York Potash Ltd proposed Polyhalite Mine

Summary of comments on the proposed mine head site
Doves Nest Farm is a typical North York Moors farm and the transformation into a mine head site which will be the point of production of up to 12 million tpa of polyhalite will change the present landscape of this 250 acre farm significantly. A huge amount of spoil will be excavated from the site, (500,000 m3) and used to reconstruct 157 acres of farmland. No images of what this transformation will look like, (before and after images) are evident in the application. Also in other respects there is a paucity of information especially on all subsurface development.

Spoil
The spoil will be excavated from two large holes 360ft deep to allow the construction of the sunken head gear. This pre –shaft sinking operation hasbeen recognised as one which may well have attendant hydrogeological problems. Two mine shafts 1700m deep, an inclined conveyor tunnel, an inclined vehicle access tunnel along with other subsurface cavities will generate around 500,000m3 of spoil which will be used to create an artificial landscape. The spoil will contain pyritic mudstones and the Sheridan (Bunter) sandstone which is a highly saline aquifer. The construction of this mine head site is expected to last over two years. During this time it is admitted that it will have a major impact.

Buildings
The buildings which will be constructed on the mine head site have been described as agricultural buildings in appearance giving the impression to many that the site will resemble a farm. Both the size and configuration of the mine’s polyhalite processing buildings will show them to have more in common with an urban industrial estate or industrial warehousing. These are industrial buildings housing heavy industrial activity. Taken as a whole, with the large administration building housing engineering workshops and other functions, the road systems, car park for 80 vehicles, helicopter landing pad, gate house and security fencing it will resemble at best an industrial estate.

Attempts to camouflage or mitigate the impact of the development by reconstructing the landscape with bunds and mounds from the spoil will only serve to emphasise the drastic change from what is presently seen of this 250 acre farm. Tree planting to help to screen the buildings from view will be slow to establish it is estimated to take 10 years beyond the construction period before the mitigating effects might be realised and it is by no means certain effective tree screening can be achieved. It will in our view become known and recognised as a polyhalite mine and as such is an inappropriate industrial development within the National Park.

Alternatives
Boulby Mine which is located only 10 miles away from the proposed mine head site at Doves Nest Farm, is presently the only mine in the world mining polyhalite and supplies the UK with about two thirds of demand for MOP. The mine has recently embarked on a development programme including shaft refurbishment and is looking at future production extending ahead for another 40 years. Therefore the UK need is satisfied for the foreseeable future as well as
an export capability.

We seriously question whether there is a need for two potash mines in the North York Moors National Park. Set against the high level of certainty of continuing production at Boulby Mine is the uncertainty of many aspects of the new proposals by YPL which are illustrated by the numerous changes made
over the last year.

Throughout 2012 the public have been subjected to a perplexing number of changes of direction in the proposed development and in some respects mislead by confident announcements about the main aspects of the proposal only to find that within months these have radically changed. This leads to the view that we are looking at a premature planning application which in many respects lacks detailed information on significant aspects of the proposals including
sub-surface development.

The planning application for the mine head development precedes a Definitive Feasibility Study (DFS) which was announced by Sirius Minerals on the 13th February 2013. This is clearly a case of putting the cart before the horse and it seems that determination of the planning application cannot sensibly be reached without consideration of the Definitive Feasibility Study which it seems is not going to be ready until later in the year.

Concluding Comment
Previous potash mining development proposals in the North York Moors National Park have been considered by the planning authorities as complete proposals including mining and mineral transportation and likewise by subsequent Public Inquiries. This proposal is complicated by having mineral transportation excluded from the mine head development proposal, making it very difficult for the planning authority to determine the development as a whole. We would have thought that it is essential to have complete view of the whole proposal especially when considering the land take up within the National Park. Clearly the two aspects being considered are completely interdependent and the refusal of one of these aspects automatically means refusal of the whole development.

This changes public perception of the development because transportation is seen as separate from the mining activity, when it is integral to it. This is exacerbated by the gaps between what will be three applications submitted at different times. We cannot see how the mine head development can be determined without a full understanding of the transportation system which it seems will not be submitted as an application until later this year and will then take as long as 15 months before being approved or refused.