CALL IN THE CRAZY CUMBRIAN COAL MINE DECISION! DEMO and PETITION HAND OVER – 10th APRIL in LONDON

Dear Friends,

*Thank you*  to everyone who wrote to Cumbria County Council about their shocking decision to approve deep mining under the Irish Sea.

The next step is to ask the Secretary of State to call in the decision. 

Tim Farron MP has done thisand I have also written on behalf of Keep Cumbrian Coal in the Hole to the Secretary of State to ask that the decision by Cumbria County Council approving the Coal Mine is Called In.

The more people and groupsthat write and request that the Secretary of State calls in the decision made by Cumbria County Council on 19th March, the better.

In fact, a show of force may demonstrate the strength of feeling against the mine.  The letter should be addressed to James Brokenshire MP, the Secretary of State. james.brokenshire@communities.gsi.gov.uk.

Re: Application Reference No. 4/17/9007 – Former Marchon Site, Pow Beck Valley and area from Marchon Site to St Bees Coast, Whitehaven, Cumbria

Our full letter is below – but you don’t need to write that much – the main point to make is that West Cumbria Mining has not given figures on CO2 Emissions with no independent assessments and there has been no detailed scrutiny or debate on the close proximity of deep mining to Sellafield’s high level radioactive wastes

ALSO

The petition has been updated to request that James Brockenshire MP, Secretary of State Calls In the Decision.

DEMO AND PETITION HAND OVER ON WEDNESDAY 10th APRIL 2-4 pm

OUTSIDE the MINISTRY OF HOUSING, COMMUNITIES & LOCAL GOVERNMENT

2 Marsham Street
London
SW1P 4DF
United Kingdom

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

 

LETTER TO THE SECRETARY OF STATE From KEEP CUMBRIAN COAL IN THE HOLE

james.brokenshire@communities.gsi.gov.uk

The Rt Hon James Brockenshire MP,
Secretary of State for Housing, Communities & Local Government, Ministry of State for Housing, Communities & Local Government, 2 Marsham Street,
London SW1P 4DF.

3rd April 2019

Dear Secretary of State,

Re: Application Reference No. 4/17/9007 – Former Marchon Site, Pow Beck Valley and area from Marchon Site to St Bees Coast, Whitehaven, Cumbria

I write on behalf of Keep Cumbrian Coal in the Hole, a campaign by Radiation Free Lakeland to ask that the Secretary of State calls in the above decision.

We are a civil society group that aims to remove the risk of environmental damage both nationally and internationally that may arise from the presence of an extensive nuclear industry close to the Lake District National Park, a World Heritage Site.

On 19th March Cumbria County Council (CCC) granted conditional planning permission for a resumption of the long abandoned onshore coal mining at St Bees to West Cumbria Mining Limited (WCM).

The applicant has confirmed that their onshore proposal is commercially dependent upon the extraction of coal from under the adjacent coastal waters of the Irish Sea for which they would need agreement from the Marine Management Organisation.

Our concerns primarily relate to potential cross boundary radiation impacts resulting from damage to Sellafield as a result of aggressive deep mining activity in methane rich coal beds and freshwater extraction to wash the coal (from a geological fault). We are, however, also concerned about wider environmental impacts arising from the mine, including climate change.

We support the call in by Tim Farron MP, and we refer you to the climate scientists and experts (Dr Laurie Michaelis, Dr Henry Adams and others) who have outlined the cross boundary climate impacts that would result from this mine (impacts as outlined by the Climate Change Act 2008).

We request the Secretary of State calls this application in for his own determination on the basis that the proposal fulfils the following (Caborn) criteria for call-in:

1. The proposal conflicts with national policies on important matters

We refer to paragraphs 205, 211, 7 and of the National Planning Policy Framework (NPPF) 2019.

NPPF Paragraph 205 states: When determining planning applications, great weight should be given to the benefits of mineral extraction, including to the economy” except in relation to the extraction of coal, in which case reference is made to paragraph 211.

Paragraph 211 states: Planning permission should not be granted for the extraction of coal unless:

a) the proposal is environmentally acceptable, or can be made so by planning conditions or obligations; or

b) if it is not environmentally acceptable, then it provides national, local or community benefits which clearly outweigh its likely impacts (taking all relevant matters into account, including any residual environmental impacts).

