Final Bradley Surface Mine Obj

BRADLEY SURFACE MINE, 2ND PUBLIC INQUIRY
19th SEPTEMBER 2014
PLANNING INSPECTORATE REFERENCE: APP/X1355/A/11/2150277/NWF

THE LOOSE ANTI-OPENCAST NETWORKS (LAONs) OBJECTIONS TO THE
BRADLEY SURFACE MINE APPLICATION
Index
Paragraph Numbers
Introduction
1.1 -1.6
Basis of the Bradley Surface Mine Objections
2.1
Adverse Environmental Impacts: Introduction
2.2
The Economic Viability of the Proposal:

Introduction
2.3 2.3.7
Objection 1) Adverse Environmental Impact:

Climate Change
3- 3.12

Additional Local Environmental Impact
3.13 3.21

Additional Air Quality Issues
3.22 3.25
LAONs Environmental Objections
3.26 3.27
Objection 2 Economic Viability of the Proposal: 4 4.3

Outlining the basis of this Objection
Objection 2 Economic Viability of the Proposal: 4.4 4.23
Do we need and is there likely to be a
market for this Coal?
The Potential Impact of the Disruptive
Technologies of Renewable Energy.
Technological and Supply Changes to the
Domestic Coking Coal Market, which could
lessen the demand for Coking Coal.
Site Restoration and Restoration Bond Issues
Objection 2 Economic Viability of the Proposal: 4.48

UK Coals Claim that it finds it difficult to gain
Planning Permission for new Surface Mines.
LAONS Economic Viability Objections
Conclusion : LAONs Objections to the Bradley
Surface Mine Proposal
4.49
5 5.3
References these begin on Page 44.

INTRODUCTION
1.1 The bulk of the documentation and the discussion in this Inquiry is
about determining that, if the Appeal is upheld, it is safe to start this
development, that the quality of the development proposal meets the
minimum standards required by regulations and the development is
entrusted to a competent company who can bring the development to a
satisfactory conclusion, restore the site according to the agreed plans for
site restoration and meet the conditions attached to the decision. The
objections which LAON is submitting challenges aspects of this case. LAON
does not agree that it will be safe to start this development. Neither is it
clear, given the applying company, UK Coal, is in administration that they
will be the company actually mining the coal. Lastly LAON is not
convinced given the rapid rate of technological change affecting the
power generating industry, especially the section of it relying on coal fired
power stations, that there is a need for this coal. LAON believes, should
this application be allowed to proceed, then there is a real risk of Co
Durham being left with a Scottish Scenario, of having an un-restored
opencast mine left as a legacy, should the appeal be upheld.
1.2. The term Scottish Scenario refers to the ongoing crisis affecting the
Scottish Surface Mine Industry after two coal operators, Scottish Coal and
ATH Resources went bankrupt, leaving up to 34 un-restored opencast
sites. The cost of restoring these sites has been put at 255m, (1) of
which only 55m can be met from various Restoration Bonds. It should be
noted that when these two firms ceased trading, the price of European
Coal varied between 55 -60 per tonne. Since then European Coal
prices have fallen to between 45 -47 per tonne (September 2014)
1.3. As a consequence of what has happened in Scotland, the Welsh
Government commissioned a review of its own Surface Coal Mine Industry,
to see if there was a risk of the Scottish Scenario being repeated in
Wales. The report, published as 'Research into the failure to restore
opencast coal sites in south Wales', in April 2014 (2), estimated that Wales
potentially faced a similar restoration problem. The Report estimated a
shortfall in funding to restore three sites at 187m, with a degree of
uncertainty over whether sufficient funds existed to restore two other
sites, should the operator go into administration.
2
1.4. However, since the Scottish Mining Restoration Crisis broke, there
has not been a similar review of English surface mine operations to see
how robust the English Planning system is at assessing the risks
associated with opencast mining and whether sufficient safeguards exist
to prevent any kind of repeat of the Scottish experience.
1.5. Given this context, of the risk that sites can be left in an un-restored
state, it is perhaps understandable why a large part of the submission
from LAON is not so concerned about whether it is safe to grant
permission to start the development. Rather, our focus is on what
circumstances will be facing the operator when coaling is about to cease
or has ceased entirely, and, with it, the associated income stream. Will the
Applicant then have sufficient financial resources to complete the
expensive process of site restoration? We consider this to be a legitimate
question to ask, especially in view of the evidence we will present about a
predictable decline in the demand for thermal coal as indicated by DECC
figures and the more unpredictable impact on the demand for coal
represented by the adoption of newer energy producing technologies.
Companies operating in an industry in decline, face significantly different
financial pressures from those operating in a stable or expanding business
environment, as credit dries up and, for this industry, it becomes
increasingly difficult to get insurance based Restoration Bonds.
1.6 LAONs conclusion from this introduction is that it will be a material
consideration to ask if either the Applicant or the Liquidators will have
sufficient resources to restore the site if the appeal is upheld.
2.1. BASIS OF THE BRADLEY SURFACE MINE OBJECTIONS
This set of objections is based on sections of both the National Planning
Policy Framework (NPPF) and the accompanying Planning Practice
Guidance Notes as follows:
2.2 ADVERSE ENVIRONMENTAL IMPACTS: INTRODUCTION
The first objection is that this application does meet the criteria that the
adverse impacts of doing so (i.e. granting permission) would significantly
and demonstrably outweigh the benefits, when assessed against the
policies in this Framework taken as a whole as defined in paragraph 14 of
the NPPF
It will be argue that the statements in the NPPF and the Planning Practice
Guidance concerning both Climate Change and Air Quality have to be
considered as material considerations when weighing up the many factors
involved in determining this application. When these two objections are
added to an additional assessment about the detrimental environmental
impact of the proposal in paragraphs 3.9 to 3.21, to those that have been
submitted by others about this issue, that this proposal has had, and will
have, on the community surrounding this site should the appeal be
upheld, then the conclusion must be that this is not a sustainable

development as defined in the NPPF.
2.3 THE ECONOMIC VIABILITY OF THE PROPOSAL: INTRODUCTION
The second objection questions both the need for coal and thus the
viability of the proposal. The conclusion presented here is that this
application, at the present time, cannot be guaranteed to bring great
benefits to the economy as required in paragraph144 of the NPPF.
2.3.1 The National Planning Guidance, in paragraphs 016 and 017, ask
that the applicant does provide evidence about the viability of the
proposal where it is considered being appropriate. Thus
However, where the deliverability of the development may be
compromised by the scale of planning obligations and other costs, a
viability assessment may be necessary. (paragraph 016)
2.3.2 This is an application which, if granted, will take many years to
complete. Evidence to be presented will demonstrate that the length of
time proposed for this development will coincide with dramatic changes in
the domestic demand for coal, affecting both the demand for thermal coal
as old obsolete power stations are taken off the grid and the development
of new technologies that are lessening the demand for thermal coal.
Technological change is also affecting the demand for coking coal, just as
a new UK development is likely to increase the domestic supply of coking
coal by 2017.These developments are likely to have an impact on this
schemes viability, especially if an account is taken of another part of
paragraph 16:
Viability assessment in decision-taking should be based on current costs
and values. Planning applications should be considered in todays
circumstances.
Attention has already been drawn, in paragraph 1.2 to the fact that the
current price for coal is now between 20 and 22 % lower than the price of
coal was before the two Scottish operators went bankrupt. In addition,
LAON suggests that UK Coal / Juniper (No 3) Limited, will bear an
additional cost of production of 2 per tonne on each tonne of coal
produced, paying this to H W Martins, the company which, LAON believes,
is the owner of the Bradley site.
2.3.3 Paragraph 017 suggests where the timescale for the development is
longer term, that:
However, where a scheme requires phased delivery over the medium and
longer term, changes in the value of development and changes in costs of
delivery may be considered. Forecasts, based on relevant market data,
4
should be agreed between the applicant and local planning authority

wherever possible.
In the absence of any other data, this objection contains evidence that
does, in some detail, question the need for the thermal coal on the
Bradley site. This should be considered a material consideration in
determining whether Paragraph 144 of the NPPF should apply in this case.
2.3.4 In addition, it is argued here that consideration should be taken of
the financial position of the Applicant. Despite appearances to the
contrary, the applying Company is not the UK Coal of old. It is a new
company, barely a year old, which does not have a history. No trading
statement has been published in the public domain and there is no
statement of assets that can be analysed. In addition it should be noted
that on 8/9/14 the Company, Juniper (no 3) Limited was still in liquidation.
The role of the Liquidator is to act in the best interest of creditors, not
shareholders. It would therefore seem reasonable to suggest that should
the Appeal be upheld, the Liquidators, acting in the best interests of
creditors, would then seek to sell the rights to extract the coal to a third
party as soon as possible. The other point related to this issue, is that if
the ongoing attempts to secure a loan are successful, then securing this
deal will be contingent on selling off the surface mine sites. (See the next
paragraph)
2.3.5) Earlier this year on 10/4/14, the Company announced that it
urgently needed to borrow 20m to stave off imminent bankruptcy and
enable the Company to initiate a phased run down of its two remaining
deep pits and that it was intending to sell off its remaining surface mine
operations as a package. On June 11th came the announcement that the
loan proposal had fallen through as Hargreaves Services was no longer
willing to be a party to the deal. (3) Since then, as of 29/8/14, there has
been no further official statement from the Company about its financial
position although more recent press reports suggests that the discussion
about a loan agreement is ongoing. If such an agreement is reached, then
the price of reaching such an agreement, LAON believes, will be to sell off
the remaining surface mine sites, where the right to exploit coal reserves
where planning permission has been granted, including Bradley, should
this appeal be upheld. If this is the case, then assurances given in the
submission documentation about UK Coal / Juniper (No 3) Limited, being
as LAON describe in paragraph 1
a competent company who can bring the development to a satisfactory

