“Flying Underwater – Black Guillemots at St Bees”. The last nesting place of Black Guillemots in England is St Bees where the first deep coal mine in 30 years will soon be decided upon.
The Coal Mine planning inspector Stephen Normington will, any day now, be making his recommendation to government (the same government who have appointed the coal boss as nuclear dump advisor).
Then the final decision will be with Secretary of State Michael Gove on whether or not to open a new coal mine under the Marine Conservation Zone off St Bees and just five miles from Sellafield.
Concerns, aside from climate, raised by Keep Cumbrian Coal in the Hole since 2017, regarding seismic, nuclear and marine impacts have been well and truly ‘talked over’ despite our vehement campaigning.
The narrowed narrative allowed in the media (with rare exceptions) and siezed upon by NGOs (with rare exceptions) has been to focus myopically on climate ignoring all other arguably more important impacts such as seismicity, Sellafield, and putting the infrastructure in place for a deep nuclear dump.
One of our eagle eyed team has just reported that the Coal Authority have just confirmed that two applications for variation ( time extension beyond the normal eight years) have been received by them from West Cumbria Mining. A decision is pending.
The more people who write to ask that the Department of Business, Energy and Industrial Strategy do not issue Coal Authority Licences the better. Please write to:
email – firstname.lastname@example.org
Twitter – @beisgovuk
Please Ask that West Cumbria Mining Ltd License Applications CA11/UND/0184/N and CA11/UND/0177/N are not awarded extensions. These conditional licenses were given 8 years ago, over and above the heads of the public and local councillors with no semblence of democracy. Before the Coal Authority issue any licence for West Cumbria Mining to extract coal onshore and offshore in the first deep mine in the UK in 30 years there should be a full public inquiry.
If central government want to take local government into account, or even to decide, as Robert Jenrick said in his “it is a local decision,” washing of hands, then they need to announce a full public consultation. The original licences that the developers are now asking for an extension of were issued above the heads of both the public and local councillors.
As you may know, Keep Cumbrian Coal in the Hole is a Radiation Free Lakeland campaign and the clue is in the title . We have been saying since 2017 that a mine that would be just five miles from the worlds riskiest nuclear waste site and directly beneath the decades of radioactive wastes discharged from Sellafield and currently lodged in the Cumbrian Mud Patch is unjustifiable on health and safety grounds. Also scientists have noted that the “expected subsidence” caused by mining in this area would resuspend radioactive wastes into the water column and back to land”.
We argue that climate is not the only burning issue surrounding this mine which is also adjacent to one of the areas in the frame for Geological Disposal of Nuclear Wastes. In what looks like conflict of interest the Department of Business and Energy Industrial Strategy appointed the CEO of West Cumbria Mining to the Committee on Radioactive Waste Management in November 2019
All these issues are within the BEIS remit.
We argue that there should be a full public consultation before the issuing of licences to mine out an area the equivalent of Wastwater lake under the Irish Sea. The coal would be shunted for decades under the Marine Conservation Zone creating a massive void under the radioactively contaminated Cumbrian Mud Patch.
It is noteworthy that the area West Cumbria Mining have asked for a license extension for is Offshore Area No2. There is a big mismatch between the Coal Authority’s resource map and WCM’s Offshore Area No2 – an area which happens to be directly adjacent to the area being mooted as a possible Geological Disposal Facility for high level nuclear wastes. Just saying!
Nearly 4000 people, including Chris Packham have signed the petition to Stop the Coal Mine in Cumbria – Please keep sharing and signing. As well as signing the petition – People can STILL WRITE individual letters to Cumbria County Councillors who will be making the decision on this to let them know STOP THE COAL MINE!
If you have time please write to Cumbria County Council and tell them to scrap this terrible plan (even if you have written before please drop them a line again).
The main points to make are that this mine would fly in the face of the Council’s own climate commitments and its own stated commitments to protect the health and well being of all Cumbrians….AND the IMPACTS of this mine would extend far BEYOND Cumbria. Send an email to email@example.com – quoting the application reference number 4/17/9007 and including your name and address.
