See our Welsh language version of this webpage.
Wales is about to decide whether to expand the UK’s largest opencast coal mine by nearly 4 years, emitting almost 6 million tonnes of CO2, and 16,000 tonnes of methane from the coal mine itself.
The climate-trashing Ffos-y-fran coal mine in Merthyr Tydfil extracts up to 50,000 tonnes of coal every month – coal that the European Court of Justice ruled was too polluting to be burned in the old Aberthaw power station, and is now burned mainly at steelworks. This locks TATA steelworks into being the UK’s 2nd most polluting site!
We demand that the Welsh Government:
When permission was granted by the Welsh Government in 2005, the local community in Merthyr Tydfil, who had fought the proposal fiercely, were promised that mining would end after 15 years, in September 2022 and that restoration of the land would be complete by the end of the following year. Yet it’s reported that coal mining hasn’t stopped, ruining the long-awaited peace for the local community who can see and hear the coal mine from their homes. And now the mining company has applied to expand the coal mine by 9 months, and has said it will for a further 3 years of coal mining, (and who knows what beyond that...?).
This will not only fuel climate change by almost 6 million tonnes of CO2, but inflict explosive further blasting, noise and dust pollution on nearby residents. On top of this, the long-awaited restoration of the land, will be pushed back by years, with concerns that it will never happen.
We sometimes hear from people that they are worried coal may be a necessary evil to keep us warm this winter. But the worst effects of this energy crisis was, and to some extent is, avoidable. Low-hanging fruit include home insulation, community-owned renewable energy generation, and an effective windfall tax on profiteering energy companies. These measures can be rapidly deployed, and we’ve seen from Covid what the Government can achieve big changes when there is political will to. Coal is not, and for the sake of our future, cannot be, the answer to how keep warm this winter. That is why half the demands of the Warm This Winter campaign centre around renewable energy and excluding fossil fuels as the way we will access affordable energy this winter and in future years.
The Warm This Winter campaign’s 3rd demand is access to cheaper energy—“Clean, renewable energy is now nine times cheaper than gas and can be brought online quickly”. Subsidy-free solar, in particular, has been demonstrated as cheaper than its fossil fuel alternatives. Prices have fallen dramatically for renewable energy since introduction – whereas fossil fuels continue to rely on huge Government subsidies, infrastructure, and underwriting of risk.
The 4th demand of the Warm This Winter campaign is to cut out fossil fuels as “it keeps us locked into an unaffordable energy for far longer than necessary”. The UK Government sells our natural resources to companies that extract it and sell it back to us at unaffordable prices to generate huge profits for themselves—never more so than in 2022.
The energy crisis has created a swing in vocal public support for coal mining since the energy crisis, and with it, political support for coal mine applications has grown in the highest echelons of Government. The Government has sent mixed signals recently on whether it will approve or reject the Whitehaven coal mine application, which has now been delayed by a further month to before the 9th December 2022.
It is particularly clear that the Government is using the energy crisis as an excuse to abandon its climate commitments wholesale since it’s citing the energy crisis for renewing its support for coal mine applications… that have nothing to do with power generation. All the current coal mine applications are to mine coal for industry—not power generation.
The Government will hand over £420 million in tax money to profiteering energy companies to keep old coal power stations, like West Burton, and coal units, like Drax, chugging along this winter. These power stations and units were scheduled for closure in 2022, but now these dirty, dusty relics will be stoked with thousands of tonnes of imported coal, paid for with our taxes. In fact this move is expected to generate so much pollution that the Government has instructed the Environment Agency to ignore its responsibility to enforce pollution limits when it comes to coal fired energy production this winter. People living locally to these power stations will pay the price in potentially dangerously poor air quality, but we will all pay the price in our taxes and in our future compromised by the climate change a reliance on coal fuels.
Rolling out home insulation tackles the energy crisis and bills not just this year, but for many years to come—and the impact is immediate. It would also help the Government get back on track with its climate commitments as housing is responsible for 19% of the UK’s carbon emissions. This should be a top priority for Government in tackling the cost-of-living crisis and energy crisis together this winter.
In 2012, the UK insulated 2.3 million loft or cavity walls. But a shift in Government policy saw uptake drop by 90%. This Government decision to cut support for home insulation after 2012 has cost taxpayers, like me and you, £1 billion in energy bills this year. If the Government had maintained the same level of support, nearly 50% of UK homes could have been insulated by now. A more recent scheme by the UK Government collapsed, and was blasted by the Audit Office for being “botched”. This would have significantly reduced the energy crisis this winter, along with our bills. Households living in homes with poor efficiency ratings will pay around £1000 more this winter.
