Safety Before LNG
Exposing the truth about the Hess 'Shannon LNG' project
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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.