It is our view that the proposal cannot be made acceptable by planning conditions or obligations and that any national, local or community benefits do not outweigh the likely impacts.

We also refer the Secretary of State to key paragraphs of the NPPF concerning sustainable development (as set out in paragraphs 7-14).

We also refer to a paper published by the Interdepartmental Liaison Group on Risk Assessment (ILGRA), in 2002 entitled The Precautionary Principle: Policy and Application. This paper highlighted a number of important points including noting that the precautionary approach should be invoked when: there is good reason to believe that harmful effects may occur to human, animal or plant health, or to the environment; and the level of scientific uncertainty about the consequences or likelihood of the risk is such that best available scientific advice cannot assess the risk with sufficient confidence to inform decision-making.

The proposal potentially conflicts with paras of the NPPF concerned with *Meeting the challenge of climate change, flooding and coastal change* (see pages 44-45).

2. The proposal could have significant effects beyond their immediate locality; give rise to substantial cross-boundary or national controversy. We draw your attention to the close 8km proximity of this coal mine to Sellafield’s uniquely dangerous storage of high level wastes and highly active liquors (see Consequences in Norway of a hypothetical accident at Sellafield: Potential release – transport and fallout Strålevern Rapport 2009:7. Østerås: Norwegian Radiation Protection Authority)

Cross boundary impacts: For example, there is no guarantee that subsidence will not occur following mining and backfill of the voids with a cement mix. If subsidence does occur, there is a significant risk that highly carcinogenic and dangerous radioactive and chemical sediment and silt will be re-suspended from the Irish Sea bed and mobilised with the tides not only to Cumbrian beaches but also to European beaches (and beyond). Similarly, mining and freshwater abstraction from faults is known to increase seismic activity. It is significant that the only area of the UK ever to experience a liquefaction event from a minor seismic event is a small village not far from Sellafield in the 1800s. A recent paper published by the Yorkshire Geological Society (The susceptibility of glacigenic deposits to liquefaction under seismic loading conditions: a case study relating to nuclear site characterization in West Cumbria by Martin Cross, Anass Attya and David J. A. Evans Proceedings of the Yorkshire Geological Society,18 September 2018) found that Sellafield and its surrounds are at “high risk” of liquefaction.

If a liquefaction event happened at Sellafield as a result of mining the consequences would be catastrophic, not just for Cumbria but for the rest of Europe. Given the catastrophic radiological impacts that a seismic event at Sellafield induced by nearby coal mining could have on other EU countries this proposal is potentially subject to Article 37 of the Euratom Treaty. Article 37 requires Member States to provide the Commission with general data so that they may give an opinion on whether the proposal is likely to have an impact on other Member States. Post Brexit we hope that this protection afforded to other European Countries is honoured.

Keep Cumbrian Coal in the Hole has a following of approximately 1500 supporters including academics and scientists. We have been campaigning to raise awareness about this development since 2015. In 2016 Radiation Free Lakeland received a personal letter of thanks for our ongoing civil society work in nuclear safety from Austria’s Federal Ministry of Agriculture, Forestry, Environment and Water Management who are equally concerned at the danger Sellafield poses to Europe even without deep coal mining under the Irish Sea.

Finally, we would also highlight that there remains a significant question about the extent of the climate change impacts arising from this scheme (even if coal used in steel production, there will be CO2emitted). In this respect, we note the purpose of the power under s.77 Town and Country Planning Act 1990 is to give the Secretary of State the power to call in planning applications where he considers that this is *necessary or desirable in the national interest* (R. (on the application of Adlard) v Secretary of State for the Environment, Transport and the Regions[2002] 1 WLR 2515). We would submit this is clearly one such case.

In light of the above, we urge the Secretary of State to call this application in for his own determination at the earliest opportunity.

Yours sincerely,
Marianne Birkby
On behalf of Keep Cumbrian Coal in the Hole A Radiation Free Lakeland campaign

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

 

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Polar Bear Urges Freeze on Coal Mine Plan

Polar bear.jpg

Whitehaven News .jpg

Last Friday 22nd February the Keep Cumbrian Coal in the Hole ‘Polar Bear’ highlighted the Beyond Crazy plan to mine for coal under the Irish Sea.  A photographer from the Whitehaven News met us at the train station in the town to walk up to the Haig Pit.