The British public overwhelmingly support the rollout of renewables, with 78% supporting solar power, 75% offshore wind, and 70% onshore wind. Unlike non-renewable sources of power like nuclear power stations, renewable energy infrastructure can be rapidly scaled up and brought online. With clear public support, the Government could rapidly accelerate renewable energy roll-out that isn’t vulnerable to shifts in geopolitics and global supply chains.
Because renewable energy is modular—one wind turbine or one solar panel can be bought and set up, or 1000s—its more affordable for communities buy their own equipment and become power generators, with the profits returning to those communities rather than disappearing into the pockets of big business. The Government acknowledges the value of community-owned renewable energy, but isn’t doing enough to encourage it. Instead, the Government dropped the Social Investment Tax Relief for community energy and has failed to provide the financial guarantees it provides to other energy projects like nuclear power stations. If the UK faced this winter with a resilient network of renewable energy zones, our dependence on gas and fossil fuels would have been much lower, and energy prices would be more insulated from Russian sanctions, geopolitics, and global demand and supply shifts.
The Government imposed a windfall tax in May 2022 as a one-off tax on the record profits made by energy companies that are due to lifted Covid restrictions and supply concerns around Russia’s invasion of Ukraine. However, BBC reported: “BP reported its biggest quarterly profit for 14 years, making £6.9bn in the three months to June. Shell recorded even higher second quarter profits of £9bn and made £8.2bn in the following three months. The majority of the April to June takings won't be hit by the government's windfall tax, as it only applies from 26 May”. The Guardian reported “Shell has paid zero windfall tax in the UK despite making record global profits of nearly $30bn (£26bn) so far this year”. Yet the Government has resisted pressure to tax these record profits and redistribute to cushion energy prices, so less of the UK have to choose between food and heating this winter.
Analysing 30 leading primary insurers and reinsurers, assessing their policies on insuring and investing in coal, oil, gas, the 6th Annual Scorecard cuts through the greenwash and sorts the meanest from the greenest. The report highlights progress and loopholes, calls out leaders and laggards, and identifies challenges and opportunities for the year ahead.
The number of coal exit policies has grown from 35 to 41 this past year, with major US insurers known for their role in fossil fuels AIG and Travelers finally getting on board. The market share of insurers with coal exclusions has reached 62% in the reinsurance and 39% in the primary insurance markets.
In terms of new power stations, this is good news: according to the report many of the key laggards that are continuing to underwrite new coal projects lack the capacity and expertise involved in insuring complex large-scale new coal power plants.
There is still a lot of work to do: many companies still have no policies excluding coal, and some of those that do extend only to power stations and thermal coal mines, not coking coal mines. Meanwhile Lloyds of London's coal exclusion guideleines are non-mandatory, and they take on 40% of the global energy market.
Insurance company restrictions on oil and gas are only just starting to catch up with those on coal. The new report shows 13 companies have adopted oil and gas restrictions, compared with 41 on coal.
Be it in the IPCC’s 1.5°C report, the IEA’s Net Zero Roadmap or the One Earth Climate Model, climate scientists are clear that there is no space for any new coal, oil or gas projects in credible pathways to limit global warming to 1.5°C. Yet most insurance companies have not taken this scientific evidence on board and continue to offer support to projects and companies expanding oil and gas production
Some insurers like Liberty Mutual, Chubb and Tokio Marine have adopted some restrictions on coal but actively insure the expansion of the oil and gas industry.
For the second year running, companies were ranked on their policies of Free, Prior and Informed consent: i.e. do they support projects that are in conflict with communities, and respect the right of communities to say no?
In summary, very few of them commit to anything like this.
While Allianz and Swiss Re mention of the right to Free Prior Informed Consent (FPIC) in their policies, AXIS Capital was the first insurer to adopt an explicit policy “to not provide insurance coverage on projects undertaken on indigenous territories without FPIC” in accordance with the United Nations Declaration on the Rights of Indigenous Peoples. The policy marks an important breakthrough for the recognition of Indigenous rights and other insurers should emulate it.
“So far, there hasn’t been real regulatory pressure. And there hasn’t been market pressure … as in the short term, it’s still a profitable business. So we think public pressure has really made an essential difference”
- Lindsay Keenan, Insure Our Future (the Guardian)
As part of the StopEACOP Coalition, we've been mobilizing to persuade insurers at Lloyds of London to drop the contraversial East Africa Crude Oil Pipeline.
