Planning Permission for Shannon LNG Terminal

Submission by Catherine McMullin of  An Taisce

An Taisce

The National Trust for Ireland

Cumann Chiarra�

Kerry Association

5, Glenashe,

Killorglin,

Co. Kerry

November 16, 2007

An Bord Pleanala,

64 Marlborough Street,

Dublin 1

Dear Sirs,

re : Sect. 37E of the Planning & Development Act 2000, as amended by the

Planning & Development (Strategic Infrastructure) Act 2006

Application by ShannonLNG Ltd. for a liquefied natural gas Regasification

Terminal in the townlands of Ralappane and Kilcolgan Lr., Co. Kerry

The Kerry Association of An Taisce wish to make a submission to the above development, under a number of headings. For your information, the list of bodies consulted, as given in Sect. 1.9.1 of the Environmental Impact Study (EIS), is not quite correct. There were no consultation with the Kerry Association of An Taisce at the scoping stage, nor were we invited to send representatives to any of the public consultation meetings which took place in 2006-7. Eventually, a few months ago, An Taisce approached the developer and was given copies of information material handed out at public meetings and invited to meet local staff. Subsequently a full copy of the EIS was received and our submission is based on the information contained in it.

We understand that a Quantitative Risk Assessment (QRA) was also carried out and has been submitted to the Health & Safety Authority. This was not available to us and, it was only today, we learnt it was made available on the ShannonLNG website a couple of days ago. As this development comes under the Seveso Directive, we believe the QSA should be considered as part of the EIS and be made available to the general public. We would ask An Bord Pleanala to ensure that this is done and that it is suitably advertised when put on public display. The public should also be given an opportunity to submit comments on it to An Bord Pleanala as part of the planning process.

Location

The site borders the River Shannon, which is an important shipping route and also has a number of conservation designations, as described in the EIS. The river is a very scenic and both it and the shoreline are used for recreational purposes. The site overlooks the river and covers about half of the landbank owned by Shannon Development.

As this is a development of national importance, a number of alternative sites around the Irish coast were examined. While most are clearly unsuitable, a number of them seemed to have similar characteristics to the Shannon site but were not investigated further because, as stated in the EIS It is unclear if the land could be purchased, under what terms it could be acquired and whether it could be rezoned for industrial use. The availability of the Shannon lands seems to have been the deciding factor, which made it superior to the other sites.

Zoning

When the Kerry County Development Plan was adopted in 2003, the site was zoned as ‘Rural General’, while the remainder of the Shannon Development lands were zoned ‘Secondary Special Amenity’. The Seventh Variation of the County Development Plan, adopted in March 2007, changed the zoning of all the Shannon Development lands to ‘industrial’.

An Taisce was not opposed to the re-zoning as such but felt that the local community should derive some amenity use from the site, so as to compensate for the inevitable change in the rural character of the area. Attached is our submission to the seventh variation of the development plan, which we would ask you to take into consideration.

Recreational Amenity

At present, local people can access the shoreline from a narrow road, which ends at a small parking area. The road runs just within the eastern boundary of the site but, in the EIS, it is stated there is no right of way along it and it will no longer be available when construction begins. This is somewhat contradicted by Sect. 19 which notes that, during construction, there may be a temporary obstruction on the shoreline.

The existence, or otherwise, of a right of way is a matter which would have to be decided by the courts but we would ask the developer to consider giving a ‘permissive right of way’ to the shore as a goodwill gesture. A ‘permissive right of way’ allows public access but can be withdrawn at any time by the landowner. Most of the road is outside the security fencing and it would be a simple matter to move the remainder of the fence eastwards to allow pedestrian passage to the shore. It would also allow access along the shoreline to the ‘lagoon’ and other conservation areas, which would otherwise be landlocked by the development. A small area set aside for parking and as a picnic area would be much appreciated by the local community.

Visual Amenity

The photomontages supplied with the EIS indicate that the storage tanks, in particular will have a significant visual impact, not only from the river and the Clare coast but also from the adjoining public road. Views 1 to 3 inclusive show huge tanks looming menacingly over local houses. The tanks are quite intrusive from the road to Carrigfoyle Castle (V11), which is a tourist route and they are even more prominent in V24 and V25, taken from Co. Clare. Photomontages of views closer to the Tarbert and Moneypoint area are less objectionable as the presence of the existing two power plants give an ‘industrial’ character to the landscape.

