An Bord Pleanala,

64 Marlborough Street,

Dublin 1.

Direct Planning Application to An Bord Pleanala in Respect of a Strategic Infrastructure Development

Case reference: PL08 .PA0002 (liquefied natural gas regasification terminal proposed for Ralappane and Kilcolgan Lower, Co. Kerry)

Subject matter of submission or observation: Proposed LNG Regasification Terminal

Reasons/Considerations/Arguments:

This submission is being made under 3 primary headings namely safety, visual impact, and environmental impact.

1. Safety: I believe that the Quantitative Risk Assessment (QRA) compiled is insufficient and does not fully acknowledge and indeed ostensibly dilutes the threat to residents should a major accident at the plant or at sea occur. The exclusion zones as evidenced in several reports from the USA go far beyond the QRA compiled by LNG consultants ERM. Buried in the QRA is reference to a 12.4km downwind threat from an unignited vapour cloud. This radius includes Ballylongford, Tarbert, Glin, Moyvane, Killimer and Kilrush unfortunately many residents in these areas are unaware of the planning application and more critically the threat posed should this plant become operational. Some of the more reputable reports that have emanated from the United States include James Faye, The Haven report and the Sandia Report (a government agency). These reports although differing on the hazardous distances go far in excess of what the documents submitted with this application purport to be safe. The physics and chemistry of LNG is complex, we naturally do not fully understand its reactive or explosive properties but the USA has 60 years of experience of this industry and has many fine academics who have written extensively on the topic.

The Shannon LNG Company have based their model for safety on the HSA guidelines for similar industry in Ireland yet in the absence of no other similar proposal on the island one wonders as to what yardstick this proposal will be measured against.

2. Visual Impact: The sheer bulk and scale of these tanks is not fully understood, with each tank 96m in diameter and 50m in height they will be an unacceptable blight on the landscape that fronts onto the Shannon Estuary. Locals were invited to Zeebrugge, Milford Haven and Barcelona to visit other LNG Plants both in operation and under construction. It should be noted that all these locations have one thing in common in that they are located in port areas and not ‘green field’ sites in scenic rural area. Tens of dwellings in the immediate area that enjoy the amenity provided by uninterrupted views of the Shannon Estuary will have their vistas destroyed and consequentially there will be serious injury to property values.

The route along the coast from Saleen to Kilcolgan has been referred to in the Buchannan landscape analysis for County Kerry.¹ It is described as an important route with views and prospects. The overbearing nature of these tanks will, if built, severely inhibit this vista. During meetings with the Kilcolgan Residents Group the company were asked if it was possible to submerge the tanks as they now do in South Korea and Japan or semi submerge as they have achieved in Belgium. The response was that it was possible but they would not be doing so. When questioned further it became apparent that it was physically possible but that there was a cost implication that they were not prepared to shoulder.

With regard to boundary treatment Shannon LNG propose to erect a 2.9m metal fence with barbed wire around the circumference of the 280 acre site. This includes several hundred metres of road frontage. There are numerous dwellings directly to the South of the site who will have hedgerow replaced by a boundary more suited to a high security prison. Yet the company maintain that there will be no impact on property values. Many residents were offered photo perspectives of the tanks as can be seen from their front doors unfortunately Shannon LNG failed to include the proposed boundary. One has to question why? Such boundary treatment proposals speak plenty about the inherent risks associated with the facility should there be an unauthorised incursion. From a purely planning perspective the boundary treatment and the tanks are completely incongruous with the receiving environment regardless of the zoning decisions made by ill informed county councillors.

In their EIS, Shannon LNG refers to the presence of large industrial scale projects like Moneypoint and Tarbert Power Stations as somehow mitigating against their own vastly larger proposal. It is a nonsense to suggest that merely because what made sense in the seventies and eighties somehow excuses the further destruction of landscape adjacent to an SAC.² It is obvious that if Moneypoint was proposed today it would have little chance of progressing. Thankfully we have entered an era where the value of our landscape has been recognised not alone by the state but by the European Union and the United Nations.

3. Environment: Shannon LNG plan to use millions of gallons of Seawater per day to regasify the LNG, this will be chlorinated/disinfected so as to protect their heat exchanging equipment and released back in to the estuary. As the seawater is used to reheat a cryogenic liquid it will be returned to source at a significantly lower temperature. Of the 4 LNG terminals currently operating in the US none have utilised this open loop method opting for the traditional method of using on site gas instead which is thought to absorb 1 – 2% of the annual gas throughput. There are however plans for several LNG’s in the Gulf of Mexico where this will be the preferred option. Fears abound that this procedure will have catastrophic effects on fisheries and marine life. The National Oceanic and Atmospheric Administration found³ a "100 percent mortality rate of all organisms entrained by the vaporizer”. It is clear that such interference with seawater content and temperature is bound to have huge ecological consequences. I am hopeful that regardless of national planning policies that the EU will see fit to preserve this SAC, the designation of which was based on marine life. Further to this intentional pollution any accidental releases that may occur will have a huge bearing on the environment surrounding the plant both on shore and off shore. Again research from other countries more familiar with the concept would prove useful.

Conclusion: It is clear that this type of development does not belong at this location. So as not to endanger any other communities it should be pointed out that it is possible to site this off the coast a safe distance from populated areas similar to a project in the offing in California⁴. Inexplicably this form of development was included in the Strategic Infrastructure Act but there is no real strategic need for a terminal in Ireland at the moment just as there is no accepted need for a Nuclear Power Station. LNG plants are underway in Milford Haven in Wales that will create a comfortable supply to the natural gas grid through interconnectors, the Corrib field is also yet to become operational. It is probable that the company have comprehensive research conducted on future supply going forward as they are requesting a 10 year permission which will allow them to construct one tank and then take a wait and see approach as to the viability of the project. In essence they are seeking a 10 year construction window where tanks will be added as desired. People in the area who are unaware of this approach would consider it grossly unacceptable to live adjacent to a construction site with all its associated hazards and nuisances for such a lengthy period. I strongly urge the board to forensically analyse this project and to strive to utilise independent and objective expertise that can expose this project for its many shortcomings.

Signed: _____________________ Date: 05/11/2007