URGENT – KEEP CUMBRIAN COAL IN THE HOLE

An Urgent Request from Keep Cumbrian Coal in the Hole

– Please Send Objections into Cumbria County Council to Make Sure we STOP the First Deep Coal Mine in the UK for 30 years. Below is an objection from Keep Cumbrian Coal in the Hole.   Please feel free to amend, adapt or just generally use as a starting point for your own objection. It doesn’t need to be long – just a sentence or two would do to let Cumbria County Council know that you oppose the plan.  Every letter of objection is a step nearer to stopping the plan!

Send Emails to

Rachel.Brophy@cumbria.gov.uk   in the Subject put : Wood House Colliery 4/17/9007

If you have time please do also tell the Development Control Committee how you feel too! They will be making the decision on March 7th in Kendal  http://councilportal.cumbria.gov.uk/mgCommitteeDetails.aspx?ID=124

Letters to be in before 19th February to stand a good chance of being included in the report to Council – but you can object up until the planning meeting on the 7th March

 

To Rachel Brophy,

Development Control Team, Cumbria County Council

Woodhouse Colliery, Application Number 4/17/9007

West Cumbria Mining [WCM]

KEEP CUMBRIAN COAL IN THE HOLE

On July 2nd 2017 Radiation Free Lakeland wrote to the Leader of Cumbria County Council to vehemently oppose the plan for the first deep coal mine in the UK in 30 years.

I am writing again on behalf of Keep Cumbrian Coal in the Hole which is a Radiation Free Lakeland campaign, to add further comments, and also ask to be allowed to speak on behalf of Keep Cumbrian Coal in the Hole.

Reasons to Refuse this application include:

  • Proximity to Sellafield
  • Hydrology Impact
  • Wildlife Impact
  • Seabed Subsidence
  • Methane Emissions
  • Carbon Emissions
  • Health Impacts

PROXIMITY TO SELLAFIELD

SellafieldPondajpg.jpg

The B30 pond showing a full loading of spent fuel rods

A recent article in The Ecologist magazine highlighted the proposed mine’s close proximity to this dangerous stockpile of plutonium:

“The potential for earth tremors and quakes resulting from mining is well known. Even if the tremors were small that is too big a risk to take in the vicinity of Sellafield.”  High intensity and liquefaction phenomena like that experienced at Christchurch in New Zealand are usually associated only with relatively large magnitude earthquakes. An earthquake in 1865 in the northwest of England (Rampside) suggests that a sufficiently shallow small event can also produce liquefaction. The Ecologist reported that: “Especially serious are the ~20 large holding tanks at Sellafield containing thousands of litres of extremely radiotoxic fission products.” Discussing these tanks, the previous management consortium, Nuclear Management Partners, stated in 2012: “There is a mass of very hazardous [nuclear] waste onsite in storage conditions that are extraordinarily vulnerable, and in facilities that are well past their designated life”The National Audit Office (NAO) stated these tanks pose “significant risks to people and the environment”.

One official review published in The Lancet concluded that, at worst, an explosive release from the tanks could kill two million Britons and require the evacuation of an area reaching from Glasgow to Liverpool. This would negate Cumbria County Council’s strategic objective of avoiding adverse impacts from developments (Objective 2, Cumbria Minerals and Waste Local Plan 2.27)

HYDROLOGY

the-beautiful-river-ehen-about-to-be-nuclearised.jpg

The River Ehen runs alongside the Irish Sea

West Cumbria’s domestic fresh water supplies are already stressed with the halting of abstraction from Ennerdale to protect the river Ehen (Sellafield will continue to abstract from the Ehen for cooling and processes).

People in West Cumbria have experienced problems with borehole water being added to their supply. The vast discharge of water required to dewater the old existing and newly opened mines would inevitably impact on West Cumbria’s fresh water supply.   “The history of contamination of watercourses in the areas raises concerns for some local residents in relation to the impact of the development on the complex hydrology of the area.” Colourful Coast Partnership. This flies in the face of NPPF and Cumbria County Council’s own Minerals and Waste Plan to have regard for provide for public health (2.25).

