The proposed Shannon LNG project
The
entire supply of natural gas for power generation in Ireland in 2007
would correspond to 38 shiploads of Liquefied Natural Gas (LNG) per
year.
Hess LNG is planning on bringing 125 shiploads of LNG into the country
to be stored in 4 tanks almost 20 stories high and each wider
than the width of Croke Park football stadium.
If this happens, then Ireland will be flooded with gas - an imported
fossil fuel - with which the Renewable Energy sector will not be able
to compete, making a mockery of the country's committments to fighting
climate change in signing up to the Kyoto Protocol. To put it plainly,
the Shannon LNG project will be the kiss of death to the renewable
energy sector in Ireland.
And yet, there is a complete silence from the Irish Establishment on
the strategic planning of this crazy, developer-lead energy project.
Why? Even the EU Commission has stated that this project should undergo
a Strategic Environmental Assessment since it is being given
development consent as a Strategic Project. But even the current
Green Ministers for Environment and Energy have ignored EU findings and
refused to require any Strategic Assessment of the LNG Energy project
to be undertaken. Why? We think that the reason is that any objective
strategic assessment of the project would recommend against the Shannon
LNG project.
Ireland may need some gas, but it does not need the amounts proposed by
Shannon LNG.
To lock Ireland into this increased gas consumption there is now a plan
to convert power stations, such as the Endesa (formerly ESB-owned)
power plant at Tarbert to gas as well as building another gas-fired
power station adjacent to the proposed LNG plant itself (owned by Hess
of course). The aim of the battle seems to be to lock Ireland
into higher levels of gas consumption by gaining monopoly access to the
national GRID via gas-fired power stations.
For all those windfarm developers currently on the GATE queuing system
for access to the national Grid, be warned that there will be a
concerted effort by companies such as Shannon LNG to
be allowed jump the queue. The excuse used - a mantra which will be
repeated by heavily-lobbied politicians - will be that companies that
can prove funding ability to complete projects should be allowed
proceed ahead of non-fossil-fuel projects such as windfarm developments
already on the queue.
Even Bord G�is seems to have already gotten in on the battle for grid
access there by using national funds to purchase four windfarm
operators (including SWS) for what the September 2010 edition of
"Business Plus" described as possibly €600 million of Irish taxpayers'
money more than their actual valuation.
This proposed Shannon LNG project will be built at the mouth of the
Shannon Estuary - one of the best deep-water estuaries in Western
Europe. It has been a stated policy to develop the Shannon Estuary as a
major deepwater transshipment port which would bring thousands of job
to the region. However, as an LNG accident would put people's lives in
danger up to 3 miles from the site and because the LNG industry itself
has self-imposed ship traffic exclusion zones around LNG tankers, the
LNG project may sterilise the entire Shannon Estuary from further
development - all for, at most, 50 long-term jobs.
The short-term construction jobs for the development would be welcomed
by all but this is not sustainable and people cannot build lives around
short-term work. The only positive spin that the Hess corporation can
put on their Shannon LNG project is that it will bring jobs and this is
constantly being repeated by bullying politicans who cannot, or refuse
to, see the bigger picture. This number started at 350 construction
jobs, but when that did not impress people too much the number
mysteriously jumped to around a thousand. But the fact remains, even
admitted by Hess, that the final number of long-term jobs will be, at
most, 50.
Alternative sites for storage of LNG already exist which would do away
with the need to sterlise the Shannon Estuary. One such site is
offshore at the near-depleted Kinsale gas fields where the pipeline and
storage infrastructure already exist. Another alternative is an
offshore storage facility similar to that currently being developed by
Norwegian company Hoegh LNG 100 miles from Dublin and 15 miles from the
UK coast.
Over 100 million gallons of super-cooled water with anti-fouling agents
will be poured into the Shannon Estuary every day as part of this
project - an area of outstanding beauty and home to the resident and
supposedly-protected Bottlenose Dolphins.
And the people who will have to pay the highest price for this crazy
LNG project for what will become the most sizeable hazard in Ireland
are the 17,000 people living within the danger zone of the LNG tanker
routes along the Shannon Estuary in what can only be described as
an accident waiting to happen.
This
web site is
dedicated to providing a detailed and truthful source of information on
all aspects of the
proposed Shannon LNG terminal project which is being opposed in its
entirety by the 'Safety Before LNG' group. If any inconsistencies
are noticed please contact us immediately and we will rectify or
clarify the information.