conclusion, restore the site according to the agreed plans for site
restoration and meet the conditions attached to the decision.
has no meaning and the claims made by the Agent in the submission
document, especially paragraphs 3.1.1 to 3.1.10 of Chapter 3 Proposed
Development of the Environmental Impact Assessment, on behalf of the
Company, should be discounted.
2.3.6) If this site is not sold, then the financial state of affairs of UK Coal is
a pertinent matters when it comes to both assessing whether this
application is financially safe enough to proceed and the need for a
Restoration Bond and what kind of Restoration Bond is required.
2.3.7) LAON argues that this is a material consideration. The applicant and
their Agent have already indicated that the National Planning Policy
Guidance Note on Minerals is relevant to this Application. We agree, and
would like to draw attention to paragraph 048 which asks the question:
When is a financial guarantee justified?
A financial guarantee to cover restoration and aftercare costs will
normally only be justified in exceptional cases. Such cases, include:
very long-term new projects where progressive reclamation is not

practicable, such as an extremely large limestone quarry;
where a novel approach or technique is to be used, but the minerals

planning authority considers it is justifiable to give permission for the
development;
where there is reliable evidence of the likelihood of either financial

or technical failure, but these concerns are not such as to justify
refusal of permission. (4)
Our objection is based on the third of these points. It indicates that the
determining authority has discretion over deciding if an Applicant will or
will not experience the likelihood of a financial failure of such a concern as
to justify refusal of permission. We would argue that there is reliable
evidence of potential financial failure of this Company and that these
concerns are of sufficient merit to justify rejecting this appeal. Paragraphs
6
2.3.5 to 2.3.7 of this submission already provide some evidence to be

considered. More will be offered later when discussing the issue of
viability in more depth.
OBJECTION 1) ADVERSE ENVIRONMENTAL IMPACT: CLIMATE CHANGE
3 The first LAON objection is that this application cannot be treated in
isolation from the effects that using the coal released from this site, either
for electrical power generation purposes or for steel making, will have on
our environment and our lives.
This is a local, national and international issue, associated with both
Climate Change and Air Pollution. Because of this the NPPF has sections
on both of these issues.
3.1 On Climate Change the NPPF states the following:
Planning plays a key role in helping shape places to secure radical
reductions in greenhouse gas emissions, minimising vulnerability and
providing resilience to the impacts of climate change, and supporting the
delivery of renewable and low carbon energy and associated
infrastructure. This is central to the economic, social and environmental
dimensions of sustainable development. (Para 93)
3.2 It is our contention that if this application were to be approved, then
exactly the opposite outcome would be achieved, that vulnerability to
greenhouse gas emissions would be increased and it would undermine
attempts to develop the delivery of renewable and low carbon alternative
forms of energy provision which are urgently needed.
3.3 Paragraph 103 states:
When determining planning applications, local planning authorities
should
ensure flood risk is not increased elsewhere.
It is LAONs opinion that the mining of this coal and the burning of it in
unabated power stations and steel works will contribute to global warming
and a rise in sea levels and make more likely, a tidal surge event that was
witnessed around the coasts of the UK last winter. Such events can result
in flooding, loss of life and damage to property.
3.4 In 2012, DEFRA and DECC published their Conversion Factors for
Company Reporting. In the table at Annex 1 they give a figure for the
amount of CO2 produced by burning coal for power generation purposes.
Each tonne of coal so used produces 2,238.2 kilograms of CO2. (5) or
2.239 tonnes. Burning 520,561 tonnes of coal will produce over a million
tonnes of Carbon Dioxide, 1,165,536 tonnes.
7
3.5 In addition, the Planning Practice Guidance (paragraph 01) states:

In addition to supporting the delivery of appropriately sited green
energy, effective spatial planning is an important part of a successful
response to climate change as it can influence the emission of
greenhouse gases. In doing so, local planning authorities should ensure
that protecting the local environment is properly considered alongside the
broader issues of protecting the global environment.
3.6 Please note the emphasis, in addition to supporting the delivery of
appropriately sites green energy. Again the emphasis on the body, or the
person, determining any planning application, is that they have a
responsibility to reduce the emission of greenhouse gases to protect the
global environment. Granting planning permission for this development
will have exactly the opposite effect from that intended in this guidance,
the release of 1,165,536 tonnes of CO2. Under such circumstance, our
responsibility is to ensure that this coal is not used in such a way that
contributes to global warming and set an example to other countries to do
the same. Those countries must take their own blame, if they then allow
the same amount of coal to be mined and burnt in our power stations. We
will have stopped this additional CO2 from being released into the
atmosphere.
3.7 It is therefore ironic that Durham County Council will have the
responsibility of regulating this site if the Appeal is upheld. Ironic because
at the same time Durham County Council, a costal county which could
experience another tidal surge, like all UK local authorities, is employing
staff at public expense, to ensure that the consequences of burning coal in
this way and releasing millions of tonnes of CO2, is minimised through
measures to mitigate the effects of climate change caused by increased
levels of CO2 in the atmosphere. A true assessment of the economic
benefit of this proposal should include an assessment of the part of the
costs borne by National and Local Governments in the UK, in trying to
counter act the consequences of climate change caused by burning coal
in an unabated way.
The latest figures from the Department of the Environment, Food and
Rural Affairs for example, show that in England, a total of 606m and
795m are budgeted to be spent on Flood and Costal Erosion Risk
Management in 2013/14 and 2014/5 respectively (6). As has already been
indicated, the burning of this coal, in an unabated way, will contribute to
increased flood risk and increased levels of coastal erosion and the need
for mitigation measures. A share of the cost of these mitigation measures
would be attributable to this proposal if the Appeal is upheld. The cost of
this should be a material consideration when assessing this planning
appeal.
3.8 Despite the Applicant and the Applicants Agent directly ignoring the
fact that burning this coal under present circumstances will result in an
increase in CO2 emissions and contribute to climate change, they have
8
implied in their submission that this is the case, when they argue that
using indigenous coal has less of an environmental impact than using
imported coal. They cite in Chapter 12 of their submission, Highways and
Transport, that using the Bradley site as a source of coal will impose less
of a burden on the environment that using imported coal, as the amount
of C02 emitted on transporting this coal would be much less, 7.8% of the
equivalent tonnage of moving the same amount of imported coal.
(paragraphs 12.5.9 to 12.5.11)
3.9 However, this analysis / argument should not be taken as a proxy
argument for the total environmental impact, or for the argument over the
amount of CO2 generated by the mining of the coal when comparing
imported coal to local coal.
3.10 Although the figures used in the limited analysis provided by URS for
the applicant are not disputed, it should be understood that the argument
that utilising indigenous coal is better, taking account of the reduced
emission of CO2 used in transporting this coal, when set against the total
amount of CO2 to be released from burning this coal if approval is given,
is a bit like the story of the boy who plugged a Dutch dyke with his finger,
but that this time, he failed to see that the dyke was crumbling all around
him.
3.11 However this is only an analysis of the carbon footprint involved in
transporting the coal. Missing is any analysis of two further aspects the
carbon footprint of extracting the coal and the local environmental
impact if rejecting the planning appeal is the result of this Public Inquiry
and the coal has to be imported.
3.12 Neither UK Coal or its Agent have provided any detail of the amount
of carbon dioxide to be emitted whilst extracting the coal by utilising
diesel powered heavy and light machinery on the Bradley site Nor does
the analysis provided give any indication of the carbon dioxide to be
emitted whilst producing the coal that would be otherwise imported. Some
of this imported coal could well be produced from deep mines which use
electrical power, not diesel, thus tending to reduce the overall carbon
footprint when compared to producing UK surface mined coal. Thus,
arguments about using indigenous coal because it has a lower carbon
footprint, has still to be proved.
OBJECTION 1) ADVERSE ENVIRONMENTAL IMPACT: ADDITIONAL LOCAL
ENVIRONMENTAL IMPACT
3.13 The other point, most important to local people, is the difference in
the environmental impact between what is proposed here, once
permission has been given and what the effect would be on the local
community if planning permission is refused:
3.14 This is the likely effect on the local community should this appeal be
upheld:
9
Up to two more years before soil stripping can commence, including

the time taken to report the conclusions of this Public Inquiry and
then to conclude both post- planning discussions over conditions
and obligations before UK Coal is given permission to start soil
stripping. This part of the timetable is not under the control of UK
Coal.
Coaling to cease 32 months after soil stripping begins, possibly 4

years and 8 months after planning permission is granted.
Then possibly, after five years and six months after the initial
planning permission has been granted, the top soil has been
replaced and the site enters the aftercare phase (i.e. 3 years and six
months after soil stripping started).
No estimate is given in the planning application for when the local

landscape will again look mature. It is suggested here that 15 years
is a conservative guess, which is in keeping with management plan
for part of the site post restoration.
This makes a total of over 20 years. During the period of site