Everyone in the town we spoke to was opposed to the mine, some of the comments we heard were: “its a backward step”  “its too near Sellafield, too dangerous”.  This was all witnessed by the photographer from the Whitehaven News and shows the distance between the truth and the enthusiastic PR we have seen from West Cumbria Mining and those with an unaccountable (?) vested interest in seeing deep mining become ‘a thing’ once again in West Cumbria.  We also spoke to folk who live opposite the Haig Pit and their view is : “We don’t want it.”

The Whitehaven News reported : “The ‘polar bear’ was actually Sam Morris who, along with Marianne Birkby of the Keep Cumbrian Coal in the Hole campaign, was protesting against West Cumbria Mining’s plans to extract coking coal off the coast of St Bees.

“The pair tore up a copy of the Paris Agreement – a global agreement to tackle climate change – outside the developer’s Whitehaven office.

They believe the application goes against the agreement and Cumbria County Council’s Carbon Reduction Plan and Climate Local programme and that the mine’s proximity to Sellafield would increase the risk of earth tremors. They also claim mining under the Irish Sea could re-suspend radioactive particles from decades of Sellafield reprocessing and argue that there are other ways to produce steel.”

In response to our protest the developers replied to the local press that : 

“The WCM planning submission clearly sets out and responds to all of the questions raised by external parties over the last three years and provides clear scientific evidence based responses to all of these points, clearly demonstrating that there are no risks or significant impacts from the scheme.”   

Really?  The fact that this must be the most deferred planning application to go before Cumbria County Council ever, rather belies this statement.  The reason for the delays are that the Council, and the regulators are not happy with the content of WCM’s application and require further clarification and answers from the developers.

What can be clarified is that this development is Beyond Crazy while the rest of the world looks Beyond Coal.   A recent document handed to Keep Cumbrian Coal in the Hole (below) gives some insight into the climate impacts and the deaths that would result from opening up this deep coal mine.

52611734_2495185493842080_7478466973567811584_n.jpg

Meanwhile, the impacts on Sellafield are of course unquantifiable – an increase in seismicity in the area housing such a vast stockpile of the world’s most dangerous radioactive wastes is unthinkable.

There is a Petition To Sign Here – Please Sign and Share and lets give Cumbria County Council the message that this dangerous coal mine is not wanted

How To Write to Cumbria County Council and tell them to Keep Cumbrian Coal in the Hole

white and black moon with black skies and body of water photography during night time
Irish Sea – the scene of the first deep coal mine in the UK in 30 years?   (Photo by GEORGE DESIPRIS on Pexels.com)

The consultation period ends on January 28th,  Cumbria County Council will still accept letters after this time but the sooner you write the better.

Send your email now to Cumbria County Council at developmentcontrol@cumbria.gov.uk.

Please also ask if you can speak at the meeting on the 22nd February – the more folk who write, speak and make a noise against this plan the better chance we have of stopping it.

Please remember to include the planning application reference number PL\1689\05 (4/17/9007) and your postcode in the subject.

The main points to make are

  • This  coal mine proposal flies in the face of Cumbria County Council’s Carbon Reduction Plan and Climate Local programme.
  • The mine workings would extend to within 8km of Sellafield, this would increase the risk of earth tremors and worse.
  • Collapse of the sea bed as a consequence of mining under the Irish Sea would resuspend radioactive particles from decades of Sellafield reprocessing.

 

Here below is an excellent letter from Sam who is a member of Radiation Free Lakeland.  Feel free to use this as inspiration to write your own letter of objection.  It doesn’t need to be long – just a sentence or a paragraph or two.

To Rachel Brophy, Development Control, Cumbria County Council

Jan 8th 2019

WOODHOUSE COLLIERY, APPLICATION 4/17/9007

In response to the current consultation I wish to make the following comments regarding the revised Environmental Statement from West Cumbria Mining [WCM]. This letter is additional to my submission of Feb 6th 2018.

I am writing to raise serious concerns concerning climate change, subsidence, earth tremors and the potential to trigger a major nuclear emergency at Sellafield.

I wish to OBJECT to the application.

I wish to raise four major grounds on which this application must be firmly rejected.

  1. The 2008 Climate Change Act

The revised Environmental Statement fails completely to address the UK Government’s commitments to carbon reduction within the 2008 Climate Change Act and the increasingly stringent restrictions regarding the extraction and burning of fossil fuels.

WCM state that 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 (reject).    (annually!)