Shannon LNG proposes to
construct a liquefied natural gas (LNG)
regasification terminal on a 104 hectare (257 acre) site located on the
Shannon Estuary between Tarbert and Ballylongford in Co. Kerry. The
site is owned by Shannon Development and Shannon LNG has an option to
purchase the site subject to obtaining development consent. Shannon LNG
is a subsidiary of the Cayman Islands-registeresd Hess LNG
Limited, which is a joint venture of Hess
Corporation and Poten & Partners, both US companies.
In spite of media reports to the contrary, Shannon LNG has not yet
obtained full development consent because, in Ireland, different
statutory bodies deal with different aspects of the development consent
process. For example, the project has, surprisingly, not yet been
assessed for pollution which is under the remit of the Environmental
Protection Agency.
There are serious
environmental, safety, economic, strategic and other concerns
surrounding the proposed LNG terminal in Tarbert parish, which have not
yet been thoroughly appraised even though An Bord Plean�la granted
permission for the project on March 31st 2008. This is because the new
fast-track planning process allowed for this application means that all
environmental, safety and development issues are being examined in
parallel and by different government bodies without the right of appeal
in the planning process that would exist if the application was first
submitted to the local planning authority - Kerry County Council.
Some of the necessary assessments - such as a marine LNG
risk assessment - are falling within the regulatory gaps and are not
being assessed by any of the statutory bodies.
Safety Concern
The primary concern is
the lack of safety for nearby residents due to
the fact that they live too close to the proposed site – a high-risk
Seveso II site - which would become the most sizeable hazard in
Ireland. Conservative scientific evidence provided below shows
that it is unsafe to live within 3 miles of the site. This area covers
the villages of Ballylongford, Tarbert and Killimer in County Clare.
This will also prevent further use being made of the rest of the land
bank due to the danger posed to people working nearby. More seriously,
the QRA undertaken by Shannon LNG itself on page 32 admits
categorically that:
“the
development of the largest cloud produced by the …catastrophic failure
of a full tank ….has a maximum downwind distance of ..12.4 Kilometers”.
This will mean that the
Kerry
towns and districts of Beal, Asdee and Moyvane, the Limerick town of
Glin and the Clare towns of Kilrush, Moyasta, Killimer, Knock and
Kilmurry McMahon, as well as surrounding countryside are in the
possible fallout zone. This is from Shannon LNG’s own research.
LNG expert Dr. Jerry Havens, in his submission to the Shannon LNG
application noted:
"If an LNGC were to be attacked in the
proximity of the shoreline,
either while docked at the terminal or in passage in or out of the
estuary, and cascading failures of the ships containments were to
occur, it could result in a pool fire on water with magnitude beyond
anything that has been experienced to my knowledge, and in my opinion
could have the potential to put people in harms way to a distance of
approximately three miles from the ship. I have testified repeatedly
that I believe that the parties that live in areas where this threat
could affect them deserve to have a rational, science-based
determination made of the potential for such occurrences, no matter how
unlikely they may be considered."
The remit of the Health and
Safety Authority (HSA) stopped at the
shoreline and so the HSA did not assess any marine safety aspects of
the project or any intentional damage to the terminal or LNG ship. The
Commission for Energy Regulation (CER) is only assessing
safety aspects of the pipeline and not of the terminal itself or any
marine safety aspect of the project. In granting Shannon
LNG permission to construct the pipeline on December 9th 2009, the CER,
in what we consider to be an abdication of its responsiblity in a mere
rubber-stamping exercise, stated that it would only assess the safety
aspects of the LNG terminal once it was built as follows:
"Shannon
LNG will not be entitled to actually operate the proposed LNG
terminal until it has applied for and received a license to operate
from the Commission. A prior condition to issuing such a license
would be that the Commission has approved a Safety Case for the
facility."
In fact, no statutory body
is undertaking or requesting a marine LNG risk assessemnt. Any safety
assessments approved by the CER or HSA to date, therefore, have no
value because they are not completely informed of the safety issues
involved.