A Briefing Paper on radiological implications of West Cumbria Mining’s plan has been sent to councillors ahead of their coming decision on whether to allow the plan for the first deep coal mine in 30 years to continue.
The author of the paper, Tim Deere-Jones is an Independent & non-aligned Marine Pollution Researcher & Consultant whose clients include: WWF, The UK Wildlife Trusts, European Climate Foundation, Greenpeace International, European Coastal Local Authorities and many others.
This comprehensive report concludes that the plan by West Cumbria Mining should be abandoned. The introduction and Major Conclusions are reproduced below…..
Introduction:This Briefing offers a review of the possible seabed morphological changes and marine pollution implications of the sub-sea coal mining venture proposed by West Cumbria Mining (WCM) at their Woodhouse Colliery site near St Bees Head.
WCM have designated and identified a sub-sea mining zone of the Irish Sea lying to the west of St Bees Head and extending at least 8kms offshore and southwards to within about 8km of the Sellafield site.
The WCM extraction proposals, using continuous mining methods, predict the extraction of approximately 3 million tonnes of coal per year over a 50 year period. This extraction rate will eventually generate a huge subterranean void space of approximately 136 million cubic metres (a volume greater than that of Wastwater Lake).
This briefing considers the impact of the creation of such a sub-sea void space on the possibility of sea bed subsidence in the area of the WCM designated sub-sea mining zone, and the subsequent potential for marine radiological pollution as a result of the subsidence induced re-suspension of the heavily radioactively contaminated sea bed sediments of the Cumbrian Mud Patch and surrounding sea bed areas.
It is noted that there is a lack of data about the status of the existing historical galleries and workings of the West Cumbrian Coalfield. It is noted that there is a lack of accurate data about the history and status of any subsidence seismicity in the coalfield.It is noted that the BGS have concluded that the coalfield is heavily faulted and has a long history of subsidence and that it appears that there are no plans to monitor for any subsidence prior to, during the operational phase or in the post operational phase of the Woodhouse Colliery.It is noted that sub-sea monitoring equipment is available and could be deployed in the region in order to monitor for any subsidence effects arising as a result of the proposed Woodhouse Colliery “mass removal” extraction.
It is concluded that there is a real potential for subsidence to occur as a result of the “mass removal” and the creation of extensive sub-sea void spaces, and it is noted that such subsidence could generate earthquake and liquefaction effects which may extend onshore as far as the Sellafield/Moorside sites.
It is concluded that any seabed subsidence in the WCM designated sub-sea mining zone would generate re-suspension of Cumbrian Mud Patch heavily radioactive seabed sediments. It is noted that such an event would generate elevated doses of man-made radioactivity to coastal zone populations and sea users along both the Cumbrian coast and at “downstream” regions further afield.
Given the potential for such a radiological effect and the delivery of increased doses of radioactivity to relevant coastal zone communities, some of which have already been identified by the authorities as Coastal Critical Groups, the Woodhouse Colliery proposal (especially in the absence of any precautionary mandatory subsidence monitoring) is strongly contra-indicated and should be abandoned
Thanks to our continued challenges the Developers of the first deep coal mine in the UK in decades have put forward an amended planning application. The difference with this plan is that the developers propose to make the lower quality middlings coal (previously called a “by product”) into coking coal.
Even if you have written previously to oppose the plan PLEASE PLEASE write and object again BEFORE 15th June – and ALSO ask to speak at the planning meeting (July 8th).
We have prepared a list of potential issues that you can object to – (this is not an exhaustive list – there are plenty more arguments you can make against this diabolic plan)
So please do use this as inspiration for your own letters of objection. Even it you can write just a line or two saying that you strongly oppose this plan. – it is all valid and it all helps!!
If you have time to write to all the members of the committee then the details are here
You can tweet Cumbria County Council here .. @CumbriaCC
Please include: West Cumbria Mining – amendment to Application Reference No. 4/17/9007.
