29 June 2021
AAPP/H0900/V/21/3271069
Metallurgical Coal Mine at Whitehaven, West Cumbria Mining Ltd
Evidence from Allerdale and Copeland Green Party
written by
Jill Perry, Secretary
Main Band House
Bullgill
Maryport
CA15 6TW
jbpgreenparty@gmail.com
1. Introduction
1.1 We are presenting this evidence on behalf of the 89 paid-up members of our branch of the Green Party, and a further 139 subscribers. Of those 228 people, 46 have a CA28 (Whitehaven) postcode, and a further 5 live in St Bees.
1.2 We have objected to this proposal to the County Council each time the opportunity has arisen and trust that our letters of objection have been forwarded to the Planning Inspectorate. As we cannot see our letters of objection on the County Council website we have no way of knowing if this is the case. We therefore append our letter of objection submitted 18th June 2020 at Appendix One
1.3 We now wish to add extra comments as things have changed since the application was last considered by the Development Control and Regulation Committee.
1.4 As things are changing frequently and rapidly we would like to give evidence verbally at the Planning Inquiry in September.
2. Climate Change
2.1 The UK 6th Carbon Budget was published by the Climate Change Committee on the 9th December 2020 and our Government announced on 20th April 2021 that it will be adopted as legally binding by the end of June this year. (https://www.gov.uk/government/news/uk-enshrines-new-target-in-law-to-slash-emissions-by-78-by-2035)
2.2 Lord Deben, chair of the Climate Change Committee wrote on 29th January 2021 that “the opening of a new deep coking coal mine in Cumbria will increase global emissions and have an appreciable impact on the UK’s legally binding carbon budgets” (https://www.theccc.org.uk/publication/letter-deep-coal-mining-in-the-uk/).
2.3 He also pointed out in the same letter that there could be no domestic need for the coal after 2035 because “Coking coal use in steel-making could be displaced completely by 2035, using a combination of hydrogen direct reduction and electric arc furnace technology to meet our recommendation that UK ore-based steelmaking be near-zero emissions by 2035." Steel-making contributes about 7% of the world’s energy-related CO2 emissions due mainly to its use of coal which means it is clear that steel-making must change.
2.4 The "end use" emissions of the expected output of the mine would be approximately 9Mt of CO2equivalent per year, causing significant climate change impacts and undermining the UK's credibility at COP26 in Glasgow this November. Until now, the County Council has argued that these "end use" emissions should not be considered, even stating that the mine would be carbon neutral, because (they have claimed) the Cumbrian production would merely replace coal that would otherwise be produced somewhere else in the world.
2.5 The Inquiry will no doubt hear from economic experts who refute this argument. We wish only to say that common sense strongly suggests that coal producers abroad are not likely to throw up their hands and close their mines because coal from Whitehaven has stolen their market, more likely they will seek alternative markets and the coal mined here will be additional.
2.6 The "transportation savings" WCM claims would result from the shorter journeys for Cumbrian coal compared with importing coal from the US would be about 0.1Mt tonnes of carbon dioxide a year. This pales into insignificance when compared with the 9Mt tonnes from using the coal.
2.7 West Cumbria Mining wanted to run the mine for 50 years. This was clearly totally incompatible with international climate agreements. Cumbria County Council was considering allowing planning consent until 2049. As the need to tackle climate changing emissions from all sectors becomes ever more urgent, and the Government acceptance of the recommendations of the Climate Change Committee in the 6th Carbon Budget show, this date is also unacceptable. Steel making must now be near zero-emissions by 2035.
3. Green Steel
3.1 We pointed out to the County Council in the appended letter that progress was being made rapidly in decarbonising steel production. Whilst most hydrogen production is not currently carbon-free, we use the term green hydrogen to reference hydrogen created by using renewable energy. In the 10 months following the writing of our letter several significant announcements by steel producers in Europe and world wide have been made.
3.2 On 23rd February 2021 Swedish firm H2GS announced their green steel plans for large-scale fossil free production "We aim to have production up and running as early as 2024.... Before 2030, we will achieve a production capacity of five million tons of high-quality steel." https://www.h2greensteel.com/on-course-for-large-scale-fossil-free-steel-production-from-2024
3.3 In Germany ArcelorMittal aims to increase its ‘green steel’ production to 600,000 tons per year by 2022 (‘green steel’ using hydrogen and Direct Reduction of iron (DRI)) and on September 30th 2020 announced its intention to be carbon free by 2050 at the latest.
3.4 Baowu steel (China), Posco steel (India) and Nippon steel (Japan) all intend to have net-zero emissions by 2050, announcements all made in December 2020 or later. China has been working on hydrogen replacing coking coal since 2019. https://www.bloomberg.com/professional/blog/china-baowu-steels-net-zero-target-is-just-the-start/
3.5 British steel makers have yet to make such commitments but with Government aid to transition they could, and should do so, or risk being left behind.