preparation and working, the local community will feel the effects of
all the nuisances associated with coal extraction including noise and
the loss of local amenities. These may be mitigated, they are not
eliminated
3.15 If the appeal is upheld and the coal has to be imported, then the
local community around the Bradley site bears none of this cost or loss.
Instead, just 4 shiploads of coal, in 140,000 tonne ships, can discharge in
Immingham and transport all this coal, in much shorter time, to Drax by
rail, with having hardly any environmental impact on any British
community.
3.16 However, this is not the only environmental cost involved. Ever since
UK Coal submitted their initial Scoping Inquiry prior to them submitting
their initial planning application in 2007, an area within 500m meters of
the boundary of the proposed Bradley site has been affected by planning
blight. This is caused by the actions of the Coal Authority which, in
responding to any property search enquiry being made on local
properties, has to inform the inquirer that there is the prospect of a
surface mine application being made within 500m of the property in
question, if the property in question is within 500m of the boundary of the
proposed surface mine. The reality that opencast mining applications
cause planning blight was acknowledged by this Government in 2013, in
their publication Major infrastructure planning: extending the regime to
business and commercial projects. Summary of responses and
government response (7)
3.17 This document summarised responses to the Governments
proposals to extend the provisions laid down in 2013 Growth and
10
Infrastructure Act, including the idea to include mineral extraction sites of

over 100 hectares as National Infrastructure Projects. The Government
noted these comments at paragraph 16:
A small number of respondents were concerned about the inclusion of
some forms of minerals and, in particular, to the inclusion of coal and
shale gas. The Loose Anti Opencast Network argued that coal should be
treated differently from other minerals, for reasons including planning
blight and the proposed phase out of coal for power generation purposes.
The Town and Country Planning Association were concerned that including
coal, oil and gas within the business and commercial category raised
questions about the Governments commitment to addressing climate
change.
3.18 In its response to the consultation exercise the Government stated
(p7)
After considering the concerns expressed about the inclusion of
proposed coal schemes, the Government has decided that planning
applications for new coal schemes should normally remain with the local
minerals planning authority. The Government therefore does not intend to
include such projects in the prescribed categories of business and
commercial projects.
3.19 From this perspective, the true environmental cost to the local
community surrounding the Bradley site includes:
Years of suffering planning blight at least seven so far,
Plus, if planning permission is granted, an additional five years of

planning blight plus the losses of amenity always associated with
opencast mining (see paragraph 3.14)
Up to fifteen additional years post restoration whilst the site takes

on a more mature aspect.
In all, that makes 26 years of the area being affected by the shadow
of the risk of, and experience of, opencast mining if permission is
granted.
3.20 This 26 year period is a far longer period than either UK Coal or their
Agent has indicated as being the extent of the time that this development
will have an environmental impact on this area. They give a different
estimate, 3 years and six months. LAON asks that in reaching a final
decision, that this longer period of 26 years in which this proposal would
have had an environmental impact is taken account of as a negative
factor when weighing up the balance between the costs and benefits of
this scheme,
11
3.21 Any weighing up of the balance of the environmental impact of this

proposal should, this submission argues, take account of this long period
of time in which the local communities have already been impacted by
this proposal, as well as giving proper consideration, not just to the
environmental impact of working this site, but the long period of time it
takes the hurt and raw landscape to mature again.
OBJECTION 1) ADVERSE ENVIRONMENTAL IMPACT: ADDITIONAL AIR
QUALITY ISSUES
3.22 In addition to the normal issues to do with Air Quality, such as the
local impact that dust particulates have on local people, this objection is
in keeping with the issue of Sustainability and the Planning Practice
Guidance paragraph 005 on Air Quality, that the utilisation of this coal for
power generation purposes, has a general effect on air quality which
cannot be ignored, when determining this planning application. The
Planning Practice Guidance on Air Quality states this, when indicating
when Air Quality issues are relevant to a planning decision, in paragraph
005, that: (my emphasis in bold)
Whether or not air quality is relevant to a planning decision will depend on
the proposed development and its location. Concerns could arise if the
development is likely to generate air quality impact in an area where air
quality is known to be poor. They could also arise where the
development is likely to adversely impact upon the
implementation of air quality strategies and action plans and/or,
in particular, lead to a breach of EU legislation (including that
applicable to wildlife).
3.23 The UK Government is already in breach of European legislation with
regard to levels of Air Pollution in the UK, according to this reference,
Clean Air Europe, Law Suites and Decisions, Client Earths Actions
against the UK (8).The fact that mining this coal and then allowing to be
burnt in unabated power stations and coke ovens and therefore
continuing to contribute to levels of pollution which breach European
Law is, LAON considers, a material consideration when determining this
application.
3.24 In addition, a recent briefing published by the Health and
Environmental Alliance makes clear that the burning of coal in UK Power
Stations contributes to increasing the number of premature deaths
associated with Air Pollution. Their Briefing Paper What does coal cost
health in the United Kingdom? (9) states:
It shows that the fumes from coal-fired power stations are responsible
for the following effects on UK citizens:
12
1,600 premature deaths, 68,000 additional days of medication, 363,266

working days lost and more than a million incidents of lower respiratory
symptoms, which is costing 1.1 to 3.1 billion (1.3 to 3.7 billion) each
year.
Knowingly enabling more coal to dug up and then used to create more Air
Pollution that knowingly leads to more premature deaths can hardly be
called sustainable in keeping with the definitions of sustainability used in
the NPPF. This too should be treated as a material consideration when
determining this application.
3.25 This evidence on the effect that burning the coal from the Bradley
site would have on Air Pollution, life expectancy and costs falling on the
NHS and should be treated as a material consideration when determining
this application.
LAONs ENVIRONMENTAL OBJECTIONS
3.26 To conclude this section, these are the Environmental Impact issues
which form the basis of LAONs Environmental Objections:
That the following be treated as material considerations when assessing
this Application:
That a share of the cost of the mitigation measures indicated in

Paragraph 3.7, to offset the impact of climate change caused by the
burning of this coal in an unabated way would be attributable to this
proposal if the Appeal is upheld. The cost of this should be a
material consideration when assessing this planning appeal. For the
full discussion of this objection see paragraphs 3.3 3.8.
That the mining and then burning of this coal will contribute to the
UK remaining in breach of EU law relating to levels of Air Pollution in
the UK (see paragraphs 3.22 -3.23)
That the burning of this coal from Bradley will contribute to 1,600
premature deaths, 68,000 additional days of medication, 363,266
working days lost and more than a million incidents of lower
respiratory symptoms, which is costing 1.1 to 3.1 billion (1.3 to
3.7 billion) each year. Lives cannot have a value put on them.
However a proportion of the cost of treatment provided by the NHS
to counter the effects of Air Pollution caused by the burning of this
coal would be attributable to this proposal if the Appeal is upheld.
The cost of this should be a material consideration when assessing
this planning appeal. For a full discussion of this objection see 3.22
3.25
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3.27 In addition, these are two other issues that LAON would like to form
part of the Environmental objection to this proposal:
An additional measure of the Environmental Impact on this proposal of:


granted.
These should also be considered when assessing the Environmental

Impact of this proposal against the benefits claimed for this development.
For a full discussion of this assessment of the Environmental Impact see
paragraphs 3.13 3.19.
Lastly, that the claim that utilising this coal reserve imposes a
smaller carbon footprint impact on the environment is not proved
(For a full discussion of this conclusion see paragraphs 3.8 to 3.12)
OBJECTION 2 THE ECONOMIC VIABILITY OF THE PROPOSAL: OUTLINING

THE BASIS OF THIS OBJECTION
4) This objection discusses the following:
Challenging the Need for Coal: Changes in the demand for thermal
coal in the UK from 2014 to 2023 based on DECC statistics.
Challenging the Need for Coal: The Disruptive Technologies of

Renewable Energy.
Challenging the Need for Coal: Changes in the demand and supply
of domestic coking coal.
Consequently, why the need exists for an Insurance Based

Restoration Bond and the issues associated with the viability of its
provision. This leads to the recommendation that this Appeal should
be rejected, if it is not possible for an Insurance Based Restoration
Bond to be provided.
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The overall viability of the proposal
These objections should be considered alongside any other objections that

challenge the need for this coal.
4.1 The National Planning Guidance, in paragraphs 016 and 017 ask that
the applicant does provide evidence about the viability of the proposal
where it is considered being appropriate. This is an application which, if
granted, will take many years to complete. Paragraph 017 makes this
comment where the timescale for the development is longer term, that:
However, where a scheme requires phased delivery over the medium and
longer term, changes in the value of development and changes in costs of
delivery may be considered. Forecasts, based on relevant market data,
should be agreed between the applicant and local planning authority
wherever possible.
In the absence of any other data, LAON is submitting evidence that does
challenge the need for this coal, which LAON argues, should be a material
consideration in determining whether Paragraph 144 should apply in this
case.
4.2 This objection challenges some of the information contained in
paragraphs 3.14.1 to 3.14.8 in the Agents Environmental Impact
Assessment, on their being a continued market for this coal, during the
lifetime of this proposed development.
4.3 Firstly, this set of objections has already indicated three sets of social
costs to set against any economic gains that can be claimed for this
project,
The cost of planning blight falling on the local community since

2007,
The cost of premature deaths caused by burning this coal thereby

causing air pollution and the associated costs falling on the NHS as
a consequence of mining and utilising the coal from Bradley.
The cost falling on Durham County Council and other UK local

authorities of implementing climate mitigation measures caused by
a rise of CO2 in the atmosphere.
OBJECTION 2 ECONOMIC VIABILITY OF THE PROPOSAL: DO WE NEED

