As promised at Monday'meeting, just a few pointers on planning matters for letters of objection some of which Wrekin Friends may wish to pick up in letters to David Coxhill, Minerals Planning, Telford & Wrekin Borough Council, Darby House, by March 3^rd.

1. Need

National and local planning policy requires the application to demonstrate need.

 

UK Coal says it will supply Ironbridge or Rugeley power stations. Both these facilities are currently well served with coal – much of which is imported. At the same price delivered –  which the coal would have to be

to compete – the overall environmental cost to the country is substantially greater from the proposed development (overburden removal, extraction, processing and road transport) than from importation (involving merely unloading and rail transport).

At a burn rate of 6000 tonnes per 15/16 hour operating day, the coal extracted will only keep Ironbridge power station going for an estimated total of just over 20 weeks – or just seven weeks per year of operation. That’s hardly a major need; especially since it is already being served quite acceptably from other sources far less damaging to the national let alone local environment.

 

Any need argument is further undermined by the extent to which both national and local policy is increasingly seeking to maximise electricity generation from renewable sources rather than from fossil fuels known to have such a major impact on CO₂ emissions and climate change

 

In various guises, the site has been subject to a series of planning applications over the past 20 or so years.

 

At the most recent (Dawley II) which went to Public Inquiry in 1998, the Inspector concluded  that ‘the coal in the application site is not of a notably high or rare quality that makes it particularly sought after’ and labelled it ‘no more than general purpose opencast coal.

 

Overall, therefore, while there could be a market for the coal to be won from the site, there is no significant national or regional need to justify its extraction at this time.

 

2. Landscape & Environment

 

Because the application affects the Shropshire Hills Area of Outstanding Natural Beauty (AONB) national and local planning policy contains a presumption against the development except in exceptional circumstances and only if it is demonstrated to be in the public interest.

 

UK Coal seeks to minimise the importance of its AONB impact by suggesting that the area affected is only very small and of relatively little value. This undermines the whole principle of safeguarding the Area and sets a very dangerous precedent for the future.

 

At the same time, the applicant fails to recognise that the site’s position on the thin northern arm of the AONB in close proximity to the major conurbation of Telfordm makes it arguably more vulnerable than most of the rest of the Area, so worthy of particular protection.

 

Beyond a possible market for the coal there is clearly:

§         No significant need for the mineral;

§         No exceptional circumstances that might it should be permitted; and,

§         No public interest in the proposal going ahead.

 

After all, the site itself would only offer a total of 40 jobs, the bulk of these being relatively low-paid and over a very short timescale.

At the same time, it would only provide sufficient coal for Ironbridge Power Station to run for 7 days in each of its year’s of operation.

 

The land in question forms one of the last remaining examples of natural post-industrial regeneration from previously mined land – all other remnants within the area having been destroyed by extensive open-casting over the years.

 

It is vitally important areas such as these are preserved intact if at all possible, their relatively low agricultural quality being a major asset given the extent to which low fertility sites are valuable in conservation terms.

 

Nor should a small part of the site’s alleged inclusion in the register of derelict land be a serious consideration, not least since the scale of its natural regeneration has clearly underlined its ecological value.

 

As a vital piece of open space forming a prominent foreground to the distinctive AONB landscape of the Ercall and Wrekin for the bulk of Telford residents the site is also far more important than would otherwise be the case both visually and for local recreation.

 

To disrupt such a vital local asset unless at a time of extreme national need would be nothing short of environmental vandalism at this stage in its successful regeneration.

 

Leave the existing reserves intact would further safeguard them for such a time, rather than allow them to be exploited when economic imported sources of fuel are readily available at far less environmental cost and community impact.

 

3. Important Sites & Species

 

As well as the AONB, the site will affect a number of nationally important sites and species for which national and local planning policy provides specific protection.

 

Drainage of water from the site into the Lydebrook may put at risk the Lydebrook Dingle Site of Special Scientific Interest which has over the past 10 years been recovering significantly from the ill-effects of pervious opencast mining and coal processing at Swan Farm and Coalmoor.

 

The proposed development also cuts across a scheduled Ancient Monument designated to preserve some of the last remnants of early coal mining in the locality from precisely the sort of opencast development envisaged.

 

UK Coal seeks to justify this by claiming that the development could improve access to the Ancient Monument which is neither necessary or desirable since the monument is designated to protect the remains rather than to encourage unrestricted access to them, which could easily have seriously negative effects.

 

The development will have an unacceptably negative effect on the setting of two Grade II listed buildings and directly affects four badger setts and the foraging territory of two further badger clans.

 

4.  Transport

 

Specific planning policies constrain mineral developments on transport grounds.