Not only does this make the pipeline harder to finance, it also informs insurance companies about the damaging impacts of oil and gas pipelines, and is part of the movement to shift the whole industry away from fossil fuels.Sign up here to commit taking regular action with us - it's easy to do from home!
Along with our partners in the #StopEACOP coalition, Coal Action Network has been targetting insurers to turn the tide on fossil fuel insurance. This month, QBE, Suncorp, Generali, Aspen and Helvetia stated that they will not be providing insurance support to the East Africa Crude Oil Pipeline (EACOP).
They follow five other insurance companies who ruled out the project in recent months, making 18 insurance companies who have ruled it out overall. QBE and Suncorp are two of Australia's biggest insurers. Generali is Italy's biggest insurer.
In addition, Italy’s largest bank Intesa Sanpaolo, Germany’s second largest bank DZ Bank, as well as Natixis from France, have joined the growing list of banks that have ruled out direct finance for the EACOP project, bringing the total to 24. Spanish bank Santander is also understood not to be financing the project, which would be precluded as part of the bank's Environmental, Social and Climate Change Risk Management Policy.
Is the EACOP project looking less and less viable? There are now no French banks backing EACOP (Total Energies being a French company), and these refusals are coming from the company's former backers.
“With so many of Total’s financiers out of the running to join the $2.5 billion project loan the EACOP needs to proceed, the pressure is growing on those few that remain. This includes South Africa’s Standard Bank, Japan’s SMBC and MUFG, Industrial and Commercial Bank of China and Bank of China, as well as UK’s Standard Chartered, which as chair of the Net Zero Banking Alliance should not be going anywhere near new oil projects of any kind, especially not one as mired in human rights and environmental damage as this.”
-Ryan Brightwell, Campaign Lead Banks and Human Rights at BankTrack
EACOP has been condemned by the European parliament for its associated human rights abuses in Uganda and Tanzania. The pipeline and associated Tilenga oil field are expected to displace almost 118,000 people in Uganda and Tanzania, and since last week nine peaceful protestors were arrested following a student-led peaceful demonstration against EACOP in Kampala, Uganda.
“Lending or underwriting to projects that are mired in human rights violations, lacking in free prior and informed consent is wrong, shameful and unacceptable. The (re)insurers and banks that are still considering or are committed to underwriting EACOP cannot claim innocence, they are on the side of the human rights violators and this therefore makes them complicit.”
-Omar Elmawi, co-ordinator of the StopEACOP
Many of the insurance companies which have failed to rule out insurance for EACOP have syndicates at Lloyd’s of London, where the companies behind EACOP have reportedly been looking for insurance cover. These include Arch, AIG, and Chubb to name a few. These insurers must rule out EACOP immediately, to stand against the human rights abuses that are taking place in the name of this climate-wrecking pipeline. Lloyd’s Council urgently needs to commit the marketplace to policies ruling out new fossil fuel projects in alignment with the science on keeping global temperatures below 1.5C warming.
Companies who have not responded to the campaign's requests for comment are:
Aegis London, AIG, Arch, Brit, Canopius, Chaucer, Chubb, Cincinnati, Liberty Mutual, Lancashire Syndicates and Tokio Marine Kiln.
All of these have syndicates at Lloyds of London. The Lloyds council is responsible for regulating the Lloyds Marketplace (see Lloyds explainer here), and could bring in measures to stop fossil fuel projects, and those with human rights abuses, from being targetted.
We can see these tactics are working. But we need all insurance companies to rule out EACOP, and stop the toxic pipeline at its source. Next, we want Arch insurance to rule it out, and we know that constant pressure works.
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Ffos-y-fran (pronounced in English as Foss-uh-vran and also known as the 'Ffos-y-Fran Land Reclamation Scheme') is a large opencast coal mine in Merthyr Tydfil, South Wales, mining primarily thermal coal. Mining company Merthyr Ltd (previously, Miller Argent) was awarded planning permission in February 2005 on appeal and began opencast coal mining. Planning permission for the opencast coal mining came to an end on 06th September 2022 (confirmed by Merthyr Tydfil County Borough Council to Coal Action Network under a Freedom of Information request).