AND IS THERE LIKELY TO BE, A MARKET- FOR THIS COAL?
4.4) In paragraph 3.16.6 of the Environmental Impact Assessment
accompanying this submission, this statement appears:
15
Demand for coal within the UK is far greater than can be met from
indigenous production with the consequence that high levels of imports
are required to satisfy the market.
4.5 This is followed by a set of historical statistics. The implications are
that for the foreseeable future its business as usual. There is no
prediction in this submission about the future demand for coal for power
generation purposes or for steel making in the UK. LAON contends that
history is an unreliable witness, when the technology of power generation
is undergoing profound changes of three kinds:
Firstly, reducing and adapting our generating capacity so that it

reduces the emission of the causes of Air Pollution discussed under
Objection 1.
Secondly, the potential development of new power stations fitted

with Carbon Capture and Storage technology.
Thirdly, the impact that the development of different forms of

Renewable Energy technologies are having, especially the
development of wind and solar power coupled with developments in
Energy Storage technology, including Battery Storage systems.
Such is the dynamic rate of both the development and the adoption
of these new technologies that the descriptive term The Destructive
Technology of Renewable Energy is being adopted to describe its
impact.
4.6 In addition, the coking coal market in the UK is also subject to two
changes. Technical developments in steel making are reducing the
demand for coking coal. In addition, during the lifetime of the Bradley
development a new domestic source of coking coal may become
available, from the Lochinvar Development.
4.7 None of these developments is taken account of by the Applicant or
their Agent in the application.
ESTIMATING THE FUTURE DEMAND FOR COAL FOR POWER GENERATION
PURPOSES
4.8 The starting point for this stage in developing LAONs objection on the
need for this coal is the last Energy White Paper, Energy Security Strategy,
and Cm 8466 published in 2012. In the Statement of Common Ground
prepared for this Public Inquiry, both UK Coal and Durham County Council
agreed that
The Government Energy White Paper is a relevant consideration in
relation to coal production. (10) .
16
LAON agrees with this statement, as it is information contained in this

White Paper which is the basis of the analysis LAON is presenting to this
Public Inquiry. What the White Paper contained was a proxy estimate of
the future demand for coal for energy use up to 2030. The graph,
Diversity Indicator II: Electricity Diversity: Generation Mix by fuel type
(2000-2030) appears on p34. (11) The scale is rather small, but it is
evident from this graph that coal use for thermal power generation is
going to decline significantly over the next few years as measured by the
amount of electricity generated by coal in Terawatt Hours (Twh), the scale
used on the left hand side of the graph. This figure of Twh of electricity
production for different kinds of fuel includes a proxy estimate for future
use of all fuels. Including coal The task is to turn this proxy estimate into
an estimate of the future need for coal in millions of tonnes.
4.9 Further inquires about the source of these figures revealed that they
were based on a new annual set of statistics that DECC had just began to
produce, the Updated energy and emissions projections: 2012, Annex E:
total electricity generation by source statistics (12). This gives the same
information, but in a tabular form. It starts by giving past and current
figures
for the amount of electricity produced in Twh for each kind of fuel used to
generate electricity, before estimate how many Twh will be produced by
each type of fuel up to 2030. Further estimates have now been prepared
for 2013 and 2014 (13).
4.10 Turning these proxy coal figures into estimates about the amount of
coal used in million tonnes, means finding a way to convert Twh figures
into coal equivalent figures. This can be done by referring to two other
sets of statics produced by DECC. One is chapter 5 of the annual Digest of
UK Energy Statistics 2013, which provides information on the amount of
electricity produce in Twh by coal annually. The other is Energy Trends,
Section 2 Chapter 2 Solid Fuel and Derived Gases, Electricity, which states
how much coal was used by the main power generators to produce
electricity in 2013 by producing figures of how many Twh are produced by
different types of fuel.
4.11 To arrive at a figure which can turn the estimated Twh figures into
coal equivalent figures means dividing the amount of coal used to produce
electricity by the number of Twh of electricity produced by burning coal for
power generation purposes. In 2013, according to the latest DUKES
figures, 131 Twh of electricity was produced by burning coal (14). In 2013,
power stations used 50m tonnes of coal. (15). If the coal used to generate
one Twh can be deduced from these figures, it can then be applied to all
the other figures in the emissions tables mentioned in paragraph 4.9, to
produce a estimate of the coal to be used in the future up to 2030. In
2013, it took 50m tonnes of coal to produce 131 Twh of electricity.
Therefore, it took c 382,000 tonnes of coal to produce one Twh, (50 / 131)
17
4.12 Table 1 below brings together all this information in a tabular form to
show what the trends estimated as Twh are for the amount of electricity
produced by coal in DECCs latest Energy and Emissions Projections, which
update the graph first published in the latest Energy White Paper,
translated into coal equivalent figures by multiplying the original Twh
figure by 0.38168, representing that, in 2013 it took 381,680 tonnes of
coal to produce each Twh of electricity. All the figures in the Estimations of
Millions of Tonnes Coal Used are based on my calculations, using the
method explained in paragraphs 4.9 to 4.11.
4.13 DECCs Energy and Emissions Projections statistics distinguish coal
use between the expected amount of electricity to be produced in coal
fired unabated power stations, referred to in the table above as old coal,
and the amount of electricity to be produced by coal fired power stations
fitted with Carbon Capture and Storage, referred to in Table 1 as new
coal. This enables estimates to be made about the total future use of coal
for power generation purposes, up to 2030, to be made.
TABLE 1 ESTIMATED USE OF COAL BASED ON STATISTICS IN DUKES
CHAPTERS 2 AND 5 PLUS DECCS UPDATED ENERGY AND EMISSIONS
PROJECTIONS: 2013.
DECC UPDATED ENERGY AND EMISSIONS PROJECTIONS: 2013 ESTIMATE X .38168
YEAR
TWH ELECT.
PRODUCED
FROM OLD
COAL
THW ELECT
PRODUCED
FROM CCS
NEW COAL
TOTAL
TWH
PRODUCED
FROM
COAL
OLD
COAL M
TONNES
NEW
COAL M
TONNES
EST. TOTAL
M TONNES
COAL USED
2013
131.00
131.0
50
50
2014
129.5
129.5
49.43
49.43
2015
106.4
106.4
40.61
40.61
2016
59.7
59.7
22.7
22.7
2017
49.3
49.3
18.81
18.81
2018
46.5
4.7
51.2
17.75
1.79
19.54
2019
37.9
4.7
42.6
14.46
1.79
16.26
2020
28.2
4.7
32.9
10.76
1.79
12.56
2021
23.6
4.7
28.3
9.00
1.79
10.80
18
2022
24.6
4.7
29.3
9.39
1.79
11.33
2023
20.2
4.7
24.9
7.71
1.79
9.50
2024
12.4
4.7
17.1
4.73
1.79
6.53
2025
8.4
11.0
18.4
3.21
4.2
7.41
2026
6.1
17.1
23.2
2.33
6.52
8.85
2027
4.3
23.1
27.4
1.64
10.46
12.1
2028
3.3
24.4
27.4
1.26
10.71
11.97
2029
2.7
28.9
31.6
1.03
12.06
13.09
2030
1.9
33.3
35.2
0.72
13.43
14.15
4.14 This estimate for coal use, based on a reinterpretation of figures

produced by DECC and on figures that first appeared in a graphical form in
the last Energy White Paper, presents a very different picture than that
suggested by the Applicant and their Agent in paragraphs 3.14.1 to 3.14.
18. A number of points are noticeable:
By 2020 the demand for thermal coal is expected to fall below the
current levels of UK Coal production, which the Agent states in
3.14.8 of the Environmental Impact Assessment (EIA), was 13m
tonnes. Put another way, by 2020, there will an excess of domestic
supply over domestic demand for thermal coal.
DECC expect the first Carbon Capture and Storage (CCS) power
station to be operational by 2018. If the schedule for developing this
power station, the White Rose project it is believed, should slip,
then the demand for coal will be less, and every year this project is
delayed increases the likelihood of an excess of domestic supply
over domestic demand for coal.
The analysis present here supports another recent statement on

coal made by the then Energy Minister Michael Fallon MP, on the
same day that he gave his written answer copied in paragraph
3.14.12 of the EIA submission document. In replying to a Lords
Amendment to the Energy Bill, he said in the House of Commons
that:
........
the economic outlook for coal generation is poor.
19
Our analysis is consistent with that outlook and shows that

unabated coal generation will make up just 7% of total generation
by 2020 and 3% by 2025, and probably 0% by 2030. There is no
evidence at the moment of a large number of operators planning to
upgrade their coal plants, but we should not rule out the possibility
that one or two might do so. (Energy Bill Debate, Hansard, 4/12/13,
column 943). (16)
use
What LAON has done, in producing this unofficial estimate of coal

up to 2030, is to flesh out the Ministers statement.
4.15 Two other factors affecting the domestic demand for coal also
suggest that on current trends, by 2020 current domestic supply will
exceed current domestic demand. Firstly for some power stations, to meet
the new lower EU pollution standards which are due to come into force in
2016, they will need to import coal with a lower sulphur content. The
second is that at least one large power station can burn cheaper coal,
cheaper because it has higher sulphur content, as it has already
introduced a technological change.
4.16 The first factor in their being a requirement to import coal was
addressed in a presentation given by Nigel Yaxley, Managing Director of
the Association of Coal Importers in 2009. In this, he pointed out that
imported coal, with its lower sulphur content, would be more important
after 2016 as
SO2 emissions are directly proportional to sulphur content in coal and
tighter limits after 2016 may mean sulphur also becomes important for
FGD stations(17).
4.17 The second factor concerns Drax Power Station, the UKs biggest
power station, which has already partly converted to biomass. It can, as a
consequence, import coal which is cheaper than domestically produced
coal because it has a higher sulphur content, burn it and still remain
within the new lower limits laid down by the EU, as explained in this article
from the Wall Street Journal Dirty US Coal Finds a Home in Europe. (18).
4.18 At present the effect of these trends for importing coal cannot be
quantified, but the likely effect will be felt by UK Coal Producers as
domestic production will be squeezed from both ends by price and quality,
Inevitably these two factors will reduce the demand for domestically
produced coal it is argued, below 13m tonnes sometime before 2020.
4.19 This estimated decline in coal demand is significant for this
application and should, it is argued here, be treated as a material
consideration. This is because the effects of the estimated dramatic
decline in the demand for coal will be occurring whilst this site is being
worked, should the appeal be upheld.
4.20 To put this into context, an assessment needs to be given of the real
timetable that is likely to occur should the appeal be upheld and
20
calibrated against the expected timetable for the development of this

