Protest staged by Keep Cumbrian Coal in the Hole after the Unanimous vote by the Development Control and Regulation Committee of Cumbria County Council. Photo credit: Philip Gilligan South Lakeland CND
Summary of speaking notes from objectors to the proposed new Cumbrian coal mine.
Cumbria County Council’s Development Control and Regulation Committee met on March 19th 2019 to consider the application from West Cumbria Mining [WCM] for a new mine at Whitehaven.
The planning documents can be found at https://planning.cumbria.gov.uk/Planning/Display/4/17/9007
Providing a submission to the Committee or registering to speak at the meeting was open to any member of the public. Some of those of us who spoke on the day had not met one another before. We tried to cover different areas of objection so as many points as possible could be raised. Objectors were given 5 minutes each to speak. These are the speaking notes from the 7 people speaking to object. We have all offered our notes to be shared. We spoke in alphabetical order – so the notes are in that order.
The speakers are –
Dr Henry Adams, South Lakes Action on Climate Change
Dr Ruth Balogh, West Cumbria & North Lakes Friend of the Earth
Marianne Birkby, Keep Cumbrian Coal in the Hole, Radiation Free Lakeland
Maggie Mason, Planning expertise and experience
Dr Laurie Michaelis, IPCC author and advisor, Living Witness
Sam Moisha, Radiation Free Lakeland
Dr Stuart Parkinson, Scientists for Global Responsibility
Contact details are listed with each presentation.
5 minute oral presentation by Dr Henry Adams on behalf of SLACCtt – 13mar19 draft for 19mar19 CumbriaCC hearing on WCM Whitehaven coal mine application
Dr Henry Adams (Ecological Consultant) Home phone: 01539 722158 Mobile: 07421 309453
Link to objection letters by Henry for SLACCtt: www.bit.ly/SLACCttNOtoCOALcov
Hi my name is Henry Adams and I’m speaking on behalf of South Lakes Action on Climate Change – SLACCtt for short, which has 40 paid up members and 160 newsletter subscribers.
SLACCtt most strongly objects to West Cumbria Mining’s application because the carbon emissions it would add are so huge that they would have very significant negative consequences that would far outweigh the benefits claimed.
We’ve calculated that these emissions would be over 9 million tonnes of CO2 equivalents per year after year 4, amounting to 500 million tonnes CO2e over 50 years.
Over 1 million tonnes CO2e per year of these emissions would be within Cumbria.
This would totally undermine Cumbria’s chances of declaring a meaningful Climate Emergency to reach zero carbon emissions by 2030. This target is what all the UK must do, as a wealthy nation, for the world to be on track to at least halve carbon emissions by 2030, and means immediately and rapidly reducing emissions.
This target is vital for us to have any good chance of keeping global average temperatures below plus 1.5 degrees, and is what we’ve been strongly advised to aim for, by last October’s Special Report for 1.5 by the Intergovernmental Panel on Climate Change.
Please note that the project extends 40 years beyond 2030 when the UK must be net zero.
Rapid and urgent reduction of our carbon emissions is essential – yet West Cumbria Mining and Cumbria CC are pushing us to do the opposite, while claiming that the mine will actually result in CO2 “savings” from shorter shipping routes!
This chart combines WCMs “savings” figure with government conversion data for upstream and combustion emissions:
You’ll see that WCM’s “savings” of CO2 emissions (the blue column) are relatively minute, in fact just 1.4% of the combustion emissions of the same quantity of coking coal (in the grey column), and only about 10% of the size of emissions within the UK at Whitehaven (in orange).
Also bear in mind, that some of the combustion emissions in grey are likely to be burnt in UK blast furnaces before the latter close down, in possibly just a few years.
WCM’s claim assumes that at least 99% of the current source of coal from elsewhere abroad will be left in the ground. Yet it’s obvious that if a new source of a coal is added to the global market this will add to the total, and also add to global carbon emissions.