The negative visual impact of the development has been described in the EIS as ‘moderate to slight’. While this is true for many of the photomontages, particularly those where the site is viewed from the distance, there are a considerable number of viewpoints, including those mentioned above, where the negative visual impact is much greater. In particular, the views from the Coast Road could be considered in the range significant to profound, due to the intrusion of large industrial units in a rural area.

There is insufficient information on the mitigating measures proposed. The white colour of the tanks is obviously a large part of the problem. It is understandable that a light colour was chosen to reflect sunlight and prevent absorption of heat but there is no information on this or if other colours were considered.

The landscaping of the site boundary should have a beneficial effect, particularly if mature trees are planted in the most sensitive locations. It would be useful to have photomontages of the effect of this planting on the views from the Coast Road.

Traffic

It is proposed to widen the Coast Road from Tarbert to the site, which is to be welcomed. However, a considerable volume of traffic could also be approaching from the west, through Ballylongford, and the narrow roads and streets in the village could create problems for traffic flow.

Surface and Waste Water

The existing stream on the site is to be dammed so as to supply fresh water for certain processes. This will change the flow rate downstream of the embankment but it is proposed to maintain a minimum flow at all times. This is obviously a change on the existing situation, where the stream almost dries up in drought conditions, and has implications for the amount of salt water backing up. The EIS sees it as a benefit but has this been fully checked out ?

Sect. 16-2 states that surface water from paved areas etc. will go to the existing stream/drainage ditch, presumably so that it can be collected in the pond created by the embankment. An alternative would be to collect water from non-process areas and use it for washing and toilet flushing in the plant buildings. It is also proposed any surplus should go to the estuary. This is not necessarily satisfactory for an industrial development, where surface waters could become contaminated, possibly with LNG. In recent times it has become more usual to have surface water disposed on site, after separation from any hazardous materials present.

It is proposed to have separate effluent treatment facilities to service the Gate House, because of its distance from the main waste water treatment plant. It is anticipated that the toilets will be used only infrequently and a biocycle unit, with a discharge pipe going to the estuary, is proposed. The low volume of waste going to the plant could create problems by providing insufficient nutrients for the bacteria which break down the waste. Has the applicant ensured that this is the best system or would other methods, such as a septic tank and percolation area, or dry composting, be more suitable ?

Industrial Process

While the process is described in the EIS, there is insufficient information on the health and safety aspects and the impact on the natural environment, particularly the Shannon itself, which is a cSAC.

Regarding health and safety, as mentioned earlier the QRA has not been available and has not yet been examined by An Taisce. We believe that information and statistics on accidents and hazardous incidents at existing LNG plants around the world should be made available, so that the risks from the processes planned for this site can be assessed and the safe distance of the plant from existing dwellings can be determined.

There is insufficient information on the effects of a spill of LNG, whether on-site or on the river. It is stated in Sect. 11-20 that ‘spillages of LNG evaporate quickly and are unlikely to affect the marine environment’ but this does not take into account the size of the spill, weather conditions etc. and more information is needed. The evaporation process will cause cooling of the river, will this be significant ?

There is also no information on the composition of the LNG itself, other than the information that, because it will be coming from different sources, it will vary in composition. It is planned to add nitrogen to ensure a uniform output but there are no details of the specifications of the final product. A typical set of analysis for the different sources which will be used should be supplied and Material Safety Data Sheets, both for pure methane and for the mixtures which will be processed should be supplied.

As part of the process, it is proposed to pump large volumes of water from the Shannon to provide a source of heat. The water will be returned to the estuary but at a lower temperature and contaminated with sodium hypochlorite. Computer modelling has been done to show the returning water will dissipate quickly and should not damage the natural environment. It is noted that the waste water from Moneypoint and Tarbert also contains chlorine but they are far enough away that they cannot be detected at the LNG site. Has any work been done on the effect of the actual discharges from Moneypoint and Tarbert to see if the chlorine dissipates as predicted and that it can be shown it has no negative effect on the estuary ?

Conclusion

We would ask An Bord Pleanala to take the above points into consideration before making a decision in this case.

Yours faithfully,

Catherine McMullin

An Taisce, Kerry Association