There is Nostalgia for the good old days of Coking Coal in West Cumbria
The Following is an excellent objection to the coal mine plan. Please feel free to use this for ideas or as a starting point for your own research and letter to Cumbria County Council.
NOTE the date of the planning meeting has now been deferred again (this is the fourth date!) until the middle of April. This gives us more time to build up a momentum against this diabolic plan to mine for coal under the Irish Sea.
To Rachel Brophy, Development Control Team, Cumbria County Council
Feb 6th 2018
Woodhouse Colliery, Application Number 4/17/9007
West Cumbria Mining [WCM]
I am writing with particular concerns about the economic sustainability and the employment claims in the application. I wish to object to the application.
The general NPPF guidance regarding coal extraction is very clear
Para 149. ‘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.’
The many consultation responses received from statutory bodies make it abundantly clear that the proposal is not environmentally acceptable on a very broad range of issues. This is well documented. WCM have been requested on two occasions via regulation 22 to provide additional information on environmental aspects of the proposal. It is now becoming obvious to all that the application is not and cannot be environmentally acceptable.
There are no planning conditions or obligations which can alter the basic fact that the carbon in the coal would end up almost entirely in CO2, whether it is burned or used in steel making and therefore fails all criteria for low carbon, sustainable development. 
The WCM application claims that it provides local community benefits by way of creating employment. As these claims relate to the creation, or otherwise, of a sustainable economy – they form a material consideration. These employment claims need to be challenged.
Economic challenges to jobs/community benefit
The production of coal for the European steel market can only be as viable as that market itself. The international steel market has been notoriously unstable in recent years. China, India and Korea are emerging as major steel producers – there have been dramatic declines in European steel production. Steel plants have been closed. There is reducing production globally. In 2016 European production declined to 10% of global production. Competition is fierce with new markets emerging. 
The production of steel is closely tied to the automobile and construction industries. With financial difficulties, austerity and cautious consumer spending the future of steel production in Europe is in a precarious place.
However much coal WCM may wish to produce the global market situation means there can be no guarantee of ready customers.
October 2017 article from the Financial Times – ‘Our current [global] overcapacity issue is bad,” said John Ferriola, chief executive of US group Nucor, speaking at the World Steel Association’s annual general meeting in Brussels earlier this month. “[It] results in a high level of exports that in some cases are illegally subsidised and dumped in other nations.” The problem of overcapacity has dogged the industry for years. When mills are underused, they use raw materials less efficiently and producers are forced to reduce prices in the scramble to win orders and cover their high fixed operating costs. But there is a new political urgency, with accusations of unfair trading practices that have caused protectionist measures in number of countries. A steep rise in exports, especially from China, contributed to a collapse in the price of steel two years ago. That hit earnings hard at companies such as ArcelorMittal, South Korea’s Posco and US Steel, triggering major job losses and raising questions about the industry’s future in some developed countries.’ 
There are also the implications of Brexit and the uncertainties about whether the UK will remain in the European Single Market.
Carbon challenges to jobs/community benefit
Building on the commitments of the Paris Agreement all signatory nations are now moving into ever tighter carbon budgets with increasing regulatory measures. There is a race on to develop processes of steel making which do not involve the burning of fossil fuels. Sweden seems to be at the forefront . It is also likely that recycling will play a greater part in the steel industry.
Investment challenges to jobs/community benefits
While the application is in the name of West Cumbria Mining it appears that the proposal is backed by EMR Capital. who describe themselves as follows – ‘We are a specialist resources private equity manager whose team has a proven track record in the three dimensions critical to achieving superior returns’
EMR Capital has offices in Melbourne, Sydney, Cayman Island and networks across the globe. They specialise in –
- Successful development, over 30 years, of resources projects and companies across a wide range of commodities and countries, advancing early stage projects through the development stages into high quality producing mines;
- Achievement of superior investment returns in the resources sector; and
- Building successful partnerships, joint ventures and linkages in Asia, emerging markets and new frontiers for resources, with investors, resources companies, commodity end users and government in those markets, who are the key drivers of global commodity markets and prices, and key buyers of resource assets.