WCM continue to refer to ‘metallurgical’ coal as if this is in no way related to the coal used in energy generation.   The simple facts of physics are that all coal produces CO2 when burned for whatever purpose.

WCM seem to be completely unaware of the global urgency of reducing carbon emissions. The proposal to open a new coal mine in our current precarious climate change situation is completely counter to Government policy.

  1. Subsidence, earth tremors and nuclear accident/emergency.

I have written to The Office for Nuclear Regulation [ONR] regarding the application.   In response to my letter they state –

‘ONR ask to be consulted on developments within the off-site emergency planning area around the Sellafield site, which extends approximately 6.1 – 7.4 km from the site centrepoint (see http://www.onr.org.uk/depz.htm for further details).  We would not expect Cumbria County Council to consult us regarding developments outside this zone, and I can confirm that we have not been consulted.’

map WCm.jpg

This ONR map shows the offsite emergency planning zone around Sellafield.   This shows the area where planning consultation with ONR is required.

The ONR state that Woodhouse Colliery would be approx. 10 km from Sellafield. WCM state the mine would reach within 8km of Sellafield. Which is correct? Surely it is essential to know exactly what the distance may be.

Even more crucially – this is not a mere surface development – the WCM application concerns undersea mining in an area known to be heavily faulted.

The nature of underground earth tremors and minor quakes is that they travel in unpredictable ways through the rock. Earth tremors have no regard for the 7.4 km exclusion zone drawn on the map.

The geology that WCM plans to mine is completely connected to the geology underneath Sellafield. That the mine would be outside the formal ONR planning zone by up to 4km is completely irrelevant given the unpredictable nature of earth movements.

Any earth tremor caused by mining or subsidence would have catastrophic effects in terms of a nuclear emergency bringing massive danger to life over a vast area.

  1. Potential collapse of the mine.

The ONR state – ‘The nature of the proposed mine (pillar and room) is one that is not designed to collapse at any point in the future, unlike for example long wall mining.   Even in the highly unlikely event of a collapse, the nature of any ensuing earth tremors would be limited to very low levels.  These levels would not be felt by persons on the Sellafield site and would not disrupt structures, systems and components important to safety on the site. ‘

This is a very worrying response. Firstly ONR states that they believe that the mine is not designed to collapse – then they state that if it did so it would not affect nuclear safety.

IMG_3707.png

‘Pillar and Room’ mines can and do collapse.

Crandall Canyon Accident Investigation
Summary and Conclusions On August 6, 2007, six miners were killed in a catastrophic coal outburst when roof-supporting pillars failed and violently ejected coal over a half-mile area. Ten days later, two mine employees and an MSHA inspector perished in a coal outburst during rescue efforts.

https://miningawareness.wordpress.com/2018/12/30/murray-energys-crandall-canyon-coal-mine-disaster-9-deaths/?fbclid=IwAR3O7nI2ICJCp9qFoMNvPTF3noiDeGly_rGtL6XaRmsJLVt0gXmEiqCc_BA

In the event of a mine collapse at Woodhouse the potential for injury and death would reach well beyond the mine shaft itself. Radioactive accidents at Sellafield could affect much of the UK and neighbouring nations.

There is a major inconsistency here as the ONR believe the mining process to be ‘pillar and room’ while the WCM website states –

‘Run-out and Pocket extraction will be the chosen mining method as this is a proven, highly versatile coal mining method that takes advantage of advancements in mining technology to mitigate risks associated with the Cumbrian Coal fields.’

How can this application possibly be agreed given that WCM and the ONR are clearly not operating on the same basis regarding the basic mining method and associated risks?

It is telling that WCM themselves are acknowledging the very real risks of the Cumbrian coal fields and are seeking to ‘mitigate’ them.

This is a glaring inconsistency and indicative of the wrong footed nature of this entire application.

What Nuclear Emergency Plans are in place by the County Council should tremors damage the containment vessels at Sellafield?

  1. Formal assessments of likely subsidence damage have proved to be very wrong

There are big lessons to be learned from the fracking industry at home and abroad.

Groningen in the Netherlands is Europe’s biggest gas field. The Netherlands Government has recently decided to close it down leaving billions of euros of gas in the ground. So far 80,000 homes have been damaged, families are living in sheds and schools are closed.

