A guide to challenging extractive applications near you
This guide draws on 18 years of organisational knowledge fighting opencast coal mine applications. This was always shoulder-to-shoulder with local communities trying to preserve their local environment, way of life, and often motivated by the looming threat of global climate chaos.
Coal Action Network has existed since 2008. It started out as a few committed activists, with a founder working many unpaid hours, living in their van, and staying in the communities we worked in. This guide is thanks to their dedication. At the start, we were opposing about 40 live applications for new opencast coal mines and extensions. Now there are none.
We have witnessed first-hand the power of committed local campaigns successfully stop applications despite the deep pockets of developers and a planning system tilted in their favour.
The threat of opencast coal mines in the UK is hopefully over – but many of the tactics we learned along the way can be used for most extractive planning applications, from a tungsten mine to a quarry. We offer this guide to any group navigating the planning system to oppose an extractive development in their community.
"Never doubt that a small group of thoughtful,
committed citizens can change the world: indeed,
it’s the only thing that ever has."
- Margaret Mead
This guide focuses on action through the planning system, but Direct Action can be taken instead of, or alongside, action through the planning system. Any tactic where people take action to directly bring about the outcome they want, rather than trying to persuade institutions (courts, politicians, regulators) to act in their favour. This can be legal or illegal action, and accountable or unaccountable. An example of legal (at the time of writing) and accountable direct action would be ‘slow walking’ HGVs driving to or away from the site to develop it. This action involves walking slowly in front of the HGV, thereby delaying it – wear a high visibility jacket and do this carefully to maintain personal safety. Coal Action Network has historically supported direct action to oppose opencast coal mining. There are many guides on taking direct action on the internet, we recommend Seeds for Change’s guide.
This guide tries to help communities oppose extractive applications, such as quarries, via the planning system. It draws on CAN's experience since 2008 of standing alongside communities to face down opencast coal mine applications, often successfully.. If you live in one of these geographies, it’s worth double-checking the planning process where you are. This guide draws on Coal Action Network’s experience of supporting local communities to oppose opencast coal mining since 2008. Much of this experience is applicable to communities opposing any large development in their area, particularly extractive industries such as quarrying.
A local campaign group is just a group of people coming together in an area to campaign on a shared issue. After the issue passes, the group can stop meeting – or can go on to campaign on other issues that might matter to the group. Below is a summary of advice for forming and maintaining your local campaign group – but there is lots of advice on the internet. We recommend this guide.
Organising together as a group will:
There are various ways to go about kicking off a campaign group such as:
The first meeting is high-stakes, you can lose people or win a committed core of the group. Here are some tips for a great first meeting of the new group:
Top tip: tea and biscuits make every meeting better!
How you divide up the work will partly depend on how much there is to do and what capacities and strengths members of the group have. It may be sensible to group tasks as:
A significant planning application can take 6 months to 5 years to be decided. This uncertainty and length of time can make it challenging to maintain momentum in the group. Consider:
At some point you will likely need some financial resources to fund things like:
Depending on the application you are opposing, and whether legal advice is needed, you could require from £50 to over £100,000 (see Getting legal advice), so your fundraising activities will vary greatly depending on your funding requirements. There are guides to fundraising online – we like the Resource Centre’s guide, and their advice on taking card payments. Options for fundraising can include:
It is common for developers to carry out pre-application engagement with the Local Planning Authority and public consultation to test the waters before submitting a full application form, at which point significant changes are harder and more expensive to make. Sometimes a developer at this stage is also trying to determine if a development is worth pursuing and has little invested. So there is an opportunity here to persuade a developer not to take a proposal further – but be aware sometimes a developer will file an application years after this initial pre-application phase.
To dissuade a developer taking an application further, you want to convince the developer that they are unlikely to gain planning permission or it will take a long time with strong local resistance – uncertain delays are likely to cost the developer more and make b`udgeting difficult. You can do this by:
The Local Planning Authority may not list a proposal on its planning portal until a formal application has been made by the developer. So, if you hear of a development proposal:
Once an application has been received by a Local Planning Authority, it will be uploaded to the Local Planning Authority’s online planning portal which is normally a section within the council’s website. It can take a few days for the application to appear on the online planning portal. Not all online planning portals are the same, but most have a ‘key word’ search function, you can try to find the application this way. If that does not locate the application, email the planning department for the application’s planning reference or a link to it in the online planning portal – you can usually find an email address for the planning department in the planning area of the council’s website. A planning reference often looks something like P/25/0037, is unique, and can be used to find the application in the online planning portal.
Top tip: bookmark the planning application page as you will want to check this page frequently for any new information/progress on the application.
Sometimes application forms are very brief and just fulfil formalities without much detail. This detail will come later in the EIA, or sometimes supplementary documents from the developer such as a planning outline or a survey. However, there is usually some useful information:
If the application requires an EIA, the Local Planning Authority is required to give a 28-day public consultation some time after the EIA is made available (generally on the online planning portal – it could instead be made available for viewing in paper-based form at the council offices but we haven’t known this to happen for years). If the application does not require an EIA, the Local Planning Authority is only required to give a 14-day public consultation (or 21 days if it is not published in a newspaper). If you can convince the Local Planning Authority to extend the public consultation (see below), or repeat it, it can be useful as it will delay the application which would likely weaken the developer’s business case for the development and may eventually contribute to the developer pulling out. In very rare instances, the Local Planning Authority may determine a planning application before the consultation ends.
Public consultation (EIA and non-EIA)
Your objection to the planning application
Send in your own objection during public consultation. You can draft it before the consultation begins so you can get it in early, but also so you have as much time as possible to encourage others to object within the public consultation period. Objections can be sent in after the consultation period, but Planning Officers are not obligated to consider those – though still worth submitting as they often do get considered in our experience. Coal Action Network has a sample consultation response.