There is no global cap for either coking coal, or their emissions, that would ensure a new source will fully replace an existing source. Additions of coking coal would also result in a downward pressure on global prices. This would impact on the economic viability of much lower carbon new methods being developed to get steel from iron ore, and also existing lower carbon alternatives – such as electric arc furnaces powered by renewable electricity to recycle old into new steel.
Earlier this month, a High Court judge ruled that the government had acted illegally when it ignored the latest climate science when it added a paragraph in the 2018 NPPF that stated that exploiting UK shale gas would be beneficial towards a low carbon economy.
The Committee Report also failed to consider the latest climate science, and contrary to its conclusion, the proposal would produce unacceptable emissions both within the county, and at national and global levels. It could thus also be illegal as a result of the High Court precedent.
Laurie Michaelis calculated that many thousands of climate deaths would result from the CO2e emitted over 50 years. This corresponds to a minimum of tens of deaths, to many hundreds of deaths per job.
Also there’d be additional harms that would include loss and damage to habitats, species, crop-growing areas and liveable areas.
Last Friday the “Kendal School Strike for the Climate” assembled outside this building insisting that the coal mine does not go ahead. It is their lives that will be damaged, and the lives of thousands abroad in the global South ||| who contribute so much lower emissions per person than us.
||| = I was timed out totally at this point, so couldn’t add my optional extra paragraph in the box below.
On 2nd May the Committee for Climate Change report for 1.5 will be published. It will most certainly not advise for NPPF updates to allow more coal mining. If the NPPF is updated to follow the advice the mine will become a stranded asset.
Cumbria County Council Planning Committee Meeting Application: 4/17/9007 – Marchon Woodhouse Colliery
Friends of the Earth England Wales & Northern Ireland
I am Dr. Ruth Balogh (West Cumbria & North Lakes FoE), also author of several research papers on the health & social impacts of flooding, an important climate change issue. Thank you for this opportunity.
FoE EWNI regret being unable to appear in person. They objected three times since 2017 but were not formally notified of the committee hearing.
- Concerns over Committee hearing notification and CCC’s duties under the Aarhus Convention
Fair public participation in decision-making is enshrined in the Aarhus Convention, especially for EIA applications. Cumbria CC should have notified all respondents – previously standard procedure here; standard procedure throughout the sector, and therefore expected by us. At least we should have been warned of this change in policy. “Lack of resources” was cited but there is a planning performance agreement in place with the developer. Other objectors may have also been denied this right. This is not in the spirit of planning systems, nor Aarhus.
- Key objections
FoE EWNI maintains 3 key objections to the application and is disappointed with officer recommendation to approve:
- impact on climate change
- The UK is bound by the Climate Change Act 2008 to reduce greenhouse gas emissions by at least 80% on 1990 levels by 2050.
- NPPF para 148 aims for the planning system to “shape places in ways that contribute to radical reductions in greenhouse gas emissions”.
- The 2015 Paris Agreement committed the UK to limiting temperature increase to 1.5°C.
Coal has the highest carbon intensity of all fossil fuels and so its extraction and combustion must be minimised. Despite the objective of steel-making, mining on this scale for 40+ years conflicts with these instruments.
Mining 2.8 million tonnes a year for 40 years represents 175 million tonnes of C02 . Climate impact will increase through additional fugitive methane release, CO2, NO2 and particulate emissions from operations/plant/transport. The UK’s binding Carbon Budgets also apply to methane and other greenhouse gases – which this mine will emit. Have the impacts of methane leakages over 40 years had proper consideration?
A Mine Gas Capture Management scheme is a condition. But this could be varied and watered down over time. And there is no guarantee the coal will be used for steel. The apportioning of “moderate weight” to climate change impacts is therefore underestimated.
- Compatibility with the Cumbria Minerals and Waste Plan (2017) and NPPF approach to coal
This proposal gives ‘considerable weight’ to a “national need” for indigenous metallurgical coal and local benefit from 500+ well-paid jobs, thus outweighing environmental impacts.
The “national need” for metallurgical coal is weak. It appears to be based purely on coal being listed in Annex 2 of the NPPF and steel demand projections – hardly robust research. Have any British steel manufacturers been consulted? What if steel manufacturing further diminished in future? This “considerable weight” is based on a lot of assumptions.
