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
This information seeks to clarify which tips are included in ERI Ltd's proposal to mine and then flatten certain coal tips in Caerphilly. The tips selected appear to be on the basis of which would be most profitable to mine of the 'waste coal' they contain, rather than which most endanger residents. This is not surprising as the proposal is being brought by a for-profit mining company, but it does differ from how the company is presenting itself as an expert in remediation rather than mining.
Tip 90319 that most concerns residents is closest to them - it backs onto the gardens of some residents. It's also a site with concerns surrounding possibly toxic elements contained within the tip. Due to its proximity to residents, it's also seen a higher proportion of intentionally set fires that the fire service has been called out for compared to the other tips sited further away. There are also more tangible signs of the tip's industrial past and ongoing monitoring than the other, more naturalised tips. If the priority was to remediate the coal tips, this tip would be prioritised. Instead, this tip has been excluded from ERI Ltd's proposal to mine coal tips, with the promise to use some of those profits to then flatten the coal tips and remediate the area.
Despite the concerns around toxic elements in tip 90319 and the visible industrial heritage of the site, there are signs of nature slowly returning to the area. It's vital that any measures to remediate this coal tip - or any others - in future take full stock of the nature that has regrown. If there are legitimate safety risks, though, this must be prioritised.
The Welsh Government's Deputy First Minister, in his response to the CCEIC’s Stage 1 Report, admits The Disused Mine and Quarry Tips (Wales) “Bill does not prevent the extraction or burning of coal” but adds “I cannot envisage a scenario in which the extraction and burning of coal will arise as a result of the Bill”. We see a clear and significant potential for the Bill to encourage the extraction of coal from coal tips for profit by the private sector, encouraged by land owners with concerns about ongoing maintenance costs, to be sold for polluting but non-energy uses.
We want to see the Deputy First Minister demonstrate his commitment to ensure the Bill does not have this unintended consequence by including on the face of the Bill an amendment that “That any coal extracted during remediation work cannot sold where there is any possibility of that coal being combusted, on the grounds that this will contribute to the climate change which the Bill acknowledges will increasingly threaten the stability risk of coal tips moving forward”.
Although the Disused Mine and Quarry Tips (Wales) Bill creates no new responsibilities additional to what is contained within the Mines and Quarries (Tips) Act 1969, it does both make potentially costly tip maintenance more enforceable and lowers the threshold to act for better prevention of tip instability.
The typical private land owner or even Council may welcome or encourage a proposal from the private sector to flatten the coal tip at no cost to them, rather than face higher ongoing maintenance costs relating to coal tip stability as a result of the above two features of the Bill. These costs can amount to millions of pounds. Although there has been a keenness to distinguish coal tip remediation from the coal tip safety monitoring and works that this Bill is concerned with, the reality is that this distinction blurs when remedial works can remove stability issues moving forward.
Caerphilly Council spent £1.8m across two coal tips (T10817 and T36144) on routine maintenance and preventative measures over just two years (2021-23). NRW responded to the CCEIC’s consultation, saying the Bill “underestimates the costs of compliance for tip owners”.
The Leader of Caerphilly County Council, in March 2025, wrote in relation to a proposal to mine two Bedwas coal tips by ERI Ltd:
“The risk of the tip is a current and real issue that is managed constantly by the infrastructure team, doing nothing is not an option… The project is designed to use the value within the land to address a risk for which it bears the responsibility to address. In return CCBC receive an asset in the form of a reclaimed tip with reduced maintenance liabilities that will be open to residents of the borough.”
This example is not in isolation either, “Andrew Morgan (WLGA) told the Committee that Rhondda Cynon Taf County Borough Council (CBC) was regularly contacted by private companies with offers to remediate disused tips owned by the council” – p.50, Stage One Report.
