Resolving the impacts of mining

Mining Risk Policy
Advice on “Na-ijlende
gevolgen
steenkolenwinning
Zuid-Limburg”

Mining Risk Policy Advice
Associated with the Former Hard Coal
Exploitation in South-Limburg,
Netherlands

December 2016

Mining Risk Policy Advice on “Na-ijlende gevolgen steenkolenwinning Zuid-Limburg”

Disclaimer
This report has been prepared by the Coal Authority for the Ministry of Economic
Affairs of the Government of the Netherlands.
Any conclusions or recommendations made are those based on information obtained
for the report and our current knowledge and practices. Data used within the report,
either obtained by the Coal Authority or 3rd Party, has been cited within the report.
Limitations of the data are identified within the report. The Coal Authority does not
accept liability for the accuracy of any 3rd party data. Should new data or information
become available these results, conclusions and recommendations may require
amending.
This report should only be used in the stated context.

Version

Status

Originated

Checked

Reviewed

Approved

Date

1.3

Final

Carl Banton

Bo Iwanskyj

Jo Wilson

Richard
Hughes

Dec 2016

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Mining Risk Policy Advice on “Na-ijlende gevolgen steenkolenwinning Zuid-Limburg”

Contents
1.

Introduction ................................................................................................................. 4

2.

Bow-Tie-Analysis and Integrated Risk Model ........................................................... 5

3.

Strategies for Proactive and Reactive Risk Mitigation ............................................. 7

4.

Understanding Liability and Responsibilities ........................................................... 8

5.

Mining Information and Data .................................................................................. 10

6.

Communication and Awareness Raising ................................................................ 12

7.

Planning, Development Control and Intrusive Site Works ................................... 15

8.

Mine Shafts and Near Surface Mining .................................................................... 16

9.

Mine Water ................................................................................................................ 17

10.

Conclusions and Recommendations ....................................................................... 19

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Mining Risk Policy Advice on “Na-ijlende gevolgen steenkolenwinning Zuid-Limburg”

1. Introduction
The Coal Authority has been requested to provide mining risk policy advice to the
Ministry of Economic Affairs of the Government of the Netherlands. It forms Phase 2
of a two-phase work programme. Phase 1 comprised a peer review of the GS-ZL
working group research study into specific mining risks undertaken for the State
Supervision of Mines (SodM).
In preparing this report on mining risk policy advice consideration has been given to
the following:• The outputs from the GS-ZL working groups identifying and mapping all the
mining risks in South-Limburg;
• The controls proposed by the GS-ZL working groups and alternatives developed
in the Coal Authority peer review;
• The Bow-Tie-Analysis and Integrated Risk Model developed in the GS-ZL
Summary Report;
• Discussion on liability and responsibilities;
• Management and communication on the risks that exist;
• Management and communication on things that could change or have an
impact on the risks.
Reference to experience in the UK has been included to illustrate the approach
adopted by the Coal Authority in managing the on-going risks from past coal mining.
The findings and initial thoughts on mining risk policy advice were presented to
representatives of the Provincial and Local Authorities of South-Limburg in Maastricht
on 3rd and 4th November 2016. The report takes account of and has subsequently
been further developed following these presentations and discussion with the
Ministry of Economic Affairs.

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2. Bow-Tie-Analysis and Integrated Risk Model
GS-ZL has utilised Bow-Tie-Analysis which provides a systematic mechanism to
appraise risk and compare relative probability of occurrence. Generally the risks
identified within the GS-ZL Bow-Tie-Analysis are valid. The Coal Authority has
referenced additional risks that should be considered for inclusion in the analysis.
To quantify and prioritise the risks and control measures within the Bow-Tie-Analysis
an integrated model has been developed and presented in the GS-ZL Summary
Report. This model contains an element of expert judgement which provides an
effective way to consider and prioritise controls.
The model calculates risk factor by using the probability of the occurrence against the
significance of consequence.
Probability is derived by using expert judgement and allocating a figure of:20 % Small
40 % Medium
60 % More likely than not
80 % Likely (assumed description but not stated within the report)
100 % Will occur (assumed description but not stated within the report)
Significance of consequence is estimated using expert judgement and a score of:1
small effect, no damage or injuries expected
5
medium effect, repairable damage or injuries expected
10
large effect, major damage or fatal injury
The integrated model then considers the usefulness of the control based on the risk
factor against effect prevention and control.
The model also considers the cost estimation of the different prevention controls
which then allows them to be grouped depending on cost from low to high
The usefulness and costs groups have been included into a final matrix that GS-ZL has
developed into categories (shown in italics below) for implementation.
•

