The presentation below has been sent to the Development Control & Regulation Committee. I will read a shortened version of it out on behalf of Keep Cumbrian Coal in the Hole at the meeting on the 31st in the County Offices, Kendal.
There will be a demonstration ahead of the meeting from 8.30 for people to make their views known about this outrageous plan. Bring Banners – bring yourselves!
You can send your own letter of objection in before 31st (do it quick) doesn’t need to be loads just a few lines of why Cumbria County Council is wrong to be ratifying this outrageous decision. They even say this coal mine would be “carbon neutral” and make “carbon savings” this is incredible magical thinking. Phone, Write to
01539 713 548
Keep Cumbrian Coal in the Hole –
Presentation to Development Control and Regulation Committee 31st oct
Application ref no 4/17/9007
Keep Cumbrian Coal the Hole is a campaign by civil society group Radiation Free Lakeland. We were first alerted to this coal mine as it would extend to within 5 miles of Sellafield. The risks are multiple and are on a planetary scale.
The overriding and often repeated message from the council’s reply to Leigh Day’s questions is that the mine would be “broadly carbon neutral”. This assumption is crucial; yet, neither the addendum report, nor in fact any of the underlying application documents, provide the evidence to support it.
It seems that this “carbon neutral” claim is simply based on vague assumptions that “coal production at Whitehaven would substitute for coal production elsewhere.” Really?
Clearly, the consideration of the likely emissions output from this development is absolutely key for any decision made by this committee. The Committee must come to a reasonable conclusion on the expected level of greenhouse gas emissions that will be produced over the next 50 years. It must do so, so that it can decide how much weight to give to that factor in the planning balance. The Applicant has simply failed to provide the Committee with sufficient information to carry out this task – this was a key point highlighted in the Leigh Day letter and it has not been addressed by the addendum report – which merely reiterates assertions about how the market might respond to the increased output in Whitehaven.
- With respect, the addendum report has raised more questions than it has answered. Notably, it states at para 4.4 of the addendum report, that the original Committee Report attached “moderate weight” to the “CO2 emissions from the extraction and processing of the coal and their impact upon climate change” which weighed against the proposal. That must have been based on an understanding that the mine would produce CO2 emissions (as undoubtedly is the case). Somewhat oddly, the Addendum Report now seeks to clarify that this should have said that “greenhouse gas emissions globally as a result of the extract and processing of coal would be broadly in balance”. It refers to other paragraphs of the original report (6.47 and 6.406) where the import-substitution point was made – however, the import-substitution point concerns emissions from reduced transportation. It does not support the argument that the coal produced further afield will stop being produced at all. So it cannot be relied upon to factor out the additional emissions associated with bringing a new coal mine into operation.
- On the emissions expected from exports of coal from the mine, we must emphasise that the vast majority of output is expected to be exported. The proposed amount of coking coal for export to Europe and beyond would be a staggering 2 million tonnes annually. Whereas the amount earmarked for UK use would be a more modest 360,000 tonnes. So most of the coking coal produced is destined to travel abroad. In relation to this, the addendum report relies on assumptions that this will all be exported to “Europe” and will replace alternative sources of coking coal from further afield. Yet there is absolutely no restriction on where the coal would be exported to. Nothing prevents it from travelling further afield. And, if it does, all the assumptions on emissions savings through import substitution fall on their face.
Has the Committee properly considered this? Where is the evidence for this idea of “substitution”? Do the councillors really believe that a mine elsewhere will stop producing coal because a mine in Cumbria has opened up under the Irish Sea, five miles from Sellafield? More importantly, do they have before them sufficient evidence to support such claims. In our view, they clearly do not.
Demand for Coking Coal for Steel
You acknowledge that the demand for coking coal is led by the demand for steel. However there is no acknowledgment in your report that technology and politics has moved on with the Department for Business, Energy & Industrial Strategy (BEIS) announcing in August, new measures to “enable a pathway to lower carbon steel production and support broader efforts to decarbonise industry”.
Nor is there any recognition of the possibility that greater supply of coking coal might impact on worldwide prices, with a real chance that demand will increase (for both the coking coal, itself, and for steel) due to reductions in the price.