3.6 Steel recycling is the other method of reducing climate impact. 10 millions tonnes of steel are scrapped in this country each year of which 90% is sent abroad for recycling. On 6th December 2019 the Labour Party announced its plan to build a steel recycling plant in Workington: https://www.newsandstar.co.uk/news/18085859.labour-plans-1-100-steel-jobs-workington/. This did not come to fruition because of the election result. However it is clear that, with investment, there are jobs to be created and carbon emissions to be saved in this country in steel recycling.
4. Pow Beck Valley
4.1 Our previous evidence on local impact focused on the marine environment and the damage to the coast to coast walk, which would be cut through by the mining operation. Section 4.11 of Copeland Local Plan 2013-28 deals with Renaissance through Tourism and identifies the coastal strip and St Bees heritage coast as areas with tourist potential, but also identifies "improved public transport, including better weekend rail services; improving walking and cycle paths and their signage; enhancing the public realm;" as necessary to achieve that full potential. This development is in direct conflict with that aim.
4.2 However the building and operation of the railhead would have a detrimental effect on the green space known as the Pow Beck Valley. There will be noise, dust, lorries and these cannot realistically be controlled by regulation.
4.3 Pow Beck Valley is an open green space adjacent to two large housing estates (Woodhouse and Mirehouse) which were formerly council estates, and are identified in Copeland Local Plan 2013 -28 thus "Some of Copeland’s highest concentrations of deprivation are found within the Locality, in particular for problems related to poor health, low educational attainment, and high levels of unemployment and crime. A high proportion of residents claim benefits with 2 of the Locality’s areas (Woodhouse/Greenbank and Mirehouse West) ranked as the 2 lowest areas in Copeland and in the worst 10% of areas nationally for income." Access to green space is at a premium and is shown to have many benefits in terms of mental health and physical fitness, which should not be removed from local residents and replaced with industrial operations which are shown to negatively impact wellbeing.
4.4. "Development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists" National Planning Policy Framework, paragraph 175 point c. Although the section of ancient woodland to be lost is small it is not insignificant as wildlife habitat and biodiverse landscape and should be preserved. For the reasons mentioned in our other sections of evidence, these are not wholly exceptional circumstances.
5 Employment
5.1 In our previous evidence we questioned whether the promised 500 jobs would exist for the projected 50 year life of the mine (now perhaps reduced to 30 years). Since the writing of that letter in June there have been several studies done which show the potential for green job creation in the area.
5.2 We have already mentioned above the potential for a steel recycling plant to provide 1,100 jobs.
5.3 Local Government Association has published research, (https://lginform.local.gov.uk/reports/view/lga-research/estimated-total-number-of-direct-jobs-in-low-carbon-and-renewable-energy-sector?mod-area=E07000026&mod-group=AllBoroughInRegion_London&mod-type=namedComparisonGroup) which shows that 861 jobs could be created in Copeland, 1,170 in Allerdale and 1,802 in Barrow by focusing on low carbon development, far outweighing the 500 jobs promised by WCM.
5.4 On March 12th 2021 Cumbria Action for Sustainability (CAfS) published research entitled The potential for green jobs in Cumbria. The research reveals the potential for 9,000 jobs over the next 15 years as Cumbria seeks to hit its 2037 net-zero target. Of those jobs, the majority (4,500) would be sited in West Cumbria. They estimate around 3,500 in renewable electricity, 650 in retrofitting buildings with energy efficiency measures, 150 in waste management and 150 in industry. (https://cafs.org.uk/the-potential-for-green-jobs-in-cumbria/)
5.5 If we are to hit our target in Cumbria and our targets nationally on carbon reduction we need, as a country, to be investing in retraining our workforce and training our young people to work in low carbon industries.
6. Balance of Benefit and Detriment
6.1 We believe the claimed benefits are largely illusory.
6.2 The market in the UK is less than claimed by WCM. We know that up to 92% of the coking coal will be exported to Europe or beyond. Only Tata steel is a possible user of Whitehaven coal as British Steel has rejected it as unsuitable because the sulphur content is too high. The UK market will fall further when the Government passes into law the recommendations of the Climate Change Committee.
6.3 The market is falling rapidly in Europe as more and more steel producers turn to replacing coking coal with green hydrogen in an effort to become carbon neutral. Therefore the claimed benefit of carbon saving from less transportation will not translate into reality.
6.4 Even in the Far East steel producers are turning away from the use of coal. https://www.bloomberg.com/professional/blog/china-baowu-steels-net-zero-target-is-just-the-start/
6.5 Because the market for coking coal for the steel industry is shrinking rapidly we believe the figures projected by WCM on job creation are wildly optimistic. Even if the projected 500 jobs existed for the projected 50 year (or reduced 30 year) life of the mine, almost 400 of these would need to be filled by experts in the field and would not go to local people. However we believe the fast reducing market and increasing mechanisation means that the lifetime of these jobs will be much reduced.
6.6 We believe that the detriment the mine and ancillary developments will cause has been understated.
6.7 The detriment to the global climate from the building and operation of the mine and the use of the coal produced is clear and outlined by the Climate Change Committee chair Lord Deben.