Category 0 - no regret, these include important measures for further handling of the
potential impacts from rising mine water with low costs and also includes measures
that serve the awareness raising and early regard to potential impacts in future
planning, building and groundwater extraction. Some of these are administrative
tasks and may also include the need for specific regulations to consider the impact
of mining legacy.

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Mining Risk Policy Advice on “Na-ijlende gevolgen steenkolenwinning Zuid-Limburg”

The Coal Authority agree, however would comment that although low cost, the
manner in which these are implemented is important as it has the potential to
generate concerns or objections from the public, questions and interest from
the media, and perceptions of blight. These could lead to social and political
pressure to provide solutions that may outweigh the original issues.
•

Category 1 - strongly recommended, these include basic needs for monitoring and
remediation measures to handle severe potential risks. This comprises the
monitoring of mine water and groundwater and remediation at 6 industrial shafts.
The Coal Authority agree.

•

Category 2 - recommended, these include additional needs for a complete survey of
the lagging effects and include the remediation measures at historic shafts and
monitoring of ground movement and involve high investment costs.
The Coal Authority consider that further review of the costs and reasoning is
required against other risks and the potential impacts.

•

Category 3 - good to have, these need to be reconsidered on the basis of the results
from the monitoring category zero and category one and will provide a better
understanding of the lagging effects in the long term.
The Coal Authority agree.

•

Category 4 - not advisable at the time being, these are measures that might be
necessary in the future if water quality or ground movement issues become obvious
on the basis of further investigation and monitoring and may include regulation
changes relating to groundwater extraction.
The Coal Authority agree.

•

Category 5 - inadequate at the time being, these include measures that are too
expensive to provide an adequate contribution to the prevention of the top event or
severe risks.
The Coal Authority agree.

The Coal Authority in general agree with the catalogue of measures and monitoring
plan developed from the integrated model. More detailed comments and
recommendations are included within the SodM Peer Review Report.
The Coal Authority has developed and utilises a risk matrix (Appendix 1) that removes
some of the subjectiveness around expert judgement. This ensures a more consistent
approach is implemented by all staff when assessing or reporting on risk. This risk

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Mining Risk Policy Advice on “Na-ijlende gevolgen steenkolenwinning Zuid-Limburg”

matrix is also useful for considering what the impact of controls may have that the
integrated model does not take into account. By way of example, the manner in which
awareness raising and communication is managed needs to be assessed in terms of
reputational and financial risk irrespective of the mining position. This type of analysis
will be essential when formulating the implementation plan and communication
strategy.
Additional information is provided in the matrix that helps define the risk appetite of
the Coal Authority and is easy to review and amend in light of the experience that will
be gained in managing the lagging effects and policy changes that may arise.

3. Strategies for Proactive and Reactive Risk Mitigation
The GS-ZL Reports and Peer Review Report have identified a comprehensive list of the
risks and control measures that should be applied to the lagging effects of coal mining
in the Netherlands. The method of implementation, responsibility and funding of
these measures and the management of the on-going lagging effects now requires
further consideration.
In broad terms the measures and management of the on-going lagging effects can be
split into two areas:•
•

Managing and communication on the risks that exist;
Managing and communication on things that could change or have an impact
on the risks.

Figure 1 below shows the elements needed to manage these two areas together with
the central decision making and policies required to implement them. To a degree, all
of the elements are interlinked and will have an influence on forward planning and
decision making. This is reviewed in more detail with recommendations in the
following sections.