OPPOSITION LETTER TO THE COAL MINE
Application Reference No. 4/17/9007.
Proposal: Development of a new underground metallurgical coal mine and associated development including: the refurbishment of two existing drifts leading to two new underground drifts; coal storage and processing buildings; office and change building; access road; ventilation, power and water infrastructure; security fencing; lighting; outfall to sea; surface water management system and landscaping at the former Marchon site (High Road) Whitehaven;
a new coal loading facility and railway sidings linked to the Cumbrian Coast Railway Line with adjoining office / welfare facilities; extension of railway underpass; security fencing; lighting; landscaping; construction of a temporary development compound, and associated permanent access on land off Mirehouse Road, Pow Beck Valley, south of Whitehaven; and
– a new underground coal conveyor to connect the coal processing buildings with the coal loading facility.
West Cumbria Mining have resubmitted this previously unanimously approved appliction with the change that high quality coking coal would now comprise up to 15% of middlings coal processed on site to render it into coking coal.
OPPOSITION ON THE GROUNDS OF:
Cumbria County Council Minerals and Local Waste Policy DC13 15.16
This proposal will have unacceptable social and environmental impacts which cannot be mitigated against and would fly in the face of Cumbria County’s own Policy DC13
a. Loss of Ancient Woodland and degradation of remaining woodland area by the proposed rail conveyorto cut through two areas of woodland.
b. Large Coal Yard Sidings and Trains Local residents are opposed to Pow Beck Valley hostinga large coal yard with six daily coal trains “The facts are; a train over 400 metres long; weighing +1500 tonnes; emitting 25.3g CO2e per tonne km” “126 Coal wagons in their sidings are hardly inconspicuous in our green landscape. More WCM rhetoric at the expense of local residents”. Local Resident.
c.Methane Rich coal seams are now safely contained under the Irish Sea. Methane is a potent greenhouse gas.The developers consultant AECOM has estimated that 74% of the on-site emissions would be the methane emitted from the exposed coal in the mine.The developers say that “The installation of a methane capture and utilisation plant will potentially eliminate the majority of fugitive methane emissions.”
Methane would continue to be emitted from the broken up coal up till and including the point of use at a steel works.Methane drainage would potentially only remove a small fraction of total methane.
d.Zero Carbon Britain – The developers state “If the emissions are less than 1% of the relevant carbon budget, the level of significance is considered to be minor adverse”. In the context of this long lived coal mine this is nonsensical.The coal mine is set to continue over 70 years.By peak production the wildly optimistic 1% of UK carbon emissions from this coal mine would be 5%, 10%– 20% or even more of an otherwise decarbonised Britain.In June 2019 the UK became the first major economy to pass net zero emissions law.The new target will require the UK to bring all greenhouse gas emissions to net zero by 2050.
e. Carbon Neutral.Cumbria County Council declared a climate emergency in September 2019 and says it is committed to becoming carbon neutral.West Cumbria Mining have stated in their amended planning applicationand in response to theGreen Alliance Report, that the Coal Mine would NOT be carbon neutral (despite having previously led people including Cumbria County Council to believe that it would be).In their amended planning statement West Cumbria Mining propose that they have ongoing monitoring requirements on the Development (from 2033 onwards) in order to stop operations past this date if the coal mine compromises the UK’s ability to meet its emissions targets.This is disingenous.Cumbria County Council should be brave enough to call a halt to this coal mine sooner rather than later.
f.Subsidence and Cement Paste.The developers propose to fill the voids left by mining with a cement paste in an effort to avoid subsidence of the vulnerable Irish Sea bed and onshore area.They say the cement backfill :“will be primarily targeted to sensitive areas including all onshore panels and selected panels close to the Marine Conservation Zone.”