Other people’s objection to the planning application
A planning application must be in the ‘public interest’ to be granted planning permission. The more people who write in to object to the planning application, the more likely it will be that the Local Planning Authority will decide it is not in the public interest. The greater the impact of the proposed development on the person objecting, the more weight that objection is generally given. That usually means residents living closest to the development, or along roads leading to the site that may see increased HGV traffic. Therefore, it is good to focus your energy on these people writing objections to the Local Planning Authority, and including their address in emails/letters.
Encourage people to object to a planning application by:
Check the Planning Committee meeting agendas to see if the development you oppose is due to be considered in the next meeting (usually monthly). The agendas are usually published online about a week before the meeting. If you can’t find it on the Council’s website, email the Planning Officer and ask where you can find the agenda, and when agendas are generally published online.
Congratulations! You successfully fended off an extractive development in your area… but it might not be over – sorry. The developer may now choose to do one of three things:
If the developer thinks there will also be vocal local opposition to an appeal or an amended application, they may decide it is less likely to be successful or they don’t need that headache – and move on. Therefore, it is good to celebrate a refusal loudly to let the developer know you’ve still got energy for the fight, and underscore in your press release that any similar applications in the future will also be fought against by the local community.
This can be gutting, particularly given all the evenings spent poring over planning jargon and days of whipping up local opposition to the application. The planning system is tilted in favour of big developers and the impacts on your quality of life and nature unfortunately take a back seat, even if not officially. Cash-strapped Local Planning Authorities also sometimes approve planning applications just to avoid big developers’ costly appeals against refusals, which can run over £100,000.
But all may not yet be lost. Whether decision was made by the Local Planning Authority, a Planning Inspector, or by a Minister, if they failed to consider some factor that was material to planning – or failed to give that factor sufficient weight – when making the decision to grant the application planning permission, you may be able to quash (negate) the planning permission with a judicial review challenge, forcing the Local Planning Authority to reconsider the application.
Ordinarily planning applications are decided by the Local Planning Authority (by either the Planning Officer or the planning committee). However, occasionally a planning application for a significant development will have impacts beyond its immediate surroundings or create widespread controversy. In these cases (look up all the grounds), if the government thinks that the Local Planning Authority cannot give these factors due consideration, it may choose to call in the application to be decided by the Government. If an application is determined the Local Planning Authority, it cannot subsequently be called-in. However, an application is often not called in until the Planning Officer’s report is published – so there is a small, nail-biting window of time in which you’ll find out if the application will be called in.
Be aware that very few planning applications are called in – only 198 planning applications were called in between 2010-2023, that’s 1 in every 23,000. Of the 43 planning applications called in 2019-2023, 60% were subsequently granted permission – a successful call-in doesn’t mean an application will get rejected.
How to get a planning application called in
England -
Wales -
Scotland -
Northern Ireland -
Process of a called-in application
Judicial reviews can be daunting… but can also be a successful last-ditch effort to stop an extractive project near you. Judicial reviews recently prevented oil drilling in Surrey and a huge underground coal mine in West Cumbria.
Getting legal advice from solicitors that specialise in planning and environmental law has a number of benefits.
However, solicitors’ costs can rapidly spiral and planning applications have been successfully opposed by local campaign groups without involving solicitors. Solicitors ostensibly charge by the hour – sometimes in 12-minute increments! So, keep communications with the solicitors focused and concise, and if there is something you can do e.g. finding contact details for planning councillors, it’ll be cheaper if you do it for the solicitors. Agree your budget and deliverables with the solicitors from the outset so that everyone is clear what the expectations are. We use Richard Buxton Solicitors, who specialise in environmental and planning law. They also have a great deal of experience helping oppose extractive projects. However, there may be legal campaign groups who will take on the case pro-bono (for free) such as Good Law Project, Lawyers for Nature, and the Environmental Law Foundation.
Depending upon what stage you involve solicitors, they can have a less or greater impact – generally the later the stage, the more worthwhile it is to involve solicitors.
CAN was one of 109 respondents to the UK Government’s consultation on ‘Growing the market for low carbon industrial products: policy framework’. This consultation was to contribute to the UK Government’s announced plans to work with industry to establish green public procurement guidance, product classifications (formerly voluntary product standards), and develop an embodied emissions reporting framework (EERF), alongside the announcement of a UK Carbon Border Adjustment Mechanism (CBAM) by 2027. When implementing these low carbon product market policies, the UK Government has said it “will account for factors beyond embodied carbon, such as product longevity, performance, and the ability to repair, reuse, repurpose, or recycle”. The UK Government admitted that “market inefficiencies and limited awareness among buyers continue to hinder demand for low carbon products. For example, there is currently no single agreed methodology for measuring the embodied carbon of industrial products, and multiple definitions of ‘low carbon’ create confusion”. What follows is a summary of what we and other consultees responded with, along with a short analysis of the UK Government’s decisions following the consultation.
We asked the UK Government to introduce mandatory embodied carbon reporting for the construction sector, such as the EU are introducing. This would support the UK’s cement sectors investments in expanding low-carbon cement production and capitalise on the expected demand from the EU, helping safeguard the UK’s cement sector’s future. The advantages of mandatory rather than voluntary reporting include a creating a level playing field, standardised reporting methodology (which would aid benchmarking and clarity), and that it would give the construction sector a clear signal the UK Government treats embodied carbon as a serious climate priority, thereby encouraging firms to embed low-carbon choices early in the design process and contribute to the UK’s Net Zero agenda. Strategic policy is needed as the construction and the built environment is responsible for at least 25% of UK emissions. This is why UK industry is also calling on the Government to introduce mandatory reporting standards.