project outlined in paragraph 3.14. Table 2 below outlines what is likely to
happen, based on the time it may take for the Inspector to announce a
decision and the time it has takes to actually allow soil stripping to
commence.
TABLE 2 SUGGESTED TIME TABLE FOR DEVELOPING THE BRADLEY SITE
SHOULD THE APPEAL BE UPHELD
CALENDER YEAR
2014
DEVELOPMENT
YEAR
YEAR 1
2015
YEAR 2
2016
2017
YEAR 3
YEAR 4 UK COALS
YEAR 1
2018
YEAR
YEAR
YEAR
YEAR
YEAR
YEAR
2019
2020
5 UK COALS
2
6 UK COALS
3
7 UK Coals
4
SITE ACTIVITY
PUBLIC INQUIRY. THE PLANNING INSPECTOR
RECOMMENDS APPROVAL. HOWEVER, THE TIME
TAKEN TO ANNOUNCE THIS DECISION CANNOT
BE PRE DETERMINED. THIS TIME TABLE
SUGGESTS THAT A DECISION TO UPHOLD THE
APPEAL IS ANNOUNCED IN JANUARY 2015
APPEAL UPHELD. BEFORE ANY ACTION CAN BE
TAKEN TO DEVELOP THE SITE ACTION HAS TO
BE TAKEN TO MEET PRE OPERATIONAL
PLANNING CONDITIONS AND SECTION 106
AGREEMENTS
SITE PREPARATION ACTIVITY CONTINUES
IF ALL PRE DEVELOPMENT CONDITIONS ARE
MET SOIL STRIPPING COMMENCES LATE
SPRING. COALING BEGINS 3 MONTHS LATER
(JULY)
COALING TO TAKE 32 MONTHS FROM JULY
2017 (SEE 3.3.38 OF THE E.I.A)
COALING
COALING CEASES c MARCH 2020 AND
RESTORATION BEGINS.
4.21 To prove the point about the lack of the need to exploit this coal
reserve, Table 3 Calibrating the Bradley Site Development with the
Estimated Demand for Coal below, brings together the suggested time
table for the development of the Bradley site should the Appeal be
upheld, with the best estimate on what will be the level of demand for
coal for power generation purposes during the lifetime of the proposed
development.
4.22 It can be seen, if these two sets of predictions are proved to be
correct, that by 2020, when coaling ceases on this site, that the level of
the demand for coal will have fallen below the UKs current level of
production. Whether this fact creates a cash flow problem when UK Coal is
about to begin site
TABLE 3 CALIBRATING THE BRADLEY SITE DEVELOPMENT WITH THE
ESTIMATED DEMAND FOR COAL
YEAR
ACTION ON DEVELOPING THE SITE (FROM

TABLE 2)
EST. LEVEL OF COAL DEMAND

(mt) (FROM TABLE ONE)
21
2014
2015
2016
2017
2018
2019
2020
PUBLIC INQUIRY
INSPECTORS DECISION UPHOLDS THE
APPEAL. SITE PREPARATION FOR PROVING
THE SITE BEGINS AS DO DISCUSSIONS
ABOUT FINALISING CONDITIONS AND
SECTION 106 AGREEMENTS
IF THERE IS ANY DELAY AND THE
FAVOURABLE WEATHER / ECOLOGICAL
CONDITIONS ARE MISSED, IT CAN DELAY
SOIL STRIPPING.
COALING BEGINS c JULY
COALING
COALING
COALING CEASES 32 MONTHS AFTER JULY
2017 IN MARCH 2020
49.43
40.61
22.7
18.81
19.54
16.26
12.56
restoration is a matter for some consideration. Only UK Coal know if, when
it comes to opencast mining, they operate a system of cross subsidising
sites. Site A, in its productive stage pays for the preparation costs of site
B. Later Site B, once productive, pays for the restoration costs of Site A as
well as
the preparation costs of site C and so on. The success of the business plan
depends on gaining new site approvals. If this is the kind of business
model operated by UK Coal, what happens in 2020, when the likelihood of
gaining new opencast approvals will have diminished? The risk is that the
company we are calling UK Coal (or Juniper (No 3) Limited) a brand new
company arising from the wreckage of the old UK Coal Company after it
went into administration last year, with no public record of its financial
trading health or assets as described in paragraphs 2.3.5 to 2.3.8, may
find itself unable to fulfil its planning obligations to restore this site, once
the coal reserves are exhausted.
4.23 At present, unless there is a real development that makes CCS a
commercial prospect it seems to be the Governments policy not to rely on
coal to meet our energy needs in the short to medium term, but to rely on
new Gas powered generation units. As indicated in Table 1, the advent of
a commercialised (not commercial) CCS power station, due to start
operating according to the DECC figures in 2018, is only going to have a
marginal effect on the demand for coal and will not, of itself, arrest the
overall decline in the demand for coal up to 2020.
OBJECTION 2 ECONOMIC VIABILITY OF THE PROPOSAL: THE POTENTIAL
IMPACT OF THE DISRUPTIVE TECHNOLOGY OF RENEWABLE ENERGY.
4.24 The other, more unpredictable impact, is what the effect will be of
another, quite separate trend, probably not accounted for in the DECC
figures used above, in meeting the UKs future energy needs caused by
what has been called the Disruptive Technology of Renewable Energy.
This was a term coined by Mckinsey to encapsulate what they believed to
be the potential dramatic impact that twelve new, developing
technologies, including two technologies that contribute towards
22
Renewable Energy, would have economically and socially on societies.

Mckinsey stated in their press release announcing the publication of their
report Disruptive Technologies Advances that will transform life
businesses and the global economy last year that: (19)
Not every emerging technology will alter the business or social landscape
but some truly do have the potential to disrupt the status quo, alter the
way people live and work, and rearrange value pools. It is therefore
critical that business and policy leaders understand which technologies
will matter to them and prepare accordingly.
Disruptive technologies: Advances that will transform life, business, and
the global economy, a report from the McKinsey Global Institute, cuts
through the noise and identifies 12 technologies that could drive truly
massive economic transformations and disruptions in the coming years.
The report also looks at exactly how these technologies could change our
world, as well as their benefits and challenges, and offers guidelines to
help leaders from businesses and other institutions respond.
4.25 Twelve developing technologies are identified in the report as being
disruptive technologies Two of them, Energy Storage and Renewable
Energy are developments already under way. These two new technologies,
McKinsey suggest, will have a dramatic impact on existing methods of
both producing electricity by using fossil fuels and then having to
distributing it through national grid type systems of delivery. What the rise
and adoption of these two new technologies questions, is whether large
fossil fuelled coal fired power stations will be needed in the near future.
(20)
4.26 In assessing the need for the coal at the Bradley site, LAON argues
that any decision should include an assessment of the impact that the two
complementary disruptive technologies of developments in energy
storage and renewable energy will have on the need for coal over the life
time of the proposed Bradley Surface Mine development. This is in
addition to the decline in coal demand as indicated in the DECC figures
used in paragraphs 4.8 to 4.13. If an assessment of the disruptive impact
of these two technologies between now and 2020 leads to the conclusion
that it will lead to an even faster decline in coal use than that already
indicated in the DECC figures used in Table 1, then LAON believes that this
should be a material consideration when determining this planning
application.
4.27 This warning from Mckinsey has already been heeded. So far four
Investment Banks have, since May this year, advised those investing with
them to review or even disinvest from fossil fuel generating companies
operating in the USA, Germany, Spain and Italy. These banks are:
Barclays (see Barclays Downgrades Electric Utility Bonds, Sees