6.8 There will be severe detriment to the reputation of the UK in the year when it hosts COP26, United Nations climate change conference in November of this year, if the mine is permitted to go ahead.
6.9 The detriment to the natural environment with the loss of ancient woodland, green space and potential damage to the seabed of a Marine Conservation Zone is there for all to see.
6.10 The loss of green space, peace and tranquility will be a detriment to both the people who live in the vicinity and tourists visiting to use the starting point of the Coast to Coast walk.
7. Conclusion
7.1The most recent major change since we last submitted comments is that the Government has agreed the carbon budget recommended by the Climate Change Committee will be binding in law.
7.2 The second change is the increasing effort by steel makes to reduce their carbon footprint. As the "Polluter Pays" principle is applied more heavily, this effort is only likely to increase.
7.3 As the benefits seem illusory and the detriments clear, we believe that the mine should be refused planning consent.
Appendix One
18.06.2020
Dear Sir,
I am writing in my role as secretary of Allerdale and Copeland Green party to object to planning application 4/17/9007 for a coal mine off Cumbria’s west coast. We are aware that our objection is slightly late and are therefore asking that you make the Planning Committee aware of our response, if it is too late to be included in the report.
Climate Change
West Cumbria Mining(WCM) claim that the only reasonable way of making steel at scale for the next 50 years involves the use of coking coal. This is unlikely to be true given that research into decarbonising steel is progressing at pace, in the UK and Sweden in particular. The aim is to reduce coal use and reach net zero by 2050.
WCM claim that if planning permission was not granted, Scunthorpe and other steel producers would still be using just as much coal, but it would be imported from the USA, as it is now. It is unlikely that, if this coalmine is allowed to operate, US mines will scale back their operations. More likely they will offer their coal at a reduced price and search for new markets, increasing demand. Thus the carbon reduction is likely to have been exaggerated by WCM.
If WCM gain permission for 50 years of extraction that could stop the UK meeting its commitments under the Paris Climate Agreement which, as shown by the Heathrow Airport decision, is legally binding in the UK.
Furthermore carbon emissions from the mine need to be measured against Cumbria's carbon budget. Cumbria has a net-zero carbon target which could be blown away by this one planning application.
The WCM offer of a legal agreement to reduce emissions or close the mine if the emissions are more than 1% of the UK emissions is unlikely to be enforceable, or is likely to be copied by other carbon intensive industries, thus rendering our commitment to net zero by 2050 unachievable. If the coking coal is used in the UK then the steel production will also have significant emissions.
We have considerable concerns about the overlap of the WCM offshore area of interest and that of licensed areas for exploration for Underground Coal Gasification and for Coal Bed Methane, meaning WCM could (in the event of lack of demand for coking coal, and with further planning consents) easily turn their attention to either of these two exceedingly damaging procedures.
The Natural World
The plant is sited close to the start of the Coast to Coast walk and could undermine the popularity of this route. This area is designated St Bees Heritage Coast. At the very least it could show the council in a very bad light to people who love the wildlife, scenery, peace and tranquility of the area.
St Bees Head is also the only English breeding site for the Black Guillemot. There is considerable potential for disturbance of these rare nesting birds.
The sea off St Bees is a Marine Conservation Zone (MCZ), and we understand that the possibility of subsidence and the effects of pumping waste rock back into the voids left by extraction on the water quality and marine life of the MCZ have not yet been considered. These should be considered now, because the refusal of an extension of mining permission to the under-seabed area will affect the viability of mining operations and therefore become a material factor in the decision. As we do not know what the potential bad effects of the whole mine will be, the Precautionary Principle must apply.
Economic Benefits
In this revised proposal, WCM claims to be providing 500 jobs lasting for the full 50 years of the project, although we do not know that phase 2 (extraction from under the sea-bed) will be given the go-ahead, given the potential adverse impacts, as yet unconsidered. It is also quite likely that increased mechanisation will reduce the number of employees needed.
We understand the need for new jobs for West Cumbria, but we would like to see sustainable, green jobs in line with The Green New Deal, https://neweconomics.org/about/our-missions/green-new-deal not those which contribute to climate change, increasing flooding, drought, hunger, poverty and mass-migration because of environmental degradation. It is worth also considering The Blue New Deal (for coastal communities) https://neweconomics.org/campaigns/blue-new-deal
Jobs provided by locally-owned companies provide economic benefit to the whole community as profits are circulated locally, using, in general, local support services and supply lines. However the profits from this venture will go to the ultimate owner EMR Capital with an office based in the tax haven of the Cayman Islands.
Conclusion
We consider that this application is in contravention of Objectives 1,2,5,6,7,8 of the Strategic Objectives shown in Box 2.3 of the Minerals and Waste Local Plan 2017 (that is 6 of the 11 Strategic Objectives). It is also in contravention of policy SP1 as it is clearly not sustainable development and we believe it will not deliver the economic benefit to the area that has been promised and the adverse impacts do outweigh any predicted benefit.
For all these reasons, we call on members of the Development Control Committee to refuse planning consent to this coal mine.
Jill Perry
Secretary Allerdale and Copeland Green Party