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Mining information and data

Understanding liability and
responsibilities

Raising awareness,
communication and public
relations

Government policy

Local Authority or other
sensitive property risks and
inspection

Development management
Intrusive site work

Risk Appetite
Role of different bodies and
future funding • Ministry of Economic
Affairs
• SodM
• Local Authorities
• Regional Authority
• Mining companies
• Others
Planned approach

Installation of monitoring /
Interpretation of monitoring

Managing the risks that exist
• Mine shaft remediation
and inspections
• Reported damage
• Emergency plans

Figure 1 – overview of the measures and management for the on-going lagging effects of coal mining.
These boxes are further reviewed in the following sections

4. Understanding Liability and Responsibilities
The Coal Authority recommend that the Ministry of Economic Affairs establishes a
clear legal position along with defined procedures for managing the future potential
claims and liabilities that may arise from releasing mining information.
This would include a clearly defined claims management process, identifying experts
that are able to assess and investigate building defects and differentiate between
damage associated with past mining and other potential causes. This may also need
to consider limitations of liability where old mining damage may be present that
should be excluded from any new claim.
It is understood that under the current legislative framework, liability for damage
attributed to mining rests with the former mining companies who held the
concessions. If liability is to be managed in a different way this needs to be
implemented such that it protects against retrospective claims being submitted for
old damage or liability being transferred for defective repairs.
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Further discussion is required with the Ministry and other stakeholders to develop
processes for managing future liability, and may include:•
•
•
•
•
•
•
•

Current legislation and statute of limitation;
What function did Government have in granting and managing concessions and
the public perception?
The responsibility and function of the different bodies shown in Figure 1;
Landowner liabilities;
Due regard to the safety of the public;
Monitoring of public areas;
The value placed on drinking water aquifers and compliance with Water
Framework Directive;
If the Government were to accept some liability what would be included:
o only new damage?
o no liability for new developments?
o the approach to funding?

Given the relatively small coalfield in South-Limburg, it appears appropriate that the
resource to oversee the implementation of the policies related to the mining risk is
located in the region where expertise can be developed to properly evaluate and
approve proposals. This also lends itself to effective knowledge transfer and
succession planning to ensure consistency of approach and establishment of a
specialist skill base rather than reliance on Consultants who are more likely to have a
transitory workforce, lack detailed local knowledge of mining and development issues
and fail to provide long-term continuity and strategic oversight.

Risk Appetite and Management
The risk appetite associated with managing the lagging effects of mining in the
Netherlands needs to be developed and agreed. Within the UK this has been shaped
by legislation, policy, historical practices and the scale of the coal mining legacy. In
managing the risks it has always been acknowledged that the impact of injury from
past mining can be high and potentially fatal but the likelihood of this happening is
very low.
Prior to undertaking awareness raising within the UK the Coal Authority considered
statistical analysis on the likelihood of injury due to past coal mining. Even with the
large extent of coal mining within the UK, due to the very low likelihood of injury
occurring it was difficult to drawn any meaningful conclusion other than to provide
some headline statements that were useful in discussions with various stakeholders
and the public.

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In the UK, if a coal mining related hazard is suspected or has occurred, the Coal
Authority has a structure in place to immediately respond, secure the area, investigate
and if found to be coal mining related to repair the damage. This position arose out
of the fact that all coal and mines of coal were nationalised and hence ownership
rests with the government. Funding is provided to the Coal Authority by central
Government. For non-coal mining related hazards, the liability typically rests with the
mineral owner or where this cannot be identified, the landowner or in some cases the
local authority. By way of contrast, the control measures and standards adopted by
the Coal Authority in managing mining related risks are typically more robust than
those adopted by landowners.
In the UK, emphasis is placed on assessing the root cause of the failure through a
combination of desk top study, monitoring and site investigation to identify the cause.
This then facilitates the design of appropriate remedial measures to prevent
recurrence or the rejection of the claim if the damage is determined to be non-mining
related. For any claim made under coal mining subsidence legislation the requirement
is for the Coal Authority to prove that damage is not attributable to coal mining.
Damage which may at first be thought to be associated with mining subsidence or
settlement of fill in a shaft may actually be caused by numerous other factors.
Typically the Coal Authority annually receives over 1,100 notifications of hazards or
claims for damage in coalfield areas. After investigation, liability for damage
attributable to the ongoing effects of past coal mining is only around 40% of these.
The Coal Authority has also trialled the use of statistics and analytical modelling in an
attempt to predict the probability and potential location of public safety hazards
relating to coal mining. In spite of the large data set within the UK the results were
inconclusive when considered against the numerous external factors that could
influence any occurrence of a hazard. The Coal Authority’s preference has been to use
high level mining risk mapping to raise awareness in the public domain and the
planning and development regime to proactively manage development with a view to
minimising the likelihood of new public safety risks being created.