Viable
Solar Competition), (21)
23
Morgan Stanley (see Solar Power & Energy Storage Policy Factors vs
Improving Economics, (22)
UBS (see Big power out, solar in: UBS urges investors to join
renewables revolution) (23)
Citi Group (see Energy 2020: The Revolution Will Not Be Televised
as
Disruptors Multiply (24)
4.28 Some quotes from what UBS has said in advising its clients are
quoted in the Guardian article and indicates why the impact of these two
technologies will be so disruptive, as we are all on the cusp of witnessing
relatively dramatic changes:
Power is no longer something that is exclusively produced by huge,
centralised units owned by large utilities. By 2025, everybody will be able
to produce and store power. And it will be green and cost competitive, i.e.,
not more expensive or even cheaper than buying power from utilities,
say the authors, who urge their financial clients to join the revolution.
Solar is at the edge of being a competitive power generation technology.
The biggest drawback has been its intermittency. This is where batteries
and electric vehicles (EVs) come into play. Battery costs have declined
rapidly, and we expect a further decline of more than 50% by 2020. By
then, a mass [produced] electric vehicle will have almost the same price
as a combustion engine car. But it will save up to 2,000 (1,600) a year
on fuel cost, hence, it will begin to pay off almost immediately without
any meaningful upfront investment. This is why we expect a rapidly
growing penetration with EVs, in particular in countries with high fossil
fuel prices.
The expected 50% reduction in the cost of batteries by 2020 will not just
spur electric car sales, but could also lead to exponential growth in
demand for stationary batteries to store excess power in buildings, says
UBS. Battery storage should become financially attractive for family
homes when combined with a solar system and an electric vehicle. As a
consequence, we expect transformational changes in the utility and auto
sectors, it says. By 2020 investing in a home solar system with a 20year life span, plus some small-scale home battery technology and an
electric car, will pay for itself in six to eight years for the average
consumer in Germany, Italy, Spain, and much of the rest of Europe.
4.29 The quote ends by saying much of the rest of Europe. It would seem
that this rapid technological change will begin to occur during the lifetime
of the proposed Bradley development. If it begins to do so, if UK residents
begin to hook up their solar PVs to domestic battery storage systems one
can imagine that the decline in fossil fuel power generation will quicken,
24
most likely with the most polluting, coal fired power generation stations,
being closed first.
4.30 Another influential person has recently addressed this issue and
supports the idea that we are all on the cusp of dramatic changes in the
way energy, in the form of electricity, is both produced and distributed. He
was, until recently, head of one of the major energy utility companies
operating in the UK, which was recently operating these UK coal fired
power:
Aberthaw (still open), Didcot A (closed in 2013) and Tilbury (closed as a
coal fired power station in 2011)
The company is, in addition, still operating both gas fired and nuclear
power stations in the UK. Until 2013 Volker Beckers was head of RWE
npower. He has now added his voice to the series of warnings about the
limited future of a national grid system fed by fossil fuels including coal.
These extracts give a flavour of his thinking after he explains that he
came to the realisation
that the centralised energy model has "reached its natural end", with
market capitalisation for the largest energy companies plummeting
almost as fast as consumers' trust in them.
Energy firms "need a different approach", he says, if they want to win
back consumers in a new market where households can produce their
own energy via solar panels and wind turbines and may soon be able to
store it in advanced batteries or electric cars. (25)
4.31 There is now some evidence that the Government is waking up to the
impact that these new technologies will have in the UK. In a recent debate
on Sustainable Energy, Matthew Hancock, the new Minister for Energy,
Business and Enterprise said:
....I think solar is one of the big opportunities. As the price falls and it
becomes competitivepotentially grid competitivein the short to
medium term, solar is a big opportunity, even in cloudy old England. (26)
Here is official recognition that there is an expectation that in the short
term that there will be price parity between solar produced electricity and
the price of electricity produced by fossil fuels. Once that tipping point is
reached, the disruptive aspect of these two new technologies will begin to
be felt, if what the Minister has said is true, before 2020.
OBJECTION 2 ECONOMIC VIABILITY OF THE PROPOSAL: TECHNOLOGICAL
AND SUPPLY CHANGES TO THE DOMESTIC COKING COAL MARKET,WHICH
COULD LESSEN THE DEMAND FOR COKING COAL.
25
4.32 In one respect, the situation with regard to the future demand for
coking coal is similar to the technological changes likely to affect the
demand for thermal coal In another respect it is very different.
4.33 It is similar because technological developments are lowering the
level of demand for coking coal and enabling lower grades of cheaper
coal, i.e. non coking coal, to be utilised in steel making. At the Redcar
Steel works Sahaviriya Steel Industries (SSI) have installed a Pulverised
Coal Injection plant, which according to a press release, issued by the
supplier of the equipment to the plant, Siemens, will:
..... will reduce the coke consumption of the blast furnace, which, in turn,
will reduce both expenditure on raw materials and energy consumption.
This is because
The new PCI plant will enable SSI to replace some of the coking coal it
uses by cheaper, non-coking coal (27)
The other large UK Steel maker, TATA Steel, is also being reported as
developing new steel making technologies that will enable lower quality
coals to be used for steel making:
....The fine raw materials are used directly without the need for
agglomeration that is collection into a cluster or mass or coking. It can
even use low calorific grade coal and iron ore which otherwise was not
possible till now.... (28)
4.34 However, the situation with regard to the domestic market
for coking coal is made more complicated by the rapid
development of the Lochinvar Project on the Canonbie Coalfield in
S.E. Scotland. Here New Age Resource are planning to develop a
new drift mine to exploit at least 110m tonnes of coking coal,
which they intend to supply steel works in Teesside, Scunthorpe
and South Wales. According to a presentation given to investors
earlier this year, they intend to commence production in 2017.
(29) What the impact of this development will be on the domestic
demand for the coking coal to be produced from Bradley is far
from clear. However, all these developments the technical
developments that reduce the demand for coking coal plus the
exploitation of new coking coal resources in the UK weakens any
case being put forwards here for the need to develop the coking
coal potential of the Bradley site.
26
4.35 It is LAONs contention that we have proved that the

arguments put forwards by the Applicant and their Agent lack a
comprehensive assessment of the future demand for coal during
the proposed life time of this development. LAON has in contrast
produced a comprehensive assessment about the estimated
future demand for indigenous thermal coal, which supports the
statement made by the then Minister for Energy, that
..unabated coal generation will make up just 7% of total generation by
2020... (see paragraph 4.15)
In addition, when an account is taken of the need to continue to
import coal with a lower sulphur content plus the very real but
unpredictable additional impact of new disruptive renewable
technologies, suggest that by 2020 at the latest, the UK will be
producing more coal than it can consume for power generation
purposes. The demand for Bradleys coking coal is also likely to
decline because of technological change. In addition, it is likely
that large amounts of coking coal from a new domestic source,
the Lochinvar Project, are likely to threaten the domestic market
for Bradleys coking coal before 2020. The conjunction of these
set of trends make it likely, in LAONs view, that this
development, taken as a whole, is unlikely to reach a successful
conclusion and is therefore unviable. This is why this evidence
should be a material consideration when weighing the various
factors when determining this proposal.
OBJECTION 2 ECONOMIC VIABILITY OF THE PROPOSAL: SITE RESTORATION
AND RESTORATION BOND ISSUES
4.36 The information contained in paragraphs 4.1 to 4.34 challenging the
Need for Coal arguments put forwards by the applicant, and as explained
in 4.35, are driven by a concern about what will happen to this site
towards the end of the period it is proposed to be worked, especially
when the coal reserve is near to being exhausted. The analysis presented
suggests that by c 2019 -2020, coal operators in the UK will be operating
in a coal buyers market, with a rapid decline in the demand for coal
especially for the thermal coal market, underway.
4.37 We have indicated that by that time, if UK Coal / Jupiter 3 operate the
business model indicated earlier (paragraph 4.22), but fail to gain new
permissions for opencast sites, that then, because of a cash flow problem,
the Company could find itself unable to restore this site. If that should
happen, then the issue of a Restoration Bond becomes critical.
27
4.38 At this point, the discussion of the situation facing Scotland and
Wales in paragraphs 1.2 1.4 plus the Applicants financial position,
mentioned in paragraphs 2.3.5 to 2.3.7 and at 4.22 again becomes
relevant.
4.39 The Agent in their EIA submission at Chapter 3, discussing the Market
for Coal, make the following statement:
3.14.7 In response to strong coal demand, indigenous coal production has
been falling due to a combination of deep mine collieries reaching the end
of their economic lives combined with unprecedented occurrences such
as the recent fire at Daw Mill Colliery which forced early closure of the
mine. Surface mines have found it difficult to obtain the planning
permissions necessary to replace this lost tonnage.
3.14.8 In 2013 UK production fell to its lowest recorded level of 13.0
million tonnes. This has led to a strong growth in coal imports to meet
demand.
4.40 Two issues arise from this statement. Firstly the decline in coal
production issue and the associated Restoration Bond issue and secondly,
UK Coals claim that since the closure of Daw Mill it has been difficult for
the Company to gain planning permission for new surface mines.
4.41 It is very generous for UK Coal, in its present guise, to take all the
blame for the problems faced by its predecessor as being solely
responsible for the recent decline in coal production. However, they
cannot take all the credit for the fall in UK Coal production, because it fails
to mention another reason for the fall in coal production in the UK, the
collapse of the two biggest opencast coal operators in Scotland, Scottish
Coal and ATH Resources. It is their demise which has left Scotland with its
Mine Restoration Crisis as explained in paragraph 1.3. This problem exists
because of weaknesses in Restoration Bond schemes.
4.42 In a consultation document Consultation on Opencast Coal
Restoration: Effective Regulation, issued by the Scottish Government in a
response to this crisis, the following statement appears:
....10.3 Following the ATH and SRG failures, it is clear that companies
will find it more difficult to obtain insurance bonds (even assuming they
are available at all)... (30)
4.43 Judging from more recent experience in England as well, such as at
the Minorca site discussed below, this market failure of no insurance
bond market existing to cover the risk of the coal operator going
bankrupt, because the risk is too great should, itself, act as a red light to
stop such risky forms of development, until sufficient confidence has been
restored in the UK domestic coal industry and proper insurance based
bonds become available again.
28
4.44 Instead, alternative forms of provision have been devised, such as