WILDLIFE IMPACT

RSPB - St Bees Black guillemot.jpg

“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.” National Trust

“ The application site is in proximity (Solway Firth 1.5km) to a European designated site (also commonly referred to as Natura 2000 sites), and therefore has the potential to affect its interest features.”Natural England

“The impact of any level of subsidence upon the terrestrial or marine heritage assets and designated sites and landscapes could be significant and permanent, therefore having a detrimental impact ..The history of contamination of watercourses in the areas raises concerns for some local residents in relation to the impact of the development on the complex hydrology of the area.” Colourful Coast Partnership

Our position is to object to the proposed development on the grounds of the adverse impact on groundwater, surface water and biodiversity.”Environment Agency

St Bees “supports England’s only breeding black guillemot – which are small in number and already vulnerable to stochastic events.” “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.”   RSPB

It is clear from objections by the Colourful Coast Partnership and those quoted above (this is just a selection, there are many more) that Biodiversity would be adversely impacted on by this development. This runs counter to NPPF policies and Cumbria County Councils own Minerals and Waste Local Plan (2.25)

SEABED SUBSIDENCE

As previously noted seabed subsidence is an issue that would have environmental consequences anywhere. Close to Sellafield the environmental consequences of seabed subsidence have far wider implications. This includes the possible resuspension of many decades worth of radionuclides that are currently on the Irish Sea bed as a result of Sellafield reprocessing. Long-lived radionuclides (like plutonium or americium 241 nuclides) are still accumulating in the mud at the bottom’ of the Irish Sea. Events like storm surges or seabed subsidence churn this up. Resuspended particles make their way to the beaches of Cumbria and beyond. This is intolerable and is already an issue for beaches in West Cumbria with radioactive particles being routinely found by the industry’s own beach monitoring system (which stops in the school holidays).

ArgocatFinds.jpg

Monitoring West Cumbrian beaches for radioactive particles – thousands are found and ‘retrieved’…

Knowingly creating the conditions for seabed subsidence from undersea coal mining runs counter to Cumbria County Council’s own policy of “risk reduction” regarding radioactive wastes.   The Irish Sea Bed should be treated with care as it acts as a saucer like container for the many decades worth of radioactive wastes which are best left undisturbed.

METHANE EMISSIONS

The fossil fuel industry’s methane emissions are far higher than previously thought. The famous landmark “candlestick” in Whitehaven is an air vent for the “most fiery pit in the kingdom.”   “Fiery” because this area is methane rich. Last year the applicants West Cumbria Mining accidently hit a methane seam off St Bees and just five miles from Sellafield while carrying out exploratory drilling. “Local authorities, fire rescue, police and the Environment Agency were all informed.”  An explosion was averted this time. Cumbria County Council have a duty of care to make sure there is no next time.

WCM drilling rig off Fleswick bay.jpg

WCM Drilling Rig off Fleswick Bay

CARBON EMISSIONS

Cumbria County Council are the custodians of hundreds of millions of tonnes of CO2 currently safety bound up in this coal under the Irish Sea. The developers are pushing the “need” to mine this coal for steel making. Why? There is a race on to develop ever more processes of steel making which do not involve the burning of fossil fuels. Sweden seems to be at the forefront

Worldwide the steel industry is well aware of the need to rapidly decarbonise. This is already happening with ever more steel recycling. For new steel production there are ultra-low carbon methods of steelmaking in development and soon to be deployed whether this is based on biomass, hydrogen or electrolysis.

This is happening now with some of the world’s largest iron ore producers (Brazil, China) also having the greatest potential for and commitment to renewable energy. There is no case for opening a new coal mine in Cumbria.   Cumbria County Council will have a case to answer should they facilitate the opening of this the first deep coal mine in the UK for 30 years.

Sellafield from St Bees - a stones throw!.jpg

Sellafield viewed from St Bees…a stones throw!

 

HEALTH

The old Marchon Chemical plant and Anhydrite mine that fed it feature in the WCM application. We note that the anhydrite mine would need to be dewatered. This would be reckless given that previous operations are still having a “significant” impact. “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 )

This direct assault on health is additional to well documented climate change health impacts and the intolerable danger that this mine would represent to the safe stewardship of Sellafield

We urge Cumbria County Council to turn down this application, which presents a danger to us all on many different levels.

 

Yours sincerely,

Marianne Birkby

On behalf of Keep Cumbrian Coal in the Hole

A Radiation Free Lakeland campaign

https://keepcumbriancoalinthehole.wordpress.com/

 

 

PETITION to Keep Cumbrian Coal in the Hole

https://you.38degrees.org.uk/petitions/keep-cumbrian-coal-in-the-hole-its-too-near-sellafield

 

 

Walk Tomorrow from Whitehaven to St Bees to Keep Cumbrian Coal in the Hole!

Sellafield and WCM

Tomorrow 28th Oct at 10.30am Campaigners to Keep Cumbrian Coal in the Hole will be gathering outside the Beacon Museum, Whitehaven to walk the challenging 7 miles to St Bees along the Colourful Coast.

