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.
Last month we worked with Members of Parliament from various parties on a Westminster Hall debate about coal tip safety and the prohibition of new coal extraction licences.
The debate happened 59 years and one day after the Aberfan tragedy which killed 116 children and 28 adults. Rooted in this context, the debate highlighted the need to prioritise coal tip safety whilst also preventing the extraction of coal from these tips.
Plaid Cymru MP, Ann Davies, led the debate and highlighted that ‘because of increasingly violent storms caused by climate change, we have experienced further coal tip slips’. This is an important point in this debate as the further exacerbation of climate change, via the extraction and use of more coal, would lead to further slips.
She added ‘The UK Government have pledged to ban new coalmining licences, but they have confirmed their belief that re-mining coal from the tips does not require a licence, meaning that such activity falls outside the scope of the proposed ban. Although the Welsh Government believe that their own planning policies will prevent re-mining, a loophole allowing coal extraction in “wholly exceptional circumstances” has raised concern’.
Labour MP, Gerald Jones, discussed mining companies failing to comply with their legal obligations – a danger which could happen again with coal tip extraction. He used the example of the Ffos - Y - Fran opencast mine in his constituency: ‘When it first opened, the company running the mine, Merthyr (South Wales) Ltd, pledged to fully restore the site after it finished operations. I call on it to honour that pledge.’
Liberal Democrat MP, David Chadwick, reflected on the Reform party policy to re-open the pits earlier in the year. A move which, in many cases is not possible, but would be a clear abandonment of our responsibilities to future generations. He said: ‘The people of the south Wales valleys have given more than enough, and we are still waiting for our new south Wales to emerge. We deserve safety, fairness and a future built on renewal, not nostalgia.’
Labour MP, Steve Witherden, made a passionate and precise demand that the Government include coal tips within its coal licence ban: ‘Mining companies offering to remove coal tips in return for commercial access to coal is an easy answer to a difficult question, which we cannot allow, so I ask the Minister this. If the Government truly believe that the Welsh Government’s coal policy and England’s and Scotland’s planning policies are robust enough to prevent coal extraction, why do investors think otherwise? ERI Reclamation is actively seeking to extract 468,000 tonnes of coal from tips in Bedwas, Caerphilly. It clearly believes that the law allows that, and it is putting serious capital behind the belief. If this is approved—it is an “if”—it could set a dangerous precedent, whereby private profits determine which coal tips are removed and others, with less content, are left. It would be a precedent categorising coal tips by their value rather than their potential impact on public safety. Could we see landowners, burdened by maintenance costs, encouraged to sell access to these sites?
We cannot and must not rely on the private sector to make coal tips safe. That duty falls on us. The Government’s coal licensing ban must be strengthened to include coal tip mining.’
Liberal Democrat spokesperson for energy security and net zero, Pippa Heylings MP, eloquently highlighted Coal Action Network’s legal advice which shows how to include coal tips in the coal licence ban: ‘In practice, extracting coal from a tip is no different from open-cast mining. The method is the same, the disruption is the same, the risks are the same and the emissions are the same. The contradiction can be easily resolved. Leading environmental lawyers, working with the Coal Action Network, have proposed an amendment to the Coal Industry Act 1994 to clarify that the mining of coal from coal tips also requires a licence. That small change would ensure that the Government’s coal ban is comprehensive and future-proof.’
Energy Minister, Michael Shanks MP, concluded the debate, summarising that ‘We acknowledge the suggestion to make this type of coal extraction a licensable activity under the MRA, which would allow for a licensing prohibition, but our view is that the current planning policies around the regulations set by devolved Governments already provide robust frameworks.
We are a Government who believe in devolution. We created devolution in Scotland, Wales and Northern Ireland because we believe in devolving power to those authorities, so they are closer to people and to individual circumstances. It is right that we take their lead on these questions. Their firm view is that they can bring into effect the aim of the Welsh Government and the UK Government to make sure that extraction of coal is a thing of the past. Their view is that their existing powers do that.’
While we at Coal Action Network hope that the Minister’s faith in devolved powers to make coal extraction a thing of the past is well founded; we fear that a different Welsh Government could have an opposing aim and would be able to achieve that under current circumstances. The English National Planning Policy Framework (NPPF) was also not considered by the Minister, which allowed the West Cumbria coal mine to gain planning permission and would also allow coal tip extraction throughout England’s coal fields.
We would like to thank each of the Members for taking part in the debate and making the case for banning coal tip extraction.
