Dear Tim Farron MP, URGENT – TRAFFIC LIGHT SYSTEM AS STRINGENT AS THAT FOR FRACKING NEEDED FOR FIRST DEEP COAL MINE IN 30 YEARS – JUST FIVE MILES FROM WORLD’S RISKIEST NUCLEAR WASTE SITE
At over 0.5 Fracking Operations were stopped – Not so with Cumbrian Coal Mine which would be “allowed” to induce earthquakes of 3.0 magnitude.
Thank you for sight of the reply from BEIS. Once again Anne-Marie Trevelyan MP, has refused to answer our questions. We agree that no one in their right mind – even those focussed on “Delivery” of a Geological Disposal Facility would consider putting a GDF in the vicinity of a coal mine, let alone putting heat generating nuclear waste into a coal mine.
Why then is the coal mine slap bang in the middle of the Cumbrian Irish Sea “search area” for a GDF when this subsea methane rich and faulted area is clearly “not suitable” for a GDF ? Mark Kirkbride’s coal mine plan is slap bang in the middle of this “search area.”
Once again we ask the questions:
Why is Mark Kirkbride’s coal mine included slap bang in the middle of the Irish Sea “search area” for a GDF when as the Minister has confirmed this subsea methane rich and heavily faulted area is clearly “not suitable” ?
Why has the Coal Authority not stepped in already, Blocked the Licences and prevented an expensive public inquiry for a development that local planners no longer support and is financially insecure? WCM’s latest accounts indicate financial insecurity with staff lay offs to “cut costs.” The coal mine with its high ash and high sulphur coal is no longer/never was financially viable.
Finally and perhaps most importantly but most ignored, Sellafield’s infrastructure just five miles away is at serious risk from this coal mine. On the Sellafield site, the Magnox Swarf Silo for example has unknown leaks from unknown cracks in the concrete containment which is partly beneath ground. Sellafield have last month asked for help in finding and mitigating the leak of 550 gallons per day of radioactive liquor into groundwater beneath the site from unknown cracks. Fracking was halted because of earthquakes, coal is known to induce earthquakes at a far greater magnitude than fracking. An induced tiny crack in the concrete at Sellafield is not comparable to a tiny crack anywhere else.
Yesterday on Womens’ Hour the Minister did not go so far as she has done in the reply to us in endorsing the coal mine. It is understandable, if unethical, that the Minister would defend the business interests of a key advisor to her department, BEIS. Mark Kirkbride is Chair of the Sub Group (on the Committee on Radioactive Waste Management) tasked with “Delivery” of a Geological Dispsoal and advising BEIS on how this can be achieved.
What is not understandable is that the the Minister supports the mine at the expense of public safety stating “In the highly unlikely event of the proposed mine collapsing, the assessment determined that any ensuing earth tremors would be limited to very low levels. In addition, any such tremors would not be felt on the Sellafield site, nor disrupt structures, systems, and components important to safety.” This is simply breathtaking in its nonchalance.
The limit of Peak Particle Velocity that Mark Kirkbride wants the earth movement to be set at for his mine is 6mm/sec, this is as high as the upper limit for blasting in a quarry. Even then, unlike fracking which would be halted at a much lower level the operations would continue while ‘investigations’ would take place. The vibrations of huge bolter mining and cutting machinery in multiple coal mining operations (as boasted by Mark Kirkbride) under the Irish Sea will be continuous rather than sporadic as in blasting,
At the Chaco National Heritage Park in New Mexico the limit is advised at 2mm/sec PPV for mining in order to protect the structures (https://pubs.usgs.gov/of/1985/0529/report.pdf). It is accepted that at 1.0mm/sec PPV the level would cause complaint from the public – Mark Kirkbride wants his “accepted” level to be 6mm/sec of Peak Particle Velocity. (United Utilities Guidance on human response to construction vibration page 10 of May 2014 UU Statement Cuadrilla Bowland Ltd Temporary Shale Gas Exploration PNR).