The two planning conditions that Merthyr Ltd are pressuring the Council to throw out are:
Merthyr Ltd want to delay its restoration responsibility and extend mining its dirty coal from the Ffos-y-fran opencast initially by 9 months (06 June 2023), but then by a further 3 years. The 9 month extension is to give the coal operator enough time to mine a further 240,000 tonnes of coal and submit an application for a 3 year extension but during this time, it’ll be mining as much coal as it can. See all the application documents at P/22/0237.
So, how does Merthyr Ltd seek to justify breaking its promise to the Council and local communities to restore and end opencast coal mining?
In a personally signed letter to the Council, Merthyr Ltd’s Director, David Lewis, claims production was reduced due to lockdowns so not all the coal could be mined in the void that was expected to be by the deadline of the 06 September 2022, so a time extension should be awarded to “ensure the full reserve can be realised”.
There are two issues with the justification attempted in Lewis’s letter:
Via repeated Freedom of Information Requests, Coal Action Network eventually succeeded in forcing the Council admit only £15 million had been deposited by Merthyr Ltd into the escrow account for restoration. In 2018, restoration was estimated to cost £62 million, meaning there is roughly a £47 million shortfall (depending on how much of the site has been restored alongside coal mining since 2018). This is shortfall is highlighted by Merthyr Ltd in its Planning Statement for the time extension: “As the Council is fully aware, there are insufficient funds within the Escrow and restoration fund to allow for the full and successful implementation of the current restoration strategy for the site.”
Merthyr Ltd’s solution is “that the additional time to finish extraction and restoration will enable a more sustainable and modernised restoration scheme”. Although Merthyr Ltd promised to fund and carry out a restoration strategy as a condition to it gaining planning permission, the company now uses its failure to fulfil this condition as a reason to let it mine more coal. And by “modernised”, Merthyr Ltd almost certainly mean cheaper restoration scheme.
Merthyr Ltd transferred most the of the land ownership to Geraint Morgan Legacy Limited of which David Lewis is the sole Director. If the Council attempts to recover the £47 million shortfall for restoration, and Merthyr Ltd cannot pay, responsibility may lie with the landowner, which appears from its Companies House records to only have £2 million in the bank. Merthyr Ltd may reap the profits from years of mining, and the Council could be face bankruptcy to pay the remaining shortfall for restoration.
Similar situations have been seen with other mining companies (most notoriously by Celtic Energy) holding Councils to ransom for permitting more coal mining by threatening to fold or transferring the liability to shell companies, knowing Councils can’t afford to fund the massive costs involved in restoring ex-coal mining sites.
Merthyr Ltd have known for years that planning permission at Ffos-y-fran would expire on 06 September 2022, yet attempts to leverage the fact that it has seemingly failed to support its workers to reskill or find alternative employment as a reason to extend the planning permission: “…it will ensure that current employees have a further 9 months to weather the cost of living crisis and look for alternative means of employment” (Planning Statement).
Incredulously, Merthyr Ltd even goes beyond this neglect towards its workers, to use its own lack of business strategy as it approached the known end of planning permission as a rationale for permitting the initial 9 month extension to allow “…the operators of the mine to look at other investment possibilities.”
Merthyr Ltd’s Planning Statement attempts the justification commonly used be coal mining companies in the UK: “The transport emissions for each tonne of UK coal delivered to Port Talbot are typically five times lower than coal imported from abroad” and therefore, less CO2 is emitted overall if coal is mined and used in the UK. This argument relies on the idea that more coal mining in the UK would displace the same amount of coal being mined in another country, and the coal mined in the UK would be used in the UK.
Coal-laden HGV leaving the Ffos-y-fran opencast coal mine on 13/09/2022
Coal operators are notorious for making lofty claims about the unrivalled quality of coal they would mine—this is to circumvent the presumption against new coal extraction in planning decisions, hoping to fit into the loophole made for exceptional need and economic value.
Merthyr Ltd has rebranded its thermal coal as “dry steam coal”, a term that doesn’t seem to be widely used by anyone except Merthyr Ltd and its trade customers. In reality, this is just thermal coal, and used to be primarily sold to RWE’s Aberthaw coal-fired power station. However, Aberthaw had to stop burning coal from Ffos-y-fran to generate electricity because the European Court of Justice ruled the toxic nitrogen oxides it emitted were too high.
With the loss of this customer, Merthyr Ltd invested £10 million in machinery to refine some of its lower grade coal to ‘metallurgical’ coal that could be used in steelworks in 2015.