Coal Action Network will continue to campaign for the inclusion of coal tip extraction in the coal licence ban.
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 that averages around 75% of cement (but can make up to 95% of the content of Ordinary Portland Cement). To make clinker, limestone and clay are heated to around 1450c, creating a chemical reaction that forms ‘clinker’. To generate this heat, the industry generally burns fossil fuels - although alternatives exist. Burning the fuel emits an average of 33% of the clinker CO2 footprint, with the remainder (67%) emitted by the chemical reaction of the heated limestone. Clinker is responsible for 94% of the total CO2 footprint of cement. 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, 49% of the heat needed to make clinker is generated 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% fuel alternatives 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. Globally, the cement industry is responsible for up to 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 78% in 2012 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. 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 do not face supply issues, and a lack of acceptance by the construction sector continues to be the most limiting factor in producing more cement with a lower clinker content. One solution to this would be Government mandating that publicly-funded construction projects must use entirely or partially ‘low carbon’ cement products where clinker substitutes have been included.
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.
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.
After the tragic passing of Hefin David MS, a by- election is being held in the Senedd seat of Caerphilly on October 23rd 2025.
Within the borders of the Caerphilly constituency is the proposed Bedwas coal tips re-mining project. In the lead up to the Senedd by-election, Coal Action Network has carried out a survey of the by-election candidates asking for their views about the re-mining of the Bedwas and other Welsh coal tips.
We asked the same two questions to each candidate:
Of the eight candidates, six responded. Each candidates response is published in full here, in order of when we received their response:
“The coal tips of Bedwas represent not only a legacy of our industrial past but a potential resource for our future, if approached with care, innovation, and community oversight.
“I support the responsible re-mining of these tips, provided it is done safely and transparently. After all, this isn’t about returning to the past, it’s about using what remains to build a stronger, fairer future for Bedwas and wider communities across Caerphilly.
“If carried out correctly, coal tip mining can be a bridge between our heritage and our progress.”
"I am opposed to Private enterprise using this just to make a profit. I do not trust them. Yes I want the colliery waste taken away. I want it taken by rail and not road. No to 50 lorries a day for years. There is a rail link close and could be accessed without driving through the villages."
“I have young children similar in age to those children that lost their lives in the 1966 Abervan disaster. That disaster was brought home to me following the coverage of the Cwmtillery coal tip slip, following storm Bert in December 2024. Not that long ago. Fortunately no one was hurt, but the slurry came very, very close to the houses.
Also, a very good friend of mine lives in the western end of the South Wales Coal field, and he tells me that another problem with abandoned coal tip's are, that they are susceptible to catching fire.
Whilst improved drainage may be a solution, it is not a guarantee and it will not stop a fire. There is also the issue of pollutants from the tip running off into the River Rhymney. The present weather pattern is showing more rain, while the Fire Service is telling us that there are more fires on open common ground to which abandoned coal tips form part of that landscape.
To quarry for coal on Bedwas coal tips will we be making the problem worse by churning up the landscape, tempting fate with the possibility of an accident waiting to happen, heavens forbid. There needs to be guarantees that the area is returned safely and with the tips removed.
The question is do we do nothing, and allow our friends, and families, to remain at risk, and that risk be handed down to our children and grandchildren, or do we do something now and remove the present danger?
It's crucial that any actions proposed during the coal extraction and tip removal works have actions in place to mitigate the negative effects on local communities and surrounding areas, such as the country parks.
While I see the potential for positive outcomes, the most important one being the removal of the unsafe tips, I want to emphasize the importance of ensuring that communities such as Bedwas are not negatively impacted. We must hold those responsible for this project accountable and ensure that all proposed mitigation measures are fully and effectively implemented to protect local residents and the surrounding environment.
I believe it's important to find a balance between addressing the long standing issues of these sites and ensuring that any development works benefit, rather than harm, the local area.
"Bedwas Tips: Safety First, but Concerns Remain. The coal tips above Bedwas are classed as high-risk under Welsh Government assessments, with dangers including landslip, fire and water pollution, risks which made worse by climate change. Maintaining and ensuring safety of the tips currently costs CCBC a significant amount of money – money which could be spent on keeping Libraries open and properly funding our schools.
ERI Ltd has proposed a major remediation project: removing spoil and coal, re-profiling the tips, and restoring the land to grassland and moorland. The scheme could last up to ten years and would be funded by selling extracted coal.
Local people rightly want the tips made safe. But the Liberal Democrats believe three key concerns must be addressed before this scheme proceeds.
