The Irish Planning Authority,  An Bord Pleanála, has demanded clarifications from Shannon LNG on its new planning application for a proposed fracked gas import terminal on the Shannon Estuary following written admissions by Shannon LNG that the upstream emissions of LNG are 2.5 times greater than those of natural gas from the UK gas network currently supplying gas to Ireland.

Using an outdated report from 2013, Shannon LNG equated the emissions from fracked Shale gas  to exactly the same as emissions from the North Sea Gas Fields on the UK Continental Shelf (UKCS), calculating the  upstream emissions from LNG solely from extraction, processing, liquefaction and transportation. This staggering figure of 2.5, therefore, does NOT even include the specific fugitive emissions from fracking, the method of production of most exported US LNG.

On July 5th, 2022, in a four-page letter that never mentions the official government policy against the importation of fracked gas and never mentions the word "fracking", An Bord Pleanála nevertheless ordered Shannon LNG to address issues highlighted in the Enviromental  Impact Assessment Report (EIAR) submitted by the company with its planning application. In the EIAR, Shannon LNG stated that the full life cycle, "upstream WTT [Well-toTank] emissions of LNG, resulting from the extraction, processing, liquefaction and transport of the gas, are significantly higher than those of the natural gas within the UK gas network". The company wrote that it estimates that "the WTT emissions of LNG are currently around 2.5 times higher than those of the UK gas network".  

The Irish and UK gas network is so closely intertwined and interdependent that both countries are considered to be the one gas market.

Bord Pleanála ordered Shannon LNG to explain "how the different elements of the proposed development comply with national policy", including the most recent policy documents published since it applied for planning in August 2021, namely, the Climate Action Plan 2021 (November 2021), the Policy Statement on Security of Electricity Supply (November 2021) , the National Energy Security Framework (April 2022) and the ongoing Review of the Security of Energy Supply of Ireland's Electricity and Natural Gas Systems.

Shannon LNG was asked by the Board for clarification on the contradictory emissions figures it supplied following its own admission in page 15.27 of Volume 2 of its EIA Report that "the upstream emissions of LNG are greater than those of natural gas within the gas networks". In page 15-38, the company informed the Board that  "emissions from the Proposed Development will equate to around 2.2% of Ireland’s carbon allowance in 2030, a major adverse impact".

The Board wrote that  "further elaboration and clarification is requested in respect of the calculation of emissions set out in Chapter 15 of the EIAR".  Shannon LNG had claimed that by 2030 it would be producing annual direct emissions of 655 kilo-tonnes of carbon-dioxide equivalent (kt CO2e)  in its detailed EIA report whereas, in page 29 of its summary volume 1 EIA Report, Shannon LNG had actually admitted that this figure would be almost 50% higher at  963kt CO2e  going on to alarmingly state:

"The higher WTT emissions from the 4 million tonnes of LNG imported annually compared with the same amount of gas from an alternative gas supply is likely to result in additional annual average Scope 3 emissions of around 940 ktCO2e/yr per operational year, or 23,971 ktCO2e over the full operational lifetime of the Proposed Development."

The company also stated that "the proposed development is expected to have a design life of 50 years".

The Board, furthermore, raised serious concerns about the permanent loss of habitats and damage to the Lower Shannon Estuary Special Area of Conservation (SAC) which would be caused by both the construction and operation of the Shannon LNG project and noted serious discrepancies in the information provided by the applicant. This is significant because under the EU Habitats Directive, permanent destruction of an SAC, which cannot be mitigated against, is only allowed if a development is in the "overriding public interest".  