It is disappointing that the UK Government has decided to proceed with a voluntary embodied emissions reporting framework (EERF), and only committed to further consultation on making the EERF mandatory at a later stage. Reasons for proceeding on a voluntary basis may include that it avoids the need to agree the EERF with devolved governments of Scotland, Wales, and Northern Ireland. The UK Government also claims an initially voluntary introduction of EERF aims to encourage the immediate reporting of embodied emissions data and improve product comparisons, while minimising risks such as potential unintended consequences and costs to taxpayers and producers. The risk and unintended consequences are not explained. With this phased approach, producers able to meet reporting requirements could provide embodied emissions data as soon as available, while others would have time to prepare for the possibility of mandatory reporting in the future. It is not clear what incentive the voluntary approach gives to ‘first movers’ to take on the additional burden of EERF. We predict low industry uptake and very limited effectiveness in leveraging industrial decarbonisation markets.
The UK Government proposes guidance on the method of embodied emissions reporting as the first phase of the EERF, while also developing an IT system to simplify and reduce the costs of reporting, ensuring the embodied emissions data is more accessible and easier to compare. We are supportive of this, in principle, but believe the voluntary nature of the guidance means various methods to calculate embodied emissions will continue to be used and that, therefore, comparability will be constrained by limited uptake of voluntary reporting. We maintain that this range of methods will become embedded in the industry, which will create resistance to later measures by the Government to make one reporting method the mandatory one.
We are pleased to see the UK Government recommend the existing European standard EN 15804 for embodied lifecycle carbon reporting, which would ease trade with the rest of Europe and reduce duplication of competing standards.
In cement works, alternative fuels are increasingly used to replace traditional fossil fuels such as gas, oil, and coal burned to generate the 1,450c needed to generate clinker, a key part of cement. Alternative fuels are generally from waste products that would otherwise end up in landfill, but when burned sometimes generate more CO2 than traditional fossil fuels. This can disincentivise cement works switching to alternative fuels, even though it diverts waste products from landfill and reduces the localised environmental harms associated with fossil fuel extraction. The UK Government has rightly decided that embodied emissions reporting for products, including cement, should be gross CO2e emissions, but that producers can optionally also include net CO2e which deducts emissions from burning alternative, waste-derived fuels. In this way, producers can promote the benefits of making their products using alternative fuels, whilst also providing a transparent account of the gross emissions involved.
Along with other consultees, CAN called on the UK Government to develop a definition of low carbon steel, cement, and concrete for the UK industry. This should be coupled with a clear banding system such as A-G scale of low to high carbon industrial products. This would help construction companies compare, for example, cement products to more easily select lower-carbon products with the confidence of a Government-endorsed standard.
Unfortunately, the UK Government has ignored the consultation majority by stating that it will not introduce a single cross-sector standard, instead relying on the existing patchwork of classifications by industry and international organisations. This was apparently prompted by some industry responders claiming a comparable rating system could obscure nuances. Furthermore, the Government inexplicably will not develop any carbon footprint classification for cement products, which are responsible for 9% of the UK’s emissions.
This response shows a disappointing adherence to consultees’ feedback, as well as a distinct lack of ambition towards supporting low-carbon markets within key carbon-intensive industries. Relying on the existing patchwork of standards will prevent carbon comparison between construction projects, reducing incentives for companies to select lower-carbon products. This is because existing standards vary in how they classify low carbon products and encourage organisations to set procurement commitments e.g. SteelZero, ConcreteZero, the First Movers Coalition, and the Construction Leadership Council (CLC). In 2023, gross construction new work output totalled £139 billion, with the private sector share over 2.5x the size of the public sector.
Along with other consultees, CAN agreed with the UK Government that green public procurement can create the confidence of demand for low-carbon products that can incentivise industry to invest in decarbonisation technologies. Overall responders focused emphasised the need for both practical and clear guidance on how to go about procurement low-carbon products, as many in procurement teams lack the technical expertise to scrutinise the range of industry product classifications.
Rather than inventing an entirely new framework from scratch, the Government decided that new procurement guidance will directly endorse and integrate existing, industry-led standard models for material classification (such as the Low Emission Steel Standard (LESS) for steel, and benchmarks from the Lower Carbon Concrete Group for concrete). We are concerned that these material classifications for industry, by industry, and may therefore not have the same rigour as a classification designed by a government body – its more industry self-regulation that we’ve seen fail before. Furthermore, these industry standards will be embedded in the Ministry of Housing, Communities and Local Government’s (MHCLG) Construction Products Regulation, which sets whether a construction product can legally be sold or used on a UK building site. Given the overriding consultation response requesting clarity for non-technical staff, we are concerned that the decision to rely on the multiple existing industry classification would require training on multiple classification standards and that these are primarily made for technical construction consultants rather than public procurement staff.
We applaud the UK Government for its commitment to meeting level 3 of the Industrial Deep Decarbonisation Initiative (IDDI) Green Procurement Pledge, which it signed at COP28. This means the government will require the public procurement of low-carbon cement, concrete, and steel in public construction projects starting from 2030 onwards.
We support the UK Government’s effort to ensure inter-departmental alignment, otherwise known as the right hand talking to the left hand. The Department for Energy Security and Net Zero is mandating that these procurement rules directly complement the Ministry of Housing, Communities and Local Government’s Construction Products Regulation reforms and the upcoming Steel Strategy, ensuring public sector buyers have a single, unified standard for what constitutes a compliant "low-carbon" purchase
Encouraging multiple approaches to decarbonisation, particularly in combination where compatible, is likely to drive the rapid and deep decarbonisation of industry being sought by the UK Government. However, not all pathways are equal and it is counter-productive not to encourage those most effective at reducing environmental harms. To do so would also create inconsistency between criterion 1 point 3 and 4. Technologies that drive greater efficiencies, using fewer materials through product design and waste reduction should be rewarded over abatement technologies such as carbon capture, utilisation, and storage (CCUS).
The UK Government has stuck to encouraging a broad range of decarbonisation approaches, including energy efficiency, resource efficiency, renewable energy, fuel switching, and CCUS, without favouring any specific production pathway. We hope that the high energy inputs and embodied emissions required to operate some decarbonisation technologies such as CCUS, is calculated into any corresponding reduction in site emissions. We also trust that the Government will be more nuanced than their statement suggests in supporting a hierarchy of abatement approaches and technologies that favours those that are proven, lowest impact, and reduce resource consumption.