Coal extracted from Bedwas must only be used where it would displace coal which would otherwise be imported, it should only be used in UK industries that have no current coal-free alternative.
This cannot be controlled through the planning application, only through the contractual agreement between ERI and CCBC. We have questioned ERI and they have confirmed that their current proposal would not restrict how the coal would be used, and therefore that it could be exported or used in power generation – uses which we cannot support.
Before the scheme goes ahead, and before planning is granted:
The role of Caerphilly Council - The tips are owned by Caerphilly County Borough Council (CCBC). That means the council is central to ensuring safeguards on finance, coal use and environmental restoration.
We note that CCBC recently issued a statement “setting the record straight”, implying there is no existing relationship between the council and ERI. We think it’ highly unusual for a private company to propose such a major scheme on council-owned land without detailed discussions. Residents deserve more transparency about what has — or has not — been agreed.
It is only CCBC who can control how any coal extracted from the tips can be used and ensure that any remediation project is well managed to completion – the statement that they issued gives us no confidence in their willingness or ability to control these matters.
The Lib Dems call on
Our position - We recognise the importance of making the Bedwas tips safe. But this cannot come at the cost of the climate, country park users or local residents. With transparency, strong safeguards and genuine community involvement, the project could deliver safety and restoration. Until such safeguards are in place we cannot and do not support the project.
The Liberal Democrats will keep pressing for a balanced, fair approach that puts people and the environment first.”
"We are in a climate and nature emergency and the response must be swift and serious, so we can pass on a Wales we are proud of to future generations. That means a managed end to the extraction and use of coal. As I understand it, a planning application for the proposed scheme has not yet been submitted to Caerphilly Council.
If a planning application is put forward, I would be open to meeting with Energy Recovery Investments Ltd and with campaigners to hear their points of view.
However, any proposal for the extraction of coal from disused tips falls under Welsh Government's Coal Policy Statement, which dictates that coal licences may be needed in wholly exceptional circumstances, and each application will be decided on its own merits, but the presumption will always be against coal extraction.
I support the Welsh Labour position to issue no new licences to explore new coal fields because they will not take a penny off bills, cannot make us energy secure, and will only accelerate the worsening climate crisis.
The climate and nature crisis is the biggest long-term challenge of our time. But the clean energy transition is our chance to grow the economy, cut bills, and make Britain energy independent again. Like my Labour colleagues, I’m committed to the mission to deliver clean energy by 2030."
“All coal tips must be made safe, but the extraction of coal from them should never happen. Fossil fuels must remain in the past – especially when our planet is in such a perilous state.”
Reform were asked to respond to the same questions as all other candidates, but did not provide any response.
UKIP were asked to respond to the same questions as all other candidates, but did not provide any response.
In 2019, Bryn Bach Coal Ltd applied to expand its Glan Lash opencast coal mine and extend the amount of time it would continue mining coal for. The proposal would see the coal mine swallowing a nearby ancient woodland, hedgerows, and grassland. The proposal was rejected by Carmarthenshire County Council in 2023. But Bryn Bach Coal Ltd applied again for a slightly different expansion that would see a smaller area of habitat destroyed - though it would still destroy the ancient woodland. In 'mitigation', Bryn Bach Coal Ltd highlighted that it had restored a site previously used as a tip for an old coal mine. However, that was restored to supposedly mitigate the habitat lost to the current Glan Lash opencast coal mine. Bryn Bach Coal Ltd claimed it would make this restoration even better, although it claimed the site was already restored to a high standard. We visited the site and found the reality to be very different...
The very concept of habitats being standardised units, where habitat A can be replaced by habitat B in another area, is a fantasy. Each habitat is as unique as the lives of individual animals that exist within it. It is comparable to saying that we will flatten Manchester and all but the most important people who live there, but it's OK because we'll support extra flats and shops to be built in Plymouth for those VIPs to move to. We don't want to stretch the analogy so we hope we've made it clear how absurd 'habitat off-setting' as a concept is. Yet, 'habit off-setting' continues to go unquestioned in Planning consideration. Priority wildlife (generally species that are endangered) relocated to the 'off-set habitat' often struggles to adapt to their new habitat - because habitats are unique - and often fail to find shelter and food, or re-establish territory, leading to death by starvation, predation, and exposure. 'Off-set' habitats are also often a far-cry from the biodiverse and established habitats that they supposedly replace, despite the far-fetched claims of developers about how they are so much bigger and better.
