proximity of deep mining to Sellafield’s high level radioactive wastes.

Marianne Birkby
Founder of Radiation Free Lakeland
Keep Cumbrian Coal in the Hole is a RaFL campaign

 

 

Local Elections and the Coal Mine

Who put their hands up for a coal mine just five miles from Sellafield?  Remember this when you vote – these councillors listened to the Mayor of Copeland who told them to ignore locals (from Whitehaven to Kendal) and experts who told them that this would be putting the ducks in line for a catastrophe and not just for Cumbria.

These councillors voted for a coal mine just five miles from Sellafield.

 

Mr A Bowness, Bothel and Wharrels, Conservative

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Mrs HF Carrick, Penrith North, Conservative, Deputy Leader of the Conservative Group

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Mr F Cassidy, Walney South, Labour

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Mr N Cotton, Sedbergh and Kirkby Lonsdale, Liberal Democrat

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Mrs BC Gray, Kendal South, Liberal Democrat

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Mr D English, Dalton South, Conservative

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Mr LN Fisher, Brampton, Conservative

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Mr KR Hamilton, Risedale, Labour

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Mr GD Cook (Chair), Kendal Highgate, Liberal Democrat

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Mr AJ Markley, Solway Coast, Conservative

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Mr W McEwan, Ormsgill, Labour

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Mr FI Morgan, Cleator Moor West, Labour

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What a shower….and then there is the Mayor of Copeland who told those in West Cumbria and those outside West Cumbria to ‘Butt Out’ if they don’t like a coal mine just five miles from Sellafield.  Don’t you get it Mr Mayor?  Fission Wastes from Nuclear Crapola wings its way through the whole of Cumbria to Sellafield almost on a daily basis – and you have agitated and puffed for a mega coal mine next door to those growing wastes.

Here he is with the Mayor of Fukushima – I kid you not…

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from the Elected Mayor of Copeland’s facebook page.

“21st March ….I (sic) was my pleasure to welcome Mayor Endo and his colleagues to Copeland Council yesterday.

Mr Endo, the Mayor of Hirono, met with me as part of his visit to West Cumbria in which he is focusing on education and revitalisation.

His community houses Fukushima and Mr Endo is particularly proud of the fact that around 90 per cent of the original population has returned to his town since the evacuation.

Mr Endo and his colleagues are keen to develop relationships with communities that have some similarities in terms of rurality and the creation of new opportunities. He also visited the Energy Coast UTC, West Cumbria Sites Stakeholders Group and The Beacon Museum, Whitehavenduring his stay.”

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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COAL!! BBC & Magical Thinking

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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?

COMPLAINT TO THE BBC

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

Who wants new Coal AND new Nuclear in their stocking this Christmas?

Santa_Letter
Local leaders in Cumbria have been agitating for new nuclear  and new coal in Cumbria just a stones throw from the most hazardous place in Europe.  They must think that Sellafield just isn’t quite dangerous enough?
The following was sent to the national and local press – unpublished.
Dear Editor,
Extinction Rebellion is much in the news with climate campaigners travelling from Cumbria to London to ask for abstract “action on climate change”.  One fossil fuel plan is getting a free ride.   With Father Christmas-like largesse in a deprived area,  this plan has its feet well under the table in West Cumbria. This is even before any planning decision.  This plan has the potential to wipe out all our concerns about climate change.  A few dedicated but much ignored nuclear safety campaigners are truly bewildered at being the ones left leading a scrappy campaign against the first deep coal mine in the UK for 30 years.
The new coal mine is proposed under the Irish Sea near Sellafield. Sellafield sits on the Lake District Boundary Fault.  The developers West Cumbria Mining have said the mine will extend to within 8 km of the existing Sellafield nuclear site and even nearer the proposed Moorside site

The plan is to extract 2.8 million tonnes every year during the lifespan of the proposed mine.  Assuming 40 years mining and an average of 2 million tonnes a year, that is a total production of 80 million tonnes!   But burning fossil fuel is not the only or even the most terrifying  concern here.

How reassured should we be by the statement provided to us by the Office for Nuclear Regulation that ” The nature of the proposed mine (pillar and room) is one that is not designed to collapse at any point in the future.. Even in the highly unlikely event of a collapse, the nature of any ensuing earth tremors would be limited…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.”
That faux “reassurance” is pulling the wool over people’s  eyes big time.  This is not an abstract thing.  It is real and it will be decided upon early in the New Year, in Kendal.
Yours sincerely,
Marianne Birkby
Keep Cumbrian Coal in the Hole, a Radiation Free Lakeland campaign

Correspondence with the Office for Nuclear Regulation below for info.

Date: December 6, 2018 at 11:01 AM
Subject: RE: GE201808194 – Proposed new coal mine near Sellafield

Thank you for your e-mail. Please accept my sincerest apologies in the delay for our response which arose due to consultations between different internal teams. I hope the below assists you with your query.

I can confirm that the proposed development, including the onshore and offshore mining areas specified in the planning application document “D46_869_AO_001_Underground Mining – Onshore and Offshore Mining Areas”, lies outside the ONR’s consultation zone around the Sellafield nuclear licensed site.  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.

In response to your expressed concern that potential resulting earth tremors could cause a major nuclear incident at the Sellafield Site, I have consulted colleagues within the External Hazards specialism within ONR and they have provided the following advice:

The proposed new subsea coal mine at c 10km from Sellafield is not considered by ONR to be capable of generating ground motions that would affect safety at the Sellafield site.  ONR has consulted with the HSE Mines Inspectorate, the British Geological Survey and its own expert panel on seismic activity in the UK.  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.

Once again, my apologies for the delay in our response.

If you have any further queries, please do not hesitate to contact me via contact@onr.gov.uk.

Kind regards,

Emma Lui