Briefing Note from Radiation Free Lakeland on the Coal Mine Plan

Poster small

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




 Part 1

  • Wildlife
  • Health
  • Seismic Activity and Sellafield

Part 2

  • Climate
  • Planning
  • Employment

 Part 1


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.

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


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.




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.


Additional Info

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

Two Months to Stop the Cumbrian Coal Mine!

 “Greenpeace would be opposed to a new coal mine for the same reason we’re opposed to fracking. We already know that there is too much fossil fuel available than we can afford to burn Therefore we should not be seeking out more.” Doug Parr Greenpeace UK

MANY THANKS to everyone who has written to oppose the coal mine.  We now have a period of time to build a campaign against this plan “The earliest Committee the application could be presented to is the 20 September 2017. Representations received after the report has been finalised (usually 10 days before the Committee meeting) will be verbally reported to the Committee on the day of the meeting.”

People and groups can write to Cumbria County Council to ask to speak against the plan and the more who do this the better chance we have of stopping the first coal mine in the UK in 30 years!

Correspondence below with Cumbria County Council from Keep Cumbria Coal in the Hole

Dear Ms Birkby

Acknowledgement of Representation on Planning Application Ref. 4/17/9007

Location:    Pow Beck Valley and area from Marchon Site to St Bees Coast, Cumbria 

Proposal:    Development of an existing surface mine entrance for a new underground metallurgical coal mine and associated surface development including: coal storage and processing buildings; access road; security fencing; lighting; outfall to sea; surface water management system; landscaping; at the former Marchon site (High Road) Whitehaven; interconnecting underground coal conveyor to a new coal loading and railway siding to the Cumbria Coast Railway Line, with adjoining office/welfare facilities; extension of railway under pass; security fencing; lighting; landscaping; construction of a temporary development compound and associated permanent service access off Mirehouse Road, Pow Beck valley south of Whitehaven.

Thank you for your representation with regard to the above planning application. Your views will be carefully considered and a summary of them will be included in my report to the Development Control and Regulation Committee which will determine the application. You will be able to view my report on the County Council’s web pages at the time. The earliest Committee the application could be presented to is the 20 September 2017. Representations received after the report has been finalised (usually 10 days before the Committee meeting) will be verbally reported to the Committee on the day of the meeting.

All representations are made available for inspection, including by the applicant.

There is also opportunity for representations to be made in person to the Committee meeting at the time the application is presented for determination; the meetings are usually held at County Hall in Kendal. Information on how to go about doing this can be found online at:


Kind Regards


Rachel Brophy


Planning Officer | Development Control


From: marianne Birkby
Sent: 02 July 2017 15:24
To: Young, Stewart F
Cc: Harrison, Nicola J; Perigo, Stuart
Subject: KEEP CUMBRIAN COAL IN THE HOLE Planning Reference NO 4/17/9007

 by email and sent by letter


Planning Reference NO 4/17/9007

Dear Councillor Young,

I am writing to you on behalf of Radiation Free Lakeland to vehemently oppose the plan for the underground and undersea coking coalmine near Whitehaven.

We agree with Coal Action Network (1) who have written to you saying:

“Given that the UK steel industry imported 4.75 million tonnes of coking coal in 2015, mainly from the USA (44%) and Russia (27%) it seems perverse to be exporting coal to other countries, while importing it for UK steelworks (2). Exporting coal increases greenhouse gas emissions and producing more coal could displace lower quality coking coal to power station usage adding to greenhouse gas emissions and air quality issues. The UK government intends on phasing-out coal by 2025, but the whole world needs to stop burning this most polluting of all fossil fuels now (3).

“The application to mine is too close to the Sellafield nuclear site and the proposal for another nuclear power station at Moorside (4). Underground mining can have a significant impact on the surrounding areas, recently a coking coal mine in Russia triggered an earthquake. In addition to being dangerous for mining personnel this could cause a nuclear catastrophe (5).”

We also agree with the former director of Friends of the Earth, Jonathon Porritt who has publicly blasted the plan saying (6):

“As I understand it, the sole justification from a sustainability point of view is that the extracted coal will be coking coal, not thermal coal (for use in power stations), with some preposterous notion that this will apparently produce a lower carbon footprint than coking coal imported from other countries. Yet so far as I can tell, no detailed lifecycle analysis, both direct and indirect, has been done by West Cumbria Mining, so why would anyone swallow that particular pile of coking crap? In cases like this, I often think I must be going mad, and that may well be true. There’s a lot of it around these days. But in this instance, my mind keeps turning to a potential spoof-tweet from the Donald: “I am a big fan of coal and a big fan of nuclear. Putting the two of them together sounds GREAT!”

Greenpeace’s scientific advisor Doug Parr has told Radiation Free Lakeland that:

“Greenpeace would be opposed to a new coal mine for the same reason we’re opposed to fracking. We already know that there is too much fossil fuel available than we can afford to burn Therefore we should not be seeking out more.     Materials science analysis shows significant emissions from the process where coke is used.  Steel is max 2% carbon. That would make any feasible market very small for coking coal if it only got incorporated into the final steel.   It’s true there is a need for a source of carbon in making steel and coke is currently the best source. But that’s different from saying there are no other sources of coke available and that we need new mines.”