The off-set site for the proposed expansion of Glan Lash opencast coal mine is the former Tir y Dail Colliery Tip site which was restored and sits south-east of the Glan Lash site. This restored area would supposedly 'off-set' the irreversible destruction of the ancient woodland on the edge of the Glan Lash mine, until new woodland planted after mining on the Glan Lash site offered comparable habitat - which would be many years, and would never truly 'catch' up with the continually evolving and growing ecosystem of ancient woodland.
What we found when we visited the so-called restored former Tir y Dail Colliery Tip site was a neglected and littered area very far removed from the ancient woodland it would temporarily stand in for.
Dead saplings not replaced
Tree guards not maintained
Replaced top soil of poor quality
Planted trees dense and immature
Dead mature trees
In November 2024, the UK Government announced its commitment to legislating a ban of new coal mining licences. This was a commitment that Coal Action Network had previously secured in the Government's pre-election manifesto, along with four other major parties.
Despite this, one loophole remains in the legislation which could still allow millions of tonnes of coal to be extracted from coal tips throughout the UK. Since the announcement we have continued to pressure the Government to ensure that this loophole is closed and that all types of coal extraction are banned.
The next step in this work is to provide the Government with the precise wording that could be used to ensure that coal tips do not remain the sole place where coal can be mined at commercial scale. To do this we commissioned advice from leading environmental barristers Estelle Dehon KC and Rowan Clapp.
The advice has been sent to the Secretary of State for Energy Security and Net Zero, Ed Miliband MP; Energy Minister Michael Shanks MP; and the Department for Energy Security and Net Zero.
The advice we received sets out how to change the Coal Industry Act 1994 so the ban of new coal mining licences also clearly covers coal-tip extraction.
Until now, the wording of the Act has been ambiguous. Without being made clearer, tip coal has been entering the energy market and could continue to do so if the legislation does not remove this ambiguity. In turn, this would undermine the ban’s purpose. A small, targeted, amendment to sections 65(1) and 25(2) will align the licencing regime with the ban’s intent.
“winning, working and or otherwise getting coal (whether underground, or in the course of opencast operations, or in the course of obtaining coal deposited as or as part of waste material from coal mining operations)”
Ensuring Coverage in Wales
Incidental Coal Agreements (ICAs) are a mechanism which already exists – to allow coal to be extracted for safety or remediation purposes. This will still be needed to ensure that the removal of coal for these purposes can continue. Fee bands for ICAs top out at 1,000 tonnes, yet many tip-reclamation schemes propose extracting well over 100 times that amount, undermining any claim that coal removal is merely “incidental.”
Without a clear licensing requirement, millions of tonnes of coal could legally flow from tips across the UK, undermining the licence ban’s aim.
Coal Action Network has obtained new legal advice from expert Barristers Estelle Dehon (KC) and Rowan Clapp of Cornerstone Chambers, London. Examining relevant legislation from 1990s, the Barristers argues that mining coal previously discarded in coal tips require a licence from the UK’s Mining Remediation Authority (national regulator). This backs up previous legal advice we’ve received from Barrister Toby Fisher of Matrix Chambers, London.
Currently deep and opencast coal mines require a licence from the national regulator, in addition to planning permission. The national regulator recently refused a licence for the West Cumbria coal mine, preventing the project from starting. But the national regulator and DESNZ both deny that legislation means mining coal tips requires a licence.
Section 25 (1) states “coal-mining operations” shall not “be carried on by any person except under and in accordance with a licence”. In plain speak, this means a ‘coal mining operation’ needs a licence. So how is a coal mining operation defined?
Section 25 (2) defines ‘Coal mining operations’ as the “winning, working and getting” of coal. It’s only relevant if it’s in the UK and if it’s not just to move coal out of the way to do something else, like build foundations for a house.
The legislation includes within ‘Coal mining operations’ things like dumping soil that was removed during coal mining, even if this happens later and outside of the mine. If the act of making a coal tip is included, then mining that coal tip should be included too.
Mining coal tips for previously discarded coal within them is clearly ‘getting’ coal, putting it within the legal definition of Coal mining operations’. For that matter, mining coal tips also fits within case-law definitions of “winning and working”. The Welsh Government’s Minerals technical advice note (MTAN2) also backs this up, defining ‘coal working’ as including the “recovery of coal from tips”.
Section 336 of the 1990 Act defines a ‘mineral working deposit’ to mean "any deposit of material remaining after minerals have been extracted from land or otherwise deriving from the carrying out of operations for the winning and working of minerals in, on or under land" – which easily encompasses coal tips.
