1) 'Demand for coking coal will continue in the UK and Europe’s steelworks until 2040 at least'

Tata steelworks in Port Talbot has publicly called on the UK Government to co-fund its transition to Electric Arc Furnace steel production which uses little or no coal—or it has warned it’ll shut down in 2023. Tata is the largest steelworks in the UK.

2) 'It is important for supply security to mine coking coal for UK steelworks'

British steel industry chiefs have further said that British and European steelworks will be largely unable to use Whitehaven coal as it is too high in sulphur.

3) 'Emissions from the coal being burned isn’t relevant to the decision'

This involves some mental gymnastics, but essentially—it’s based on flawed reasoning that because West Cumbria Coal Mining Ltd can’t control how steelworks use the coal, it isn’t responsible for the resulting emissions. If end-use emissions can’t be a reason to refuse the coal mine, neither can end-use be a reason to approve the coal mine, yet end-use is precisely the basis for the coal mine’s approval.

4) 'Even if emissions from coal use was relevant, it wouldn’t create any overall increase in emissions'

This absurdity is based on coal industry testimony referring to supposed ‘swing suppliers’ of coal in the USA. Not only is this potentially biased and based on one country, it also wasn’t demonstrated that the market it responsive enough to reduce supply with Whitehaven’s production. Yet, Gove’s claim that emissions won’t increase is based on substitution that largely relies on this unsubstantiated testimony. It also rest on the notion that ‘if we don’t do it, someone else will’—an approach if everyone took, would mean no one would ever take action to reduce emissions and large parts of the world would become uninhabitable.

5) 'The coal mine seeks to be net-CO2 neutral'

Gove’s letter is careful not to say the coal mine will be net-CO2 neutral, only that it’ll seek to be—because, like all greenwash, it’s quickly shown to be empty promises to justify climate-trashing business as normal. Issues with off-setting aside, the off-setting scheme the coal mine cited in its application publicly rejected working with a coal mine soon after, and the head of Offsetting Gold Standard called the idea of offsetting a coal mine “nonsense”. Whitehaven coal mine will emit 340,000 tonnes of climate accelerating methane, only some of which is intended to be captured, and even the coal operator admits this will only start 4 years into the project.

6) 'Steelworks will be decarbonised partly through carbon capture and storage'

Given the weakness of Carbon Capture and Storage (CCS) and despite the billions pumped into its research and promotion so far, the only way to achieve steelworks decarbonisation will be removing coking coal from steelmaking. CCS has done little more than to continue business-as-normal by gambling on a largely unproven, expensive, energy-intensive technology that may create a future time-bomb and is yet to capture 100% of emissions anywhere.

7) 'The coal mine will negatively affect views from the busy coast-to-coast pathway'

Gove admits that the Coast-to-Coast pathway that beings in Whitehaven will be significantly and negatively impacted by the coal mine structures. This pathway draws tourism to the area.

8) 'The coal mine will not significantly reduce tourism to the area'

Gove’s conclusion that tourism won’t be significantly reduced seems incompatible with admitting the coal mine would have a significantly negative effect on the leading draw for tourism to the area, the Coast-to-Coast pathway.

9) 'The coal mine will create significant economic benefits to the area and the UK economy'

Arguments for the economic benefits to the area from the coal mine does not consider the costs to the economy from climate change, reduced tourism, and the distraction this creates from supporting sustainable industries creating jobs for the future. It is also based on assumptions such as workers relocating rather than commuting for work at the coal mine.

10) 'The coal mine has an unacceptable impact on the landscape justified by economic benefit'

It’s recognised that the landscape impact from above-ground structures is unacceptable. Yet, without any details, this ‘unacceptable impact’ is somehow quantified into a price, and that is weighed as worth less than the supposed economic benefit of the coal mine. This isn’t a technical decision—it is wholly subjective about what we consider the environment to be worth.

11) 'The coal mine will be restored with the result that the area will be better than before'

The subject of recent research by Coal Action Network, the UK is littered with under-restored or unrestored coal mines—right now, Merthyr (South Wales) Ltd is threatening to walk away from the UK’s largest coal mine without completing the restoration promised. The promise of restoration is rarely one that is kept and cannot be relied on. The ecosystem, and the lives supported by it, currently on the land also won’t be put back—it is as unique as each of us, and will be lost forever. The idea that a new one will be the same as the old one, that ecosystems and lives are interchangeable, is a subjective view to justify its termination.