Unlike fracking , West Cumbira Mining do not propose stopping operations even if earthquakes of a far greater magnitude than 0.5 ML occur. This is outrageous given that coal mining is known to induce earthquakes of 3 ML and more.
Geologist Peter Styles in his 2018 paper said: UK Seismic Traffic Light Thresholds postulate a cessation and subsequent modification (or even halting) of fracking activities if an earthquake of magnitude 0.5 ML occurs. This size of event corresponds to a movement of only a few millimetres on a short fault segment of a larger fault. Fracking and Historic Coal Mining: Their relationship and should they coincide? by Professor Emeritus Peter Styles.
Cuadrilla’s Environment Statement Appendix L on Induced Siesmicity states. “It should be noted that the TLS (Traffic Light System) required for hydraulic fracturing in the UK is significantly more stringent than the maximum ‘allowed’ induced seismic event for other hydrocarbon industries in the UK such as coal mining where magnitude >3.0ML events have been observed.” Quite!
Will BEIS step up as their predeccesor DECC did and impose a seismic Traffic Light System on West Cumbria Mining? To not do so puts the whole of Europe at risk from this coal mine just five miles from Sellafield. The Lake District Boundary Fault starts at Whitehaven, to run under Sellafield and down to the Duddon Estuary. Should the Secretary of State be minded to approve this mine a Traffic Light System at least as stringent as that for fracking MUST be put in place.
Finally the Minster for BEIS states that: “The process to identify a site for a GDF is based on positive support from a willing community together with a suitable site. No sites have yet been selected”
Evidence suggests otherwise. In a document published in August by HM Treasury “Analysis of the National Infrastructure and Construction Pipeline 2021” (an advance warning of all the planned big-money spends for the UK Gov’) (LINK below) in part 7 (page 28) [a section called: Methodology Used for Regional Analysis of Investment to 2024/25] it is explained that:
“Projects in the National Infrastructure and Construction Pipeline are allocated to individual regions (as defined by the ONS), based on the location of the built asset when the asset is located within one region.”
Then at part 7.6 (also Page 28) – this is written:
“…investment in the Geological Waste Disposal Facility is allocated to the North West”
This document evidences that The Government and The Treasury have set-aside funds for a GDF in “the Northwest” for the years 2024 and 2025.
This contradicts the position that no site has yet been chosen.
It is Urgent that a Traffic Light System at least as stringent as that for fracking is put in place for this highly mechanised first deep coal mine in 30 years five miles from Sellafield
Yours sincerely Marianne Birkby on Behalf of Radiation Free Lakeland CC Paul Haggin Cumbria County Council Planning Inspector Stephen Normington
PREVIOUS CORRESPONDENCE
16th July 2021
Dear Tim,
Thank you for sight of the reply from Anne-Marie Trevelyan MP, Minister of State for Energy, Clean Growth and Climate Change.
It was good to hear the Minister say that “I would like to reassure your constituents that Radioactive Waste Management Ltd (RWM), the developer of the GDF, has absolutely no plans to consider coal mines for the geological disposal of radioactive waste, because they are simply not suitable. ” We agree that no one in their right mind – even those focussed on “Delivery” of a Geological Disposal Facility would consider putting a GDF in the vicinity of a coal mine, let alone putting heat generating nuclear waste into a coal mine. This said we have to ask: Why is the coal mine slap bang in the middle of the Cumbria Irish Sea “search area” for a GDF when this subsea methane rich and faulted area is clearly “not suitable” for a GDF ?
CRONYISM – THE MOST BLATANT EXAMPLE EVER IN UK HISTORY?
This question of the relationship between the GDF and the Coal Mine has added piquancy given that the said Coal Mine is the business interest of Mark Kirkbride who is advising the Minister on the GDF having been appointed to a number of key positions on the Committee on Radioactive Waste Management. The Minister does not address the thorny issue of coal/nuclear/private/public cronyism in her reply to you.