The safety concerns posed
by LNG shipping has even now reached the European Court of Human Rights
in its investigation into the LNG
terminals at Milford Haven in Wales in which it has recently declared
that a
government has:
"a positive obligation to protect the
rights of people" by ensuring that they have
"properly assessed the risk and
consequences of a collision of LNG
vessels or other escape of LNG from a vessel in [...] harbour
or while berthed at the jetty".
Hess LNG
CEO, Gordon Shearer, admitted for the first time ever on a US TV
interview on May 20th 2008 that an LNG ship one mile from any point of
land is the nearest point “at which
risk is down to acceptable levels”.
However, any LNG ship will never be more than 1 mile from land once it
starts travelling up the Shannon Estuary therefore putting over 17,000
residents at
risk all along the North Kerry and South Clare coasts. Not
surprisingly, Hess LNG has no operating LNG regasifcation
terminal and its other LNG terminnal proposal in Fall River,
Massachusetts, USA has been continually refused permission on safety
grounds
over the last 5 years.
Environmental Concern
The most serious
environmental concern is that up to 100 million
gallons of chlorinated seawater, used to reheat the LNG back into
a gas, will be pumped into the estuary daily,
causing serious environmental damage to this SAC area. The withdrawal
and discharge of huge volumes of seawater would affect marine life by
killing ichthyoplankton and other micro-organisms forming the base of
the marine food chain unable to escape from the intake area.
Furthermore, the discharge of 10 to 12 degrees cooler and
chemically-treated seawater
would also affect marine life and water quality.
Economic and Strategic Development Concern
The
most serious economic concern is that the gas-industry’s own standard
recommended exclusion zone of 2 miles around an LNG tanker will stop
shipping – including the Tarbert-Killimer car ferry - in the estuary
every time an LNG tanker is in the area (and Shannon LNG plans up to
125
tankers a year) and prevent marine use of the rest of the land bank.
As
there has been no LNG
marine risk assessment undertaken of the project it is impossible to
ascertain the cumulative effects LNG tankers travelling in the
Shannon
Estuary will have on the strategic development of one of the best
natural deep-water ports in Western Europe. A major "Transhipment Hub"
on the Estuary has been a stated policy supported almost unanimously by
all stakeholders in the region for many years because it
represents sustainable development of the Estuary region. The widening
of the Panama Canal, expected to be completed by 2014, will mean that
the size of the largest ships able to navigate the Canal (currently
called 'Panamax' ships) will increase and there will be an increasing
demand for new deepwater ports capable of receiving them. We believe
that the LNG project could end all hope for major port development of a
transhipment hub on the Shannon Estuary because of the exclusion zone
around LNG container ships required for safe transport. Even the
developer itself - Shannon LNG - cited the
current lack of marine traffic in the area as one of their reasons for
choosing this brownfield site. At the very least, it is incumbent on
the Irish Government to ascertain what are the minimum conditions
needed that will allow the current "Transhipment Hub" policy to one day
come to fruition. In other words, the Irish Government needs to
determine if an LNG industry at the mouth of the Estuary will prevent
the development of a Transhipment Hub.The Irish government is allowed
by law to make "bad" decisions but is prevented under currrent
legislation from making uninformed decisions.
More seriously still,
a
defacto oil and gas energy strorage hub is being created on the
southern shores of the Shannon Estuary with oil storage facilities
being proposed or developed in Foynes, West Limerick, adjacent to
Tarbert power station and adjacent to the proposed LNG terminal itself
without any public consultation whatsoever. This goes against all
accepted standards and norms of proper and sustainable planning and
development.
There
has been no Strategic
Environmental Assessment of the rezoning of the lands for the LNG
terminal as required by the EU SEA Directive, nor of the defacto oil
and gas storage hub being created. Following a direct petition to
the European Parliament, the EU Commission is currently investigating
the circumstances which allowed a strategic development get planning
permission under the Strategic Infrasructure Act without any strategic
assessment. The Commission, in January 2010 in an interim finding,
agreed with us that a Strategic Environmental Assessment (SEA) should
have been undertaken before any new Plan for the Estuary is implemented.
Finally, whereas the
developer emphasises that it is in the national
strategic interest to have an LNG terminal in Ireland, we are of the
opinion that only a strategic interest in LNG as another strategic
alternative source of gas in Ireland has been accepted and that there
has been no acceptance of the strategic need for an LNG terminal if no
suitable site in Ireland is found. This distinction is very important
because this need for LNG is already being met with the construction of
the LNG terminals in the UK which are already providing LNG-sourced gas
to Ireland via
the existing gas pipelines from the UK.
