The Minorca Opencast Protest Group has just published its 6th set of objections to UK Coal's latest plans to opencast the Minorca site near Measham in Leicestershire. These objections centre on the risk that working the site will threaten the River Mease Special Area of Conservation
MOPG 87th Press Release 30/12/10
THE WATER QUALITY OF THE RIVER MEASE SPECIAL AREA OF CONSERVATION IS THREATENED BY UK COAL’S MINORCA OPENCAST PROPOSAL SAY OBJECTORS.
As the New Year approaches, so does the date on which the future of the Minorca Opencast Mine Application will be determined. The Minorca Opencast Protest Group has begun to release its remaining set of objections to the Application to explain the remainder of it’s objections.
In the latest set of objections published by the Minorca Opencast Protest Group (MOPG), today, their sixth set of objections to be published so far, MOPG conclude that there is a grave risk that disturbing the water flow through the rock strata adjacent to the Giliwiskaw Brook, a tributary of the River Mease, will damage the River Mease Special Area of Conservation.
A report written for Swepstone with Newton Burgoland Parish Council, by a Chartered Geologist with over 20 years experience of being consulted on water management and mining issues has concluded that
“The new hydrogeology report is based on poor field data. This has led to the use of complex computer models to try and justify the UK Coal position. However, the lack of field data means that the models cannot be adequately calibrated and verified, resulting in my opinion, to a low confidence in the model output and conclusions drawn from them.
The UK Coal approach is to base a high degree of reliance in the output of the models. In my opinion this is ill considered.
It is not possible, on the information presented, to concur with the predictions that are being made and therefore the contingency plans as designed.
In my opinion, the numerical models should be reviewed in detail, by an independent (from the regulators and UK Coal) expert groundwater modeller to assess their veracity, given the level of protection afforded to the SAC status of the Giliwiskaw Brook.”
In a detailed four page submission the expert Geologist criticises aspects of the hydrogeological Report submitted by Wardle Armstrong on behalf of UK Coal. The UK Coal Water Management Plan is flawed given the special status of this site as a Special Area of Conservation (SAC). In terms of the risk of damage being caused by working the open cast site the Geologist says
“It is therefore important that the probability of a problem occurring is as close to zero as could reasonably be expected. It is considered that based on the assessments carried on the impacts on the Giliwiskaw Brook, with respect to flow and quality, that this probability is ill defined. This is particularly the case where the conclusions are based on the numerical modeling that has been undertaken.
On Wardle Armstrong’s Supplementary Hydrology Report / Results of –Preliminary Groundwater Modeling the expert opinion offered is that
“It is considered that there are significant shortcomings in the baseline data and hydrogeological conceptualisation described in this report.”
On the new information that has been supplied since 2009 the expert passes this judgment:
“The test method and analysis technique is rudimentary and prone to error.”
On the section which contains other methodological criticisms this comment is made
“In themselves, these and other points within the report are relatively minor; but in combination they represent a very poor baseline data set and in some cases a poor or incorrect interpretation. These together must result in a low confidence in the conceptual model of the system.”
This approach is known in the trade as the ‘rubbish in rubbish out’ scenario since our critic goes on to state
“This becomes important when the conceptual model is then used as the basis of a complex numerical model. The lack of good quality field data and time series water level and river flow data, means that the computer model cannot be calibrated with any degree of certainty”.
and
“Due to the poor foundations of the computer models, the confidence in the outcomes and predictions can only be low. I am particular concerned with the predicted impact on the baseflow of the brook. The impact predictions are based on a poorly conceived and constrained model, and no real flow monitoring, other than one accretion survey. The only other data is generically modeled data.
The same comments are valid for the salinity model.
It is not possible to say whether the conclusions drawn from either model are correct; only that the basis on which the conclusions are drawn are, in my opinion seriously flawed, and therefore must be considered with a low level of confidence.”