5. Mining Information and Data
The research and compilation of the GS-ZL working group reports and plans has
produced a comprehensive database and GIS of the available mining information.
The GS-ZL Summary Report recommends that results from the monitoring data
should be summarised in yearly reports with an updated risk assessment and
proposal for further monitoring. The Coal Authority agrees with this.

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The mining database should be held in a central location to facilitate assessment and
further development of risk management policy. It should be updated on a regular
basis when new information becomes available. The data from the proposed
monitoring should be incorporated along with the interpretation of the data into an
understandable format. The database should also include records of damage,
monitoring, investigation and treatment works.
The mining database, updating of information, interpretation and release into the
public domain should come under the responsibility of a single organisation. Ideally
this organisation would also provide expert advice on the mining legacy to
consultants, drillers, developers, local authorities and the general public. Dependent
on the level of advice and information to be provided part of this could be subject to a
fee paying service designed to recover operational costs.
To manage the identified mining risks that exist the mining database and GIS should
be considered against any sensitive properties, structures or locations that may
require special consideration, risk assessment or particular awareness raising to
manage the risk. Within the UK the Coal Authority undertook this exercise for schools
and other public property to support discussions on managing the mining risks with
local authorities.
The mining data will need to be presented in varying formats to different groups of
people. For the general public and identification of mining risk areas for planning and
development purposes high level plans within a web based GIS package are
appropriate. General information on mining risks within public facing documents or
electronic web pages needs to be written in non-technical language that can be
readily understood.
At the other end of the scale for structural design and assessment of development in
mining risk areas examination of the original base information and plans will be
required to allow for full appraisal and mitigation of the risks.
To ensure the quality of future mining data common standards of data capture and
reporting should be fully considered and implemented.
There will be an ongoing need for mining knowledge and expertise. As this is currently
limited it is important to ensure knowledge transfer and succession planning takes
place.
It is recommended that a single organisation takes control of the mining information
and collaborates with the Provincial and Local Authorities in South-Limburg to help
develop the requirements for awareness raising and the planning and development
procedures.

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6. Communication and Awareness Raising
The GS-ZL Summary Report identifies the need for communication and awareness
raising around the information on mining legacy and the Coal Authority fully agrees
with this. This is particularly relevant where there is the potential for others to change
the current position or ‘status quo’ that may then have an impact on or be impacted
by the mining risks.
The main reason for undertaking awareness raising is to increase safe behaviour by
informing and educating professional bodies, the public and other stakeholders. This
also has the benefit that mining information is in the public domain facilitating open
and honest views on the risks and their management.
Provision of the coal mining information into the public domain needs to be managed
carefully, and needs to recognise the potential impacts of doing so. Communicating
on the risks that exist and on things that could change these risks needs to be
considered in conjunction with the need to have procedures in place to manage both
the potential claims for damage and how future development can be safely
implemented in the mining risk areas.
When the Coal Authority undertook a similar exercise on a larger scale this was done
in a very controlled way with a step-by-step approach that incorporated mine shaft
inspections, the release of high level risk plans on the Internet and a development
control process with specific procedures. Early engagement with public bodies and
elected representatives was an important aspect of the communication strategy.
It is not considered feasible to undertake awareness raising, making mining
information available into the planning or development control regimes, without also
raising awareness to the general public. This was particularly relevant in the UK when
preparing for the general disclosure of mining information against the need to
complete the residential mine shaft inspection programme which required face to
face assurance to members of the public who had a mine shaft on their property.
In the Coal Authority’s experience the manner in which this information is received by
the general public is dependent on several factors including the facility to offer expert
advice and a clear message relating to liability for mining related damage. The fact
that the Coal Authority would investigate (and remediate if coal mining related) future
problems did help soften this message, particularly where residential properties were
impacted by mine shafts. This was further influenced by the Coal Authority being a
trusted government body with a proven track record.
There are several ways of communicating the risk around mining into the public
domain. These will need to be developed taking into consideration timescales, social

