County Cork, Ireland
References: PL08 .PA0002 and PC 08.PC0002
Re: Planning application by Shannon LNG
Liquefied Natural Gas (LNG) regasification terminal
and Kilcolgan Lower, County Kerry
of the Irish Environment was established in 1997 with a primary
objective of monitoring the full implementation of European law.
12 of the EU Seveso II directive states:
States shall ensure that their land-use and/or other relevant
policies and the procedures for implementing those policies take
account of the need, in the long term, to maintain appropriate
distances between establishments covered by this Directive and
the case of the proposed Liquefied Natural Gas (LNG) regasification
terminal on the River Shannon, given the proximity to centres of
population and the riparian location, we are concerned that the issue
of alternative locations was not properly addressed in the
Environmental Impact Statement. [EIS Volume 2.4.1]
EIS notes that off-shore terminals are a ‘preferred option for
environmental and planning purposes’, but rejects their
consideration because of ‘cost and technical difficulties.’
of Offshore siting’ omits any reference to the Proceedings
of the 2nd International Conference of Renewable Energy in Maritime
which took place on 26 – 28 April 2006 and which included a
presentation entitled ‘Security
of Energy Supply in Ireland - A Key Driver for Renewable Energy’.
The authors of this study suggested a location adjacent to the
Kinsale Gas field in the following terms:
LNG terminal in Ireland could be constructed near Kinsale Gas Field,
connected to the gas platform, thus the existing gas pipeline from
the gas field to Inch can be used. In this way, LNG could be used
provide at least a quarter of national gas demand or be sufficient
entirely for the Cork area . LNG can also be used as seasonable
gas storage at the LNG plant (liquefaction and storage during warm
season and vaporisation and injection into local pipelines during
cold period). This service can increase the volume of storage in
Ireland, which is currently limited to what is contained within the
pipelines and remaining reserves at the Kinsale Gas Field.’
would be grateful if this alternative location was considered for the
at the proposed location a new pipeline will connect the LNG terminal
to the Bord Gáis Éireann pipeline network which is approximately
25km to the east of the site. This part of the project is integral to
and will cause an inevitable environmental impact which must be
considered as part of this application to avoid ‘project splitting’
under the EIA Directive 97/11/EC.
from an energy regulation and planning perspective, we understand
that the licensing of this project is a matter for the Commission for
Energy Regulation (CER) who must consider and assess an application
for a contractual right to link up to the gas network as required by
the Gas Acts.
licence is, however, in no way an environmental/planning consent. We
are anxious that your Board might not provide itself with the
necessary technical advice to address the full range of policy
planning issues raised by this major development.
is particularly true as residents are concerned that such independent
expert advice may not be within their means; it must, therefore, be
made available by your authority in the interest of open and
transparent decision making.
of the Irish Environment
company limited by guarantee registered in Ireland.
No. 326985. Directors: Caroline Lewis, Tony Lowes.
mailing address: Allihies, County Cork, Republic of Ireland [No
& Fax: 353 (0)27 73131