The purported benefits of fulfilling ‘a national need’ fail to outweigh the clear environmental harms, and regional employment benefits could adversely affect jobs in tourism and leisure.
- Incompatibility with government announcements on coal phase-out
In 2018, Claire Perry said: We’re proud to be leading the world when it comes to getting rid of [coal], well ahead of our 2025 target.
The NPPF’s new approach makes it clear that the days of coal mining are very limited. The sheer scale of extraction, including 335,000 tonnes of middlings coal remains incompatible with these government approaches.
This application should be refused. The environmental impacts will not be outweighed by employment benefits and “need”, making legal challenge likely.
KEEP CUMBRIAN COAL IN THE HOLE
PRESENTATION FOR DC&R Committee 19:3.19
Marianne Birkby email@example.com
I am Marianne Birkby speaking on behalf of Keep Cumbrian Coal in the Hole. This is a Radiation Free Lakeland campaign set up following the proposal by WCM. People have asked why would a nuclear safety group be campaigning against coal.
The answer to that can be seen in our petition which I present to you today.
The petition headline says: Keep Cumbrian Coal in the Hole – it is too close to Sellafield. (1,154 signatures and growing)
West Cumbria Mining say our petition objections have been answered. Not true. Our objections stand and are escalating the more we find out about the plan.
Others will speak forcibly today of the terrible climate impacts. I would like to concentrate on seismic and water impacts.
At 8km from Sellafield the extent of the mine lies 600 metres from the Office for Nuclear Regulation’s legal remit to consult. The ONR say therefore that they do not need to be consulted by CCC.
For the ONR to completely wash its hands of any real scrutiny regarding this unprecedented deep mining so close to Sellafield’s 140 tons of plutonium is scandalous. The Precautionary Principle is enshrined in UK laws that CCC are bound by and we would urge Councillors to ask the ONR for full consultation and scrutiny before making a decision. That scrutiny should include a recent paper published last September by the Yorkshire Geological Society. The paper outlines the high risk of liquefaction at the Sellafield and Moorside sites. (1)
Barrow is the only place in the UK ever to have experienced liquefaction from a much smaller seismic event than that outlined in the recent paper.
A liquefaction event at Sellafield caused by coal mining induced earth movements would be disastrous not just for Cumbria but for Europe too. The Precautionary Principle in this instance must be applied.
Coal, like nuclear, is a water intensive industry, leaving long lasting carcinogenic products . For every ton of coal, two and a half tons of water are required to wash that coal. West Cumbria Mining propose to ‘recycle’ the water pumped from the voids and ‘surface’ water. Only today have we been told that water would also be extracted from a geological fault – water extraction on a big scale also causes seismic activity.. I have asked for scrutiny from CCC and WCM on fresh water usage but have not received any answers. My calculations from WCM’s coal production figures is that the mine would need to use 3 million litres of water a day to wash the coal before transportation.
West Cumbria’s fresh water situation is already stressed with many people in the Copeland area suffering health impacts from having to drink a mix of 80/20 borehole
water. Borehole water can be very good but not from a complex geologically faulted area which has been heavily mined in the past.
To impose another water intensive, dirty and geologically damaging industry on West Cumbria is an attack on the most basic of human rights, the right to fresh water.
Text for DC&R Cttee: 19.3.19: 4/17/9007: Maggie Mason: Kendal
My name is Maggie Mason. I have an Architecture Degree and Post Graduate Diploma in Town Planning and was a senior Minerals and Waste planner in Kendal for 10 years to December 2015.
I object to this planning application because the development would significantly increase Greenhouse Gas Emissions and damage our climate and planetary home.
I think that this Committee Report has misrepresented:
- the climate change impacts;
- the UK need for metallurgical coal;
- the national, local and community benefits, and therefore
- the overall planning balance
- Climate change impacts
- The Committee Report says there are NO Climate Change impacts because the “moderate” benefits of reduced GHG from transportation balance the TOTAL adverse impacts of non-combustion emissions ( construction, extraction, AND transportation). Logically these cannot balance – as SLACCtt demonstrate in their diagram. One is a fraction of a fraction of the total. They cannot be the same.