Section 55 (4) (a) (i) defines a ‘mining operation’ as the “removal of material […] from a mineral-working deposit.”. As coal tips amount to a mineral-working deposit, it follows that mining coal tips amounts to ‘mining operation’. The 1990 Act requires any mining operation to get planning permission – accordingly, mining coal tips requires planning permission under this definition, which has been accepted since the Act was introduced.
This planning law is aligned with Barristers’ Estelle Dehon’s (KC), Rowan Clapp’s, and Toby Fisher’s interpretation of the The Coal Industry Act 1994, which came 4 years later.
The Mining Remediation Authority (MRA) has stated that it does not consider coal tip extraction to be a ‘coal mining operation’ because it claims that coal tip extraction does not meet any of the requirements listed within the s.65(1) of the 1994 Act definition of a ‘coal mining operation’ or a ‘coal mine’. As a result, the MRA states that it has no power to licence or not licence mining a coal tip. And DESNZ adds that it does not plan to make any changes so that coal tip mining projects would require a licence from the MRA in future (based on the understanding it is not currently required, which is against our Barristers’ understanding).
This boils down to a difference in interpreting some heavyweight law that’s over 30 years old. Some of the argument hinges on whether you read a sentence such as “to be a thing, it must include the following: X, Y, ‘and’ Z” to mean it needs to be all of X,Y,Z to be the thing, or it’s enough for it just to be Y, for example. The only way to settle the argument is a costly court case with our Barristers on one side and UK Government Barristers on the other side – and the UK Government has much deeper pockets than us.
The civil servants within the UK Government are right now busy cooking up new legislation to ban the MRA from issuing any new licences for coal mining – which is great news because all coal mining needs a licence…so that means no new coal mining projects (existing licences can still be used). The problem is that it won’t ban mining coal tips, because of the MRA’s belief that this doesn’t require a licence in the first place. That means, once this new legislation passes, the only place coal can be mined in the UK is coal tips – which will still be fair game, undermining the intention of the coal ban to stop coal mining.
This is a particularly absurd situation as mining previously discarded coal from coal tips or mining new coal from opencast coal mines involves the same processes – moving large volumes of soil around with HGVs, separating spoil from saleable coal, transporting that coal etc. and generating the same local environmental and community impacts such as noise, dust, and disruption. It will also have the same climate change effects when burned. Mining coal tips is an industry that dates back until at least the 1980s. With over 5,000 coal tips around the UK and a live proposal to mine two coal tips in South Wales of over 400,000 tonnes of coal, we begin to understand why it matters whether coal tips are included within the new legislation to ban coal mining.
PLAN A
The easiest option would be for the civil servants beavering away at the new coal ban legislation to simply include an amendment requiring coal tips to need a licence (via clarification or change to existing legislation). This would bring coal tip mining, opencast mining, and deep mining all within the same requirement for a licence – which the new legislation would then ban in one swoop. Find out more about the simple legal wording our Barristers have suggested including to do this.
PLAN B
If Ministers and civil servants refuse to explicitly include coal tips within the new legislation, we are going to have to consider a legal challenge to the UK Government’s belief that mining coal tip doesn’t need a licence. If we win that, then mining coal tips would be banned within the new legislation by default. We hope you’ll support our fundraising efforts if we are forced to do that.
On July 1st, 2025, CAN organised an impactful drop-in session at the Senedd to reinforce the urgent need for action on Wales' coal legacy issues. The event, sponsored by Delyth Jewell MS, saw strong cross-party engagement, with Members of the Senedd (MSs) from Labour, Plaid Cymru, the Conservatives, and the Liberal Democrats in attendance.
Framed as a call to action on two interconnected issues—the future of coal tips and the restoration of the Ffos-y-fran opencast site—the session demonstrated growing momentum for change across the political spectrum.
CAN supported Delyth Jewell’s proposed amendment to the Disused Mine and Quarry Tips (Wales) Bill, which would rule out the sale of coal from disposed land for the purpose of burning. This simple but powerful clause would ensure that coal removed during the management of old coal tips cannot be fed back into fossil fuel supply chains—closing a loophole that could otherwise undermine climate commitments.
We also spoke with MSs to urge the Welsh Government to work constructively with the Department for Energy Security and Net Zero (DESNZ) in Westminster to ensure the UK-wide coal mine ban currently under development includes coal extraction from coal tips. As it stands, tip-extracted coal is not covered—a glaring omission that risks opening the door to a new phase of coal exploitation under the guise of legacy management.
