llihies, County Cork, Ireland

http//www.friendsoftheirishenvironment.org

The Secretary,

An Bord Pleanala,

Marlborough Street,

Dublin 1,

15 November, 2007

By email: [email protected]

Your References: PL08 .PA0002 and PC 08.PC0002

Our References 07.000456

Re: Re: Planning application by Shannon LNG

Proposed Liquefied Natural Gas (LNG) regasification terminal

Ralappane and Kilcolgan Lower, County Kerry

Dear Sirs;

Friends of the Irish Environment was established in 1997 with a primary objective of monitoring the full implementation of European law.

Article 12 of the EU Seveso II directive states:

“Member States shall ensure that their land-use and/or other relevant policies and the procedures for implementing those policies take account of the need, in the long term, to maintain appropriate distances between establishments covered by this Directive and residential areas”.

In the case of the proposed Liquefied Natural Gas (LNG) regasification terminal on the River Shannon, given the proximity to centres of population and the riparian location, we are concerned that the issue of alternative locations was not properly addressed in the Environmental Impact Statement. [EIS Volume 2.4.1]

The EIS notes that off-shore terminals are a ‘preferred option for environmental and planning purposes’, but rejects their consideration because of ‘cost and technical difficulties.’

‘Considerations of Offshore siting’ omits any reference to the Proceedings of the 2nd International Conference of Renewable Energy in Maritime Island Climate, which took place on 26 – 28 April 2006 and which included a presentation entitled ‘Security of Energy Supply in Ireland - A Key Driver for Renewable Energy’. The authors of this study suggested a location adjacent to the Kinsale Gas field in the following terms:

‘An LNG terminal in Ireland could be constructed near Kinsale Gas Field, connected to the gas platform, thus the existing gas pipeline from the gas field to Inch can be used. In this way, LNG could be used provide at least a quarter of national gas demand or be sufficient entirely for the Cork area [16]. LNG can also be used as seasonable gas storage at the LNG plant (liquefaction and storage during warm season and vaporisation and injection into local pipelines during cold period). This service can increase the volume of storage in Ireland, which is currently limited to what is contained within the pipelines and remaining reserves at the Kinsale Gas Field.’

We would be grateful if this alternative location was considered for the proposed development.

Further, at the proposed location a new pipeline will connect the LNG terminal to the Bord G�is �ireann pipeline network which is approximately 25km to the east of the site. This part of the project is integral to and will cause an inevitable environmental impact which must be considered as part of this application to avoid ‘project splitting’ under the EIA Directive 97/11/EC.

Finally, from an energy regulation and planning perspective, we understand that the licensing of this project is a matter for the Commission for Energy Regulation (CER) who must consider and assess an application for a contractual right to link up to the gas network as required by the Gas Acts.

This licence is, however, in no way an environmental/planning consent. We are anxious that your Board might not provide itself with the necessary technical advice to address the full range of policy planning issues raised by this major development.

This is particularly true as residents are concerned that such independent expert advice may not be within their means; it must, therefore, be made available by your authority in the interest of open and transparent decision making.

Yours, etc.,

Tony Lowes

Tony Lowes

087 2176316

[email protected]

Friends of the Irish Environment

A company limited by guarantee registered in Ireland.

Company No. 326985. Directors: Caroline Lewis, Tony Lowes.

Full mailing address: Allihies, County Cork, Republic of Ireland [No postal code.]

Tel & Fax: 353 (0)27 73131 

Email: [email protected]

Website: http://friendsoftheirishenvironment.net/