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and political factors, how information may be received and the ability to implement
some of the other identified control measures that would alleviate concerns raised.
Awareness raising for the planning and development control regime is covered within
Section 7. The following paragraphs relate more to communicating on risk with the
general public.
Before undertaking any awareness raising the following points need to be considered
and addressed:• Full consideration of the risks and how these are going to be managed;
• Legal position, statutory duties and any responsibility for having due regard for
the safety of the public;
• Responsibility on property owners (for the public) and any risk assessment;
• Clear approach and procedures to managing any liabilities;
• Mine shaft remediation, inspections and near surface mining risks;
• Position on perceived or actual ‘blight’.
How the public view or perceive risk is often as important as understanding the risk
itself. They can have a very different perspective to experts and this can be based on
different assumptions. For example in the UK, the potential impact on property value
outweighed the safety aspects in the eyes of some property owners. This is important
when considering proportionality and the level of protection required.
Communication should also be proportional and targeted to the risk. A low risk may
be viewed differently by the public if the communication is not correctly managed or
for example wrongly portrayed by the media. It is important to adopt a consistent
message that provides adequate assurance and manages risk in a proportionate
manner.
When communicating on the risks the public will make a judgement about the source
of information, how it is delivered and if they trust those giving the information.
For these reasons it is necessary to have a communications strategy to:• Manage the risk;
• Map out the way ahead with a clear idea of the goal to be achieved and how to
get there;
• Anticipate future problems so that they can be dealt with or to be prepared for
them;
• Identify who to communicate with and when;
• Define what you want to say (your key messages);
• Decide how to reach your audience and what communications channels to use;
• Identify resources required;
• Provide a framework to monitor progress, review and evaluate;
• Deal with emergency and crisis through a well-defined escalation protocol.

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The hierarchy of what is trying to be achieved by the awareness raising and
communication is:1. Awareness – to make people aware that they live in an old mining area and
what that means, some may not be aware;
2. Informed – people are aware of the risks involved, the context and how it may
affect them;
3. Prepared - people know what signs to look out for and what to do if there is a
problem including who to call and what to expect;
4. Comfortable – the public understand sufficient to be relaxed and able to accept
the risks;
If the Ministry of Economic Affairs decides to adopt an approach similar to the UK in
South-Limburg with regard to mine shafts inspections and reactive management then
the Coal Authority experience in particular when talking directly to the public should
be incorporated into the communications strategy. This included:•
•
•
•
•
•

An initial cautious approach;
Being honest, open and empathetic;
Giving clear and consistent message;
Don’t provide information overload – provide simple accurate account of issues
and what is being done;
Ensuring all relevant staff know what to say, how to say it and when to escalate
(if needed);
Using the ‘right’ staff for frontline work who are genuine, can interact with the
public, answer questions and provide assurance.

Some of the mining issues identified in the GS-ZL reports require additional
monitoring to fully understand the risk and their implications. Where possible this
monitoring should be implemented before commencing the wider information
dissemination programme to provide assurance that it is being put in place. The
results of the monitoring, implications and trigger levels can then be communicated to
demonstrate that long term management of mining legacy issues are being
addressed.
The GS-ZL reports conclude that the probability of a major collapse or injury is not
high. The Coal Authority would recommend that awareness raising on the mining risks
and locations is undertaken with the Emergency Services such that they are fully
aware of the specific issues that they could face. The procedure for managing an
emergency situation related to the mining should also be developed and
disseminated to local authorities. This should include clearly defined escalation
procedures (including flow diagrams), detailing roles, responsibilities and
accountability for decisions relating to mining incidents.

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It is recommended that a communications strategy is developed as soon as possible
along with preparing responses to any immediate questions that may be asked.