Carmarthenshire County Council has rejected Bryn Bach Coal Ltd’s second attempt to expand and extend the currently dormant Glan Lash opencast coal mine, amidst hundreds of hand-written and online objections from residents in the county (see below for a small selection). The decision reflects a clear, strategic commitment to climate leadership, rare habitat protection, and safeguarding the health of surrounding communities. There are no live applications for new coal mines, and only two active coal mines remain in the UK – a large, underground coal mine in Aberpergwm, Glynneath and a small underground coal mine called Ayle Colliery in Northumberland. There is further a proposal (pre-application stage) to mine the Bedwas coal tips of waste coal.
The proposed expansion was the mining company’s second application following unanimous rejection by Councillors of the company’s first application in September 2023. The second application reduced the amount of coal to be mined from 95,000 tonnes to 85,000 over 5.4 years, with a slightly smaller area to be excavated. However, the latest application remained incompatible with Wales’ coal and protected habitats policies. Rejecting this application has prevented the release of hundreds of thousands of tonnes of CO2 and methane, as well as exhaust emissions from years of heavy machinery. The would-be commercial buyers of this coal – as listed by the mining company – sell anthracite coal to burn on the international market, and undermining the mining company’s claims that coal mined at Glan Lash would not be burned. Selling Glan Lash coal on the international market would fuel dependence abroad on the world’s number one dirtiest fossil fuel, whilst the UK itself transitions to greener, cleaner industry and air quality.
Beyond emissions, an independent ecologist’s report outlines in stark terms how the mine expansion would have destroyed a further 2.5 hectares of woodland, including sections of listed ancient woodland, as well as over 400 metres of precious hedgerow habitat. It also would have delayed the excavated area’s restoration (which planning permission originally required to be delivered in 2019) by a further 5.4 years. The mining company originally committed to start restoring the site in 2018, but delayed this with successive attempts to extend mining instead. These delays have coincided with the deterioration of protected habitats on the site such as those supporting the threatened Marsh Fritillary butterflies, whose numbers have plummeted across the UK by 64% since just 2005. This refusal paves the way to finally require the company to return the land for the benefit of nature and local communities.
With the closest homes just 30 metres from the edge of the opencast site, the application was also clearly incompatible with the 500-metre minimum buffer zone required by Welsh Government policy to protect surrounding communities from excessive noise, dust, and air pollution and disturbance.
Carmarthenshire Planning Authority’s decision reflects alignment with the Welsh Government’s positions on coal, climate, and nature recovery, the UK Government’s commitment to prevent new coal mining licences, and the international movement to phase out coal.
Deep (AKA underground) coal mines have a long history in the UK dating back some 400 years. On the other hand, opencast coal mines only became common between 1940 and 60, becoming the dominant mining method in the UK as deep coal mining entered rapid decline. Opencast coal mining techniques were largely imported from the USA (Hansard, 1950) together with the heavy machinery they required. In 1942, the UK Government established the Directorate of Opencast Coal Production under the Ministry of Works to exploit coal seams near the surface (National Archives, n.d.) that were too shallow or fragmented for deep-mining techniques (Ritchie & Roser, 2019). The UK Government encouragement of opencast coal mining was partly the result of a need to boost coal production and a wartime shortage of labour to do it (British Geological Survey). Opencast coal mining was cheaper and used less labour - it also did not require the specialised skills that deep coal mines do. Although opencast coal mining was introduced as an emergency wartime measure, it persisted due to its economic viability compared with deep coal mining. Yet, despite this transition from deep to opencast coal mining, as of 2026, deep coal mines have outlived opencast coal mines as the only active mines remaining in the UK - namely, Aberpergwm in South Wales and the relatively small Ayle Colliery in Northumberland.
The Opencast Coal Act 1958 provided the first comprehensive legal framework for the industry, regulating land acquisition and restoration requirements as the practice moved from emergency status to a long-term economic strategy. However, today we see that this legislation and subsequent legislation was not strong enough to secure restoration of the sprawling opencast coal mines.
We worked with media outlet, Nation.Cymru, to ask where the main political parties in Wales stands on restoration issues ahead of the Welsh election on 07th May 2026. This is a key issue for many people, but particularly those who live near under-restored opencast coal mine sites. These sites need Welsh Government support to bring them more in line with the quality that was promised to local residents. It's also vital that Wales learns lessons from its scarred landscape. We hope that these political parties remember these pre-election commitments when it comes to determine the called-in Ffos-y-fran ex-opencast restoration planning application. Reform was the only party not to respond - but this is a summary of what the other political parties of Wales had to say:
(see the Nation.Cymru article for the full account)
Industry Accountability: Strengthening "polluter pays" laws to ensure companies that profited from heavy industry are legally responsible for land restoration.
National Remediation: Implementing a nationwide strategy to monitor and restore every coal tip, while demanding Westminster fund the clean-up of pre-devolution hazards.
Community Planning: Reforming land-use planning to balance development with nature restoration and better public access to green spaces.
Justice First: Mandating that polluters pay for all prevention and repair, ensuring environmental damage is never subsidized by the public.
Ecological Regeneration: Focusing on long-term ecological repair of mining sites rather than short-term safety fixes to deliver environmental justice.
Fundamental Access: Treating high-quality nature access as a fundamental right, prioritizing new green spaces in communities historically affected by industry.
Pollution Reform: Introducing a new Clean Water Bill and a dedicated watchdog to crack down on water pollution.
Tip Safety: Establishing a "Disused Tips Authority" in Merthyr Tydfil to secure 400+ sites and exploring solar energy or mine-water heating on reclaimed land.
Green Renewal: Expanding on the 4,000+ green spaces already created by launching an urban rewilding taskforce.