In the UK the Governments Oil and Gas Authority [OGA] has allowed fracking in Lancashire to proceed with the ‘traffic light’ system of monitoring tremors. Since fracking recommenced in autumn 2018 there have been over 30 Lancashire quakes recorded by the British Geological Society.     Many of these quakes causing shut down of production.   The UK OGA has said – ‘it is rare for damages, even cosmetic ones, to occur at magnitudes of less than 4.’

The truly frightening aspect of this is that ALL of the Groningen quakes measured less than 4. The Netherlands Government had insisted that they were harmless, yet the damage stands at 8 billion euros so far and the closure of the industry.

Groningen had few geological faults or earth tremors before the extraction began.   West Cumbria has a history of both faults and of tremors.

https://www.channel4.com/news/why-the-dutch-are-ditching-gas-extraction

 

CONCLUSION

The nature of subsidence and earth tremors is by nature unpredictable.

What is certain is that this constitutes a very real potential.

The damage caused in the Netherlands by allegedly ‘safe’ levels of tremor would result in radioactive mayhem were such tremors to occur in West Cumbria where we have Europe’s largest collection of deadly nuclear waste.

This potential risk of a nuclear accident/emergency is simply too great a risk.

There is no way that Cumbria County Council can possibly assure the public safety of this proposed mine and the application must be firmly rejected.

 

Sam Moisha

Member of Radiation Free Lakeland

Rebel Against Double Whammy Extinction Event in Cumbria: Coal & Nuclear

Extinction Rebellion seems to be very much in the news just at present.   Here in Cumbria we have our own terrifyingly real threat of extinction.     Not only is there Sellafield with its deadly collection of nuclear waste – we also have an ongoing planning application for a new coal mine reaching under the sea to within 5 miles of the nightmare nuclear site.

West Cumbria Mining have an active planning application with Cumbria County Council to open the first deep coal mine in 30 years.       Given the urgent need to cut carbon emissions this is total madness.   Given the proximity to Sellafield of mining operations, known to cause earth tremors, the proposal does threaten very real extinction here and now.

As far as we can ascertain from the documents available on the Cumbria County Council’s website there has been no consultation with Sellafield concerning the risks of a major nuclear emergency. Seismic disturbance affecting Sellafield would be a very rapid extinction of all life forms within a very wide radius.   And wherever the wind blows. EXTINCTION IN CAPITAL LETTERS ON A HUGE SCALE.

And then there is the carbon.     West Cumbria Mining [WCM] have a way of describing their proposal as the extraction of metallurgical coking coal for the steel industry – implying that somehow the burning of this fossil fuel is somehow different to burning fossil fuels for energy generation.

Burning coal is burning coal – and WCM plan to extract 2.8 million tonnes of it every year during the lifespan of the proposed mine.  Assuming a 40 year life (following construction), and an average of 2 million tonnes a year, that is a total production of 80 million tonnes!

In terms of the Paris agreement and the current Katowice discussions this application must be stopped.

The WCM application and the many letters of concern and objection can be found at https://planning.cumbria.gov.uk/     The Application reference is 4/17/9007

Anyone wishing to comment can write to Rachel Brophy, Senior Planning Officer rachel.brophy@cumbria.gov.uk

The WCM planning application was made in mid 2017. It has been postponed and postponed and postponed by Cumbria’s Planning Committee during all of 2018.   It may, or may not, come to Council early in 2019.

We need to be as vocal and as visible as we can possibly be in opposing this hideous proposal.   It is a very real threat to life on an unimaginable scale far larger than the threat to Guillemots that the RSPB has limited its comments to.

We have with the help of top lawyers Leigh Day ensured that we may still have a chance to stop the plan should Cumbria County Council say yes to this diabolic fossil fuel development.  But lets MAKE SURE CUMBRIA COUNTY COUNCIL SAY A BIG FAT NO!!!

 

MORE INFO

This application may be decided on these dates (tbc)  in the new year by Cumbria County Council’s Development Control and Regulation Committee at County Offices, Kendal

18 Jan 2019 10.00 am

22 Feb 2019 10.00 am

The WCM application and the many letters of concern and objection can be found at https://planning.cumbria.gov.uk/     The Application reference is 4/17/9007

Anyone wishing to comment can write to Rachel Brophy, Senior Planning Officer rachel.brophy@cumbria.gov.uk and ask that your letter is sent to all members of the Development Control and Regulation Committee.