John McElligott of 'Safety Before LNG' stated that he fears that the emissions figures provided by Shannon LNG are so contradictory because "he who pays the fiddler calls the tune", and called for independent and neutral climate experts to be brought in to analyse the figures supplied by Shannon LNG as he does not trust the company. He said that the figures supplied by Shannon LNG make no mention of the fugitive emissions from fracking and are based on a very conservative and outdated 2013 report from the UK Department of Energy and Climate Change (DECC) which uses the 100-year global warming potential of methane compared to carbon dioxide (25 times) rather than the more realistic 20-year period (and in any case now outdated by the latest Intergovernmental Panel on Climate Change IPCC, reports from 2021 which have calculated in table 7.15 on page 1739 as 108 times for the 20-year period and 40 times for the 100-year period). The DECC report also assumed that "methane released during completion would be 90% captured and flared" but this takes no account of the latest peer-reviewed scientific studies which have found that one third of the total increased methane emissions from all sources globally over the decade up to 2019 was coming from US fracked gas (shale gas) .

Shannon LNG equates the emissions from fracked Shale gas  to exactly the same as emissions from the North Sea Gas Fields on the UK Continental Shelf (UKCS)  - see table 15-19 in volume 2 of the EIA - and it calculated the upstream emissions from LNG solely from extraction, processing, liquefaction and transportation. It is now clear that the upstream emissions of imporitng fracked LNG will be significantly higher than the  figure Shannon LNG gave for importing unfracked LNG and this is a real cause for concern when considering the true climate impacts of the energy choices we make in Ireland. 

McElligott highlighted the fact that in October 2019 Professor Robert Howarth of Cornell University directly informed the Joint Oireachtas Committee on Climate Action that importing US Shale Gas into Ireland would have a carbon-equivalent footprint 44% greater than that of coal over a 20 year period. In his oral testimony, Professor Howarth explained that "if we do not reduce methane emissions, the Earth will shoot through the 2 degree Celsius mark within the next 20 to 30 years, with devastating consequences".

An Bord Pleanála made no direct mention of the the official government policy on the importation of fracked gas published on May 18th, 2021 before Shannon LNG had lodged its planning application. This policy statement declares that "Ireland imports much of its natural gas via the two interconnector pipelines from Moffat in Scotland, which provide the majority of natural gas currently used in Ireland. Given the level of fracked gas in the imports from Scotland is considered very low, the highest risk of fracked gas being imported into Ireland on a large-scale would be via liquefied natural gas (LNG) terminals, if any were to be constructed". The policy statement concludes that “pending the outcome of the review of the security of energy supply of Ireland’s electricity and natural gas systems, it would not be appropriate for the development of any LNG terminals in Ireland to be permitted or proceeded with”. 

Regarding the ongoing security of energy supply review, the Department for the Environment ordered that “any options identified must be in keeping with the commitments in the Programme for Government. This includes any policy statement that is developed to establish the approach to the Government’s stated commitment not to support the importation of fracked gas”. The latest government Framework Document on national energy security, published on April 13th, 2022 states that this review is due for publication between July and September 2022. 

An Bord Pleanála made no mention of the eight data centres that Shannon LNG wants to build on the site which would consume a large portion of the energy created from the imported gas in the first place.  In the EIAR Shannon LNG refers to this as its "overall masterplan for the Energy Park" which will be subject to a separate planning application. The proposed 8 data centres on the site undermines the whole argument that the LNG terminal would bring security of supply to Ireland, if the company thinks it can be its own customer. A situation where you have U.S.-owned data centres, powered by a U.S.-owned power station, fuelled by a U.S.-owned terminal importing U.S. fracked gas, killing and poisoning people in Pennsylvania raises such a level of other questions to be answered, given that there is a policy against fracked gas imports in place, renders that plan highly problematic. CEO of New Fortress Energy,  Wes Edens, owner of Shannon LNG was too blatant about this when he stated in an Earnings call in August 2019: 

 
“I can't emphasize enough, I think the downstream assets we develop around these terminals are, in many respects, our most important projects. We basically end up creating our own demand. We're, essentially, negotiating with ourselves, so we know the guy who owns the data centers if we're building data centers.” 

On October 19th, 2021 Minister for Energy, Eamon Ryan, wrote directly to An Bord Pleanála stating "In conclusion, I wish to make it very clear that I believe that the permitting of this project would be in direct contravention to Government policy and therefore it should not, under any circumstances, be permitted".

Shannon LNG has until August 19th to submit the requested information to the Board.