All Councillors on the Committee making the decision have been sent the following Briefing Note from Radiation Free Lakeland. Please do use this as an inspiration for your own objections to the first deep coal mine in the UK for 30 years. The planning meeting has been deferred (fourth time this!) until May 30th so more time to get your fingers dancing on the keyboards, get those pens out, get on the phone to Councillors and Object, Object Object!!! Councillor Details here
BRIEFING NOTE FROM RADIATION FREE LAKELAND
WEST CUMBRIA MINING PROPOSAL Ref No: 4/17/9007
- Seismic Activity and Sellafield
The West Cumbria Mining proposal would have adverse impacts on designated sites of national and international importance
Minewater Discharge and The Cumbria Coast Marine Conservation Zone (MCZ)
The National Trust have said: “We are particularly concerned in regard to the potential impact upon the wider marine and coastal environment of the discharge of water into the sea, which has been pumped from the flooded anhydrite mine.” RSPB have also noted concerns regarding potential pollution of the Marine Conservation Zone.
Seismic impacts on St Bees Head Site of Special Scientific Interest (SSSI)
West Cumbria Mining conclude that “minor seismic events will be significant below a magnitude 3 event, and any event which may occur as a result of mining activities will not cause damage to people, property or the natural environment” (Page 75 of the WCM Addendum: Seismicity). . The RSPB in their submission note that “We consider it imperative that the Council deploy a suitable level of expertise to ensure that the additional information provided by the applicant provides a robust assessment of the potential for seismic events – both in magnitude and frequency – to have an adverse effect upon designated sites listed above. In particular, upon the notified features of the SSSI – which include geological features and isolated breeding bird colonies. It should be noted that the SSSI supports England’s only breeding black guillemot – which are small in number and already vulnerable to stochastic events.”
Noise Disturbance, Dust, Vibrations etc.
The development has the potential to have an adverse effect upon the St Bees Head SSSI through disturbance to breeding birds during excavations and coal processing. Notwithstanding the developers assurances the RSPB state “In our previous response, we considered that there was insufficient evidence to be able to evaluate the potential for impacts upon the SSSI, nor the efficacy of the proposed mitigation. In particular, the noise assessment detailed in Chapter 14 does not make the link between the development and any ecological receptors. We note that no further evidence has been presented by the applicant in this regard. In summary, the RSPB’s opinion is unchanged – in that insufficient information has been submitted by the applicant to allow a robust assessment of the potential ecological impacts of this proposal.”
Solway Firth European Designated Site (Natura 2000)Precaution must be adopted when considering potential impacts from a development adjacent (1.5km) to an internationally recognised marine environment
The old Marchon Chemical plant and Anhydrite mine that fed it are key to the WCM application. As referenced above, The anhydrite mine would need to be dewatered. This would exacerbate the previous legacy operations which are still having a “significant” impact on health.
“There is also a significant radiological impact due to the legacy of past discharges of radionuclides from non-nuclear industrial activity that also occur naturally in the environment. This includes radionuclides discharged from the former phosphate processing plant at Whitehaven, and so monitoring is carried out near this site.” Radioactivity in Food and the Environment 2016. https://www.food.gov.uk/sites/default/files/report2016_0.pdf
These cumulative assaults on West Cumbrian health would be additional to well documented climate change health impacts and the intolerable danger that this mine would represent to the safe stewardship of Sellafield
- SEISMIC ACTIVITY AND SELLAFIELD
At just 8km away from Sellafield (even nearer to Moorside) according to West Cumbria Mining this development is ridiculously near to over 140 tons of plutonium. Increased tremors and quakes resulting from mining is well documented The potential for man-made tremors at the Sellafield site is too awful to contemplate.
There are~20 large holding tanks at Sellafield containing thousands of litres of extremely radiotoxic fission products.”
Nuclear Management Partners, stated in 2012: “There is a mass of very hazardous [nuclear] waste onsite in storage conditions that are extraordinarily vulnerable.