The submission goes on to make similar comments on other aspects of Wardle Armstrong’s submission covering Assessment of Discharge Quality, Treated Water Discharge Procedure Guidelines, Water Monitoring Plan, and the Contingency Plan. Only the Floodplain Assessment just one out of 7 reports submitted on water quality is praised as being
“clear, concise and relevant”
even if the Swepstone with Newton Burgoland Parish Council expert judges it to be incomplete on the evidence provided.
Steve Leary for MOPG said,
“Again we have a set of objections to UK Coal’s plans which, we argue, prove how risky this application is, in particular to the continuing existence of the River Mease Catchment Area retaining its status as a Special Area of Conservation. This report wasn’t commissioned by or for MOPG, it was for a neighboring Parish Council. Still, in our view there is a real risk of damaging the River Mease SAC’s water quality. This judgment, on the poor quality of UK Coal’s second set of submission papers with regard to subterranean water flows clearly comes to the conclusion that if the base line data and the other information fed into a software program that models the expected outcome is poor that the conclusions drawn will be unreliable. The Swepstone expert argues that this is indeed the outcome here – the ‘rubbish in – rubbish out’ point already alluded to.
We are aware that this set of objections is probably one of the reasons why Natural England have asked UK Coal for further information on these Hydrological issues. But as we know, UK Coal in regard to this application failed to get it right first time and as a consequence over two years on from when this whole process started we are still left with national regulators requesting more information, even after a second submission and without a planning decision being made
Rather than trying to buy permission with their offer of such a large contribution to restore the Ashby Canal, a project which has nothing to do directly with this planning application, their money and effort would have been better spent on having improved this planning application in the first place rather than keep so many people waiting for a decision for such a long time.”
This date for determining this application has now been postponed and will take place in the New Year, but no date has yet been set.
END END END END END
FOR MORE INFORMATION ON THIS PRESS RELEASE CONTACT:
STEVE LEARY, SPOKESPERSON, MOPG
tel 05601 767981, email
steve46leary@googlemail.com
FOR MORE INFORMATION ON MOPG PLEASE GO TO:
http://www.mopg.co.uk or
http://www.leicestershirevillages.com/measham/minorca-protest.html
FOLLOW NEWS ABOUT MOPG and UK COAL on TWITTER by logging on to http://twitter.com/seftonchase
THE WATER QUALITY OF THE RIVER MEASE SPECIAL AREA OF CONSERVATION IS THREATENED BY UK COAL’S MINORCA OPENCAST PROPOSAL SAY OBJECTORS.
As the New Year approaches, so does the date on which the future of the Minorca Opencast Mine Application will be determined. The Minorca Opencast Protest Group has begun to release its remaining set of objections to the Application to explain the remainder of it’s objections.
In the latest set of objections published by the Minorca Opencast Protest Group (MOPG), today, their sixth set of objections to be published so far, MOPG conclude that there is a grave risk that disturbing the water flow through the rock strata adjacent to the Giliwiskaw Brook, a tributary of the River Mease, will damage the River Mease Special Area of Conservation.
A report written for Swepstone with Newton Burgoland Parish Council, by a Chartered Geologist with over 20 years experience of being consulted on water management and mining issues has concluded that
“The new hydrogeology report is based on poor field data. This has led to the use of complex computer models to try and justify the UK Coal position. However, the lack of field data means that the models cannot be adequately calibrated and verified, resulting in my opinion, to a low confidence in the model output and conclusions drawn from them.
The UK Coal approach is to base a high degree of reliance in the output of the models. In my opinion this is ill considered.
It is not possible, on the information presented, to concur with the predictions that are being made and therefore the contingency plans as designed.
In my opinion, the numerical models should be reviewed in detail, by an independent (from the regulators and UK Coal) expert groundwater modeller to assess their veracity, given the level of protection afforded to the SAC status of the Giliwiskaw Brook.”
In a detailed four page submission the expert Geologist criticises aspects of the hydrogeological Report submitted by Wardle Armstrong on behalf of UK Coal. The UK Coal Water Management Plan is flawed given the special status of this site as a Special Area of Conservation (SAC). In terms of the risk of damage being caused by working the open cast site the Geologist says
“It is therefore important that the probability of a problem occurring is as close to zero as could reasonably be expected. It is considered that based on the assessments carried on the impacts on the Giliwiskaw Brook, with respect to flow and quality, that this probability is ill defined. This is particularly the case where the conclusions are based on the numerical modeling that has been undertaken.