pay-as-you-go or escrow accounts. However, recent English experience
suggests that, writing into any planning Section 106 agreement for a
Restoration Bond that utilises this pay-asyou-go system of a Restoration
Bond payment, is not a sufficient safeguard to ensure that a site does,
indeed, get restored, should the operator get into financial difficulties.
With the escrow account method, as the coal from the site is sold,
payments are made into a separate fund held by a third party, usually the
local planning authority, to guarantee site restoration should the operator
go bankrupt. In practice, this has not proved to be as watertight as it first
seems.
4.45 In Leicestershire, earlier this year, UK Coal / Juniper 3 announced that
it was seeking Government help in arraigning a 20m loan to enable it to
undertake a phased run down of Thoresby and Kellingley Collieries. Less
well known was the fact that at the same time, UK Coal / Juniper 3 had
asked Leicestershire County Council (LCC) for a Period of Grace, a
payments holiday, which would mean not paying a total of 972,250 due
under various Section 106 agreements associated with the Minorca
Surface Mine development, including a payment of 700,000 as the next
instalment due on the pay-as-you-go Restoration Bond, due on April 17th.
4.46 Granting this Period of Grace would enable the Company to arrange
the loans and continue its operations as normal. No time limit was put on
this Period of Grace. Once it was known that the potential loan
agreement had fallen through on June 11th, a local action group alerted
LCC to this fact, leading to LCC releasing a press statement on 27/6/14,
announcing that the Period of Grace was now over (31).
4.47 It would seem that anything other than a proper insurance bond as
the form of provision for a Restoration Bond can create a conflict of
interest for any planning authority that makes a Section 106 condition for
the provision of a pay-as-you-go Restoration Bond. This is because, by not
granting a Period of Grace they can bring about the bankruptcy of the
company concerned and be seen as acting to increase levels of local
unemployment. By granting such a Period of Grace and allowing normal
operations to continue, they may actually increase the risk that
insufficient monies will be available to restore the site, should the operator
become bankrupt. Only an insurance bond provision, in this case, removes
the planning authority from this invidious position. Unless such a Bond can
be provided, this application should be refused.
OBJECTION 2 ECONOMIC VIABILITY OF THE PROPOSAL: SITE RESTORATION
AND RESTORATION BOND ISSUES : UK COALS CLAIM, THAT IT FINDS IT
DIFFICULT TO GAIN PLANNING PERMISSION FOR NEW SURFACE MINES.
4.48 Does this claim stand up to any scrutiny? Since the closure of Daw
Mill was announced in March 2013, UK Coal has, in addition to Bradley,
29
been pursuing a number of new surface Mine proposals, five of which had
reached the stage of being ready for determination:
Shortwood Farm in Nottinghamshire was approved in December

2013. An attempt by the local MP to get the decision called in was
rejected by Eric Pickles, Secretary of State for Communities and
Local Government, in July 2014
Minorca Surface Mine, Measham Fields Farm Extension,

Leicestershire County Council (LCC), approved in February 2014. No
licence has been issued by LCC to allow the site to be worked as UK
Coal have yet to sign a financial agreement under a new Section
106 condition to pay 60,000 into a community fund.
Deansfield, Wakefield. Wakefield Council rejected a planning

application for this site in March 2014
Hoodsclose in Northumberland. This site is just three miles away.

Without any public explanation, UK Coal withdrew their planning
application, on which they had been working for five years, seven
days prior to Northumberland County Councils determination
meeting, in June this year.
Marley Hill Colliery Reclamation Scheme. This is a cross border site

between Gateshead and Durham County Council. Gateshead
approved the plan in July 2014. However, Durham County Council
subsequently rejected the proposal in late July.
The score is then two approvals, two rejection and one dont know, the
latter because of the decision taken by the Company to withdraw the
application almost at the last minute without any public comment. Hence
the claim made in the EIA about how difficult it is to get planning
permission does not seem to be fully supported by the evidence.
4.49 To conclude this section, these are LAONS Economic Viability
Objections:
the Bradley Surface Mine Application.
The social costs identified in the objections at 3.26 be given

negative weight in the overall assessment of the viability of this
development
The Applicant will not have sufficient resources to restore the site.
(see paragraphs 1.2;1.5 1.6; 2.3.1 2.3.5; 2.3.6 2.3.7 and 4.36 -4
30
.47) We ask that considerable weight be attached to this material

consideration.
That it is not clear that it is the intention of the liquidators to work

this site should the appeal be upheld. If they plan to sell the site
within 6 years of the start of this Public Inquiry, then the statements
in paragraphs 3.1.1 to 3.1.10 of Chapter 3 Proposed Development
of the Environmental Impact Assessment, made by the Agent on
behalf of the Applicant, should be discounted (See paragraphs 2.3.5
2.3.6). We ask that considerable weight be given to this material
consideration
That the applicant and their agent have made no case based on any
forward projections about the need to mine this coal. LAONs
assessment, based on DECC figures, indicates that before the coal
reserves on this site have been exhausted, the UK will be producing
more thermal and coking coal than it can use for power generation
purposes or steel making. See paragraphs 4.4 to 4.31 for thermal
coal, and 4.32to 4.37 for coking coal). We ask that considerable
weight be given to this material consideration.
In addition, any assessment about the future need for coal should
include an additional assessment on the impact that the disruptive
technologies of renewable power generation and energy storage
will have up to 2020. The Applicant and their Agent have provided
no information on the impact of these technologies. LAON has
indicated that the adoption of these technologies is likely to hasten
the decline in the demand for coal before 2020, even more quickly
that the published DECC statistics suggest. The likelihood of this
happening should be considered a material consideration. (See
paragraphs 4.24 - 4.31)
There is evidence that no market exists for the provision of an

insurance based restoration bond. This lack of a market is itself, an
indication of how big a risk opencast mining is, given the current
price of coal and the future decline in the market for coal in the UK.
The lack of such a market should itself be considered a significant
material consideration when assessing this planning application.
This companys own behaviour, shows why having an insurance
31
based bond is the only guarantee that, should the worst happen,
and this company goes bankrupt again, then a fully paid up bond
exists to restore the site. Such is the importance of this material
consideration that LAON suggests that if it is impossible to put such
an insurance based bond in place, then this application should be
rejected. (See paragraphs 1.3 and 4.41 4.47)
That the Applicants and Agents claims that ...Surface mines have
found it difficult to obtain the planning permissions necessary to
replace this lost tonnage.... is at best not proven in the discussion
at paragraph 4.48 and should be discounted .
CONCLUSION: LAONS OBJECTIONS TO THE BRADLEY SURFACE MINE

OBJECTIONS
5. These are LAONs specific objections:
These are the Environmental Impact issues which form the basis of
LAONs Environmental Objections:
5.1 That the following be treated as material considerations when
assessing this Application:
That a share of the cost of the mitigation measures indicated in

Paragraph 3.7, to offset the impact of climate change caused by the
burning of this coal in an unabated way would be attributable to this
proposal if the Appeal is upheld. The cost of this should be a
material consideration when assessing this planning appeal. For the
full discussion of this objection see paragraphs 3.3 3.8.
That the mining and then burning of this coal will contribute to the
UK remaining in breach of EU law relating to levels of Air Pollution in
the UK (see paragraphs 3.22 -3.23)
That the burning of this coal from Bradley will contribute to 1,600
premature deaths, 68,000 additional days of medication, 363,266
working days lost and more than a million incidents of lower
respiratory symptoms, which is costing 1.1 to 3.1 billion (1.3 to
3.7 billion) each year. Lives cannot have a value put on them.
However a proportion of the cost of treatment provided by the NHS
to counter the effects of Air Pollution caused by the burning of this
coal would be attributable to this proposal if the Appeal is upheld.
The cost of this should be a material consideration when assessing
this planning appeal. For a full discussion of this objection see 3.22
3.25
32
5.2 In addition, these are two other issues that LAON would like to form
part of the Environmental objection to this proposal:
An additional measure of the Environmental Impact on this proposal of:


granted.
These should also be considered when assessing the Environmental

Impact of this proposal against the benefits claimed for this development.
For a full discussion of this assessment of the Environmental Impact see
paragraphs 3.13 3.19.
Lastly, that the claim that utilising this coal reserve imposes a
smaller carbon footprint impact on the environment is not proved
(For a full discussion of this conclusion see paragraphs 3.8 to 3.12)
5.3 These are the Viability and Need for Coal issues which form the basis
of LAONs Viability and Need for Coal objections:
the Bradley Surface Mine Application.
The social costs identified in the objections at 3.26 be given

negative weight in the overall assessment of the viability of this
development
The Applicant will not have sufficient resources to restore the site.
(see paragraphs 1.2;1.5 1.6; 2.3.1 2.3.5; 2.3.6 2.3.7 and 4.36 -4
.47) We ask that considerable weight be attached to this material
consideration.
That it is not clear that it is the intention of the liquidators to work

this site should the appeal be upheld. If they plan to sell the site
within 6 years of the start of this Public Inquiry, then the statements
in paragraphs 3.1.1 to 3.1.10 of Chapter 3 Proposed Development
33
of the Environmental Impact Assessment, made by the Agent on

behalf of the Applicant, should be discounted (See paragraphs 2.3.5
2.3.6). We ask that considerable weight be given to this material
consideration
That the applicant and their agent have made no case based on any
forward projections about the need to mine this coal. LAONs
assessment, based on DECC figures, indicates that before the coal
reserves on this site have been exhausted, the UK will be producing
more thermal and coking coal than it can use for power generation
purposes or steel making See paragraphs 4.4 to 4.31 for thermal
coal, and 4.32to 4.37 for coking coal. We ask that considerable
weight be given to this material consideration.
In addition, any assessment about the future need for coal should
include an additional assessment on the impact that the disruptive
technologies of renewable power generation and energy storage
will have up to 2020. The Applicant and their Agent have provided
no information on the impact of these technologies. LAON has
indicated that the adoption of these technologies is likely to hasten
the decline in the demand for coal before 2020, even more quickly
that the published DECC statistics suggest. The likelihood of this
happening should be considered a material consideration. (See
paragraphs 4.24 4.31)
There is evidence that no market exists for the provision of an

insurance based restoration bond. This lack of a market is itself, an
indication of how big a risk opencast mining is, given the current
price of coal and the future decline in the market for coal in the UK.
The lack of such a market should itself be considered a significant
material consideration when assessing this planning application.
This companies own behaviour, shows why having an insurance
based bond is the only guarantee that, should the worst happen,
and this Company goes bankrupt again, then a fully paid up bond
exists to restore the site. Such is the importance of this material
consideration that LAON suggests that if it is impossible to put such
an insurance based bond in place, then this application should be
rejected. (See paragraphs 1.3 and 4.41 4.47)
34
That the Applicants and Agents claims that ...Surface mines have
found it difficult to obtain the planning permissions necessary to
replace this lost tonnage.... is at best not proven in the discussion
at paragraph 4.48 and should be discounted.
Stephen Leary, for The Loose Anti Opencast Network, with assistance
which includes the following persons:
Anthony Rae, Jeremy Ackertill and Dr Orest Mulker
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1)
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2)
Research into the failure to restore opencast coal sites in south