The Coal Policy Statement of March 2021 cites that wholly exceptional applications for coal extraction would be considered if they could demonstrate why extraction is needed to “ensure the safe winding-down of mining operations or site remediation.”, amongst other criteria that could also apply to coal tip-remining projects.
The Coal Licencing Ban currently under formulation by the UK Government will also fail to catch such applications as they do not require a licence, only planning permission.
The Hardship Grant Scheme for landowners only exists where those landowners are unable to afford maintenance works, not for those who are technically able to but would struggle to, or understandably prefer to avoid, this new significant financial burden.
To ensure the Bill does not have this unintended consequence, we ask the Cabinet Secretary for Climate Change and Rural Affairs to reconsider including on the face of the Bill an amendment that “That any coal extracted during remediation work cannot sold where there is any possibility of that coal being combusted, on the grounds that this will contribute to the climate change which the Bill acknowledges will increasingly threaten the stability risk of coal tips moving forward”.
This is an amendment supported by the Welsh Local Government Association in its consultation with the CCEIC, civil society (including consultees Coal Action Network and FOE Cymru), and the CCEIC itself in its Stage 1 Report.
Although the UK entirely removed coal from its electricity generation with the closure for Ratcliffe Power Station in October 2024, it continues to rely on coal in a number of industries. The UK must rapidly decarbonise these carbon-intensive industries to meet its climate commitments. Click on the tabs below to find out about each industrial application of coal.
WORLDWIDE
The direct use of coal as a feedstock (not just energy) is particularly significant in China, where coal is used extensively in coal to gasification plants to produce chemicals such as methanol, ammonia, and polyvinyl chloride (PVC). In 2017, China's chemical industry alone used about 180 million tonnes of coal as feedstock, which constituted about 5% of China’s total coal use that year.
China is unique in its heavy reliance on coal for chemical manufacturing, accounting for a large share of global coal-to-chemicals production. For example, 89% of methanol and 76% of ammonia production in China is coal-based, and producing 1 tonne of methanol from coal requires about 2.7–3 tonnes of coal.
India is also expanding its coal gasification capacity, with government plans to gasify 100 million tonnes (MT) of coal annually by 2030
In contrast, other major chemical-producing regions (Europe, North America, Middle East) primarily use natural gas or crude oil as feedstocks rather than coal.
UK
There is negligible or close to zero coal gasification industry in the UK as of 2025: over the past 20 years, gasification projects have focused on waste or biomass, rather than coal.
WORLDWIDE
Global brick production was estimated at 2.18 billion tonnes in 2020, resulting in approximately 500 million tonnes of CO2e (1% of current global GHG emissions). Brick production could rise to 3.35 billion tonnes by 2050. Approximately 375 million tonnes of coal are used globally per year in brick production, mostly as fuel to heat kilns. Research indicates that coal is added to clay bricks at rates of 1–15% by weight of the clay mixture.
Switching from coal to alternative fuels, together with more efficient kilns, will lead to reduced CO2 emissions.
UK
Heating brick-firing ovens in the UK uses a mix of natural gas, electricity, coal and coke, diesel and LPG fuels. The primarily for use of coal in bricks, though is as an additive to colour it. According to coal mining company, Energybuild Ltd, UK brickworks consume approximately 70,000 tonnes per year of additives, which includes coal.
Annual tonnage of anthracite coal used by the UK brickmaking industry is not made public but the proportion used within the UK generally falls within the range of 1–5% of the brick mix by weight, depending on the desired product characteristics. This contributes to the high emissions released from the raw brick materials upon firing.
WORLDWIDE
Activated carbon is typically made from charcoal (wood) and is a common filtration medium in water treatment systems. It can be manufactured from other sources, with anthracite coal being a common source. Alternatives include nutshells. These sources are first processed into activated carbon through high-temperature treatment to create a porous structure suitable for adsorption
The global market for coal-based activated carbon was valued at approximately USD 4.44 billion in 2024, with demand driven by applications in air purification and water treatment.