Companies House lists 12 Directors for WCM five of whom live in Australia, one in France and one in Scotland. The registered address is in Surrey.
It would seem that despite the local sounding name of ‘West Cumbria Mining’ this application represents a speculation of global capital. The investors and recipients of any profit from the mine are likely to be in Asia or Australia.
Despite the interest of EMR Capital however – there is a powerful global movement of divestment from fossil fuel industries and any such investment will become increasingly risky.
From a June 2015 article in the Guardian – ‘ . . . . the UN has lent its “moral authority” to the divestment campaign, while Desmond Tutu has said that “people of conscience need to break their ties with corporations financing the injustice of climate change. Second is the financial argument, which rests on the premise that if international agreements on climate change are met, the investments will become worthless. The theory that these “stranded assets” are creating a trillion dollar “carbon bubble” that could plunge the world into another economic crisis is now the subject of an investigation by the Bank of England, after Governor Mark Carney said publicly that “the vast majority of reserves are unburnable. The World Bank has come out in support of the financial argument for divestment, with president Jim Yong Kim stating that: “every company, investor and bank that screens new and existing investments for climate risk is simply being pragmatic.’ 
Safety challenges to jobs/community benefits
We know that the coal mining industry has a long and sad history of fatalities. Some miners still remain where they died under the sea off Whitehaven. Any accident at the mine reaching out 5 miles under the sea would have serious consequences for continuing production/jobs as well as for the bereaved and injured themselves.
Additionally – any minor induced seismicity or earth tremor that affected the Sellafield location would have catastrophic consequences in the potential release of radioactivity and would undoubtedly need to result in the immediate closure of the mine.
The nature of potential earth tremors is in that very potential. They are unknown. An application, such as this, which increases the possibility and potential of induced seismicity/earth tremors is simply too dangerous to be approved.
It is of critical importance that the Coal Authority has formally objected to the application on safety grounds
The application from WCM assumes employment prospects/community benefits based on a steady demand for the coal produced. This is clearly a nonsense given the instabilities of the global steel and investment markets; coal phase – out; the increasing regulatory controls on the burning of fossil fuels and the many safety threats at the mine including methane, subsidence and seismicity.
There can be no guarantee whatever of the employment WCM may prove able to provide. There are simply too many complex global factors which are outwith the control of the company.
The NPPF statement on achieving sustainable development states –
‘International and national bodies have set out broad principles of sustainable development. Resolution 42/187 of the United Nations General Assembly defined sustainable development as meeting the needs of the present without compromising the ability of future generations to meet their own needs. The UK Sustainable Development Strategy Securing the Future set out five ‘guiding
principles’ of sustainable development: living within the planet’s environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy; promoting good governance; and using sound science responsibly.’
In addition to failing to provide a sustainable environment – the WCM application clearly fails to provide both a sustainable economy or sustainable employment. There can be no jobs, economic growth or prosperity when the fossil fuel products are no longer viable.
The people of West Cumbria do most certainly need greater employment opportunities – these need to be sustainable in all senses – both economically and in terms of low carbon. This is a very real challenge to create future sustainable employment that creates decent local jobs and honours both the people and the landscapes of West Cumbria.
One model for the creation of sustainable local economies is that of CLES which is gaining great interest – and action – among various Local Authorities in the North West and beyond. ‘ CLES is the UK’s leading, independent think and do tank realising progressive economics for people and place. Our aim is to achieve social justice, good local economies and effective public services for everyone, everywhere.’  
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 – despite the detailed information on proposed shift patterns for miners.
Despite being on the far west seaward side of Europe – West Cumbria cannot extract itself from global market, investment and environmental realities. Cumbrians deserve decent, local, stable, sustainable jobs.
Member of Radiation Free Lakeland