Not to mention the Subsidence and the Radioactive Mud Patch
This is our response to West Cumbria Mining and the Council’s agreement on conditions should the Secretary of State rubberstamp WCM’s coal mine.
We vehemently disagree with the conditions on seismicity and subsidence as agreed by WCM, the Rule 6 parties and Cumbria County Council. We ask for evidence of justification from WCM for the generous conditions on subsidence and seismicity. The very small concession to monitor all seismicity is meaningless when the limits set at which actions would be taken are generous and the outcome is not to halt operations but for WCM to merely deliver a report.
We are devastated to have been sent the report by (WCM) planning advisors, IC Planning, that: “The Rule 6 parties, Friends of the earth and SLACC, have both confirmed that they have no issue with the subsidence and seismic activity condition as they are currently drafted. Both parties have provided extensive commentary on a wide range of other conditions and aspects of the proposals, but have not chosen to do so in relation to these specific conditions.” (Note: SLACC have contacted me saying they “do not agree” with the conditions on seismicity and subsidence – lets hope that disagreement from SLACC is voiced in the final conditions).
We agree with the former UK climate envoy John Ashton who has said: “It is morally incoherent” to focus on climate without looking at subsidence of the contaminated Irish Sea bed and induced seismic impacts on the Sellafield site. It will be interesting to see how this all plays out given that the coal boss Mark Kirkbride is employed by Government to advise on nuclear waste plans, his expertise is, after all, in digging very big holes https://www.lakesagainstnucleardump.com/post/government-take-advice-from-coal-mine-boss-over-deep-nuclear-dump-plans .
RADIATION FREE LAKELAND REPLY TO WCM RESPONSE TO CONDITION AMENDMENTS AS RECOMMENDED BY RaFL
66. Seismic Activity – Monitoring
WCM Response
“WCM can approach these parties and request access to monitor using their electricity and wifi but cannot guarantee permission will be granted.”
RFL Response: WCM must be responsible for providing power and wifi for equipment used in seismic monitoring at high vibration- sensitive and high hazard consequence onshore receptors in the region such as i) West Cumberland Hospital ii) South Egremont boreholes utilised for public drinking water and Sellafield. The receptors should not be responsible for providing electricity and monitoring for WCM.
WCM Response on distances to identified receptors
Note. Egremont = approx. 5 miles, Sellafield = approx. 9 miles.
RFL Response
Unless seismic activity is taking the very long route by road, the shortest distance from the nearest point of the coal mine’s subsea area identified by WCM’s location maps is South Egremont under 4 miles and Sellafield, five miles. Unless WCM can prove otherwise their disingenous claims on distance between the nearest point of the subsea coal mine and the highly vulnerable receptors, should be struck out of official records.
67 Seismic Activity – Investigation
WCM Response
“1mm/s threshold is unreasonable and impractical, – suggest retaining 6mm/s as per original condition.”
RFL Response
What evidence is there that the 1mm/s peak particle velocity threshold agreed by the Planning Inspector during RFL’s contribution to conditions is unreasonable and impractical?
WCM’s 6mm/s PPV is the threshold used for blasting and 1mm/s is the point at which residents will complain of vibrations.
WCM Response
“This is not a fracking project”
RFL Response
If this was a fracking project a stringent Traffic Light System would by legal requirement be put in place – as Cuadrilla have said: “It should be noted that the Traffic Light System required for hydraulic fracturing in the UK is significantly more stringent than the maximum ‘allowed’ induced seismic event for other hydrocarbon industries in the UK such as coal mining where magnitude >3.0ML events have been observed”. Cuadrilla Environmental Statement Appendix 1. Induced Seismicity May 2014 Preston New Road.
WCM Response
“Unreasonable to stop if cause not known. Outside body not defined.”
RFL Response
If the cause is not known operations should be halted until the cause is known. The “Outside body” refers to the appropriate regulatory authority.
68 Seismic Activity – Mitigation
WCM Response
“Suggest the WCM TLS =
- C66 – continuous monitoring (Green)
- C67 – investigation if PPV > 6mm/s
(Amber) - C68 – mitigation if investigation
demonstrates WCM at fault (Red)
Although a case could be made from the references later to increase the threshold, WCM have not pursued this”
RFL Response – WCM TLS applies only to PPV not to Magnitude of earthquake
C66 – continous monitoring (GreenP
C67 – investigation if PPV > 1mm/s (Amber)
CC8 – halt to operations if investigation demonstrates WCM at fault (Red)
Magnitude TLS
Green light a seismic event up to 0.0 occurs operations continue normally.
Amber light: A seismic event between 0 and 0.5ML occurs during mining within the operational boundary (a specified geographical area). Operations continue with caution unless this coincides with a peak particle velocity of 1mm/s and then operations should halt.
Red light A seismic event of 0.5ML or greater occurs within the operational boundary or within the near region up to 5 miles.
69 Subsidence Monitoring
WCM Response
“Prawn fishing in the mud patch and weather conditions are more likely to have an influence.”
RFL Response
What evidence does WCM have that “prawn fishing” and “weather” are more likely to have an influence on resuspending radioactive silts from the Cumbrian Mud Patch than subsidence and climate impacts ?
We have searched for referenced academic research studies of the volume/mass of seabed sediment re-suspension following prawn trawling in, or near, the unique seabed fine sediment feature known as the Cumbrian Mud Patch. We have found no reference to any such studies.