Aggressive Enforcement: Taking tough action on sewage and industrial dumping, ensuring big companies—not local taxpayers—foot the bill for clean-ups.
Green Opportunity: Moving past "empty nostalgia" by transforming former coal sites into hubs for green industry, housing, and skilled work.
Land Reclamation: Partnering with councils to turn derelict land into parks, tree-filled areas, and safe walking or cycling routes.
New Oversight: Scrapping Natural Resources Wales and replacing it with a new independent regulator to enforce environmental rules.
Conservation Funding: Establishing a £20m "Wildlife Wales Fund" to support conservation efforts and community green spaces.
Economic Focus: Prioritizing economic transformation in coalfield areas while protecting heritage and improving site safety.
As part of our Politics Unspun series we are unpacking politicians' public comments on coal to challenge any misleading or incorrect messages.
Todays' focus is on comments made in a BBC interview during the Senedd election campaign about coal mining in Wales. During the interview, Reform UK candidate in Afan Ogwr Rhondda, Ben Hodge-McKenna, made some statements about coal mining which we would like to address as part of this series.
Mr Hodge-McKenna claimed that reopening Welsh coal mines could help meet the UK’s energy needs. However, the UK no longer operates any coal‑fired power stations and the country’s energy strategy is now centred on renewables, storage, and electrification. Coal has not been a major part of the UK energy mix for almost a decade and Welsh coal cannot substitute for modern low‑carbon energy systems. Reopening mines would not contribute to UK energy security.
"It doesn't make sense for us to be sabotaging our economic policy and sacrificing jobs in Wales when you have other countries around the world that are ramping up,"
Reopening mines now would not recreate the large, long‑term workforces of the past. Modern mining is highly mechanised, and any jobs created would be limited and short‑lived, particularly due to the decreasing demand for coal in the UK. Aside from this though, the UK Government will soon legislate a prohibition of new coal mining licences, making new mining activities impossible approve in Wales or anywhere in the UK.
In contrast, Wales’s growing renewable energy sector offers larger, more stable employment opportunities which offer long term jobs in an expanding industry to workers today and in years to come.
Mr Hodge-McKenna said he understood the concerns about climate change, but the emissions that are produced in Wales on a global scale "are absolutely minuscule" meaning any changes would have "virtually no impact".
Regardless of other countries ramping up their coal production, it is in our own economic interest to pursue a clean energy future. All countries could, and some do, avoid taking action because of larger current or historic emissions being produced by another country. Wales can only control its own coal production and be the example to other countries as to how to transition in a just way which benefits workers, communities and the climate.
"I don't think anybody's talking about sort of going back to the 70s or 80s and reopening mines in the conditions that they were previously. But if there are commercial opportunities to enjoy the natural resources that we have then we shouldn't be automatically closed off to any options without at least giving them a fair consideration,"
While safety standards in coal mining have improved, this does not address the core issue: coal is the highest‑emitting fossil fuel. The UK’s climate commitments require rapid reductions in emissions, and new coal extraction would run counter to those goals. Additionally, Wales still faces safety risks from legacy coal infrastructure, such as abandoned opencast sites and unstable tips which require ongoing management.
Improved safety conditions in mining do not change the environmental and climate impacts associated with burning coal.
Merthyr (South Wales) Ltd illegally mined coal at Ffos-y-fran for over a year, profiting from record coal prices. Now, it wants to keep all the profits by trying to downgrade the restoration plan, breaking its promise to the 60,000 residents of Merthyr Tydfil, South Wales.
Your objection means much more if it's put in your own words why you want Merthyr Tydfil Council to refuse the application to downgrade this huge restoration project. Here's some points you might choose to include, or go straight to the objection form:
This will take you to the Merthyr Tydfil Council's short objection form.
Ironically, the original approval of the opencast coal mine was to fund the restoration of the area which had been scarred by previous iron ore and coal mining. Key to the agreed restoration plan is that the huge overburden mounds (coal tips), currently dumped in 3 mountainous piles around the site, would be returned to the void, both of which were created by the opencast coal mining. That would return the site to the undulating landscape it was before and in sync with the rest of the lanscape in that area. Merthyr (South Wales) Ltd agreed to this restoration plan in 2015, when it took over operations at the site - but is now trying to wriggle out of that contract.
We got internationally renowned foresnic accountants, C. Lewis & Company, to analyse mining company Merthyr (South Wales) Ltd's accounts. Guess what? Not only can the mining company afford the full restoration, it has even set the money aside for it, and it can't legally spend it on anything else... unless the Council agrees to downgrade the restoration by granting the company's cut-price restoration application.
It's a stitch up! Don't let it happen
The new proposal was published on Merthyr Tydfil County Borough Council's website on Friday 21/02/2025. It is a plan to do as little as possible that would justify the company getting its hands on the £15 million currently held by the Council in an ESCROW account. But that £15 million was only intended to cover the barest necessities to make the site safe in case Merthyr (South Wales) Ltd goes bust. Merthyr (South Wales) Ltd hasn't gone bust though, and should be stumping up around £75-110 million to pay for the restoration.
The 218-page environmental impact assessment for the new plan is overflowing with greenwash. The assessment even claims that the lack of restoration it's now proposing for the opencast coal mine will be an 'educational resource' and testament to the area's mining history - more like a permanent reminder to Merthy Tydfil residents of broken promises and rampant profiteering at their expense.
The assessment fails to account for the impact that a loss of land and associated loss of carbon sequestion will have over the decades. The State of Nature Wales 2023 reveals the devastating scale of nature loss across the country and the risk of extinction for many species. This is not the time to cut the restoration budget by around 80-90% of a huge site - much of which has been off-limits to nature for too long.
Despite 2024 being a momentous year for UK coal mining and use, the fight's not over.
