Coal Mining Risk Assessments (CMRA)

Michael D Joyce Associates LLP

For development sites in a Coal Mining Development High Risk Area,  the Coal Authority will require a CMRA as part of any planning application. The CMRA is in addition to the standard Coal Authority Mining Reports.

We have over 30 years of producing such reports, and which comply with the new guidance. We can advise on the most appropriate and cost-effective way to treatment of mineworkings so as to render the site suitable for the proposed end-use.


Waste Management and Waste Accetance Criteria (WAC)

The main objective of the Landfill Directive is to prevent or reduce as far as possible the negative effects of landfilling waste on the environment and on human health.  It is intended to reduce the disposal of waste materials to landfills and to encourage more sustainable approaches to dealing with wastes.  It bans the landfill of liquids and certain solid wastes, introduces requirements for the treatment of wastes prior to landfill and provides for the classification of landfills as sites for inert, hazardous or non-hazardous waste and prohibits co-disposal. 

It sets out procedures for waste acceptance at landfills and the types of waste for each class of landfill as specified by Waste Acceptance Criteria (WAC).  The WAC are predominantly lists of “limit values” for certain parameters obtained from standard leaching tests of wastes going to landfills.  WAC are set out in the Landfill Directive itself.  Full details can be found in the Environment Agency document “Guidance for waste destined for disposal in landfills” Version 2 June 2006.


The Environment Agency has set out guidance as to the classification of waste arising from construction sites in its document “The Definition of Waste” dated April 2006.  This document outlines how waste is to be handled. 

The following activities are not regarded as a waste management activity requiring licensing.

Construction activities carried out for the purpose of producing a suitably engineered soil e.g. lime stabilisation, vibro-replacement and piling. 

Uncontaminated materials produced on site (including excavated soils and materials from demolition) which can be reused without further treatment.  Examples include site regrading and footing excavations.

These must be done in accordance with the Planning Permission.  Demolition material must be used in accordance with the quality protocols for the production of aggregates from inert waste, subject to appropriate testing and the lack of any harmful constituents.  Uses include pipe bedding, backfill and sub-base. 

Contaminated soils can be moved on-site providing they do not require treatment or containment.  There should be no risk to the environment i.e. non-leachable and in accordance with Planning Permission.  Relevant activities can include site regrading and use of materials below clean cover systems, capping, buildings and hardstanding. 

Where contaminated materials have to be placed in an engineered cell to prevent pollution, then this would be classed as landfilling and require PPC permits.  Any material taken off site is considered to be waste.  However, this is under review.  If material is waste, then there is a duty of care including ensuring material is transported by a registered carrier.  The destination of material leaving the site should be regularly checked and Waste Transfer Notes kept.


In March 2007, the NHBC issued a report entitled “Guidance on Evaluation of Development Proposals on Sites Where Methane and Carbon Dioxide are Present”. 

The document recommends that a Conceptual Site Model is produced at the desk study stage.  This can be used to produce a Preliminary Risk Assessment (PRA), with a view to assessing whether a ground gas investigation is necessary.  The NHBC guidance suggests that the production of a PRA is a preliminary tool only and “cannot remove the need entirely for ground gas monitoring data ..”.  This suggests that gas monitoring is needed in all circumstances.  This would normally comprise the use of gas monitoring wells over a suitable time period in order to establish maximum gas concentrations and flow rates.