Merthyr Ltd has clearly been studying other coal mine applications in the planning system, and likewise in its Planning Statement emphasises Port Talbot Steelworks’ reliance on coal, claiming its thermal coal is needed in the vaguely worded “steel manufacturing process”.
Like most coal operators, Merthyr Ltd (and former coal operators) like to change the rules along the way. The original coal operator agreed to all the conditions attached to the original planning permission in 2005, but in 2008, the coal operator wanted to rip up condition 37 requiring col to leave the site by freight train. The coal operator applied for a 'S73' change to use HGVs to transport 100,000 tonnes of coal each year by road, rather than rail. The company pragmatically reduced this to 50,000 tonnes but HGVs loaded with coal on the roads is dirty and dangerous, so the Council rejected the attempt to change this condition. The company didn’t accept this, and won the right to change this condition on appeal in May 2011 (APP/U6925/A/10/2129921)
Merthyr Ltd want to change the rules again with this 'S73' application for a time extension to mine more coal and delay the promised restoration. Each time the coal operators change the rules, it’s inevitably the local communities living in Merthyr Tydfil that pay the price. Enough is enough.
Latin America's biggest coal mine, Cerrejón, is being blocked by protesting members of communities which have been displaced and polluted by coal mining.
The mining multinational Glencore, has not complied with their commitments including to provide clean water for displaced indigenous and afro-descendant communities.
In La Guajira, a remote region in northern Colombia, community defenders are endangering their lives by stepping into a non-violent confrontation with the mining company; activists here are routinely targetted with violence. We must show that the world is watching and that we support the coal-affected communities' demands.
Three actions you can take in solidarity with the communities:
1. Add your voice to demand Glencore respects protestors and meets their demands
2. Attend the blockade via facebook as a show of international solidarity, organised by Colombia Solidarity Campaign
3. Tweet @Glencore so they hear the communities demands:
Glencore must:
- Meet with the communities represented at the Cerrejón blockade and return to dialogue with them
- Comply with the government order to provide safe drinking water for communities displaced by Cerrejon and to stop polluting the lands of nearby communities
- Ensure the safety of the community defenders
The defenders will not back down until they get an audience with Glencore. They are asking for international solidarity to get the company's attention and to stay safe.
The communities south of Cerrejón have been impeding the progress of Latin America's biggest coal mine for over 30 years through the courts and local government. Now they are taking non-violent action to stand their ground.
We all owe them our suppoort for their decades long struggle to keep fossil fuels in the ground while safeguarding their right to territorial lands from European colonisation.
Talanx, Germany's third largest insurer, is the latest (re)insurance company to confirm to the #StopEACOP Coalition that they will not (re)insure the East African Crude Oil Pipeline (EACOP). They join 11 other (re)insurers, including 4 of the world’s biggest (re)insurance companies - Munich Re, Swiss Re, Hannover Re, and SCOR.
Talanx follows fast in the steps of three other (re)insurers (Argo Group, Axis Capital and RSA Group), who last week also confirmed they would not be involved in underwriting EACOP.
In an email to a member of the StopEACOP campaign, Talanx's Group Strategy and Sustainability Manager, Dr. Jan-Philippe Lüdtke, stated:
"I can now confirm that there is and will be no involvement in EACOP by Talanx or any of its subsidiaries."
This statement implies that Talanx subsidiary, Lloyd’s of London member Argenta Insurance, will also stay away from the controversial EACOP project.
The total number of (re)insurers who have confirmed they would stay away from EACOP is currently 13.
Despite recent media reports claiming that the EACOP has been fully insured through a local consortium, the #StopEACOP Campaign maintains that the project needs substantial international insurance and reinsurance to proceed. See the full statement here.
“More and more (re)insurers are learning about the many problems that EACOP is bringing to the people of Uganda and Tanzania and the health, social, and climate impacts that the pipeline will leave in its wake, and they are wisely distancing themselves from the project. It is time for other (re)insurance companies to follow suit and refuse to be accomplices to such dreadful projects that are premised to only benefit the oil companies Total and China National Offshore Oil Company (CNOOC) at the expense of everyone else,”
- Samuel Okulony, Chief Executive Officer, of Ugandan-based Environment Governance Institute (EGI).
The EACOP project is a climate bomb. Its direction depends on the decisions (re)insurers make today. They have the power to save humanity, to rescue the thousands of people being displaced in Africa, to save the source of the longest river in the world, to save biodiversity that is on the verge of extinction which includes elephants, chimpanzees, giraffes, birds, insects, reptiles, forests, game reserves, rivers and waterfalls that people pay to visit in Africa. All these and more are at their mercy,”
- Hilda Flavia Nakabuye, climate activist and founder of Fridays For Future- Uganda.