The UK steel and cement sectors (and to a lesser extent, bricks) are the largest users of coal following the closing down of the UK's last coal-fired power station in September 2024. But tried and tested alternatives to coal exist. Check out our coal dashboard for our most recent coal stats including an industry break-down. We support the UK Government's commitment to ban new coal mines opening in the UK - but this must be accompanied by a commitment to rapidly wean domestic industry off coal by adopting existing alternatives. Failing to do this simply off-shores the dangers and localised environmental harm of coal mining to where it's out of sight. This kind of practice marked the British colonial period, where some of the dirtiest and most grueling work was forced upon colonised countries, to supply and develop the UK. Continuing this pattern is called 'neo-colonialism', and the UK must avoid this by de-coaling domestic industry.
As the UK no longer produces thermal coal, the type used by the cement industry (and to a lesser extent in the steel industry), 1.78 million tonnes was imported in 2024 – primarily from Colombia and South Africa, two countries plagued with poor track records in coal mine-based health and safety, forced displacements of communities, and killings of environmental defenders. Without a plan to decisively and rapidly wean cement works off coal, the UK is open to accusations of perpetuating neocolonial patterns of trade.
Coal is shipped from abroad to the UK's major coal ports, then ferried up river to further inland coal stocking areas. From here, coal is loaded on trucks and cargo trains to cement works, Scunthorpe steelworks, and to coal merchants.
Major commodity traders are essential to global shipments of coal by organising logistics and buying coal from coal producers and selling it to consumers. These international traders include the likes of Javelin Global Commodities and Jera Global Markets. Sometimes there are additional middle-men such as Hatfield Energy, responsible for a significant amount of the coal imported into the UK - likely bought on the open market from international commodity traders. Unfortunately, banks' coal-exclusion policies open exempt commodity traders, meaning these cogs in the fossil fuel machine still receive £millions in finance.
Carbon footprint
The steel industry produces 9-11% of the annual CO2 emitted globally, contributing significantly to climate change. In 2024, on average, every tonne of steel produced led to the emission of 2.2 tonnes of CO2e (scope 1, 2, and 3). Globally in 2024, 1,886 million tonnes (Mt) of steel were produced, emitting in the order of 4.1 billion tonnes CO2e (75% of which are direct emissions). This is largely due to the reliance on ‘coking’ coal in blast furnace primary steel production.
Coal-free steel pathways
Four of the five biggest global steel producers aim to reach carbon neutral steel production by 2050. This would be through a combination of using ‘electric arc furnaces’ (EAF) to recycle scrap steel into secondary steel products, and a newer technology called Direct Reduced Iron that replaces coal with natural gas or hydrogen in primary steel making. The hydrogen option could be generated from renewables but relies on the roll-out of much more renewable generation capacity and massive green hydrogen infrastructure, which has so far received little of the huge investment required. So where this new Direct Reduced Iron technology (also requiring significant investment) is being used, it’s generally with natural gas instead. Those steelworks could be switched to hydrogen in the future, if the price of green hydrogen drops to a competitive level and the infrastructure to get the hydrogen to steelworks is built.
Threats to coal-free steel decarbonisation
There is a global over-supply of steel, primarily generated by China which produced 54% of global output in 2023. This has reduced the price that steel can be sold for to the point that many steelworks are running at a loss, supported by government subsidies to continue operating. This threatens the very significant private sector investments needed into green steel production as the industry’s current position makes a profitable return on that investment unlikely. A blast furnace can continue for 15-20 years before undergoing a ‘relining’ (refurbishment) process to extend its life further. Relining can cost 25-50% of the cost of a new blast furnace, but still amount to hundreds of £millions. Due to the long life and large capital investments, it’s essential that investments now are in greener steel-making processes or the world will be ‘locked in’ to CO2-intensive steel-making for many years to come.
In 2024, UK steel production made up 32% of domestic consumption and was responsible for 13.4% of GHGs from manufacturing, and 2.2% of total UK greenhouse gas emissions. The vast majority of this footprint is due to the coal burned at Scunthorpe steelworks. With the UK Government rightly ruling out any new coal mining projects in the UK, it is vital that UK steelworks becomes coal-free. Switching domestic coal mining for coal mining abroad would perpetuate colonial patterns of trade where the impacts of extractive industries are off-shored.
UK primary steel-making is wholly dependent on imports for the two main resources needed to make steel: ‘coked’ coal and iron ore. Coal needs to be ‘cooked’ in ‘coking ovens’ before it becomes coked coal capable of burning at very high temperatures required in blast furnaces. The UK closed its last coking oven in Port Talbot in March 2024. Since then, UK primary steel-making has depended on other countries to process coal in coking ovens before being imported into the UK.
The UK’s largest steelworks, Tata Steel UK’s Port Talbot steelworks, recently closed its blast furnaces, which had come to the end of their operational life. With £500 million from the UK Government, Tata seized the opportunity to shift from making coal-based blast furnace primary steel to using electricity to recycle scrap steel into new secondary steel products instead.This technology is called an ‘electric arc furnace’ (EAF). Although the transition should have had more Union and worker involvement, the conversion to EAF is a pragmatic move given the UK’s scrap steel surplus, the financial losses being made in the blast furnace steel production, and the UK’s net-zero commitments. Four of the UK’s other steelworks also recycle scrap steel using EAFs. The fifth is British Steel’s Scunthorpe steelworks, which still produces coal-based primary steel, and so is the second biggest single site source of CO2 in the UK.
Scunthorpe’s blast furnace steelworks needs to decarbonise to remain competitive, improve local air quality, and avoid fuelling climate chaos. Before the UK Government took partial control of the steelworks around April 2025, the operators – Jingye Group – claimed financial losses of £700,000 per day. Additionally, customers – who will soon face mandatory carbon reporting – may increasingly choose to import lower carbon steel from other European countries like Sweden and Spain who are pursuing low-emission primary steel production. The current options for Scunthorpe steelworks are:
1) convert to Direct-Reduction Iron technology to produce primary steel
2) convert to recycling scrap steel in a EAF to produce secondary steel products.