The planned annual production after 5 years will reach a steady state and is estimated at 2,780,000 tonnes of metallurgical coal, and
150,000 tonnes of reject. The reject will be blended with water and a binder (e.g. cement) and the resultant paste material will be pumped back underground and placed directly behind a working panel as it is mined. When used, the paste will fill an estimated 65 % of the void space behind a worked panel. The use of the paste backfill will significantly increase the stability of mined-out areas and subsidence over backfilled panels will be reduced by at least 65 %. This applies to both single panels and to groups of panels. For example, for a single panel with 65 % backfill the maximum vertical displacement will be reduced from 21 cm to 9 cm. There will be sufficient paste produced each year to fill two of the eight panels mined each year, i.e. 25 % of panels will be backfilled. Backfill will be primarily targeted to sensitive areas includ- ing all onshore panels and selected panels close to the MCZ.
Cement Paste Backfill (of the “panels” – the voids left by the mining process) is a relatively new and unstable process. “many factors such as sulfate presence, geothermal factors, and rock pressure in a mine water context have significant effects on the properties of Cement Paste Backfill.” The last thing needed near the Sellafield nuclear waste plant is a new coal mine with unstable ‘cement paste backfill.’
The Colourful Coast Partnership has noted that : “The impact of any level of subsidence upon the terrestrial or marine hertiage assets and designated sites and landscapes could be significant and permanent, therefore having a detrimental impact…the history of contamination of watercourses in the area raises concerns…”
Local planning authorities such as Cumbria County Council are required to have regard to the prevention of major accidents and limiting their consequences.They must also consider the long-term need for appropriate distances between hazardous establishments and population or environmentally sensitive areas. They must also consider whether additional measures for existing establishments are required so that risks to people in the area are not increased. Sellafield is less than five miles from the area of mining proposed in the WCM development.We have seen no detailed risk assessments for this.
g.“Water is heavily used in coal processing” Exactly how much Groundwater would the mine abstract daily from the Byerstead Fault at full peak production ?West Cumbria Mining have not given any indication of fresh water abstraction. No research has been done on the hydrological and geological impact of this abstraction from the Byerstead Fault?
“Water is heavily used in coal processing and would be obtained from the following sources:
Groundwater (Byerstead Fault)
Recycled from the CHPP
Mine water ingress
Moisture in the coal
Harvested rain-water “
(WCM presentation to CCC 19th March 2019)
h.Blight from Construction and operation. West Cumbria Mining’s own Environmental Assessement says “the construction and operational activities of the proposals ‘have the potential to generate a number of land contamination related adverse impacts on identified receptors.’ And that “the significance of residual effects related to potential geological and contamination related impacts associated with the Proposal during the construction and operation phases are likely to be minor or moderate adverse, and therefore not significant.”The blight forpeople living near the proposal would be Very Significant. The would experience the coal mine blight of toxic mine tailings, coal dust, chemical pollution,rail wagons,and associated noise.The beginning of the first section of Wainwright’s Coast to Coast walk would be impacted by the noise and disturbance of the coal mine’s rail loading facility. Should Cumbria County Council approve this plan they would be in contravention of Cumbria’s Statutory Development Plan (SDP)-Cumbria Minerals & Waste Local Plan; POLICY SP15 Environmental Assets. “Protect, maintaintain and enhance people’s overall quality of life and the natural, historic and other distinctive features that contribute to the environment of Cumbria and to the character of its landscapes and places”
Cumbria County Council Minerals and Local Waste Policy DC13 15.16
“Planning applications for coal extraction will only be granted where;
the proposal would not have any unacceptable social or environmental impacts; or, if not
it can be made so by planning conditions or obligations; or, if not
it provides national, local or community benefits which clearly outweigh the likely impacts to justify the grant of planning permission.
For underground coal mining, potential impacts to be considered and mitigated for will include the effects of subsidence including: the potential hazard of old mine workings; the treatment and pumping of underground water; monitoring and preventative measures for potential gas emissions; and the disposal of colliery spoil. Provision of sustainable transport will be encouraged, as will Coal Mine Methane capture and utilisation.”
I have just sent a tweet to the Wildlife Trusts …..Wowee- with this public reach @WildlifeTrusts are uniquely placed to #KeepCumbrianCoalintheHole #StBees is the last breeding place in England of the #BlackGuillemot the #IrishSea is under threat Save our #LivingSeas and PLEASE @CraigBennett3 tell @CumbriaCC 2stop @WCumbriaMining….