To reiterate: In 2011 the same year Charles Hendry MP was prematurely congratulating Cumbria Council on their ‘steps towards geological disposal of hot nuclear wastes’, he was also cutting the ribbon on one Mark Kirkbride’s venture as CEO at Itmsoil a Sussex based International company specialising in instrumentation measuring stress in large scale construction projects. Mark Kirkbride’s Itmsoil company went into Administration in 2014 in order to give ”protection from creditors.” Charles Hendry was the predecessor of Anne-Marie Trevelyan MP, he was doing her job with the same responsibility for both the GDF and the Coal Authority.
FINANCIALLY VIABLE ?
The Minister states that the Coal Authority has to be satisfied that the coal mine must prove its financial viability before licences can be issued. We have previously made the point that the coking coal from this mine would not be the premium quality product first vaunted by WCM but would be of a high ash and high sulphur content and most likely unsaleable (as coking coal).
The latest accounts from West Cumbria Mining clearly state that the company is financially unviable. Staff have been laid off, the office in Haywards Heath has closed, the secretive financial backer is prepared to stand the cost until the end of the planning process and a third party funder says they are prepared to fund development, whatever that development is as we have not been given sight of it.
In fact No one has had sight of the latest licence applications from WCM as the Coal Authority is deferring to Mark Kirkbride’s wish not to make his development plans public. Given the relationship between WCM, CoRWM and with BEIS who have ultimate responsibility for both the Coal Authority and CoRWM this is an example of epic cronyism WCM have made much of employment of the local workforce but the Directors have a past record of using administration tactics to avoid paying creditors and then rise phoenix like into another incarnation. The amount of money spent by WCM on political lobbying (New Century Media/Tony Lodge – cosy visits by Mark Kirkbride with MP Trudy Harrison to BEIS) is in the £millions. It is clear that PR and political and financial chicanery is more important than keeping the WCM office staff on.
The paperwork has already been put into place by WCM to ensure that when it all goes pear shaped (or to plan?) WCM’s land and assets go to EMR Capital who are acting on behalf of other parties.
Further Questions include:
Why is Mark Kirkbride’s coal mine included slap bang in the middle of the Irish Sea “search area” for a GDF when as the Minister has confirmed this subsea methane rich and heavily faulted area is clearly “not suitable” ?
Why has the Coal Authority not stepped in already Blocked the Licences and prevented an expensive public inquiry for a development that local planners no longer support and is financially insecure? WCM’s latest accounts indicate financial insecurity with staff lay offs to “cut costs.” The coal mine with its high ash and high sulphur coal is no longer/never was financially viable.
Finally and perhaps most importantly but most ignored, Sellafield’s infrastructure just five miles away is at serious risk from this coal mine (notwithstanding the nonchalance of the Office for Nuclear Regulation). On the Sellafield site, the Magnox Swarf Silo for example has unknown leaks from unknown cracks in the concrete containment which is partly beneath ground. Sellafield have last month asked for help in finding and mitigating the leak of 550 gallons per day of radioactive liquor into groundwater beneath the site from unknown cracks. Fracking was halted because of earthquake risk and yet the Royal Society and the Royal Academy of Engineering have stated that coal mining induced earthquakes are of a magnitude greater than fracking : “Seismicity induced by hydraulic fracturing is likely to be of smaller magnitude than the UK’s largest natural seismic events and those induced by coal mining”. Sellafield is on the Lake District Boundary Fault and WCM plans to abstract profligate amounts of ground water from their newly voided mine via the Byerstead Fault – no one knows how these faults relate to each other. Why aren’t lessons being learnt in the Sellafield area from the fracking experience in the Blackpool area when coal mine induced seismicity is of a magnitude greater than that of fracking?
Many thanks for persisting with our questions to Ministers.