As well as creating unacceptable levels of traffic in and around the site, the development will add an excessive burden of additional heavy lorry traffic on a stretch of road insufficiently well-engineered to take it and potentially cause serious traffic problems in a major focus of current urban development.

 

This section of road on the approach to Horsehay, in particular, is already badly crumbling under the constant pressure of HGVs moving to and from the Candles Landfill site. An additional 130 or so extra heavy lorry movements a day over the period would clearly cause immense problems to this section of the highway network.

 

It would also add significantly to the danger of the Horsehay road junction where the poor road surface has led to a number of near accidents over the years.

 

Were the coal to be destined for Rugeley power station,the extra traffic would also have a serious effect on the major developments taking place at Lawley and scheduled to cause disruption to the local highway network for some considerable time to come.

 

5.  Other Local Impacts

 

Local minerals planning policy stipulates that people and the environment should be protected from adverse effects including visual, noise and dust.

The location of a substantial primary school and major current residential area and site of current massive residential development less than 1 km immediately downwind of the site raises serious health worries over dust pollution.

 

Local experience with repeated opencast coal mining over the years reinforces the inadequacy of dust control measures in practice and the almost total inability of local residents to gain action over clear dust problems once sites are up and running.

 

The effect of dust and disturbance on the adjacent Shortwoods ancient woodland and two local wildlife sites is also likely to be considerable.

 

The lack of effective mitigation over reversing bleepers in particular, together with the potential for blasting and the extended 42 month timescale for the development will further cause serious problems for the local community within 250 m of the site at New Works, Huntington and Arleston, not to mention residents of Lawley and parts of Wellington.

6.  Cumulative Impact

 

National and local planning policies provide specific protections from the cumulative impact of minerals developments.

 

The proposed development would significantly add to the disruption and disturbance of the local community from more than 50 years of extensive open-casting and directly-related activity in the immediate vicinity.

 

Whereas, UK Coal assesses cumulative impact almost entirely on the basis of current sites, national minerals planning policy clearly defines cumulative impact as arising from ‘successive opencast developments over a number of years’.

 

As well as opencast coal mining at Ketley Brook, Arleston, Candles, Simons, Coalmoor, Swan Farm and a whole host of other sites since the 1950s, the local area continues to be blighted by the effects of poorly controlled land-filling following mining at Smalley Hill and the operation of the Candles landfill which continues to be the source of much local complaint as a result of traffic, litter, odour and vermin.

 

Large numbers of local residents have been affected by the cumulative impact of these and other developments in their lifetime.

 

7.   Special Protection

Local planning policy states that applications for coal or fireclay working in the South Western Telford Area will only be granted planning permission if one or more of three exceptional circumstances apply.

 

(i)  Where the need for the mineral outweighs the material planning objections;

(ii) Where working would prevent the sterilisation of the resource; or

(iii) Where significant benefits would be obtained as a result of the exchange or surrender of existing permissions.

UK Coal’s proposals clearly do not meet exceptional circumstance (i) since there is no demonstrable need for the mineral – other than a possible market for it – and there are a large number of highly material planning objections.

 

They also fail to meet circumstance (ii) because the mineral is in no danger of sterilisation – defined in national planning policy as ‘new permanent development above the coal reserves’.  This was confirmed by the Inspector’s clear ruling at the 1998 Public Inquiry.

 

And finally they cannot meet circumstance (iii) because UK Coal has no existing permissions in the area to surrender.

 

8.  Reclamation and After Use

Planning policy requires the development to incorporate a scheme to reclaim the site for a suitably beneficial after-use within a reasonable timescale.

Quite contrary to UK Coal's assertion that the site will be reclaimed within five years, experience with successive opencast sites reclaimed to agricultural use in the immediate area in recent years have conclusively demonstrated that the lack of reasonably amounts of soil and the soil handling practices employed are unlikely to result in land in an acceptable condition for at least 10 years; and in at least the condition it is current in for more than a generation.

 

At the same time, UK Coal has already admitted in public than an associated company is looking to exploit the ‘brownfield’ status the site will have after opencasting for a future major development of housing, so its reclamation proposals are little more than fantasy.

 

Happy letter writing !!!!!

[Later additions by George Evans]
Just one addition to the objections. Where it talks of particle fallout, the commercial/business park around Tesco is right in the path of the prevailing winds blowing toxic dust. Not only will customers' cars be covered in dust but so will the food; Tesco might even lose money!

Oh, and another. Post industrial regeneration - the way 'Nature' fights back from the effects of human activity - is an up-and-coming subject for academic research. It is fascinating to watch the sequences of regrowth and will be even more interesting as more is learned of soil science, which is still in its infancy. The paleotechnic landscape on this site is unique and of great value to earth scientists. # Posted by George Chancellor at 15/2/08; 7:15:58 PM
To the Gossip & Rumour dept.
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Friends Objections to Opencast Mining