- Even if combustion emissions are disregarded, an adverse impact from an increase in emissions as a result of the proposed mine’s construction and operation is acknowledged in the Committee Report but not carried through into the planning balance.
- UK Need for metallurgical coal :
- The Committee Report claims “it is reasonable to assume that demand for steel and coking coal will continue to exist both within the UK and EU for the foreseeable future”. A graph of soaring scenarios from an industry/consultant source is presented with the comment “I have no doubt to conclude these are reasonable” .
- This optimistic and “business as usual prediction” conflicts with official Government reports and easily available information. The Port Talbot steel plant is only “guaranteed” until 2022, and the only other UK steel plant at Scunthorpe , which was bought by an Investment Bank for a £1 announced the loss of 400 jobs in November2018 .
- If the UK steel industry is dying as the Financial Times explained in January 2019, and the UK Government has offered warm words but no subsidies, there is little national or local economic benefit in the proposed coal mine. The coal will travel further or not be sold, the transportation emissions “savings” disappear and the West Coast is left with another derelict industry, this time leaking methane emissions.
- National, local and community benefits
- The Committee Report “weighs up” combined “UK and EU” need or economic benefit, but translates this into “potential..national benefits ..of considerable weight” when applying NPPF paragraph 211. Benefits to the EU are not relevant to the NPPF, and should be omitted.
- The Report implies 500 jobs for 50 years, without clarifying that only benefits due to the (onshore) planning application are a material planning consideration. If multi-generational jobs” from the combined proposals DO influence Members decision, THEN so should adverse impacts from the offshore proposals (such as subsidence that mobilises contaminants and radioactive particles from the sea bed, and earthquakes from pumping liquidised waste into mine voids).
- I agree with CCC that the proposal is not environmentally acceptable even without the climate change impacts,
- but in addition, there are significant Climate Change impacts that increase the total likely impacts, even if end use/ combustion is ignored.
- significant national economic benefit has NOT been demonstrated in considering the second test of NPPF Paragraph 211, and
- local and community benefits (mainly jobs) are medium to short term only, not multigenerational as promised in the proposal.
When a more reasonable and evidence based assessment is applied to Paragraph 211, the impacts increase, and the benefits decrease.
Therefore the proposal has not been shown to “provide benefits that clearly outweigh its likely impacts”; NPPF paragraph 211 test fails; the presumption against coal extraction stands; and the application should be refused.
I respect this Committee, and know that refusing consent against officers’ advice takes courage, but the report’s flaws and its disregard of current climate science make a legal challenge likely. Please refuse this planning application.
West Cumbria Mining proposal – issues related to climate change
Speaking points from Dr Laurie Michaelis, Living Witness
I’m Laurie Michaelis. I’ve worked on climate-related issues for thirty five years, been a lead author for reports of the UN’s Intergovernmental Panel on Climate Change – the IPCC – and provided technology policy advice for the UK government, European Commission and UN climate negotiators.
Speaking to you feels like possibly the single most important thing I’ll do in my life.
I work now with Quaker charity Living Witness helping communities face up to climate change and find sustainable ways forward.
Climate change is already wrecking lives. Last year’s IPCC report made clear that global warming beyond 1.5°C could be catastrophic for humanity and other life including in Cumbria. For instance global warming of 1.5 to 2°C could bring long term sea level rise of 6-9m. To prevent that, global carbon emissions must fall to zero by about 2050.
Refusing this mine could save thousands of lives and help build momentum to cut carbon but I’m worried you don’t have enough information to decide safely. The applicant has made wrong and misleading statements about climate impacts of the development, the steel industry and policy context. Your officers have not obtained suitable expert advice to correct the misinformation. For instance:
Unrealistic expectations of future coking coal demand
The IPCC says demand for raw steel and coking coal must fall to limit warming to 1.5°C. The UK Government and European Commission have published decarbonisation pathways for iron and steel to 2050 which include using biomass or hydrogen instead of coke.