The Wildlife Trusts feature the Black Guillemot – the same Black Guillemot that is under threat from the plan to mine for coal deep under the Irish Sea. The damage done by this development would be many layered from climate change to physical damage to the nesting site at St Bees – the only nesting site in England left for the Black Guillemot.
This is what the Wildlife Trusts say:
“Did you know?
The black guillemot is also known as the ‘Tystie’ in the Scottish Isles, which was probably derived from the Norse name for the bird.
How people can help
The Wildlife Trusts are working with fishermen, researchers, politicians and local people towards a Living Seas vision, where coastal and marine wildlife thrives alongside the sustainable use of the ocean’s resources. Do your bit for our Living Seas by supporting your local Wildlife Trust.”
Send a Tweet to the Wildlife Trusts – Now it is the Wildlife Trusts turn to “Do Your Bit” – and oppose the coal mine plan. So far there has been silence.
As you know we had planned a Spring Watch Wildlife Walk and Draw along the cliff top walk from Whitehaven to St Bees. As we cannot do that here is a virtual walk with sketches of some of the birds that it is possible to see. Some are very vulnerable indeed such as the Black Guillemot, just one of the reasons why we want to stop this coal mine.
The date of the week beginning the 20th July has now been set for the Legal Challenge which you have so generously donated funds towards. A Press Release has been sent out to media and can be read below. With many thanks for your continued support in the battle to stop this coal mine. We will let you know more details about the 20th July date as soon as we know more.
POSSIBLE JULY DATE FOR CUMBRIAN COAL MINE LEGAL CHALLENGE
Keep Cumbrian Coal in the Hole are challenging the decision by Cumbria County Council to allow the first phase of a major new coking coal mine deep under the Irish Sea. The date for the Judicial Review is planned for the week commencing the 20th July (dependent on the situation with Covid19 restrictions) and will be heard at the High Court in Manchester.
The case is being brought on behalf of KCCH by Mrs Marianne Bennett (which is the legal name of the Cumbrian based artist Marianne Birkby). KCCH was founded by the campaign group Radiation Free Lakeland which was set up in 2008 to fight the plan for the geological disposal of nuclear wastes under Cumbria. A crowdfunder set up by Mrs Bennett following Cumbria County Council’s decision in March 2019 to grant the coal mine planning permission has generated £10,435 to cover court costs and legal expenses. KCCH have engaged the services of top environmental lawyers at Leigh Day, Matrix Chambers and Francis Taylor Buildings.
On 20 June 2019, Leigh Day wrote to Cumbria County Council addressing a number of legal issues. Despite being alerted to those concerns, Cumbria County Council ratified its decision on 31 October 2019.
Consequently, KCCH launched its Judicial Review on 12 December 2019, arguing that Cumbria County Council had failed to properly assess the greenhouse gas (GHG) emissions of the mining operations, by wrongly claiming that the development would be “carbon neutral” without any evidence whatsoever to support such a claim. KCCH also submitted that Cumbria County Council had a legal requirement to consider whether the extraction and use of the coal would be in line with the Government’s target of Net Zero CO2 emissions by 2050, given the Whitehaven development will last for at least the next 50 years.
The developers West Cumbria Mining as ‘interested party,’ have throughout, strongly resisted the legal challenge. Arguing that KKCH’s case against Cumbria County Council is “without merit” in respect of both carbon emissions and the need for coking coal. WCM also argued that the KCCH should be exposed to much higher costs, which could have jeopardised the Judicial Review going ahead. However, Mrs Justice Beverley Lang agreed in February 2019 that the legal issues are arguable, that they justify a public hearing and that KCCH could have a cap of £5,000 on court costs under Aarhus rules.
WEST CUMBRIAN MINING ‘U-TURN’ ON MIDDLINGS COAL ?