Or write to all members of the Development Control and Regulation Committee – their contact details can be found here

WRITE, PHONE, EMAIL, MAKE A BIG NOISE

 

RSPB - St Bees Black guillemot

New Coal Mine Would be a Myriad of Threats – Letter in the Westmorland Gazette

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Oppose the coal mine plan – letter in the Westmorland Gazette

The new coal mine proposed under the Irish Sea is ‘not a threat’? (Letters July 5) True, it is not just one threat! Like a many headed hydra it promises a myriad of threats to wildlife, health, climate and the safe stewardship of Sellafield.

Despite this myriad of threats. Kent Brooks’ letter of support for the mine is evidence that the PR for this plan has been astonishingly successful.

So what is the threat to wildlife?  RSPB and others have pointed out that the development has the potential to have an adverse effect upon the St Bees Head Site of Special Scientific Interest. through disturbance to breeding birds during excavations and coal processing.

The impacts from this vast mine on Cumbria’s troubled water resources and hydrology are also of great concern to human welfare, as well as that of wildlife.

What about the climate impacts that Kent Brooks believes are non existent?  At a production rate of 2.8Mt/year the produced coal would generate 1.24Mt/year CO2.

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.

Kent Brooks says he does not understand why nuclear safety campaigners are so concerned about this plan.

This is why we are concerned –

at just 8km away from Sellafield (even nearer to Moorside) according to West Cumbria Mining, this development is ridiculously near to more than 140 tons of plutonium.

Increased tremors and quakes resulting from mining are well documented. Also well documented is the fact that there are large holding tanks at Sellafield containing thousands of litres of extremely radiotoxic fission products.

As well as nuclear wastes on teh Sellafield site there are radioactive wastes on the Irish Sea bed from ongoing and historic discharges.

Don’t take my word for it. All these threats can be read about on the submissions to Cumbria County Council on their website under planning application reference 4/17/9007.

Please do write to CCC before mid August and make your voice heard in opposition to this new coal mine plan which threatens Cumbria in a myriad of ways.

Marianne Birkby

On behalf of Keep Cumbrian Coal in the Hole

NOTE: The planning meeting has been deferred again until the Autumn – so more time to get your objections in!  You can write to the Senior Democratic Services Officer quoting planning application reference 4/17/9007 West Cumbria Mining

Email       Jackie.Currie@cumbria.gov.uk

 

STOP PRESS – COAL MINE PLANNING DECISION DELAYED AGAIN! TILL AUTUMN

Sellafield from St Bees

St Bees looking across to Sellafield

We have just heard that the planning meeting for the first deep coal mine in the UK  that was due to be heard on August 23rd in Kendal has been delayed yet again.

We have lost count of the deferments – it must be some kind of record.  We have to ask why hasn’t this dangerous mad bad plan been knocked on the head already?  Is it to embed West Cumbria Mining into Cumbrian society with its largesse and promises of jobs?   It it to soften West Cumbria up for deep mining of an altogether different plan, concerning nuclear wastes?  That may be way off course but it is a thought that has crossed many a Cumbrian mind.

So the new date – as far as we know is the autumn.

We shall continue to fight this plan and welcome all hands to the deck until the plan for the first deep coal mine in the UK in 30 years is stopped once and for all.

 

 

Fisheries and Conservation Authority Concerns: Irish Sea Subsidence and Resuspension of Radionuclides

 

Keep Cumbrian Coal in the Hole – Petition

There are many reasons to object to the plan for the first deep coal mine in the UK for 30 years.  The North Western Inshore Fisheries and Conservation Authority has voiced concerns. They highlight the following concern which is uniquely perilous to this area of the Irish Sea:

“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.”

Keep Cumbrian Coal in the Hole along with others have also highlighted this specific concern and would draw the Development Control and Regulation Committee’s attention to this photograph supplied to us by the Low Level Radiation Campaignsellapart04337.JPG

This is what radiation does to plastic

The centre of this image shows radiation tracks from a particle found near Sellafield. This is what radiation does to plastic. The Low Level Radiation Campaign tell us “it’s probably Plutonium, and about 1 micron diameter. Official reports since 1989 state that the Bristol Channel contains radioactivity from Sellafield. Since 1965 Hinkley Point also has discharged particles. Evidence that particles like this are present in the sediment has been covered up. When inhaled they are likely to be scavenged to lymph nodes. They deliver high doses of radiation to whatever body tissue they lodge in.”  Plutonium is found being washed up on West Cumbrian beaches from radioactive wastes discharged to the Irish Sea from Sellafield reprocessing.  Seabed subsidence would dramatically increase the “natural”  resuspension of Sellafield wastes from the seabed.