The middlings coal you say would be up to 15% of coking coal extraction. To describe up to 15% of production as a “by-product” is disingenous. It is a significant amount of production, in and of itself, and members should not be distracted by this type of terminology. The level of middlings coal produced could easily be a development in itself, so the impacts of it need to be fully considered.
You say that an assessment of CO2 emissions “would not be a reasonable requirement.” Given that the UK government has just signed up to a Climate Emergency we say that a full and comprehensive assessment including the various scenarios of transport exports to near Europe, far Europe and beyond, of the CO2 emissions from both coking and middlings coal is an entirely reasonable requirement.
At paragraph 6.71 of the original report, it stated in relation to middlings coal production that “There are valid arguments made in respect of climate change, but we consider these issues could be better managed by applying regulatory controls at the point of use.” The addendum report now seeks to clarify, at para 4.14, that the mere reference to there being “valid arguments made in respect of climate change” meant that the issue was weighed in the planning balance but was not considered of sufficient weight as to justify the refusal of permission, or to require a condition requiring disposal of the middlings coal. That is not how we read the original report. It is not clear at all what the “valid arguments in respect of climate change” referred to were and by reference to other regulatory controls, it was clear that the officer did not factor emissions from middlings coal production into her assessment.
Interestingly, the addendum report now recognizes that the burning of middlings coal would “undoubtedly” result in the generation of CO2 but argues that it would not be a “reasonable requirement” to expect the decision-maker to assess possible emissions associated with it. This is a fundamental failing in a case where the officers are nonetheless arguing that the “greenhouse gas emissions of the mining operations would be broadly carbon neutral” and the “greenhouse gas emissions globally as a result of this extraction and processing of coal would be broadly in balance”.
With respect, you cannot reach a conclusion that operations are carbon neutral if you have failed to estimate the emissions associated with 15% of production.
If you are going to assess the net carbon output of a development, then you have to assess the whole of it. To do otherwise is irrational.
Finally, on middlings coal, we can still see no reasoning as to why the level of output has been limited by condition to 15%? Why not 10% or 25%? What evidence or understanding rationalises this conclusion and how has it been shown to be necessary, relevant to planning, relevant to the development to be permitted, or reasonable in all other respects?
The addendum report concludes that whilst the new net zero target makes the Climate Change Act 2008 target more challenging, it does not change the original report’s assessment on the impact on climate change and efforts to reduce CO2 emissions, which were both treated as key considerations in that report.
With respect the addendum report fails to appreciate the substantive change brought about by the new net zero target. By 2050 there needs to be a 100% reduction in emissions as compared to 1990 levels. That means that all emissions need to be offset, or somehow compensated for, so as to produce a “net zero” emissions output level overall.
This development will result in significant emissions far beyond 2050. If consent were to be granted next year, the permission would last until 2070. Even if the Committee were to accept – what we say are the incorrect – assumptions that the production of coking coal will be carbon neutral, it now seems accepted by officers that the production of middlings coal will result in unquantified levels of emissions. That – at the very least – needs to be properly factored in.
The Committee must have due regard to the emissions output that any permission will grant consent for beyond 2050 and what will be needed to offset this. This is clearly a material consideration in light of the legally binding net zero target.
And, it only supports the need for the Committee to obtain robust evidence from the Applicant on what exactly the likely emissions output will be. To reiterate, we do not consider the Committee has sufficient information at present.
Finally and without any supporting evidence at all the report claims that “whilst greenhouse gas emissions of the mining operations are very likely to be carbon neutral, it is still considrered that some carbon savings must exist from reduced transportation distances.” (4.6) Incredible! So this massive coal mine which proposes to operate over 50 years would actually result in carbon savings from reduced transport with this ‘home grown’ coking coal-? Even though the plan is to export the majority of coal to Europe and beyond.
We ask that the Council do not ratify this disastrous and planetary damaging application for the first deep mine in the UK in 30 years extending to within 5 miles of Sellafield. There is no supporting evidence at all to back up the false claims of the mine being “carbon neutral” and making “carbon savings.”