“from the St Bees cliffs,  the only place in England where black guillemots nest, you can see the West Cumbria Mining’s test drilling rig, turn to the left and there is Sellafield.  This is a bonkers plan, the only thing worse than opening up a new coal mine, is opening up a new coal mine in close proximity to Sellafield”  Keep Cumbrian Coal in the Hole

Campaigners invite others to join them tomorrow – either to stand with banners at the start of the walk to show resistance to West Cumbria Mining’s plan or if people can, please do join us for the whole walk.

https://keepcumbriancoalinthehole.wordpress.com/2017/10/14/a-walk-from-whitehaven-to-st-bees-to-keep-cumbrian-coal-in-the-hole/

Please join us on the 28th October as we Walk to Keep Cumbrian Coal in the Hole.  This is a challenging walk  and weather dependent.  (If the weather is really inclement we will still meet at the Beacon for our photo opportunity!)

Whitehaven coastal walk to St Bees

This is a dramatic cliff-top walk.  We will be meeting at the Beacon Museum (now run by Sellafield) on Whitehaven’s historic 17th-century harbour.  The walk takes in the old Saltom Pit, the Haig Pit and the beautiful Fleswick Bay.

The cliffs of St Bees provide the only nesting site in England for the black guillemot. Although rarely seen, puffins are also believed to nest here.  This area was once teeming with wildlife.  In 2017 that wildlife is now much rarer, with many species being on the red list..what remains is so very important to protect ( not to mention our  fresh water, hydrology would be impacted upon, and health)

Trail: Walking

Grade: Hard  (muddy in parts and some parts near the cliff edge…Carefully, Slowly does it!)

Distance: 7 miles (11km)

Time: 4 hours

We will be meeting at 10.30 am  at the Beacon – we will leave no later than 11am after photos with our banners (foldable ones to put in rucksacks with picnic!)  to ensure we have plenty of time for the walk.  

Look forward to seeing you there

RSPB SLAM COAL MINE PLAN FOR CUMBRIA

Below is the RSPB’s opposition to West Cumbria Mining’s proposal for a new coal mine off St Bees.  Despite “further information” asked for from the developers the RSPB’s objections still stand (how could they not!)  It is so very bizarre that the many objections to the mine are not front page news in the national press.   There is only three months to stop the mine, if you can make a pledge towards our legal case  please do…no matter how small. 

Please join with the RSPB and Keep Cumbrian Coal in the Hole and others in objecting , please do – the more objections the more chance that the Council will say a big fat NO!

RSPB - St Bees Black guillemot

11th October 2017

BY EMAIL ONLY to:

Mrs Rachel Brophy BA(Hons) MA MRTPI Planning Officer
Development Control

Dear Mrs Brophy

Reference: 4/17/9007

Proposal: Notification and Consultation on A Mineral County Matter Application For Planning Permission Accompanied by an Environmental Impact Assessment (EIA) – Pow Beck Valley and area from Marchon Site to St Bees Coast, Cumbria

Applicant: West Cumbria Mining

Thank you for further consulting the RSPB on the above proposed development. The RSPB submitted a previous response (27th August 2017) in which we noted that some gaps in the evidence provided in support of the planning applicationhadbeenidentified. SomeoftheseomissionsmayberesolvedaspartoftheseparateMarine Management Organisation (MMO) licensing process – when a full EIA will be submitted. However, because the MMO licensing and planning application processes are not simultaneous, this causes difficulties for the Council when considering the planning application. Therefore, the RSPB agrees with Natural England’s advice that a suitable level of precaution must be adopted when considering the potential impacts of the development upon the marine environment.

We have had the opportunity to review the applicant’s documents, submitted in response to Regulation 22 notice issued by Cumbria County Council – in particular the Wood House Colliery Planning Application – Environmental Statement (ES):

  • Addendum
  • Chapter 11 – Ecology (revised)However, the RSPB’s initial opinion remains – that insufficient information has been submitted by the applicant to allowforarobustassessmentofthepotentialimpactsoftheproposeddevelopment. Ourmainareasofconcern (along with detail of further information required) are detailed below:

    The proposal has the potential to have an adverse effect upon the designated sites listed below – both during construction and operation.

  • The Cumbria Coast Marine Conservation Zone (MCZ)
  • St Bees Head Site of Special Scientific Interest (SSSI)

Direct impact upon the MCZ arising from mine wastewater discharge

Paragraph 17.28.1 states that “a temporary discharge of water from the dewatering of the anhydrite mine works is currently under discussion with regulators, including the Environment Agency, Natural England and the Marine Management Organisation. Since this will be subject to a separate application and environmental assessment for Permit to Discharge, this aspect is not considered further here”.