Merthyr (South Wales) Ltd, which operated the Ffos-y-fran coal mine, is seeking to drastically reduce its contracted restoration obligations by up to £110 million. This is despite public filings showing £91.2 million already allocated for the site's restoration by the mining company. MSs attending our drop in session spoke with local residents we invited, viewed our gallery images of the coal mine site, and explored it for themselves via our 360 drone photos.
This raises serious concerns about transparency and risk—particularly given the site's proximity to local communities and the significant safety and environmental hazards involved. See our brief to find out what actions MSs can take today to deliver justice for Merthyr Tydfil.
Attendance at the drop in session by every Senedd party shows there is political appetite for action. Members across party lines recognised the urgency and legitimacy of the issues we raised. This is not about party politics—it’s about public safety, environmental justice, and the integrity of our climate commitments.
We thank every MS who took time to attend, engage with our materials, and listen to affected communities. We will continue to campaign so that Wales does not repeat the mistakes of its past but instead leads the way in managing its coal legacy responsibly.
We’re actively setting the record straight when fake news about coal is spread through public figures, social media, or the press. The rise of populist politics and politicians tend to drive statements that are don’t entirely match the evidence, but may win them some votes. Sometimes this is due to poor research, at other times it can be more calculated. Either way, the danger of this is that if those politicians are eventually elected, they will then need to pass policies based on the fake news if they want to keep those voters. This can lead to unnecessary, and sometimes damaging, policies that harms those very voters.
In a Climate Change, Environment, and Infrastructure Committee meeting for the Welsh Senedd (parliament) on 04/06/2025, some falsehoods were voiced around coal which we’re keen to debunk:
“I just believe that anybody living within a community with a coal tip, as long as they knew that there was no further mining taking place, I cannot see how there would be an issue with the removal...”
Coal is never just lying in a neat heap on top of a coal tip – it’s mixed in with soil and rocks, and will always require mining to extract and filter it for the market. The only live proposal to extract coal from a coal tip is being strongly challenged by a determined group of people living locally to those coal tips, called the Friends of Sirhowy Valley Country Park. They oppose the local dust, noise, and disruption that would be caused by the coal extraction.
“We're very lucky in the fact that some of the coal mined—but we're not talking about mining, we're just talking about finding it in terms of remediation—burns at a higher temperature and so burns very cleanly.”
Anthracite is a high-carbon content coal which, when burned, emits a high amount of CO2 but is low in other pollutants. It is an expensive and relatively scarce grade of coal – as such, it’s not what would be widely discarded within coal tips. However, coal mined from the most recently closed opencast coal mine, Ffos-y-fran, was thermal coal – which had to stop being burned to generate electricity because the European Court of Justice ruled the toxic nitrogen oxides it emitted were too high. Cleaner imported coal had to be used at Aberthaw power station instead. Even after Merthyr Ltd invested £10 million in machinery so its coal could be burned at the Port Talbot Steelworks, doing so frequently made the steelworks exceed air pollution limits.
“I politely ask the Member from where she wants the 3.4 million tonnes of coal required in the UK annually to come from...if her answer is 'abroad', to explain how such a position is in the best interests of climate change, our carbon footprint, and Wales.”
Although this is phrased as a question, it implies that it would be better for the climate if the UK extracted as much of the 3.4 million tonnes of coal as possible here rather than importing it. Firstly, the UK also exported 731 thousand tonnes of coal in the same year, reducing the actual amount required in the UK. Secondly, this demand will now be much lower with the closure of the UK’s last coal power station in October 2024, and the decarbonisation of Port Talbot steelworks which started mid-2024. Regarding remaining demand, a recent High Court decision confirmed that extracting coal within the UK (through any means) would not significantly reduce coal mined abroad – so it would increase the global supply and use of coal. Flooding the UK market with more coal also discourages industry from investing in using alternative processes that cuts coal out, keeping up demand for the number one fossil fuel driving climate chaos today.
This is what the 58,000 residents of Merthyr Tydfil face every day...and with a new plan by mining company, Merthyr (South Wales) Ltd, to evade its responsibility to restore the site, this risks becoming a permanent reality. This would set a dangerous precedent for other quarries and large infrastructure projects too, with other companies also flaunting planning control and conditions with impunity. The Welsh Government must bring this disreputable mining company to heel and deliver the restored, safe, and green landscape promised to Merthyr Tydfil and Commoners for over 16 years.
If you're a Senedd Member, see our brief for what you can do today.
Find out more about Ffos-y-fran opencast coal mine and join the campaign to get it restored.
Published: 02. 07. 2025