Producing secondary steel option would be much cheaper, but politically difficult as it would mean the loss of many jobs and the loss of the UK’s primary steel-making capacity. Find out more about the technology options below:
Read more about coal in steel in our 2021 report.
Blast furnace primary steel production: Metallurgical-grade coals converted to ‘coke’ which has a dual role in a blast-furnace, providing the required heat and creating a chemical reaction with iron ore reducing it to ‘pig’ iron which is heated with other additives (including small quantities of existing scrap steel) to make steel.
Electric arc furnace secondary steel production uses 99% less coal than blast furnaces per tonne of steel produced by using electricity to melt down scrap steel to make secondary steel products, with small quantities of coal added to remove certain impurities. In countries, such as the UK, which generates a large share of its electricity through renewables, EAFs have a much smaller carbon footprint than blast furnace steel production. The UK currently produces a surplus of scrap steel, exporting it to EAFs abroad. Having greater EAF capacity in the UK will keep the scrap here, and the jobs it supports. Steel is – in theory – an endlessly recyclable product, but when it’s fused with other metals and materials, or has other properties added to it, it can be challenging to recycle it in EAFs into high-grade metals needed for certain applications, even with small quantities of coal added to remove certain impurities.
Direct reduced iron (DRI) primary steel production: is an emerging alternative to blast furnaces where natural gas or hydrogen replaces the role of coal in heating and reducing high-grade iron ore down to iron, ready for primary steel-making in an electric arc furnace. There are successful commercial test-cases for this technology, such as HyBrit in Sweden which uses hydro-generated green hydrogen to make steel. However, green hydrogen is prohibitively expensive, currently, so DRI facilities tend to use natural gas whilst being “hydrogen ready”. DRI production also makes capture rates for CCS much higher than a blast furnace.
It is vital that the forthcoming UK Government’s green public procurement policy for construction and Carbon Border Adjustment Mechanism should be sufficiently robust so as to support UK low-emission steel to compete with cheaper higher emission steel imports. Together, this should add confidence within the British steel sector that the UK Government’s public procurement pipeline will be a pipeline that supports domestic industry.
The UK Government must take action to secure the UK’s production of virtually coal-free secondary steel-making:
The UK Government’s steel safeguard Tariff Rate Quota expires in June 2026 – but the UK’s Carbon Border Adjustment Mechanism is not expected to be implemented until 2027. The UK Government should introduce stop-gap measures to prevent high-carbon steel imports causing carbon-leaking and undermining investment to produce greener steel in the UK.
The UK Government should engage in honest conversations now with unions and workers at the loss-making Scunthorpe Steel Works regarding the future of steel-making at the site. EAFs are currently the only financially viable technology to replace the coal-fed blast furnaces currently in operation. That would result in job losses but this can be a just transition with enough time to allow for proper planning, union and worker involvement, and funding. This should be followed with a commitment to add DRI primary steel production by mid-2035 as the technology and green hydrogen are expected to become more financially viable.
Except where specified, figures are sourced from the GCCA, Getting the Numbers Right Project, Emissions Report 2023 - for External Stakeholders industry-reported dataset or gccassociation.org/gnr
Except where specified, figures are sourced from the GCCA, Getting the Numbers Right Project, Emissions Report 2023 - for External Stakeholders industry-reported dataset or gccassociation.org/gnr
Worldwide, the amount of cement being used for every person in the world has nearly tripled in the past 45 years and demand is projected to increase over 33% by 2050. This demand is driving an exponential growth in cement production - and 'clinker', a key binding agent in cement. Clinker is the main ingredient in most cement mixes, averaging 75% of its content, but can be up to 95% of the content in Ordinary Portland Cement mix (a common type of cement). To make clinker, limestone and clay are heated to around 1450c, creating a chemical reaction. To generate this heat, the industry generally burns fossil fuels - although alternatives exist. Burning the fuel emits an average of 35% of the clinker CO2 footprint, with the remainder (65%) emitted by the chemical reaction of the heated limestone. In total, the cement industry has reduced its reliance on fossil fuels to heat clinker by 22% from 98% in 1990 to 76% in 2023, with post-use mixed waste and biomass increasing their share as alternative fuels. This concrete progress has helped reduce the carbon intensity of the fuel mix by 8% between 1990 and 2023. Unfortunately, this reduction has been outstripped by increases in cement production overall since 1990, so total fossil fuel consumption has actually increased by 100 million gigajoules (GJ), from 1.78bn GJ in 1990 to 1.88bn GJ in 2023.
(Except where specified, figures are sourced from the GCCA, Getting the Numbers Right Project, Emissions Report 2023 - for External Stakeholders industry-reported dataset)
Cementing coal use
Today, 76% of the heat needed to make clinker is generated by burning fossil fuels, with coal constituting 49% of the fossil fuel mix - meaning 37% of cement worldwide is made by burning coal. Consequently, the cement industry consumes around 4% of global coal produced, which amounts to approximately 330 million tonnes of coal per year. UK Government research and commercial examples from around the world indicate that the elimination of fossil fuels in cement production is possible. Thermal coal is the most common fuel burned to produce the high heat required.
Successful, at-scale, examples already exist of cement works burning 100% alternative fuels to traditional fossil fuels, including pilot projects using combinations of hydrogen and biomass (UK) and hydrogen and electricity (Sweden). Yet, innovations such as use of hydrogen and kiln electrification are forecast to play only a small role, providing 10% of energy needs by 2050. Worldwide, only 24% of cement in 2023 was produced using alternative fuels, with 76% of cement produced using fossil fuels (37% of cement overall is heated using coal). The continuing reliance on burning fossil fuels to generate heat at cement works contributes to its high CO2 footprint – particularly its upstream footprint due to the resources and methane emissions associated with mining coal. Depending on the alternative fuels used 1-7% reductions in CO2 can be achieved, or up to 12% using LNG. Generally, other sources of airborne pollutants are also reduced when alternative fuels are used, depending on the choice of fuel which could include old tyres, waste oil, biomass, LNG, and post-consumer solid waste. Globally, the cement industry is responsible for up to 7-8% of CO2 emissions (but only 1.5% of UK CO2 emissions) – nearly as much as steel.
