Planning Permission for Shannon LNG Terminal
Submission by Catherine McMullin of An Taisce
National Trust for Ireland
November 16, 2007
An Bord Pleanala,
64 Marlborough Street,
: Sect. 37E of the Planning & Development Act 2000, as amended
& Development (Strategic Infrastructure) Act 2006
by ShannonLNG Ltd. for a liquefied natural gas Regasification
Terminal in the townlands of Ralappane and Kilcolgan Lr., Co.
The Kerry Association of
An Taisce wish to make a submission to the above development, under a
number of headings. For your information, the list of bodies
consulted, as given in Sect. 1.9.1 of the Environmental Impact Study
(EIS), is not quite correct. There were no consultation with the
Kerry Association of An Taisce at the scoping stage, nor were we
invited to send representatives to any of the public consultation
meetings which took place in 2006-7. Eventually, a few months ago,
An Taisce approached the developer and was given copies of
information material handed out at public meetings and invited to
meet local staff. Subsequently a full copy of the EIS was received
and our submission is based on the information contained in it.
We understand that a
Quantitative Risk Assessment (QRA) was also carried out and has been
submitted to the Health & Safety Authority. This was not
available to us and, it was only today, we learnt it was made
available on the ShannonLNG website a couple of days ago. As this
development comes under the Seveso Directive, we believe the QSA
should be considered as part of the EIS and be made available to the
general public. We would ask An Bord Pleanala to ensure that this is
done and that it is suitably advertised when put on public display.
The public should also be given an opportunity to submit comments on
it to An Bord Pleanala as part of the planning process.
The site borders the
River Shannon, which is an important shipping route and also has a
number of conservation designations, as described in the EIS. The
river is a very scenic and both it and the shoreline are used for
recreational purposes. The site overlooks the river and covers about
half of the landbank owned by Shannon Development.
As this is a development
of national importance, a number of alternative sites around the
Irish coast were examined. While most are clearly unsuitable, a
number of them seemed to have similar characteristics to the Shannon
site but were not investigated further because, as stated in the EIS
It is unclear if the land could be purchased, under what terms it
could be acquired and whether it could be rezoned for industrial use.
The availability of the Shannon lands seems to have been the
deciding factor, which made it superior to the other sites.
When the Kerry County
Development Plan was adopted in 2003, the site was zoned as ‘Rural
General’, while the remainder of the Shannon Development lands were
zoned ‘Secondary Special Amenity’. The Seventh Variation of the
County Development Plan, adopted in March 2007, changed the zoning of
all the Shannon Development lands to ‘industrial’.
An Taisce was not opposed
to the re-zoning as such but felt that the local community should
derive some amenity use from the site, so as to compensate for the
inevitable change in the rural character of the area. Attached is
our submission to the seventh variation of the development plan,
which we would ask you to take into consideration.
At present, local people
can access the shoreline from a narrow road, which ends at a small
parking area. The road runs just within the eastern boundary of the
site but, in the EIS, it is stated there is no right of way along it
and it will no longer be available when construction begins. This is
somewhat contradicted by Sect. 19 which notes that, during
construction, there may be a temporary obstruction on the
The existence, or
otherwise, of a right of way is a matter which would have to be
decided by the courts but we would ask the developer to consider
giving a ‘permissive right of way’ to the shore as a goodwill
gesture. A ‘permissive right of way’ allows public access but
can be withdrawn at any time by the landowner. Most of the road is
outside the security fencing and it would be a simple matter to move
the remainder of the fence eastwards to allow pedestrian passage to
the shore. It would also allow access along the shoreline to the
‘lagoon’ and other conservation areas, which would otherwise be
landlocked by the development. A small area set aside for parking
and as a picnic area would be much appreciated by the local
supplied with the EIS indicate that the storage tanks, in particular
will have a significant visual impact, not only from the river and
the Clare coast but also from the adjoining public road. Views 1 to
3 inclusive show huge tanks looming menacingly over local houses.
The tanks are quite intrusive from the road to Carrigfoyle Castle
(V11), which is a tourist route and they are even more prominent in
V24 and V25, taken from Co. Clare. Photomontages of views closer to
the Tarbert and Moneypoint area are less objectionable as the
presence of the existing two power plants give an ‘industrial’
character to the landscape.
