Kilcolgan
Residents Association
March 7th, 2008
Re:
Serious New Information on H�egh LNG
and Irish Sea Offshore Gas Storage for PA0002 post oral hearing into
the proposed LNG terminal in County Kerry.
Since the fast-track oral
hearing into the proposed LNG terminal at Tarbert, County Kerry held
from January 21st to 30th 2008,
profoundly-serious new information has come to light which is so
important that it will have to be taken into consideration if a
fully-informed decision is to be made.
This information covers
the following 8 areas:
The Norwegian LNG
company, H�egh LNG,
has announced its intention to develop another Offshore
LNG terminal 35 Kilometres also
off the coast of Blackpool in Morecambe Bay – in the Irish
Sea. The project – called
“Port Meridian Offshore Morecambe Bay”-
will use SRV technology, which is an LNG vessel with onboard LNG
vaporisers.
Separately, a new
offshore gas storage facility, also in the Irish
Sea 24 Kilometres off the coast of Britain and
approximately 100 miles from Dublin is at an advanced planning stage
and is expected to come on stream by 2011. This real, tangible
example of an offshore gas storage facility so close to Ireland
proves categorically that the offshore alternative proposed by us at
the oral hearing and planned by Exxon Mobil off the coast of New
York, is able to be put into practice in Irish waters and cannot now
be ignored as a viable and safe alternative to the proposed LNG
terminal at Tarbert.
The “Gateway Gas
Storage Project”
is being project-managed by Stag Energy Development Company Ltd for
Gateway Storage Co. Ltd. Gateway is building a natural gas
storage facility to store natural gas offshore in 20 man-made
underground caverns, created specially in the salt strata underlying
the Irish Sea. Gateway has stated that, once commissioned, the
facility will help to substantially improve the security of energy
supplies for both the UK and the Irish Markets.
Both
Gateway and H�egh LNG have highlighted the benefits of their
projects as having no negative visual impact and especially of
enhancing safety to the general public. Once completed, a permanent
500 metre safety zone, representing a total 12
square kilometre exclusion zone,
will be created around the whole facility. This is therefore setting
an extremely serious precedent which the Health and Safety Authority
should now be made aware of in its evaluation of the Hess LNG project
at Tarbert and which An Bord Plean�la should take into account in
its evaluation of the sterilisation of the remaining Landbank and
risk to the residents and landowners of Kilcolgan. This offshore
exclusion zone in the Irish Sea does not even have to consider the
general public meaning that any onshore exclusion zone would
obviously have to be larger than that.
An
Executive meeting of Blackpool Council took place on February 13th,
2008 to consider both the Gateway Gas Storage and H�egh LNG Port
Meridian Terminal projects.
The Executive meeting recommended acceptance of the project by the
Council subject to receiving assurances from the Health and Safety
Commission that there will be no risks of explosion from that
facility to Blackpool residents or visitors. Both projects, although
not connected, can operate in parallel.
Rudall
Blanchard Associates, a specialist environmental and planning
consultancy, completed the Environmental Impact Assessments
and is acting on behalf of both Gateway and H�egh LNG.
Exxon Mobil has
decided to press ahead with its drilling commitment on
its giant Dunquin prospect in Porcupine basin off the west coast of
Kerry. On February 21st
2008 it announced that it is looking for farm-in partners to allay
the cost of drilling. ExxonMobil said two prospects have been
identified, Dunquin North and Dunquin South. Both are anticipated to
hold gas or gas/condensate with the estimated potential to hold over
18 trillion cubic feet of gas; Corrib holds only one trillion cubic
feet.
Throughout the oral hearing into the proposed Hess LNG terminal at
Tarbert it was claimed that Ireland was running out of gas because
Corrib was only expected to provide 40% of national
gas needs at most when it comes fully on stream. This means that in
the medium term, Ireland will be a net exporter of Gas, as Norway
and the UK currently are. This issue on whether or not Ireland will
become a net exporter of gas in the medium term needs to be
reassessed as this would bring into question the stated need for an
onshore LNG terminal – supplying gas to Ireland. It would seem now
that the aim in the medium term will be to use the terminal for even
more export of gas via the pipelines to the UK and Continental
Europe from Ireland. Why put our lives at risk if that is the case?
Shannon LNG and Hess
LNG stated throughout the oral hearing that Ireland is running out
of gas, yet Hess Exploration Ireland have just taken a 42% share in
two exploration licences from the Norwegian group Statoil, in
partnership with Shell Ireland, in the Slyne-Erris Basin.
This proves that even HESS itself is really of the opinion that
there are huge quantities of gas in Ireland and the firms are
expected to start drilling in 2008.
Marathon Oil
announced on February 20th 2008 that it is selling its
Irish operations. The depleted reservoirs could therefore be bought
out by the Irish state and used as a natural gas storage facility as
proposed by the Gateway Gas Storage facility in the Irish Sea.
Indeed, within
hours of the Marathon announcement, Bord G�is �ireann chief
executive, John Mullins, said the State-owned gas company would be
taking a serious look at acquiring some, or all of Marathon’s
Irish assets.