Wales, pgs 39-40, Welsh Government, April 2014 @
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UK Coal - Investment update 10/4/14 and UK Coal Statement

11/6/14, UK Coal, @ http://www.ukcoal.com/latest-news (checked on
29/8/14
4)
National Planning Policy Guidance : Minerals, paragraph 048, DECC,

6/3/14 @
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2012 Guidelines to DEFRA / DECC's GHG Conversion Factors for

Company Reporting, DEFRA / DECC, Annex 1 Converting Fuel Use to
Carbon Dioxide Equivalent Omissions @
https://www.gov.uk/government/uploads/system/uploads/attachment_
data/file/69554/pb13773-ghg-conversion-factors-2012.pdf
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Defra Funding for Flood and Coastal Erosion Risk Management in

England Department for Environment, Food and Rural Affairs, April
2014 @
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t_data/file/300247/pb13900-flood-funding.pdf
35
7) Major infrastructure planning: extending the regime to business

and commercial projects. Summary of responses and government
response, pgs Department of Communities and Local Government,
June 2013 @
https://www.gov.uk/government/consultations/nationally-significantinfrastructure-planning-extending-the-regime-to-business-andcommercial-projects
8)
Clean Air Europe, Law Suites and Decisions, Client Earths Actions
against the UK, 1/5/2013, Legal Clean Air Europe Campaign @
http://legal.cleanair-europe.org/legal/united-kingdom/lawsuits-anddecisions/
9)
What does coal cost health in the United Kingdom?, Health and
Environmental Alliance, December 2013 @ http://www.envhealth.org/IMG/pdf/heal_briefing_what_does_coal_cost_health_in_the_
uk_29112013final1_1.pdf
10) Town and Country Planning Act 1993 Appeal By Juniper (no 3)
Limited, Statement of Common Ground, Planning Inspection
Reference APP/X1355/A/11/2150277/NWF, paragraph 12.42 (c),
Nabarro 2014
11) Energy Security Strategy Indicator II: Electricity Diversity:
Generation Mix by fuel type (2000-2030) p34, Cm 8466, DECC,
November 2012 @
https://www.gov.uk/government/publications/energy-security-strategy
12) Updated energy and emissions projections: 2012, Annex E: total
electricity generation by source @
https://www.gov.uk/government/publications/2012-energy-andemissions-projections
13) Updated Energy Emissions Projections for 2012 and Updated

Energy emissions projections for 2013 , DECC @
https://www.gov.uk/government/collections/energy-and-emissionsprojections
14) Electricity Chapter 5 Digest of UK Energy Statistics (DUKES) (2013)
DECC, Key Points @
https://www.gov.uk/government/statistics/electricity-chapter-5digest-of-united-kingdom-energy-statistics-dukes
36
15) Energy Trends Section 2, Solid Fuel and Derived Gases, Chapter 2,
Paragraph 2.20 @ https://www.gov.uk/government/statistics/solidfuels-and-derived-gases-section-2-energy-trends
16) Energy
Bill
Debate,
Hansard
4/12/13,
column
943
@
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04/debtext/131204-0002.htm#13120494000005
17) Russian coal in the UK Market, Association of Coal Importers, Coal
Imp
Annual Luncheon Meeting 2009 @
http://nigelyaxley.com/resources/Coaltrans+Russia+30-03-09.pdf
18) Dirty US Coal Finds a Home in Europe Wall Street Journal, 5/5/14 @
http://online.wsj.com/news/articles/SB100014240527023034171045795
43814192542586
19) Disruptive technologies: Advances that will transform life, business,
and the global economy, Mckinsey & Company, May 2013, @
http://www.mckinsey.com/insights/business_technology/disruptive
_technologies
20) Disruptive technologies: Advances that will transform life, business,
and the global economy, Mckinsey Global Institute, Chapters 8, Energy
Storage and Chapter 12, Renewable Energy, May 2013, downloadable
from
http://www.mckinsey.com/insights/business_technology/disruptive_technolo
gies
21) Barclays Downgrades Electric Utility Bonds, Sees Viable Solar
Competition , Barons, 2/5/14 @
http://blogs.barrons.com/incomeinvesting/2014/05/23/barclaysdowngrades-electric-utility-bonds-sees-viable-solar-competition/
22)
Solar Power & Energy Storage Policy Factors vs Improving

Economics, Morgan Stanley Blue Paper, 28/7/14 @
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%20Jul y%2029%202014.pdf
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revolution, Guardian, 27/8/14 @
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24) Energy 2020: The Revolution Will Not Be Televised as Disruptors
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GAzn7%2feoGJhCRKXBw2LnpF%2bmPt5wCNmiHIw%3d
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25) Fossil fuel energy system has 'reached its natural end', says exnpower boss Business Green, 28/8/14) @
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26) Hansard, Sustainable Energy Debate, 4/9/14, Column 415 @
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04/debtext/140904-0001.htm
27)Order from United Kingdom: Siemens to construct pulverized coal
injection plant for the Sahaviriya Steel Industries blast furnace in
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38
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Final Bradley Surface Mine Obj

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BRADLEY SURFACE MINE, 2ND PUBLIC INQUIRY

19th SEPTEMBER 2014

PLANNING INSPECTORATE REFERENCE: APP/X1355/A/11/2150277/NWF

Basis of the Bradley Surface Mine Objections

Adverse Environmental Impacts: Introduction

The Economic Viability of the Proposal:

Objection 1) Adverse Environmental Impact:

Objection 1) Adverse Environmental Impact:

Objection 1) Adverse Environmental Impact:

LAONs Environmental Objections

Objection 2 Economic Viability of the Proposal: 4 4.3

Objection 2 Economic Viability of the Proposal: 4.48

References these begin on Page 44.

upheld, then the conclusion must be that this is not a sustainable

should be agreed between the applicant and local planning authority

a competent company who can bring the development to a satisfactory

very long-term new projects where progressive reclamation is not

where a novel approach or technique is to be used, but the minerals

where there is reliable evidence of the likelihood of either financial

2.3.5 to 2.3.7 of this submission already provide some evidence to be

3.5 In addition, the Planning Practice Guidance (paragraph 01) states:

Up to two more years before soil stripping can commence, including

Coaling to cease 32 months after soil stripping begins, possibly 4

No estimate is given in the planning application for when the local

This makes a total of over 20 years. During the period of site

Infrastructure Act, including the idea to include mineral extraction sites of

Years of suffering planning blight at least seven so far,

Plus, if planning permission is granted, an additional five years of

Up to fifteen additional years post restoration whilst the site takes

3.21 Any weighing up of the balance of the environmental impact of this

1,600 premature deaths, 68,000 additional days of medication, 363,266

That a share of the cost of the mitigation measures indicated in

Years of suffering planning blight at least seven so far,

Plus, if planning permission is granted, an additional five years of

Up to fifteen additional years post restoration whilst the site takes

These should also be considered when assessing the Environmental

OBJECTION 2 THE ECONOMIC VIABILITY OF THE PROPOSAL: OUTLINING

Challenging the Need for Coal: The Disruptive Technologies of

Consequently, why the need exists for an Insurance Based

The overall viability of the proposal

These objections should be considered alongside any other objections that

The cost of planning blight falling on the local community since

The cost of premature deaths caused by burning this coal thereby

The cost falling on Durham County Council and other UK local

OBJECTION 2 ECONOMIC VIABILITY OF THE PROPOSAL: DO WE NEED

Firstly, reducing and adapting our generating capacity so that it

Secondly, the potential development of new power stations fitted

Thirdly, the impact that the development of different forms of

LAON agrees with this statement, as it is information contained in this

4.14 This estimate for coal use, based on a reinterpretation of figures

The analysis present here supports another recent statement on

the economic outlook for coal generation is poor.

Our analysis is consistent with that outlook and shows that

What LAON has done, in producing this unofficial estimate of coal

calibrated against the expected timetable for the development of this

ACTION ON DEVELOPING THE SITE (FROM

EST. LEVEL OF COAL DEMAND

Renewable Energy, would have economically and socially on societies.

Barclays (see Barclays Downgrades Electric Utility Bonds, Sees

4.35 It is LAONs contention that we have proved that the

4.44 Instead, alternative forms of provision have been devised, such as

Shortwood Farm in Nottinghamshire was approved in December

Minorca Surface Mine, Measham Fields Farm Extension,