“We now have 20 banks, 4 export credit agencies and 13 (re)insurance companies that have confirmed to us that they will not give project financing or underwrite EACOP. The other insurers and banks still considering any involvement in EACOP, like Industrial and Commercial Bank of China, Standard Bank-South Africa, and Sumimoto Mitsui Banking Corporation, are putting corporate needs and profits before people’s lives, nature and climate. It is time they choose sides. The whole world is watching and hoping they do what’s right – which is putting people’s lives before corporate greed.”
- Omar Elmawi, Coordinator of the #StopEACOP Coalition
Now Talanx CEO Torsten Leue must adopt a more comprehensive policy that excludes not just EACOP but all other new oil and gas projects. Talanx currently lags behind not just its major rival Allianz but also its own subsidiary Hannover Re, both of which adopted more comprehensive policies earlier this year.
“It is good to see Talanx HDI finally join the growing group of insurers who are snubbing EACOP. However, it is also imperative for the company to produce a sensible, comprehensive oil and gas policy that goes beyond oil sands alone. Instead of publicly advertising its expertise as an insurer of onshore and offshore fossil fuel extraction, Talanx HDI ought to swiftly exclude the complete unconventional sector, and in general, all new projects along the oil & gas value chain to then decisively phase out fossil fuels in line with climate science.”
- Regine Richter, Finance and Insurance Campaigner at Urgewald
Insurance providers Argo Group and Axis Capital, both Lloyd’s of London members, and RSA Insurance Group Limited, a leading UK insurer, have informed the #StopEACOP coalition that they will not be involved in underwriting the East African Crude Oil Pipeline (EACOP) project.
The decision by the three firms brings to 11 the total number of (re)insurers who have committed not to provide insurance coverage for the EACOP project. This is significant because the project needs substantial levels of international (re)insurance to proceed. The firms cite the EACOP project’s potential impact on people, nature and climate as among the reasons for their refusal to underwrite the project.
“We are able to confirm that providing insurance for the EACOP project, its construction, contractors, infrastructure or operation is not within our risk appetite. Therefore, we have not and will not provide insurance services associated with this project.”
- Alex Hindson, Chief Risk & Sustainability Officer, Argo Group
RSA Insurance Group Limited officially communicated that “our underwriters follow our Climate Change and Low Carbon Policy, which means we would not provide cover to the East Africa Crude Oil Pipeline.”
Axis Capital noted the insurance firm “…do[es] not support the East Africa Crude Oil Pipeline” and also confirmed that they “...do not envisage supporting EACOP in the future,” in email correspondence with Coal Action Network.
The EACOP and the associated Tilenga and Kingfisher oil fields are faced with widespread resistance locally in Uganda and Tanzania and globally, with over 1 million people signing a global petition against the projects. The planned pipeline is displacing tens of thousands of households in Uganda and Tanzania.
“TotalEnergies insists on forging ahead with the EACOP project even in the face of substantial local and global opposition. The company downplays the negative impacts of the project while arguing that the project is good for Uganda’s economic development. The truth is that the project is only good for Total and its shareholders and not the frontline communities facing displacement and human rights violations that have harmed their livelihoods. Financial institutions that are serious about protecting human rights and avoiding climate breakdown should rule out supporting the EACOP.”
- Diana Nabiruma of Africa Institute for Energy Governance (AFIEGO), Uganda
The EACOP, its associated upstream oil projects and related infrastructure such as roads, pose a threat to livelihoods, local cultures, sensitive ecosystems and wildlife, including endangered species in the Lake Victoria basin, Budongo forest, Murchison Falls National Park, Biharamulo Game Reserve and others.
The news comes against the backdrop of a worldwide concern that oil companies are making a killing by harming the environment and leaving communities where their projects exist languishing in poverty.
“As oil companies continue their operations in Africa, raking in huge profits, local communities are left to deal with the negative socio-economic and environmental impacts of these exploits. We welcome the move by Argo Group, Axis Capital and RSA not to offer (re)insurance coverage to the EACOP project, a project that not only comes at a huge cost to people, nature and climate but also jeopardizes key sectors that employ the majority of people in Uganda and Tanzania such as agriculture, tourism and fisheries. We call on other financial institutions that are yet to distance themselves from EACOP to do so and seal the fate of this harmful project.”