We challenge WCM to provide the referenced academic research data on which they base their claim that sediment re-suspension generated by shrimp trawling and weather factors will generate a greater degree of sediment re-suspension than sub-seabed mining subsidence.
Unless WCM can produce copy of the relevant, fully referenced academic data we urge the Inquiry to regard the WCM statement/claim as spurious and un-substantiated, to disregard it, and to ensure that it is struck out of any record of official proceedings.
If WCM can produce copy of the relevant, fully referenced academic data, we request that the material be regarded as late submitted evidence and that we be granted an extension period in which we can review, consider and respond to this late submitted evidence. If such a time extension is not available or not permitted we formally request that the late submitted evidence be withdrawn and that any reference to the WCM claim be struck out of the record of of official proceedings.
We note that the North Western Inshore Fisheries and Conservation Authority provided an early submission to Cumbria County Council on Subsidence saying:
“impact on shoreline profile and wave heights. NWIFCA note that WCM propose a ‘no mine zone’ within Cumbria Coast MCZ and St Bees SSSI which we welcome. WCM state that “Given the small predicted seabed height changes, the slow rate of subsidence and the small changes in slope, combined with the fact that subsidence will not occur over the whole mined area it is likely that impacts on statutory protected areas in the vicinity of the development (i.e. the Cumbria Coast MCZ and the Solway Firth pSPA) will be negligible”.
This does not dispel concerns over potential for subsidence of the seafloor outside of these Protected Areas which could have impacts on the benthos plus potential consequences to shoreline profile and wave heights, which could in turn result in unintended consequences that would affect these protected sites and elsewhere.Data and understanding are limited at the present time and in order to address this, WCM will commission surveys and a numerical modelling study to more accurately predict the potential impacts, if any, of subsidence on the intertidal and marine environments, to be completed prior to commencement of works.
“Data will also be gathered regarding subtidal communities to determine the distribution, extent and likely responses of any potential sensitive receivers. In addition, a Marine Monitoring Plan will be implemented to monitor the bathymetry of the seabed and surficial sediments properties (including benthic communities) overlying the extraction zones using the data collected in 2016-17 as a baseline”.
NWIFCA would ask who the regulator for subsidence risk is and stress the need for further dialogue and engagement over this issue once predictions of potential impacts have been produced.
The NWIFCA have said that they “will respond formally to an MMO consultation”.
70 Subsidence – Investigation and reporting
WCM response
“Chapter 17 and the HRA did not come to a conclusion that this would occur. CCC have considered this 3 times and have not sought such a condition”
RFL response
It was assumed by the NWIFCA, the County Council and NGOs that the subsea impacts of this coal mine would be scrutinised by a Marine Management Organisation consultation. The onshore impacts from subsea mining induced seismicity and subsidence ( including radiological impacts and the question of who is liable should the “expected subsidence” result in resuspension of Sellafield’s wastes from the mud patch) would be one of the issues given scrutiny in a public consultation by the MMO. However, WCM have said that they “may not need” a MMO licence. What is the evidence for this statement? Has a pre- licence application been submitted behind closed doors ?
71 Subsidence – Mitigation
See above.
Refs
North Western Inshore Fisheries and Conservation Authority
Ref No: 4/17/9007 RE: Consultation on Further Information submitted in relation to a Mineral County Matter Application for Planning Permission accompanied by an Environmental Statement 29th January 2018 – full document attached“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.”
Drinking Water Boreholes at South Egremont https://www.eib.org/attachments/registers/72189417.pdf
Note: Planning loop hole and WCM -Onshore conditions are the responsibility of Cumbria County Council’s Mineral Planning Authority https://cumbria.gov.uk/planning-environment/DC/dc.asp and marine conditions are the responsibility of the UK Government’s Marine Management Organisation https://www.gov.uk/government/organisations/marine-management-organisation from whom WCM say they “may not need a licence”
The result of this would be that the seismic and subsidence issues having not been addressed by Rule 6 Parties in the Planning Inquiry will also not receive any scrutiny in a public consultation from the Marine Management Organisation. The Mineral Planning Authority of Cumbria County Council has the responsibility to manage conditions for any onshore effects and harms resulting from Woodhouse Colliery should Michael Gove approve the mine. But if their source of origin is subsea, the local planning regime outsources responsibility to the UK government’s Marine Management Organisation, from whom the developers clearly expect a rubber stamp.
If a rubber stamp is to be issued by Government (who employ the coal boss as a nuclear waste ‘disposal’ advisor at the Committee on Radioactive Waste Management https://www.gov.uk/government/people/mark-kirkbridg) it is imperative that a seismic Traffic Light System for the Woodhouse Colliery is implemented. The TLS should be at least as stringent as that for fracking.
“MORALLY INCOHERENT”
In his statement to the Planning Inspector, the independent speaker and writer, formerly UK climate envoy 2006-12 John Ashton CBE included the following points. https://www.itv.com/news/border/2021-09-08/cumbria-coal-mine-inquiry-evidence-from-day-two
: “it is also dysfunctional that the terrestrial and marine dimensions are being considered separately.
I understand the procedural reasons. But it is the consequences of the project as a whole that will shape the lives of those in the firing line. It is both intellectually and morally incoherent, as well as administratively inefficient, to subdivide those consequences: to consider the climate implications, for example, without looking at the risks arising from the destabilization through subsidence and seismicity of Sellafield waste on the seabed above the mine.” Although the former UK Climate Envoys’ statement was widely reported the points he made on seismicity and subidence never made it into the headlines.
Keep Cumbrian Coal in the Hole 