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.
Keep Cumbrian Coal in the Hole 