- Omar Elmawi, Coordinator of the #StopEACOP Coalition
These commitments illustrate the growing level of rejection of the project by international (re)insurers. EACOP can not proceed without international (re)insurance. RSA is a leading UK insurer, while Argo and Axis are members of Lloyd’s of London, the world's largest (re)insurance market. This adds to the pressure on the other Lloyd’s members and the wider insurance market also to reject EACOP. We also call on insurers as investors to proactively support renewable energy projects in Uganda, Tanzania and throughout Africa, where such projects are not in conflict with communities or ecosystems.
In addition to the 11 (re)insurers that have distanced themselves, 20 banks and 4 export credit agencies have committed not to provide project financing for the EACOP project.A recent report noted that the EACOP presents various violations of the IFC Performance Standards and Equator Principles in terms of both human rights and climate impacts.
Bryn Bach Coal Ltd submitted an application in 2019 to expand the existing Glan Lash opencast coal mine by 6.68 hectares (originally 7.98 hectares) with the site boundary at 10.03 hectares. The coal operator wants to extract a further 95,038 tonnes of coal (originally 110,000 tonnes, and represents more than the original coal mine licenced for just 92,500 tonnes) over 6.1 years (planning ref. E/39917). This amounts to around 325 tonnes/week. The Standard Mineral Application Form submitted to Carmarthenshire County Council is only partially filled out. There is a pending call-in request (from 03/01/2020) to the Welsh Ministers to determine this application. It could be quashed by Ministers (as of 27/07/2022, the Welsh Ministers are waiting on the Local Planning Authority Officer's report).
There are many calls to reject the proposed expansion on the grounds of climate change, citing Planning Policy Wales (Edition 10). But Llandybie Community Council and Councillor Davies support it—citing jobs, community fund, and repeating the company’s claims of low climate change impact.
Based on the planning permission issued on 25 January 2012, coal mining was to cease by the end of 2016 and progressively restored, with completed restoration by the end of December 2017, followed by a 5-year aftercare period. However, as so often happens, this promised restoration has yet to even be started. Bryn Bach Coal Ltd submitted a Section 73 time-extension application to delay restoration works, which the Council permitted ahead of the coal operator submitted an application to extend mining. As a consequence, the local community has suffered an unrestored coal mine on their doorsteps for almost 5 years whilst the mining extension application is considered. To add insult to this injury, Bryn Bach Coal Ltd also write in their environmental impact assessment (EIA) that the extension applied for would “enable the full restoration of the existing and the proposed extension”, making the completion of the previously promised restoration now appear dependent on profits from the extension—not dissimilar from the narrative in Celtic Energy Ltd’s extension applications.
Bryn Bach Coal Ltd claim Glan Lash produces ‘premium quality anthracite’, without parallel in South Wales—a suspiciously similar claim is also made by EnergyBuild Ltd about their Aberpergwm deep coal mine in South Wales.
Despite admitting that 50% (which the company recently changed to 25% in 2022, without explanation or evidence) of the coal mined would be burned for domestic heating, and failing to account for what percentage is destined for other uses, Bryn Bach Coal Ltd haughtily claim in their EIA “that to refuse planning permission based on the impact our proposal will have on Climate Change and Carbon Emissions would be globally irresponsible.”
Bryn Bach Coal Ltd does not determine global coal market conditions and cannot predict demand of different industries. Ultimately, the company will sell to whoever wants the coal and is offering the highest price for it. There will be nothing in the planning permission that controls how the coal is consumed. Bryn Bach Coal Ltd's claims around this may well just be an attempt to make the mine seem more acceptable to Planning Councillors and the public - don't fall for it.
Council commissioned the independent reviews of the technical reports paid for, and submitted by, Bryn Bach Coal Ltd on how the coal mine extension would impact water flows (hydrology) and the ecology reliant on that in the area. An independent Planning Ecology report in July 2022 recommends rejection of the application to fulfil the Council’s duty to “maintain and enhance biodiversity under Section 6 of the Environment (Wales) Act 2016, Section 6.4.21 of Planning Policy Wales or under Well-being Goal Two of the Well-being and Future Generations Act 2015 (AResilient Wales)”, and points out “documentation provided by the applicant is misleading in places as it makes frequent reference to the restoration of habitats”. In a letter to the Council, Friends of the Earth Cymru precede this independent Ecology Planning report’s conclusions by pointing out that “While mitigation is proposed in the form of restoration and replanting, these trees and associated landscape proposals will take years to grow back to current levels, and existing habitats may not recover”.