Coal-free fuel examples from around the world:
Holcim’s cement works in Saint-Pierre-la-Cour, France, uses a combination of calcined clay to reduce clinker content required in the cement, and biofuels and waste heat recovery systems to heat the remaining clinker required. This combination has displaced 100% of fossil fuels from its calcined clay cement production process to deliver up to 500,000 tonnes a year. This cement works received funding from France’s ‘France Relance’ industrial decarbonisation fund.
Holcim’s cement works in Retznei, Austria, used alternative fuel in 96% of its fuel mix last year – virtually eradicating fossil fuels from its operations – and is working towards 100%.
JK Cement’s cement works in Muddapur, Karnataka, India, has increased its use of alternative fuels to 78%, and is completing the installation of a waste heat recovery system, which it expects to make the cement works 100% fossil fuel-free.
Huaxin, a global cement producer headquartered in Wuhan, China, has reached 40% and 60% alternative fuels (mainly refuse-derived fuels) at its Diwei Chongqing (2,500 tonne/day) and Huangshi cement works, respectively. In developing economies, certain alternative fuels are highly variable in materials and moister content, resulting in heating fluctuations that challenges consistent quality in clinker production. At Huangshi cement works, Huaxin uses AI and other technologies to adjust production processes in real-time response to changing fuel properties, allowing it to create consistent clinker quality.
Globally, the clinker ratio to cement (Portland and blended) has reduced from 85% in 1990 to 75% in 2023. The use of clinker substitutes has correspondingly increased by 12.7 million tonnes between 1990 and 2023, but much of this increase may be accounted for by the overall growth in cement production. Although most ‘green cement’ works around the world substitute up to 40% of clinker, there is at least one commercial example of a cement works substituting up to 100% of the clinker in their cement production. The use of alternative cementious materials reduce, or even eliminate the needs for clinker and is the most effective way for the cement industry to cut its dependence on coal and other fossil fuels. Unlike clinker, these alternative cementious materials don’t require as much, or any, heating – thereby reducing the amount of coal burned. Some of these materials, such as the coal by-products of fly-ash and blast furnace slag, are in increasingly short supply as economies decarbonise. However, other clinker substitutes such as burnt rice husks and calcined clay do not face supply issues. Rather, it is a lack of acceptance by the construction sector that continues to be the most limiting factor in producing more cement with a lower clinker content. The UK Government is attempting to address this demand-gap by requiring publicly-funded construction projects to use ‘low carbon’ cement products where - although we believe ambition needs to be increased to stimulate widespread supply-side adoption of clinker alternatives.
Clinker substitution examples from around the world:
Hoffmann Green cement works in Bournezeau, France, has a capacity to produce 50,000 tonnes of three varieties of cement per year, all with 0% clinker content. This cement works replaces clinker with a mix of slag, clay, gypsum – supplied by local producers. It also removes the need for further extraction, unlike clinker which requires quarrying limestone. This cement works received funding from France’s ‘France Relance’ industrial decarbonisation fund.
US start-up, Sublime Systems has developed a new 0% clinker cement using calcium silicates and other commonly used substitutes in an electrochemical reactor, which requires heating only to 100c. Its pilot cement works only has capacity to produce a few hundred tonnes of cement per year, but it is developing a new cement works with capacity for up to 25,000 tonnes per year by 2026.
CRH’s Jura cement works in Wildegg, Switzerland, uses calcined clay to produce a cement with a clinker factor lower than 65%, with potential for further reductions. One tonne of calcined clay replaces on average 0.75 tonne of clinker, thereby saving more than 0.25 tonne of CO2. The resulting cement contains approximately 20% less CO2 per m3 compared to ordinary Portland cement.
In contrast to worldwide trends, UK cement production has been in decline since a peak in the 1970s, and roughly halving since 1990. Despite this decline, the UK cement industry still burned just under 400,000* tonnes of coal to make 7.3 million tonnes of cement in 2024 – averaging roughly 1 tonne of coal for every 18 tonnes of cement. To put that into context, around 8,000 tonnes of cement is needed for a new hospital, while between 3-5 tonnes are needed to build a four-bedroom family house.
*There is no cement-specific coal consumption statistics available, but the UK Government reported that 395,000 tonnes of coal were used in the minerals industry in 2024, the vast majority of which would be cement. The burning of this coal alone would have emitted nearly a million tonnes of CO2 in 2024. The UK's cement works emitted 4.2 million tonnes of CO2 overall.
At the moment, there are isolated examples of cement works around the world that operate entirely without burning coal or fossil fuels. Yet all large UK cement works continue relying on coal and fossil fuels. The £3.2 million public fund to research pathways to decarbonise UK cement making is welcome, but to get value for money, proven pathways must be implemented at commercial cement works.
Carbon Capture & Storage - risks:
There is also a proposal to create a CCS network (Peak Valley Cluster), funded in part by the new UK National Wealth Fund. The CCS project would aim to reduce CO2 emissions from several cement works in Derbyshire and Staffordshire. But the high-risk CCS technology is an extremely expensive decarbonisation pathway, with high construction and running costs. The UK Government pledged an eye-watering £22 billion from 2025, driving even more households into fuel poverty (currently 11% of UK households struggle in energy poverty). Given the many £billions poured into the technology around the world, it has a disastrous global track-record of cancellations, suspensions soon after operating, and under-performance of up to 50%. Crucially, CCS will also do nothing to remove coal from the cement-making process, failing to reduce any upstream emissions or harms associated with coal mining and resource extraction in the supply chain. Investment in CCS is investment diverted from eliminating our use of fossil fuels, thereby prolonging our reliance on them.