The National Audit Office (NAO) stated these tanks pose “significant risks to people and the environment”. These dangerous tanks have also been the subject of repeated complaints from Ireland and Norway who fear their countries could be contaminated if explosions or fires were to occur.
- The North Western Inshore Fisheries and Conservation Authority have submitted to Cumbria County Council that
“Offshore Subsidence – resuspension and dispersal of radioactive contaminants. The documentation has confirmed to NWIFCA that a risk of subsidence exists and therefore there remains an overwhelming concern over the potential for disturbance and resuspension of radioactive contaminants and sediments.”
Radiation Free Lakeland agree and would add that this risk of subsidence of the seabed would enable the resuspension of decades worth of radioactive and chemical contaminants not only from Sellafield but also from the firing of depleted uranium shells into the Irish Sea and the Solway Firth. http://theseacannotbedepleted.net/
CLIMATE and PLANNING
The WCM proposal fails to quantify the overall carbon emissions resulting from it’s activity. It also fails to address the climate impact of its activity. The application is clearly incompatible with national and international climate change policy and legislation as summarised below.
- The UK is signatory to the 2015 Paris Climate Agreement committing us to the rapid phase-out of fossil fuels.
- The UK is working to the 2008 Climate Change Act committing us to a legally binding 80% reduction in carbon emissions by 2050. The UK will phase out coal for electricity generation by 2025. The proposed 50 year lifespan of the mine goes well beyond the UKs existing commitment to bring carbon emissions nationally to zero. When the Intergovernmental Panel on Climate Change publishes their latest report later in 2018 it is acknowledged that UK legislation will need yet further strengthening to meet our international carbon reduction commitments.
- The National Planning Policy Framework states –
Para 93 ‘“Planning plays a key role in helping to shape places to secure radical reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change and supporting the delivery of renewable and low carbon energy and associated infrastructure. This is central to the economic, social and environmental dimensions of sustainable development”
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 proposed Woodhouse Colliery would produce combined CO2 from the methane emissions of the mine; the energy used in running the mine itself and transport; the burning of the lower class of coal and the burning of the higher class coal in steelmaking. At a production rate of 2.8Mt/year the produced coal would generate 1.24Mt CO2.
- The WCM application seems to imply that coal used in steelmaking does not produce CO2 emissions. This is clearly not the case. WCM even claim to be reducing CO2 emissions compared to importing coal from the USA. Some of the CO2 would be produced in Cumbria and some at the locations of steelmaking where the coal is to be exported. Given that all countries are equally bound by the Paris Agreement and equally committed to reducing fossil fuel use – it is highly unlikely that steel manufacturers will be seeking to import Cumbrian coal. There is rapid innovation in steel making processes to eliminate the fossil fuel component and the unknown impact of Brexit.
- The FOE submission July 2017 states – ‘Despite the applicant’s stated intentions for the use of coke coal, the proposal is nonetheless incompatible with recent government announcements and consultations linked to coal phase-out. Its use within ore extraction and steel making will inevitably lead to its being burnt and CO2 release. . . . . coal is on the way out and applications for its extraction are incompatible with government’s strategic approach which aims to reduce its well documented contribution to climate change.’
- FOE also state in Oct 2017 – ‘Our view is that the applicants have failed to demonstrate the scheme’s ability to comply with UK carbon budgets and to satisfy Schedule 4 of the 2011 EIA regulations (re consideration of significant impacts on…” climatic factors”)’
- There are also planning issues relating to carbon, climate, subsidence and pollution issues which relate to other nations within and outwith the UK and the necessary consultation with such nations.
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.’
The people of West Cumbria need employment opportunities to be sustainable in all senses – both economically and in terms of low carbon.
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.
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.
Coal Mining Causes Earthquakes – National Geographic
Fisheries and Conservation Authority Concerns: Irish Sea Subsidence and Resuspension of Radionuclides
Greenhouse Gas Emissions in the Steel Industry
World Steel Figures in 2017
Sweden aims for first place in carbon free steel race
Beginners Guide to Fossil Fuel Divestment
Progressive Economics for people and place
The Preston Model