The 2018 EIA report paid for by the coal operator, Bryn Bach Coal Ltd, identifies that ancient woodland extends 2.52 hectares inside the site boundary, which would be at risk if the extension goes ahead, but claim the woodland should not be categorised as ancient woodland. The ecologists refute the 2011 classification by Countryside Council for Wales and Forestry Commission Wales, by citing a more obscure historic 1988 source that does not list it as ‘ancient woodland’. In a more recent EIA report by Pryce Ecologists, they stopped using the downgraded term ‘historic woodland’ and stuck to the correct ‘ancient woodland’ classification. This is reinforced by the July 2022 independent Planning Ecology report citing the woodland to be “circa 120 years old” and “cannot be compensated for by the creation of new woodland within a 17-year timeframe”. This is in direct contraction to what was claimed by the Pryce Ecologists EIA report paid for by Bryn Bach Coal Ltd. The independent report goes on to say it would take 120 years for the newly planted woodland to support the same biodiversity, by which time the existing woodland would be 240 years old if it wasn’t removed, and therefore probably still ahead in biodiversity. The independent report is also critical of the 2018 EIA report as ‘The applicant has incorrectly assessed that none of the hedgerows on the site are “important”’, arguing the loss of these hedgerows should be a ‘material consideration when considering this planning application’, particularly as the restoration plan’s “amount of new hedgerow planting is well below the 2:1 ratio associated with habitat compensation and habitat loss” and “40-50% of this planting is in positions where it will contribute little to biodiversity”.
The independent hydrology review commissioned by Council is highly critical of the reports provided by Bryn Bach Coal Ltd, with specific criticisms like “it is my very strong opinion that the information provided is insufficient”, “here appears to have been a complete absence of research on the hydrological management of abandoned mine workings in the area”, and “unsafe assumption[s]”, “I disagree entirely with this statement, and find it hard to understand how the reported data collection exercise could have informed the understanding of whether the marshy grassland is groundwater-dependent to any degree”. Lambasting one of the most recent hydrology reports by Humphries and Leverton in 2022 (again commissioned by Bryn Bach Coal Ltd), the independent review claims “it is based on a wholly inadequate ecohydrological conceptual model, the central limitation being an extremely poor understanding of the hydrogeology of the area … I am strongly of the opinion that the information provided is not sufficient to enable the Local Authority to determine whether or not the proposals will cause significant ecohydrological impacts”. In relation to the restoration plan, the review highlights that the “current claim that sequential backfilling of mined areas will completely restore the original hydrology as the workings move from west to east is, in my opinion, unsafe.”
As a statutory consultant, Neil Bateman responded to the extension application by pointing out that the Planning Policy Wales 10 (para. 5.10.14-15) applies in this case: “Proposals for opencast, deep-mine development or colliery spoil disposal should not be permitted…” (although acknowledging there is ambiguity about whether this applies extensions or only new coal mines). Bateman also highlights that the Minerals Technical Advice Note 2, para. 29 states “coal working will generally not be acceptable within 500 metres (m) of settlements”. The nearest settlement to the extension would be 440 metres, 60 metres less than the stipulation in this policy.
Bryn Bach Coal Ltd is the coal mining company that operates the Glan Lash opencast coal mine, which has been dormant since planning permission expired in 2019. In 2018, it applied for an extension which was unanimously rejected by planning councillors in 2023. Undeterred, Bryn Bach Coal Ltd is trying again! This time with a slightly smaller extension of some 85,000 tonnes rather than 95,000 tonnes. Check out the company's application and public responses so far.
Coal to be sold: 85,000 tonnes in total – average of 328 tonnes per week
CO2: Approximately 271,000 tonnes of CO2 in total (2024 BEIS Conversion Factors)
Methane: ~659 tonnes in total - circa108 tonnes each year.
Coal operator: Bryn Bach Coal Ltd – since grant of planning permission January 2012 - 2019
Type: Anthracite coal
Mining method: Opencast
Purported destination: Brake pads, water filtration, brick colourant etc.
Local Planning Authority: Carmarthenshire County Council
Address: Glan Lash Mine Site, Shands Road, Llandybie, Blaenau, Carmarthenshire SA18 3NA
Physical size: 10.03 hectares, with a void of 5.92 hectares (extended void = roughly 11 football pitches)
Time: 5.4 years of coal extraction, 7 years of all works on the site
Published: 15/10/2024