Bord
G�is would be interested in Marathon’s stake in the Corrib gas
field and the strategic undersea storage facilities owned and
operated by Marathon. Bord G�is has the resources and access to
funds to comfortaly buy some or all of the assets on offer. This
therefore brings into question the need for a dangerous onshore LNG
terminal at Tarbert.
We believe that
serious misrepresentation by Shannon Development has taken place at
the Oral Hearing in Tralee from January 21st -30th
2008. Shannon Development has NO REMIT for
attracting industrial development since this role was taken off them
in 2005 following an announcement by Micheal Martin TD that “the
existing enterprise support functions carried out by the Company in
relation to both the indigenous and overseas enterprises will be
assumed by the national agencies, Enterprise Ireland and IDA
Ireland”.
This means that all expert opinion given by Shannon Development at
the Oral Hearing had no value as they are no more than property
owners and in our opinions completely misrepresented their actual
areas of expertise throughout the eight days of the oral hearing.
Shannon Development misrepresented their organisation as an inward
investment facilitator, we believe. They should have outlined their
remit clearly so anything they had to say could be taken in context.
We are now of the opinion that the IDA and Enterprise Ireland should
answer the questions that were originally posed to Shannon
Development on how they expect a top-tier Seveso II LNG site with an
exclusion zone around it to attract new industry to an area which is
designated in the County Development Plan as lands “for a premier
deep-water port and for major industrial development and employment
creation”.
An earthquake
measuring 5.2 on the Richter Scale hit the UK on February 27th
2008 – the largest in over a quarter of a century. No account has
been taken of the consequences of an earthquake on the proposed
development.
The “Planning
(Location of Hazardous Sites) Bill [Number 55]” was introduced in
the British House of Commons by Mr. Bob Spink MP (Castle Point) on
January 15th 2008.
The Bill will require the introduction of binding guidance regarding
minimum distances between developments classified as Control of
Major Accident Hazard sites and other specified types of building;
and for connected purposes: The Bill was ordered to be read a Second
time on Friday 6 June 2008, and to be printed. We believe that in
the absence of specific legislation in Ireland on exclusion zones
around top-tier Seveso II sites, the HSA should await the outcome of
this Bill for the precedent of best practice it will set for
Ireland.
When introducing
the Bill, Mr. Spink stated that “the Bill seeks to improve
protection for communities across Britain from the new development of
potentially dangerous industrial sites. It will ensure increased
safety by giving the Health and Safety Executive a framework for
COMAH plant siting decisions, thereby improving the consistency of
such decisions and affording a predetermined level of protection for
communities.” He argued that his Bill “would increase and
formalise the protection afforded to communities” and that it would
“give clarity and certainty to applicants, the HSE and planning
authorities, saving time, expense and much community anguish.” He
stated that the “Planning Bill fails conspicuously to give the
necessary procedural rigour for the infrastructure planning
commission (IPC) to deal with the location of hazardous sites.”
He argued that the Planning Bill “will cause more difficulties”
as “the location of a dangerous plant will be decided by an
unelected quango”. We feel that the Bill deals with the same issues
as we are faced with in Ireland and would like both the HSA and An
Bord Plean�la to take cognisance of the issues raised therein.
Recent reports in
the media since the oral hearing took place have raised issues that
we feel ought to be considered by An Bord Plean�la and the HSA in
its consideration of the LNG planning application:
Calls have been
made for an inquiry into alleged profiteering by energy giants
following the announcement, on January 21st 2008, by
British Gas of a 500% increase in profits..
Dr. Jerry Havens
and Dr. James Venart have had another peer-review article accepted
for publication by “The Journal of Hazardous Materials” on 7
February 2008 entitled “Fire Performance of LNG Carriers
Insulated with Polystyrene Foam”.
The Irish Constitution – Bunreacht na hEireann – states in
Article 40 (1) that “All citizens shall, as human persons, be held
equal before the law”. It states in Article 40 (3)(1) that “The
State guarantees in its laws to respect, and, as far as practicable,
by its laws to defend and vindicate the personal rights of the
citizen”. And in Article 40(3)(2) it states that “The State
shall, in particular, by its laws protect as best it may from unjust
attack and, in the case of injustice done, vindicate the life,
person, good name, and property rights of every citizen.”
We expect that An Bord Plean�la and the HSA, as an organ of the
state should uphold these aforementioned constitutional rights in our
interest. As residents of a sparsely-populated area we want to be
treated with the same degree of protection from danger as residents
of a more densely populated area, such as Dublin would be as obliged
by Article 40(1).
Our right to life is being threatened by the siting of an LNG
terminal close to our homes and properties where world-renowned LNG
expert Dr. Jerry Havens clearly stated in the oral hearing how people
within a three-mile radius would be in danger in the case of an
accident. Under Article 40(3)(1) and 40(3)(2) we now formally request
that our lives and property be protected and that the consequences of
an LNG accident be taken into considerations as opposed to the purely
probability-based (and, in our opinion, unconstitutional) approach of
the Health and Safety Authority – especially since an example of a
perfectly safer alternative is now being put into practice in the
Irish Sea. We equally ask, for the same constitutional reasons, that
this new information be taken on board in the decision-making process
because we are of the opinion that we, as a
country, had best be careful about the freedoms of individuals that
we take away in order to benefit a larger group or organisastion.
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