On Wardle Armstrong’s Supplementary Hydrology Report / Results of –Preliminary Groundwater Modeling the expert opinion offered is that
“It is considered that there are significant shortcomings in the baseline data and hydrogeological conceptualisation described in this report.”
On the new information that has been supplied since 2009 the expert passes this judgment:
“The test method and analysis technique is rudimentary and prone to error.”
On the section which contains other methodological criticisms this comment is made
“In themselves, these and other points within the report are relatively minor; but in combination they represent a very poor baseline data set and in some cases a poor or incorrect interpretation. These together must result in a low confidence in the conceptual model of the system.”
This approach is known in the trade as the ‘rubbish in rubbish out’ scenario since our critic goes on to state
“This becomes important when the conceptual model is then used as the basis of a complex numerical model. The lack of good quality field data and time series water level and river flow data, means that the computer model cannot be calibrated with any degree of certainty”.
and
“Due to the poor foundations of the computer models, the confidence in the outcomes and predictions can only be low. I am particular concerned with the predicted impact on the baseflow of the brook. The impact predictions are based on a poorly conceived and constrained model, and no real flow monitoring, other than one accretion survey. The only other data is generically modeled data.
The same comments are valid for the salinity model.
It is not possible to say whether the conclusions drawn from either model are correct; only that the basis on which the conclusions are drawn are, in my opinion seriously flawed, and therefore must be considered with a low level of confidence.”
The submission goes on to make similar comments on other aspects of Wardle Armstrong’s submission covering Assessment of Discharge Quality, Treated Water Discharge Procedure Guidelines, Water Monitoring Plan, and the Contingency Plan. Only the Floodplain Assessment just one out of 7 reports submitted on water quality is praised as being
“clear, concise and relevant”
even if the Swepstone with Newton Burgoland Parish Council expert judges it to be incomplete on the evidence provided.
Steve Leary for MOPG said,
“Again we have a set of objections to UK Coal’s plans which, we argue, prove how risky this application is, in particular to the continuing existence of the River Mease Catchment Area retaining its status as a Special Area of Conservation. This report wasn’t commissioned by or for MOPG, it was for a neighboring Parish Council. Still, in our view there is a real risk of damaging the River Mease SAC’s water quality. This judgment, on the poor quality of UK Coal’s second set of submission papers with regard to subterranean water flows clearly comes to the conclusion that if the base line data and the other information fed into a software program that models the expected outcome is poor that the conclusions drawn will be unreliable. The Swepstone expert argues that this is indeed the outcome here – the ‘rubbish in – rubbish out’ point already alluded to.
We are aware that this set of objections is probably one of the reasons why Natural England have asked UK Coal for further information on these Hydrological issues. But as we know, UK Coal in regard to this application failed to get it right first time and as a consequence over two years on from when this whole process started we are still left with national regulators requesting more information, even after a second submission and without a planning decision being made
Rather than trying to buy permission with their offer of such a large contribution to restore the Ashby Canal, a project which has nothing to do directly with this planning application, their money and effort would have been better spent on having improved this planning application in the first place rather than keep so many people waiting for a decision for such a long time.”
This date for determining this application has now been postponed and will take place in the New Year, but no date has yet been set.
END END END END END
FOR MORE INFORMATION ON THIS PRESS RELEASE CONTACT:
STEVE LEARY, SPOKESPERSON, MOPG
tel 05601 767981, email
steve46leary@googlemail.com FOR MORE INFORMATION ON MOPG PLEASE GO TO:
http://www.mopg.co.uk or http://www.leicestershirevillages.com/measham/minorca-protest.html FOLLOW NEWS ABOUT MOPG and UK COAL on TWITTER by logging on to
http://twitter.com/seftonchase 
e-mail:
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