The Chief Executive Officer Mark KirkBride insisted when questioned at the June 25th “drop in day” that there will be no induced Seismic activity from the coal mining and that the close proximity of the proposed drifts (8km) to Sellafield is not a problem (but refused to be videoed or recorded saying that).

The CEO also stated that there is no requirement in this planning application for any mention of Seismic activity but also that they have sent in documentation to the Office for Nuclear Regulation “for approval. ” I asked if we could have sight of that documentation to inform our response to CCC but no apparently we cannot have sight of that either (9)

Incredibly the lifecycle carbon footprint is not yet available for public to view and from what the CEO said it is pretty meaningless anyway as it stops short of the coking process, the carbon footprint of which is “the responsibility of the steel producers.”   Not all the coal mined will be for “coking’ (metallurgical). according to the company’s own Environmental Statement

“At full annual production the mine will extract:

  • 2.43 million tonnes of metallurgical coal;
  • 350,000 tonnes of lower grade ‘middlings’ coal; and
  • 150,000 tonnes of rock overburden

Metallurgical and middlings coal will go to the port of Redcar for export to European steel and industrial plants.”

This is planned to continue for 50 years accessing new coal drifts using the old sulphur (anhydrite) mine entrance at St Bees

  • 80% of the coal to be mined is for export.

The CEO says the sparks we can see clearly on their own video of “modern mining methods” will not cause explosion or fire (despite the Whitehaven mining area being notorious for methane)

ON the 25th June we leafleted in Whitehaven. From what West Cumbrian Mining has been saying we should have been pelted out of town with rotten eggs.   It is clear that WCM’s claim that over 97% of people locally are in favour is wildly optimistic, certainly we spoke to a lot of people who are at least dubious about it despite the persuasive “green” credentials plus the incessant promises of jobs and good times ahead.


Diversification away from the stranglehold of the nuclear industry has been used as a reason to support the return to coal mining in West Cumbria. The existence of Sellafield should however make mining in its vicinity forfeit.  There should be no turning back of the clock to deep coal mining with its risk of induced seismic activity now that Sellafield’s already intolerable risks have to be managed. There are other safer, healthier and more stable industries than coal mining. from renewables to sport and tourism which should be embraced in West Cumbria. For example:

Many have said they would have much preferred the jobs offered by the (deliberately?) scuppered plan for the Pow Beck Valley Sports Village. Pow Beck is now earmarked on West Cumbria Mining’s plan to host a new underground coal conveyer belt from the coal drifts off St Bees to the Railway (10). This area is also earmarked as workers housing for the proposed Moorside plan (11). We note (along with others) that one of the Corporate Directors of Copeland Council who was in charge of (scuppering?) this multi million sports village plan is now working for NuGen (12).

In Conclusion we vehemently oppose this plan for the following reasons (there are many more)

  • If planning permission is granted this vast new coal mine “Woodhouse Colliery would be the first new deep coal mine in the UK for more than 30 years.” This would fly in the face of every climate agreement that Cumbria County Council has signed up to.


  • WCM have not yet produced a carbon footprint and will not be including the emissions from the coking process “that is up to the steel industry.”   Much of the coal mined from WCM will be “middlings” coal not suitable for coking (WCM Non Technical EA page 5).


  • It is too near Sellafield, off St Bees, just 8km away from Sellafield (even nearer to Moorside) according to West Cumbria Mining


  • Coking coal mines worldwide have caused induced seismic activity


  • The coking coal market is volatile with China closing plants because of “overcapacity” (14).


  • West Cumbria Mining state there “would be no significant environmental impacts” the opposite is true – the environmental, economic and health impacts of coal are very well documented (13) and these impacts are significant. Returning to coal mining in this area would add to the cumulative toxic burden in an area where “Nearly half of adult residents reported their health as ‘not good” (15).

Yours Sincerely,

Marianne Birkby

On behalf of Radiation Free Lakeland’s

Keep Cumbrian Coal in the Hole campaign


  1. Coal Action Network
  2. Digest of UK Energy Statistics (2016) P55. Table 2.1 Commodity balances 2015
  3. Vaughan, A (09/11/16) Britain’s last coal power plants to close by 2025
  4. Reuters (04/04/17) UK’s Moorside nuclear project in turmoil as Toshiba’s French partner backs out
  5. UPDATE 1-Mining in Siberian coal region part-suspended after quake
  6. Jonathon Porritt Blog
  7. Greenpeace Study
  8. Significant Emissions from the coking process

    9. 25th June Open Day

10.Whitehaven Sports Village Step Closer to Being Built

11. Pow Beck

12. Fergus McMorrow

13. More Coal = More Poverty – Oxfam Report


15. China Coal – Overcapacity


note: Resuspension of radioactive wastes from seabed landslides caused by coal mining collapse