Misinformation about climate impact
Over 50 years, this development’s climate impact would be equivalent to about 450 million tonnes CO2, the same as the total UK greenhouse gas emissions in 2017.
When coal is used to make steel, 99% of the carbon content ends up as CO2 in the atmosphere.
Just the methane emissions in the mine ventilation air and from the coal could add over a million tonnes a year of CO2 to Cumbria’s climate footprint – that’s about 15% – and its ten times bigger than the reduction claimed from international shipping.
If you consent, the resulting emissions could mean tens of thousands of people losing homes or livelihoods. Thousands could die early because of heatwaves, disease and other causes. You will share responsibility with WCM, steel manufacturers and final users.
If you refuse, coal might be sourced elsewhere; that’s the kind of argument people often use to justify wrongdoing. You can prevent this coal from being used.
Cumbria County Council has promised to play its part in meeting national climate goals which are likely to be tightened in light of the IPCC report following advice to the Government from the Climate Change Committee, due in May.
The High Court just ruled that the National Planning Policy Framework did not take climate change properly into account and the Government must revise it. More court cases like this are being brought around the world.
A positive strategy for Cumbria
As an outsider, I can’t tell you what sustainable development here should look like but the vision and action plan must come from the local community, NOT from fossil fuel industries parachuting in.
My name is Sam Moisha
I wish to object strongly to the application.
Para 211 of the government’s National Planning Policy Framework regarding coal extraction is totally clear
‘Permission should not be given for the extraction of coal unless the proposal is
A] environmentally acceptable, or can be made so by planning conditions or obligations;
– or if not, . . . .
B] it provides national, local or community benefits which clearly outweigh the likely impacts
The CCC report has stated that a] the application is not environmentally acceptable yet it gives ‘considerable weight’ to community benefits with regard to jobs/employment. [6.515]
I am challenging this ‘community benefit’ aspect with regards to jobs and employment.
What happens to the proposed jobs when –
- Volatile market forces in the global steel industry close further UK and European steel plants – as China, Korea and Australia increase steel production and global overcapacity?
- WCM may become non viable commercially as a result of global markets – a potential clearly identified in the committee report – with regard to bonds and securities for remediation work as and when the mine may close early.
- The UN declaration of our climate emergency accelerates the carbon budget limits on all co2 emissions – and the burning of any fossil fuel in steel making or otherwise?
- The climate emergency accelerates new technologies of steel production that do not use coal?
- Production at the mine may be stopped due to accidents – including methane, subsidence and seismicity – which has currently stopped production at Preston New Road fracking site?
- Global divestment from fossil fuel industries makes all fossil fuel investments increasingly risky – and likely to become stranded assets?
- If the major investors in China withdraw funding in the face of Brexit uncertainties?
- If Brexit makes export to eurpoean steel producers un economic?
WCM simply do not have control over global steel markets, overcapacity or Brexit and so cannot guarantee any sales at all of any coal produced.
Or any jobs depending on this.
It would be truly difficult to find a bigger dead duck proposal than producing fossil fuels for a declining European steel industry.
The Lancashire fossil fuel experience –
In Lancashire officers recommended approval of the fracking site at Preston New Road.
Lancashire County Councillors rejected the application. They said NO.
This should have ended here – but as we know central government overturned the local democratic decision and we have seen years of protest, judicial review, court cases, arrests and massive policing costs . . . . fracking at PNR has now ground to a halt.
Conclusion – request
Cumbria has had it’s fair share of dead and dying industries – old coal and now nuclear – we do not need another dead duck industry . . . Coal is not the future.
It could perhaps be said of the WCM proposal that it was a well-intentioned attempt to bring employment to the area.
It could equally be said that it was an unrealistic bubble from the start
What we need are jobs that do have a future.
Please look to the future stability of jobs in Cumbria and JUST SAY NO.