Alternatives to the traditional sand/activated carbon dual medium to filter water include glass, garnet, magnetite, and other materials.
UK
The exact annual tonnage of anthracite coal used by the UK water filtration industry is not made public but it does use both domestically mined and imported coal.
WORLDWIDE
The cement industry consumes around 4% of global coal production, which amounts to approximately 330 million tonnes per year. Most of this coal is combusted to generate the heat required to fire the kilns to about 1450c to create the chemical reaction that produces cement. Roughly 0.5 tonnes of coal are needed to produce 1 tonne of cement.
Coal in cement production is primarily used as a fuel to heat kilns, but it can also serve as a minor feedstock in the form of fly-ash for introducing carbon into the clinker. Fly ash is used as a substitute for Ordinary Portland Cement (OPC) used in cement production, and can actually increase the concrete durability, reducing the need for replacement. By using waste coal fly ash as a substitute for kiln-based ‘clinker’ in cement production, the cement industry can significantly reduce its carbon footprint. Post-consumer waste can also be used to both reduce the coal used to heat the kilns and to produce the fly-ash input, helping to decouple coal from the cement industry.
UK
Over 95% of UK concrete is produced in the UK. UK cement manufacture has begun switching from traditional fossil fuels such as coal and petcoke to the use of waste, waste biomass and waste part- biomass fuels. These alternative fuels now account for 43 per cent of the fuel used (2020), replacing the equivalent of half a million tonnes of coal every year. This means 1.16 million tonnes of coal would be used if it weren’t for replacement fuels, and 660 thousand tonnes of coal is still used in UK cement manufacture.
UK carbon dioxide emissions from concrete and cement were 7.3 million tonnes in 2018; around 4.4 million tonnes of this was ‘process emissions’ from clinker production, 2.2 million tonnes from fuel combustion and the remainder from electricity use and transport. This puts direct and indirect emissions at 53% lower than 1990. UK concrete and cement accounted for around 1.5% of UK carbon dioxide emissions in 2018. UK Government research indicates that the elimination of fossil fuels should be possible with no negative impact on clinker quality, kiln stability or build-up issues, but plant-specific modelling would be required. If coal used as a fuel and clinker input was switched for alternatives at all cement plants in the UK, the annual CO2 saving would amount to over 2 million tonnes of CO2.
WORLDWIDE
The steel industry produces 9% of the annual CO2 emitted globally, contributing significantly to climate change. This is largely due to the reliance on coking coal in primary steel production. 4 of the 5 biggest global steel producers aim to reach carbon neutral steel production by 2050, using green hydrogen instead of coal.
UK
Scunthorpe Steelworks still relies on coal-based steel production, and is the second biggest single site emitter of CO2 in the UK. Port Talbot steelworks recently closed to convert to using electricity to recycle scrap steel, decoupling it from coal inputs. The other two large steel producers – Liberty Steel and Celsa also recycle scrap steel in ‘electric arc furnaces’.
To keep up with global decarbonisation trends, Scunthorpe steelworks needs to decarbonise as well. If not, customers aiming to reach their own climate goals will likely choose to import lower carbon steel from other European countries like Sweden and Spain who are pursuing low-emissions steelmaking projects.
Read more about coal in steel in our 2021 report.
Graphite is a naturally occuring substance used in everything from pencils to batteries. Anthracite is one of several suitable carbon-heavy materials that can be used to make artificial graphite. If anthracite is used to make artificial graphite, it must be heated to extreme temperatures of 1,000c for ‘baking’ and up to 4,000c for ‘calcination’ to remove impurities making up 8% of the anthracite. This stabilises the artificial graphite end product. The heating would release greenhouse gasses in a similar way to if it were burned for household heating.
This process can be avoided by using natural graphite and scrap graphite. The UK doesn’t manufacture any artificial graphite and UK demand is also relatively low: “UK is a small net importer of natural and synthetic graphite”.