The negative visual
impact of the development has been described in the EIS as ‘moderate
to slight’. While this is true for many of the photomontages,
particularly those where the site is viewed from the distance, there
are a considerable number of viewpoints, including those mentioned
above, where the negative visual impact is much greater. In
particular, the views from the Coast Road could be considered in the
range significant to profound, due to the intrusion of large
industrial units in a rural area.
There is insufficient
information on the mitigating measures proposed. The white colour of
the tanks is obviously a large part of the problem. It is
understandable that a light colour was chosen to reflect sunlight and
prevent absorption of heat but there is no information on this or if
other colours were considered.
The landscaping of the
site boundary should have a beneficial effect, particularly if mature
trees are planted in the most sensitive locations. It would be
useful to have photomontages of the effect of this planting on the
views from the Coast Road.
It is proposed to widen
the Coast Road from Tarbert to the site, which is to be welcomed.
However, a considerable volume of traffic could also be approaching
from the west, through Ballylongford, and the narrow roads and
streets in the village could create problems for traffic flow.
Surface and Waste Water
The existing stream on
the site is to be dammed so as to supply fresh water for certain
processes. This will change the flow rate downstream of the
embankment but it is proposed to maintain a minimum flow at all
times. This is obviously a change on the existing situation, where
the stream almost dries up in drought conditions, and has
implications for the amount of salt water backing up. The EIS sees
it as a benefit but has this been fully checked out ?
Sect. 16-2 states that
surface water from paved areas etc. will go to the existing
stream/drainage ditch, presumably so that it can be collected in the
pond created by the embankment. An alternative would be to collect
water from non-process areas and use it for washing and toilet
flushing in the plant buildings. It is also proposed any surplus
should go to the estuary. This is not necessarily satisfactory for
an industrial development, where surface waters could become
contaminated, possibly with LNG. In recent times it has become more
usual to have surface water disposed on site, after separation from
any hazardous materials present.
It is proposed to have
separate effluent treatment facilities to service the Gate House,
because of its distance from the main waste water treatment plant.
It is anticipated that the toilets will be used only infrequently and
a biocycle unit, with a discharge pipe going to the estuary, is
proposed. The low volume of waste going to the plant could create
problems by providing insufficient nutrients for the bacteria which
break down the waste. Has the applicant ensured that this is the
best system or would other methods, such as a septic tank and
percolation area, or dry composting, be more suitable ?
While the process is
described in the EIS, there is insufficient information on the health
and safety aspects and the impact on the natural environment,
particularly the Shannon itself, which is a cSAC.
Regarding health and
safety, as mentioned earlier the QRA has not been available and has
not yet been examined by An Taisce. We believe that information and
statistics on accidents and hazardous incidents at existing LNG
plants around the world should be made available, so that the risks
from the processes planned for this site can be assessed and the safe
distance of the plant from existing dwellings can be determined.
There is insufficient
information on the effects of a spill of LNG, whether on-site or on
the river. It is stated in Sect. 11-20 that ‘spillages of LNG
evaporate quickly and are unlikely to affect the marine environment’
but this does not take into account the size of the spill, weather
conditions etc. and more information is needed. The evaporation
process will cause cooling of the river, will this be significant ?
There is also no
information on the composition of the LNG itself, other than the
information that, because it will be coming from different sources,
it will vary in composition. It is planned to add nitrogen to ensure
a uniform output but there are no details of the specifications of
the final product. A typical set of analysis for the different
sources which will be used should be supplied and Material Safety
Data Sheets, both for pure methane and for the mixtures which will be
processed should be supplied.
As part of the process,
it is proposed to pump large volumes of water from the Shannon to
provide a source of heat. The water will be returned to the estuary
but at a lower temperature and contaminated with sodium hypochlorite.
Computer modelling has been done to show the returning water will
dissipate quickly and should not damage the natural environment. It
is noted that the waste water from Moneypoint and Tarbert also
contains chlorine but they are far enough away that they cannot be
detected at the LNG site. Has any work been done on the effect of
the actual discharges from Moneypoint and Tarbert to see if the
chlorine dissipates as predicted and that it can be shown it has no
negative effect on the estuary ?
We would ask An Bord
Pleanala to take the above points into consideration before making a
decision in this case.
An Taisce, Kerry