Planning Application 4/17/9007: Woodhouse Colliery
Spoken submission by Dr Stuart Parkinson, Scientists for Global Responsibility
I am speaking in opposition to the application from West Cumbria Mining Ltd.
- My name is Dr Stuart Parkinson. I am executive director of Scientists for Global Responsibility, a UK organisation whose membership includes 600 science, design and technology professionals. I am an environmentalist scientist, with nearly 30 years’ experience of research and advocacy work on climate change and energy issues. My professional background also includes: a PhD in climate change science from Lancaster University; five years as a post-doctoral research fellow in climate and energy policy at Surrey University; and a year as an expert reviewer for the UN advisory body on climate change, the IPCC. I have also worked in and with UK industry, including carrying out research for the energy industry.
- The main grounds on which I object to the planning application is that it would make a large contribution to global climate change. The coal mine, if approved, would significantly undermine local, national and international efforts to reduce carbon pollution – as agreed in policy documents including the 2015 Paris Climate Agreement, the 2008 UK Climate Change Act, and Cumbria County Council’s climate change strategy. These efforts are essential to help reduce the risk of extreme storm and flood events similar to those which Cumbria has experienced in recent years.
- The most recent report of the IPCC highlighted our vulnerabilities even to relatively modest levels of climate change. The report showed that efforts to reduce carbon pollution need to be stepped up rapidly, with approximately one decade left for the world to take transformative action. This action would need to include major changes in the iron, steel and cement industries.
- Coal is a highly polluting fuel, especially in terms of carbon pollution. Based on the figures for estimated coal production provided in the planning application, and additional data from technical sources, I have calculated that during the main production phase the mine would lead to emissions of over 9 million tonnes of carbon dioxide equivalent for every year it is in operation. This amount is similar to the annual emissions of over 1 million British citizens. This estimate includes both direct emissions from coal use in the steel-making process and indirect emissions from, for example, transportation.
- Coal mines emit significant levels of methane, a powerful greenhouse gas which further exacerbates climate change. This coal mine would be no different. Such emissions are very hard to control, despite claims made in the application.
- Because it is planned to export much of the coal, most of the emissions would appear in the ‘environmental accounts’ of other countries, not the UK – but they would still be subject to the Paris Climate Agreement – and the UK, and Cumbria in particular, would arguably bear ethical responsibility.
- The steel-making industry has been slowly moving to less carbon intensive production processes. Such processes include electric arc furnaces which have particular environmental benefits over coal-fired blast furnaces, if the source of electricity is lower carbon, as in the UK. This new mine would do nothing to help the low carbon transition – indeed it would slow down the process.
- Claims that coal from this mine would ‘save’ some carbon pollution because it could, for example, offset US coal are speculative and probably misleading. By increasing international supply, this mine would help depress coal prices – and thus it would actually be more likely to increase coal use internationally in the short term. In any case, the transportation emissions are a tiny proportion of the emissions released during coal use in steel-making.
- In line with international trends, the UK is phasing-out coal for electricity generation by 2025. Other uses of coal will also need to be rapidly reduced to tackle climate change – and the IPCC and others have recommended ways in which this could happen. Hence, this mine is highly unlikely to be economically viable for anything close to its claimed 50-year lifespan – thus becoming a ‘stranded asset’. Cumbrian authorities would therefore do better to encourage economic activities with a more promising future, for example, renewable energy, forestry or tourism.
- The UK government has repeatedly been criticised by its advisory body, the Committee on Climate Change, for not taking adequate action to meet its carbon pollution targets. The Committee itself has yet to update its assessments in light of the latest IPCC report, meaning that the government’s policies are even further behind scientific evidence of the climate threat. Yet the failings of central government should not be an excuse for Cumbria County Council to ignore the scientific evidence of the major threat that this coal mine poses to our shared climate.
In summary, approving this application for a coal mine would be a huge step backwards for efforts to tackle climate change – and thus would increase the risks of extreme weather events such as storms and floods. Meanwhile, the economic case for the mine is flawed. Therefore, I strongly urge the planning committee to reject the application.