More from the North Western Inshore Fisheries and Conservation Authority below.

“The North Western Inshore Fisheries and Conservation Authority is the relevant body for the regulation of inshore sea fisheries within its District. It has a range of duties including sustainably managing the exploitation of sea fisheries resources and balancing the social and economic benefits of exploiting resources with the need to protect the marine environment.

Issues of concern to the NWIFCA regarding potential impacts on the coastal and marine environment relate to all marine and coastal areas located near to the project that could be impacted, not just Marine Protected Areas (MPAs) – Natura 2000 sites, SSSI and Marine Conservation Zones in this case. There are legal procedures for assessing risk and impacts on protected sites and obligations for minimising / mitigating against these risks. However NWIFCA would ask that assessments take a broader approach and consider any risk posed to all of the coastal / marine environment within the zone of effect.

Details of many of the aspects of the development are naturally currently relatively sketchy and it is therefore not possible to provide in-depth response. However at this stage there are areas of concern highlighted below.

Issues of particular concern are outlined as follows:

  1. Dewatering of mine and discharge – will require an environmental permit to discharge from the Environment Agency. The level of pre-discharge treatment that the water will require and the discharge limits are yet to be set, and require more detailed assessment of the chemistry of the water within the anhydrite mine. It is noted that West Cumbria Mining is also to carry out a series of modelling and assessments of impact of the water on the marine environment.The documentation states that “At this stage it is not possible to model how the discharged water will disperse, and therefore it is not possible to accurately predict what effect there might be on the local” … fish and invertebrate life.

    Until this data is obtained, firmer proposals are put forward and dispersal modelling has been completed the NWIFCA will continue to have serious concerns about the risk posed by contaminated water affecting coastal and marine environments and would request full continuing consultation and engagement with EA permitting over this aspect of the mine development.

    It is noted that WCM will conduct a wide-ranging marine environmental baseline monitoring study in support of the application to be made to the Environment Agency for a Permit to Discharge the mine water to sea. NWIFCA would request early sight of the study’s results to assist in our future responses.

    It is understood that the water taken from the anhydrite mine will be subject to continuous monitoring, to ensure that it continues to meet the water quality standard set by the Environment Agency. NWIFCA would request it is fully engaged in discussion over the nature of the monitoring subject to results of the water chemistry and assessed level of risk.

  2. Position of the discharge pipeline and diffuser – will be subject to an MMO Marine Licence application at which point NWIFCA will respond formally to an MMO consultation. Until more detailed particulars are decided for pipeline specification and position NWIFCA reserves concerns over impacts on coastal and intertidal habitats and species.At this stage NWIFCA would ask that the design ensures that all outfall pipeline discharge is below the lowest astronomical tide to prevent risk of impact on intertidal areas.
  3. Further potential impacts on coastal and marine systems could be impacted by the following during construction of the mine and its associated infrastructure:
    1. Physical mobilisation (such as soil erosion, run-off and sediment deposition);
    2. Disturbance of existing contaminated soils during earthworks or increased infiltration;
    3. Leaching once the soil is removed and areas of open excavations are exposed.

    The NWIFCA notes that construction works will be managed under a Construction Environment Management Plan (CEMP) that will be developed post-planning determination, and would request early sight of the plan once drafted. As above NWIFCA reserves concerns over the risk of contaminated water reaching the coastal and marine waters until further detail has been put forward.

  1. Storm water discharge – NWIFCA has learned from the documentation that during the operational phase, the anticipated discharge of excess storm water flows from the site into the sea via the existing outfall has the potential to provide a pathway for contaminants into the marine environment. These flows will be sporadic and unpredictable in nature. WCM state that drainage and water treatment infrastructure on-site will be designed to ensure that storm flows are passed through silt traps and oil interceptors and to enable flows to be discharged at a controlled rate to ensure that any significant influx of storm water into the marine environment does not occur.As a result WCM consider that the risk of the storm water discharge leading to adverse operational phase effects are considered be negligible. An Environmental Permit for this discharge will be required and NWIFCA deigns to Environment Agency advice on this point.
  2. Offshore Subsidence – 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.

  3. 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.