7. Planning, Development Control and Intrusive Site Works
As development or site investigations can change the current position with regard to
the mining risks and potentially cause instability it should be a mandatory
requirement in mining risk areas that the risks are assessed before undertaking any
site works. Policy and procedure on the management regime to implement planning
and development control is therefore required. Mining issues should not preclude
development or intrusive site works (drilling, trial pits or piling) within the identified
risk areas however the developer or operator should take cognisance of the mining
risk and mitigate this within their proposals.
The mining risk areas presented within the GS-ZL reports should be rationalised and
then incorporated into a suitable web based GIS system to allow developers and local
authorities to recognise if development or intrusive site works could be influenced by
mining risk. This information should also be incorporated into the local authority
future strategic ‘development plans’.
Local authorities need to be able to identify if suitable mitigation is fully considered in
the development designs. This needs to be incorporated into the planning and
development control processes within the mining areas and will require specialist
expert knowledge of development / building design with regard to mining risks.
The planning regime in the UK has adopted policy instigated by the Coal Authority (the
Statutory Consultee for coal mining) whereby any developer embarking on
development on the shallow coalfield or in close proximity to a mine entry must
undertake a coal mining risk assessment and take appropriate care to ensure that the
proposed development addresses the mining risks in a proportionate manner. To
assist this, the following guidance is freely available on the internet “Risk Based
Approach to Development Management – Resources for Developers”. (Appendix 2)
The Coal Authority has produced policy advice and guidance when developing or
undertaking intrusive site works in former coal mining areas. We recommend that
similar policy advice is developed and implemented in the Netherlands, which should
include:




Gas monitoring;
Intrusive site works in mining areas;
Construction over unstable ground and in the vicinity of mineshafts;
Water monitoring;

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• Water quality monitoring;
• Assessing building damage in mining areas.
A cautious approach should be taken in all cases of ground investigation related to
mining high risk areas, mining subsidence damage or shaft investigation due to the
risks presented by potentially unstable ground and mine gas.
It is recommended that a planning and development procedure is developed to cater
for:•

Mining information to be made readily available to developers and others
engaged in evaluating, designing and implementing mitigation measures to
address mining risks;

•
•
•

A mandatory requirement for risks associated with past mining operations to
be assessed prior to development taking place;
Proportionate measures are implemented to address mining risks;
Guidance to assist developers and those undertaking intrusive site works
should be developed.

8. Mine Shafts and Near Surface Mining
With regard to mine shafts a proportionate approach should be taken to effectively
manage risk but not necessarily require the risk to be eliminated. The Coal Authority
agree with the GS-ZL view that development within shaft-protection-zones should be
carefully controlled.
In the UK, Coal Authority statistics show that the number of surface hazards
associated with shallow mining is similar in frequency to those associated with mine
shafts. If this similar probability of occurrence is applied to South-Limburg, the risk is
one of severity versus the costs of prevention. It could be argued that the risk posed
by the historical shafts is no different than that posed by shallow mine workings.
However there is often a greater perceived risk around mine shafts and their threat
compared to that of near surface mining.
The risk appetite associated with managing mine shafts in the Netherlands needs to
be developed and agreed. The UK generally adopts the position that a shaft treatment
is effective unless there is information to suggest potential instability or some signs of
failure of the shaft or treatment that requires reactive measures to be taken.
The GS-ZL reports have identified industrial shafts that may have a low factor of safety
and the Coal Authority agree that these require further investigation or monitoring.
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In the case of the historical shafts in Kerkrade the Coal Authority agree that the target
should be to avoid creation of new risks however we believe there is insufficient
justification at the present time to establish a target to eliminate the risks of shafts
subsiding or collapsing.
The Coal Authority recommend that an inspection programme is established to
monitor the location of shafts and to disseminate information to those that may be
affected, particularly for residential dwellings. This accords with the approach
adopted in the UK. Due to the low number of mine shafts the frequency between
inspections could be short with the ability to note indicative signs of change or
movement
Before undertaking the mine shaft inspection programme the communication
strategy with reference to mine shafts around residential dwellings will need to be
developed and should include:•
•
•
•
•
•
•

Free inspection service;
Provision of generic information;
Reassurance and empathetic approach;
Use of plain language;
Notification of who the responsible body is to undertake and fund any repairs;
No proactive investigation or remedial action (dependent on risk appetite);
No funding or compensation for perceived diminution in property value
(dependent on risk appetite).

