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Welsh position on a coal ban needs to change

A response from the Welsh Climate Change Minister

Open letter to the Welsh Climate Change Minister... and their reply in full

(Click for PDF)

Open letter

Minister's reply

Background

On 23 October 2023, over 30 Wales-based NGOs, businesses, and community groups signed an open letter to Wales’ Climate Change Minister, Julie James, calling for the Welsh Government to ban coal mining once and for all (sent by Climate Cymru). On 10th January 2024, Julie James wrote back—but claims a ban isn’t needed, even though 1.6 million tonnes of CO2 could have been prevented since 2022 if the Welsh Government had adopted a ban. That failure has caused 362 additional deaths from climate change related causes. Julie James’ claims just don’t stack up against those lives lost. Here’s why:

What the Minister didn’t respond to

The open letter to Julie James highlighted that an issue with the current policy is that it is riddled with caveats and exceptions. Carmarthenshire County Council’s Planning Officer even wrote in September 2023 that it was “difficult to know for certain how to interpret the coal policy”. Julie James failed to respond to this point entirely. A clear ban would remove the existing ambiguity that makes the current policy challenging to apply.

Julie James also did not respond to our point that Merthyr (South Wales) Ltd would not have been able to mine 500,000 tonnes of coal from Ffos-y-fran over the past 1.5 years if there was a clear ban on coal mining. The mining company exploited the exceptions in existing policies to secure a de facto extension. To protect against this climate assault recurring by closing the loopholes, a clear coal ban is needed now.

In the open letter to Julie James, it’s stated “A coal mine ban can be drafted is such a way that allows for the safe winding down of existing coal mines, and Coal Authority access to fulfil its regulatory duties”. That didn’t stop Julie James trying to use that against a ban anyway: “we also have a duty to manage the safe closure and restoration of existing and historic mining infrastructure”. Julie James accompanies this with a reason that’s even more bizarre: “The incidental extraction of limited coal may also be required during the construction of infrastructure projects”. Those wouldn’t be coal mines so wouldn’t fall under a ban—the Coal Authority even licences this differently as an ‘incidental coal agreement’. The burden and hazards of historic mines across Wales would diminish under a coal ban, rather than risk being added to—a very real risk in light of Ffos-y-fran.

The Minister's presumptions against a coal mine ban

Julie James says “…coal licences may be needed in wholly exceptional circumstances and each application will be decided on its own merits”. But this creates exactly the problem that Julie James lamented in her letter in October 2011 to then Minister for BEIS Kwasi Kwarteng: "both the developer and the Coal Authority committing significant resources respectively to preparing and determining applications... before Welsh policy can properly be applied”. A coal ban would end the pipeline of applications, and the private and public funds they waste.

Julie James twice hails “the presumption being against extraction” in current policies. We hope it’s not presumptuous to argue for a commitment stronger than a ‘presumption’ in the face of catastrophic climate change. What justification could opening a new coal mine have in the face of the 362 lives that’ll be cut short due to the Welsh Government’s refusal to ban coal mines up until now? Climate vandalism over the past year shows nothing short of a ban on coal mining can protect the lives and ecosystems at stake.

Finally, Julie James concludes her letter by claiming the “Welsh Government has adopted and implemented the strongest policy opposition to coal extraction across the UK Governments”. Even if that were true, the Welsh Government clearly needs to go further given current policies have failed to prevent 1.6 million tonnes of avoidable CO2 in the past 1.5 years. But it’s also not true. Julie James’ claim to be leading on a progressive coal policy is based on her comparison to a similar one set out in the Scottish Parliament back in November 2021. She ignores the de facto ban that the Scottish Government more recently introduced in October 2022—as referenced in the open letter to Julie James. If Julie James actually wants the Welsh Government to boast the strongest policy opposition to coal mining, she’ll have to be bolder by committing to a ban on coal mining in Wales.

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