Current State of the Shannon LNG project
Development
Consent in Ireland is shared by An Bord Plean�la (the Planning
Authority) and the Environmental Protection Agency (the EPA). Shannon
LNG has not yet obtained full development consent.
The project has obtained the planning permission from An Bord Plean�la
to construct the terminal
and 26-kilometre pipeline. It still requires an Integrated Pollution
Prevention and Control (IPPC) licence
to pollute from the Environmental Protection Agency (EPA), However, the
EPA assessment process is very limited because the EPA is not allowed
to consider alternative sites that might lead to less pollution even
though An Bord Plean�la considers alternative sites on other grounds
but not on pollution grounds. This is one more example of the
regulatory gap in Irish Planning law where neither of the statutory
bodies involved in giving development consent considers the pollution
levels of alternative sites.
The
project also requires a Foreshore licence to develop 2 jetties on
10 hectares of SAC waters protected under the EU Habitats
Directive. Any Foreshore Licence given without the Strategic
Environmental Assessment (SEA) deemed necessary by the EU in January
2010 would be in complete contravention of the planning and development
rules set by EU Directives.
A safety case and Emergency plan still has to be approved by the
Commission for Energy
Regulation (CER) before the terminal can become operational - but it
seems highly bizarre that the CER would wait until the terminal is
built before it undertakes a safety assessment.
The project must also obtain EU approval for Third-Party Access
arangements as well as considering the lack of a Strategic
Environmental Assessment and the lack of a marine LNG risk
assessment and we believe that these issues will
prove more difficult stumbling blocks for Hess to overcome.
The 'Safety Before LNG'
group is of the opinion that it is now abundantly clear to all
informed opinion that the oral hearings and assessments of this project
have been, to date, nothing more than a cosmetic exercise. Our research
has proved that
the decision to site a dangerous LNG terminal is being made without the
proper risk assessments being completed – notably the emergency
plan and the Marine Risk Assessment of an LNG spill on water.
Even if the LNG project obtains full development consent, Hess still
has to
make the actual investment decision. We believe that unless Shannon LNG
manages to export gas to the UK it will not currently make this
investment decision because, of the 125 yearly shiploads of LNG
proposed for delivery to Tarbert, only around 37 shiploads are needed
for electricy generation in Ireland. This would require decoupling
from the UK gas market and a change in direction of the gas
interconnector to the UK. We believe that this is highly unlikely in
the short term because depending on the imported shipping of LNG is
less secure than depending on gas via the interconnector and even the
Irish
Government is unlikely to allow Shannon LNG have such a powerful
monopoly.
Energy market intelligence experts, ICIS Heren, were told by Hess LNG
CEO Gordon Shearer on February 2010:
"A final
investment decision could be right at the end of this year or early
next year, but it could drag on further. We are going to look at
the third-party access arrangements because this defines the project
parameters. And it is not just in the control of the Irish authorities,
because the EU needs to approve it too. And we need to get these before
making a commercial decision."
ICIS Heren went on to report:
"Shearer added that three other aspects
remain to be completed: engineering, fine-tuning the planning
applications, and crucially, the securing of LNG supplies. Shannon
LNG has asked for a 30-35 year exemption from regulated third-party
access but, CER has indicated that it will offer a maximum of 25 years,
partly on account of concerns it had about the possible domination of
the Irish market in the long term should it "decouple" from the UK. "
Endesa has applied for planning permission to construct a 450 Megawatt
gas-fired power station at Tarbert and Shannon LNG has plans to develop
its own gas-fired power station adjacent to the proposed LNG terminal.
Both plants, as current proposals stand, would only have access
to Shannon LNG-sourced gas because both plants are over 26 kilometres
from the national gas grid at Foynes in West Limerick and the proposed
pipeline from Tarbert to Foynes will only contain gas from the Shannon
LNG plant because the gas cannot flow in both directions. We believe
that this monopoly of becoming a "pivotal supplier" to at least 700
Megawats of power generation by Shannon LNG will be detrimental to
competition in the wholesale market of gas-fired electricity generation
in the Shannon Estuary region and is now a highly-relevant
issue in Third-Party Access arrangements to be ruled on by the
CER and the EU.
|