9. Mine Water
The installations of mine water and ground water monitoring points (piezometers) has
been identified within the GS-ZL Reports and they are essential for the ongoing
assessment of the risks to aquifer pollution, potentially wetting and surface outbreak
of mine water.
The installation of piezometers can be technically difficult and expensive particularly
when drilling into deep mine workings. The future programme of monitoring work
should be carefully prioritised and managed to ensure the piezometers are correctly
designed, installed and monitored.
Data from the piezometers needs to be reviewed by technical specialists who can
interpret the data to further calibrate the mine water and ground water models and
predictions. Based on the monitoring and predictions trigger levels, actions points

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should be developed to allow sufficient time to develop and implement any proposed
mitigation measures as these may require extended timescales to implement.
Ground and surface water bodies are subject to Water Framework Directive
requirements and will need to be considered at Government level if there is the
possibility of deterioration. If aquifers are to be threatened there will be a need to
undertake a form of benefits valuation to assess the benefits of retaining good water
quality compared with the potential cost of resuming pumping of mine water at an
appropriate time to prevent pollution occurring.
There should be early discussions with the water authorities and abstractors in the
South-Limburg area to fully understand the value of the ground water bodies and
potential threats to supply. At this stage it is unwise to discount any options in favour
of allowing the aquifer to become polluted, at least locally near (known or unknown)
hydraulic windows. This is because allowing the pollution is effectively irreversible.
The cost and complexity of multiple relocations to aquifer abstractions may be very
large, and possibly excessive. The cost burden may even be unacceptable to private
industry.
It is recommended that the benefits of selected approaches to managing the risks
from rising mine water be evaluated once further information is gained.

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10. Conclusions and Recommendations
The mining database, updating of information, interpretation and release into the
public domain should come under the responsibility of a single organisation. Ideally
this organisation would also provide expert advice on the mining legacy, part of this
could be a fee paying service.
Provision of the mining information into the public domain needs to be carefully
managed with recognition of the potential impacts.
In conjunction with this there needs to be procedures in place to manage both the
potential claims for damage to existing property and how future development can be
safely implemented.
Liability for damage associated with the lagging effects of mining has to be clearly
defined.
Given the relatively small coalfield in South-Limburg, it appears appropriate that the
resource to oversee the implementation of the policies related to the mining risk is
located in the region.
There will be an ongoing need for mining knowledge and expertise.

It is recommended that:•

A single organisation takes control of the mining information and collaborates
with the Provincial and Local Authorities in South-Limburg to help develop the
requirements for awareness raising and the planning and development
procedure.

•

A communications strategy is developed as soon as possible.

•

A planning and development procedure is developed to cater for:
o Mining information to be made readily available to developers and
others engaged in evaluating, designing and implementing mitigation
measures to address mining risks;
o A mandatory requirement for risks associated with past mining
operations to be assessed prior to development taking place;
o Proportionate measures are implemented to address mining risks;
o Guidance to assist developers and those undertaking intrusive site works
should be developed.

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Mining Risk Policy Advice on “Na-ijlende gevolgen steenkolenwinning Zuid-Limburg”

•

The risk appetite around mine shaft remediation is developed. This should
include an inspection programme to monitor the location of shafts and to
disseminate information to those that may be affected, particularly for
residential dwellings.

•

The benefits of selected approaches to managing the risks from rising mine
water should be evaluated once further information is gained.

The Coal Authority has gained valuable experience and expertise in managing on a
larger scale the on-going lagging effects of coal mining in the UK. We believe that
much of this can be transferred and implemented with local variations to the
Netherlands and would be very willing to assist with the implementation of the
proposals.

20

Appendix 1 - Coal Authority Risk Matrix

Appendix 2 - Risk Based Approach to Development Management –
Resources for Developers