Since then, and in an apparent U-turn, WCM has sent a letter to Cumbria County Council (disclosed as part of the legal case) that says all of the extracted Coal can now go into the Steel Industry. In light of that change, WCM indicates in the letter that it will submit a revised planning application to Cumbria County Council. However, much is unknown as to whether the total amount of Coal will remain the same or whether there is still going to be a by-product of Middlings Coal, and if so how the environmental impact of disposing of that waste product will be assessed by Cumbria County Council before any revised planning application is approved.
Neither WCM nor Cumbria County Council have yet addressed criticisms of the climate change impact of the Coal Mine raised in a report published by the Green Alliance. We understand from the same letter that WCM intends to do so as part of any revised planning application.
Meanwhile, KCCH intends to proceed with the legal challenge, because there are still questions concerning GHG emissions and the Net Zero target which campaigners believe are unaffected by these revisions.
Marianne Birkby from KKCH, said:
“We are pleased that a date has now been set for the legal challenge which has had to overcome so many hurdles already to get us to this point. We feel that this coal mine has gone way under the radar for so long – the climate impacts alone should have stopped this plan in its tracks from the outset but there is also the issue, much on our minds, that this coal mine would extend to within 5 miles of the Sellafield site. Cumbria would be the only place in the UK with deep mining infrastructure in place. We are delighted that full legal scrutiny of the climate change impacts will be addressed despite the manoeuvrings of West Cumbria Mining to try and circumvent any such legal challenge. We will continue to work tirelessly along with others to stop this, outrageously dangerous coal mine plan under the Irish Sea.”
Walk and Spring Wildlife Watch – date to be confirmed
Thank you So Much for keeping on sharing and donating to the CrowdJustice page –everything put in the hat will go direct to the legal fund to take our case to Judicial Review. We are still waiting for a date for our case to be heard – but it will be in Manchester!
Will let you know just as soon as we hear.
In the meantime we are planning a walk along the beautiful (but a bit challenging) cliff top from Whitehaven to St Bees. The walk will include wildlife watching and maybe a bit of drawing too!
Seabirds, guillemots, gulls, ravens and more are all descending on the cliffs to nest so it is an exciting time. This is the only nesting place in England of the black guillemot and the coal mine threatens that , as well as much else! What is left of our wildlife is increasingly important. A date for the walk is yet to be set but watch this space!
Let 2020 be the year that we Keep Cumbrian Coal in the Hole and stop this terrible plan. Thank you so much to everyone who has contributed to the crowdfunder and equal thanks to those who have been sharing and talking about this.
The image above is a small watercolour painting and the final person to donate to the crowdfunder will receive the original painting.
Thanks to you all we now have the means to push forward with a legal challenge.
But we are not resting on our laurels and will be pursuing every means possible to stop this coal mine, alongside the legal challenge.
The St Bees area of the Irish Sea is in a Marine Conservation Zone and will need a license from the Marine Management Organisation in order for coal to be extracted from deep under the Irish Sea. From what we can see the MMO only consults with conservancy agencies and organisations (?) This is rather scary as the organisations tasked with the protection of Cumbria’s wildlife have, incredibly, so far been rather nonchalant about this coal mine and the impacts it would inevitably have on the Irish Sea and the Irish Sea bed. We will be pushing for a full public consultation with the public and with surrounding countries. The countries that are on the Irish Sea shoreline are, Scotland, England , Wales, Isle of Man, Northern Ireland and the Republic of Ireland . All of these countries should be consulted by the MMO in their deliberations on whether or not to give West Cumbria Mining free rein to mine out coking and industrial “middlings” coal from under the Irish Sea just five miles from the world’s riskiest nuclear waste site, Sellafield.
ALSO: The Climate Change Act 2008 is a legally binding, long-term framework for the UK to mitigate and adapt to the impact of climate change. Under the Act, public bodies (including the Marine Management Organisation) must report on the steps that they are taking to respond to climate change. The purpose of this report is to highlight the ways in which the MMO’s work is at risk of being affected by a changing climate and to set out any actions to help the organisation adapt.