With best wishes,
Marianne
Radiation Free Lakeland
Campaigns include Keep Cumbrian Coal in the Hole and Lakes Against Nuclear Dump
Additional Notes WCM on the Rocks – or Ready for Next Venture?https://keepcumbriancoalinthehole.wordpress.com/2021/07/11/west-cumbria-mining-on-the-rocks-or-divesting-in-readiness-for-next-venture-a-big-hole-costing-1-7-billion/
Sellafield Leaks – Ongoing – https://www.gamechangers.technology/challenge/Leak_prevention_or_minimisation WCM
06 Jul 2021View / Download(PDF file, link opens in new window)06 Jul 2021Group of companies’ accounts made up to 30 June 2020View PDF Group of companies’ accounts made up to 30 June 2020 – link opens in a new window – 32 pages(32 pages)
Letter from the Minister
Dear Tim,
The Rt Hon Anne-Marie Trevelyan MP
Minister of State for Energy, Clean Growth and Climate Change
Department for Business, Energy & Industrial Strategy 1 Victoria Street London
SW1H 0ET
T +44 (0) 20 7215 5000 E enquiries@beis.gov.uk W http://www.gov.uk
Our ref: MCSL2021/15192 Your ref: TF126325
6 July 2021
Thank you for your email dated 11 May, to the Rt Hon Kwasi Kwarteng MP, on behalf of your constituents, regarding the West Cumbria Mine. I am responding as this matter falls within my Ministerial portfolio.
There is a good deal of information about the Coal Mining licensing process, including the different types of licences and permits, available on the pages of GOV.UK. Including here: http://www.gov.uk/government/publications/surface-and-underground-coal-mining- licences/guidance-notes-for-underground-coal-mining-licences.
The Coal Authority’s duties about licensing are set out in statute – in the 1994 Coal Industry Act – and to operate a coal mine an operator needs relevant rights and permissions including planning permission, a licence from the Coal Authority and to notify the Health and Safety Executive.
In general terms planning permission covers local social, economic and environmental aspects – i.e. is this the right place for this activity? whereas, a coal mining licence considers practicalities – can the mine operate in a way that is effective and financially underpinned to ensure that any land or property impacted can be compensated and the mine eventually closed in a safe and appropriate way. The Health and Safety Executive considers whether the operations can be undertaken safely.
When assessing an application for a coal mining licence, the Coal Authority are required to consider:
Whether the applicant can finance coal mining operations and related liabilities
The nature of the land or property that may be impacted by subsidence and that damage can be properly compensated by the operator.
That the operation will be carried out by properly experienced people In the case of West Cumbria Mining, this is what the Coal Authority will be assessing in consideration of the operator’s application to extend the term of their conditional licences. A conditional licence does not allow coal mining operations to commence (the purpose of a conditional licence is explained in the link above). As you are aware, planning permission for this mine is subject to an inquiry and it would not be appropriate to comment on the outcome of that but as outlined above, the Coal Authority assesses applications to it based on the duties set out in its enabling legislation.
To disclose the financial matters and commercial activity of the mine operator would be a breach of confidence to the clauses within their licence and their commercial interests. The Coal Authority also has a duty under S59 of the Coal Industry Act 1994 to ensure that it maintains confidentiality in respect of the business affairs of any individual or a business. Whilst the Coal Authority may be asked to input on aspects such as the history of the site or the quality of the coal, its processes are distinct and separate to that of planning and therefore any planning enquiry.
Given the Coal Authority’s duties under s59 of the Coal Industry Act, the Coal Authority have advised they would not disclose details of the application without the applicant’s consent.
Your constituents are also concerned that the coal mining licence applications are in some way linked to the process to find a site for a Geological Disposal Facility (GDF).
I would like to reassure your constituents that Radioactive Waste Management Ltd (RWM), the developer of the GDF, has absolutely no plans to consider coal mines for the geological disposal of radioactive waste, because they are simply not suitable.
The process to identify a site for a GDF is based on positive support from a willing community together with a suitable site. No sites have yet been selected. Two Working Groups (the first formal step in the process) have been formed in West Cumbria – in Allerdale and in Copeland – with more expected to be announced in England later this year. It is the Working Groups which will identify the initial search areas for a location for the GDF. The site selection process will stretch over several years and the decision to go ahead at a prospective location will ultimately be subject to a test of public support. It can only proceed if the community wishes it to proceed.
Thank you once again for taking the time to write. I hope you will find this reply helpful. Yours sincerely,
THE RT HON ANNE-MARIE TREVELYAN MP
Minister of State for Energy, Clean Growth and Climate Change
Comments