In particular, we would like to see further information on the composition of the mine wastewater along with a modelling of dilution.

Direct impact upon the MCZ/SSSI arising from subsidence

In our previous response, whilst accepting that the majority of excavation will not take place beneath the MCZ or SSSI, the RSPB advised that further assessment was necessary as to the potential for impacts from subsidence arising from excavation of the two proposed access zones.

We also considered that an assessment should be undertaken of the potential for vibrations/subsidence arising from construction and operation of this development to impact any weaker areas of the cliff face (through rock fall) which supports the main nesting seabird colony.

Page 75 of the Addendum: Seismicity – provides further detail as to the risk of induced seismicity as a result of mining activities. The applicant concludes 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 naturalenvironment”. WeconsideritimperativethattheCouncildeployasuitablelevelofexpertisetoensurethat 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.

Impact on the SSSI from the outfall pipe during construction and operation

Paragraph 11.11.8 states “the overland pipe, if installed, will extend from the western edge of the Application Site, and then travel across land for approximately 1km. The pipe will pass through the northern edge of the St Bees Head SSSI, before linking with the existing outfall (outside of the SSSI). Although the pipe will pass through land within the SSSI, no significant adverse effect upon the site’s interest features are considered likely. The pipe will be regularly maintained and monitored meaning the risk of any significant leakage is considered to be low. The pipe will be removed once the dewatering operation is complete (expected within 10-12 months of start of dewatering)”.

In our previous response we advised that further information/evidence was required as to how the developer has undertaken the above assessment and arrived at the conclusion of no adverse effect. We note that a botanical survey has been undertaken of the proposed pipeline corridor but it is also important that the applicant assesses the potential for the pipeline to have an impact upon nesting birds during its construction, decommissioning and operation.

Indirect effects on nesting seabirds through disturbance during construction and operation

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.

Paragraph 11.10.7 – 11.10.8 states that “coal processing during operation has the potential to create acoustic disturbance, vibrations and dust as by products from the processing operations. This has the potential to impact upon birds nesting within the SSSI to the west. To address this, the processing area will be housed within a series of large geodesic domes. No element of the process will be within the outdoor environment. Further, that specific mitigation measures will be built into the processing domes to address these potentially damaging impacts. This will include sound attenuation material within the outer structure, which will reduce transmitted noise to acceptable levels. This is described in more detail in Chapter 14 (Noise and Vibration).”

Paragraph 11.11.9 concludes that “during the operational phase of the development and in accordance within the designed mitigation measures described previously, any operational noise, vibration and dust emanating from the site and processing operations will be significant at site level only. No significant impacts arising from the working operation are anticipated to affect the St Bees Head SSSI, located 500 metres to the west”.

Paragraph 11.11.4 concludes that “no significant adverse effects arising from construction phase activity (such as vehicle movements, site clearance, and increased percussive noise) within the main development site upon statutorily protected sites within wider area, including the St Bees Head SSSI are considered to be likely”.

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.

Yours sincerely,

Christina Taylor
Conservation Officer – North East and Cumbria

Northern England Region

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A Walk from Whitehaven to St Bees …to Keep Cumbrian Coal in the Hole

guillemots5  st bees.JPG
Guillemots at St Bees

Please join us on the 28th October as we Walk to Keep Cumbrian Coal in the Hole.  This is a challenging walk  and weather dependent.  (If the weather is really inclement we will still meet at the Beacon to walk and view the original coal pit entrances)

Whitehaven coastal walk to St Bees

This is a dramatic cliff-top walk.  We will be meeting at the Beacon Museum (now run by Sellafield) on Whitehaven’s historic 17th-century harbour.  The walk takes in the old Saltom Pit, the Haig Pit and the beautiful Fleswick Bay.

The cliffs of St Bees provide the only nesting site in England for the black guillemot. Although rarely seen, puffins are also believed to nest here.  This area was once teeming with wildlife.  In 2017 that wildlife is now much rarer, with many species being on the red list..what remains is so very important and mining for coal with (just for example) damage to hydrology, risk of subsidence and seismic activity is worse than vandalism.

Trail: Walking

Grade: Hard

Distance: 7 miles (11km)

Time: 4 hours

We will be meeting at 10.30 am  at the Beacon – we will leave no later than 11am after photos with our banners (foldable ones to put in rucksacks with picnic!)  to ensure we have plenty of time for the walk. 

 

Note:

It is suggested that shared cars are left at St Bees and the train is taken to Whitehaven for the start of the walk (it is one mile from the Station to the Beacon, a 20 minute walk)St Bees to Whitehaven.jpg