Exposing the truth about the Hess 'Shannon LNG' project

HOME

European Commission

Consultation on the list of candidate Projects of Common

Interest in gas infrastructure

[email protected]

Submission against the Addition

'PCI 5.3 Shannon LNG' Terminal and Connecting Pipeline'

and

its enabling and connected projects

'PCI 5.1.1 Moffat Physical Reverse Flow (IE/UK)'

'PCI 5.1.2. SNIP Physical Reverse Flow (NI/GB)'

the 4th Union List of Projects of Common Interest

29th May 2019

INTRODUCTION

PCI accreditation from the European Commission is an extremely powerful initial development consent for gas projects such as the proposed Shannon LNG US fracked gas import terminal because it sets the framework for future development consent within the Member States. Article 7 of the PCI Regulation states that "projects of common interest shall be allocated the status of the highest national significance possible and be treated as such in permit granting processes". The Regulation goes on to state that "With regard to the environmental impacts addressed in Article 6(4) of Directive 92/43/EEC and Article 4(7) of Directive 2000/60/EC, projects of common interest shall be considered as being of public interest from an energy policy perspective and may be considered as being of overriding public interest, provided that all the conditions set out in these Directives are fulfilled".

The boom in proposed LNG import terminals throughout Europe is motivated by the expansion of the US fracking industry which has moved the US from being a net importer to an exporter of gas. However, this comes with a high environmental, public health and climate change price. The most up-to-date scientific knowledge is categorical on the following points: The number one climate threat in Europe is fracked gas. Cornell University's Professor Robert Howarth, a leading scientist in this area, states that this is no bridge fuel, that switching from coal to shale gas is accelerating rather than slowing global warming, that methane's impact on climate over 10 years is 105 times more potent than carbon dioxide, that one half of Methane emissions in the US is coming from Shale Gas Leakage and that, to put it simply, fracked gas is the dirtiest of all fossil fuels with a bigger climate footprint than coal. This was not the thinking over 10 years ago when the Shannon LNG project initially obtained planning permission.

Indeed, DG Trade, in its final Trade Sustainability Impact Assessment (SIA) on the Transatlantic Trade and Investment Partnership (TTIP) between the EU and the USA in March 2017, citing the UN Framework Convention on Climate Change (UNFCCC), the Kyoto Protocol and the Paris Agreement found that while a shift to gas away from coal in the EU could lead to some environmental gains "locally", "environmental benefits from LNG over coal (which are debatable due to methane leakage during extraction and energy needed during production, conversion and transport) are perhaps even negative if a combination of LNG+coal crowded out ‘greener’ energy sources such as renewables in the global energy mix".

However, The European Commission is proceeding, nevertheless, with the implementation of the Energy Plan to import fracked US gas announced by President Juncker in July 2018 following his visit to President Trump in the USA through multiple LNG terminals and countries and imposed via the PCI procedure. We assert that this represents unlawful State Aid and Misuse of aid at each Member State Level and is also a breach of the SEA Directive, which requires an assessment of reasonable alternatives before a plan. A project is not allowed to have the PCI status unless it is approved by the Member State because Article 3.3(a) of Regulation 347/2013 states "each individual proposal for a project of common interest shall require the approval of the Member States, to whose territory the project relates". The current PCI list was approved by Ireland on 17th October 2017.

Shannon LNG is applying once more for inclusion on the 4th PCI list on the grounds that it promotes diversification and gives security of supply to Ireland. However, this criteria is not fulfilled since the N-1 condition through a joint risk approach where Ireland and the UK are treated as a single region was already achieved and will be enhanced with the completion of the construction of the twinning of the second independent interconnector from Brighouse to Cluden in Scotland (PCI 5.2). The PCI 5.2 Twinning of the Interconnector for the final 50km in Scotland already brings security of supply to Ireland with 2 completely independent interconnectors, representing 2 separate pieces of gas infrastructure. In addition, the European Commission itself recognises that Ireland and the UK represent the one "area" in the gas region that is the North-South gas interconnections in Western Europe (‘NSI West Gas’) priority corridor. The UK already has access to US fracked gas imports with the first fracked gas imports arriving to the UK in September 2018. This also means that the security of supply and competition criteria put forward by Shannon LNG will not be met technically because the UK already has access to appropriate connections, diversion of supply sources, supplying counterparts and routes .

If anything, an LNG terminal for fracked US gas in Ireland will create fossil fuel lock in and compromise the development of the indigenous biogas industry, which could help in the reduction of the GHG emissions from the agricultural sector. Developing domestic renewable energy sources could enhance the country’s energy security in the middle to long term

Ireland banned both fracking and the importation of fracked gas. Why is there no consideration of fracked gas in the energy mix of what is being supplied under the generic heading of “LNG”? Only one Member State is affected - Ireland - unless the aim is to export gas from Shannon LNG to the UK (once the PCI project of the Reverse Flow of the Interconnector to Moffat is implemented) , benefiting from lower corporation tax in Ireland and the implementation of the US-EU trade deal. The Trade Deal should have nothing to do with the PCI process.

Ultimately, the Shannon LNG project in particular, and the importation of fracked US gas to Europe in general, is a highly politically-motivated energy plan which is favouring trade over climate, which gives strong support for the removal of Shannon LNG from the proposed list of Projects of Common Interest.

Click Here to Download full PCI Submission by Safety Before LNG

INTRODUCTION

PCI accreditation from the European Commission is an extremely powerful initial development consent for gas projects such as the proposed Shannon LNG US fracked gas import terminal because it sets the framework for future development consent within the Member States. Article 7 of the PCI Regulation[1] states that "projects of common interest shall be allocated the status of the highest national significance possible and be treated as such in permit granting processes". The Regulation goes on to state that "With regard to the environmental impacts addressed in Article 6(4) of Directive 92/43/EEC and Article 4(7) of Directive 2000/60/EC, projects of common interest shall be considered as being of public interest from an energy policy perspective and may be considered as being of overriding public interest, provided that all the conditions set out in these Directives are fulfilled".

The boom in proposed LNG import terminals throughout Europe is motivated by the expansion of the US fracking industry which has moved the US from being a net importer to an exporter of gas. However, this comes with a high environmental, public health and climate change price. The most up-to-date scientific knowledge is categorical on the following points: The number one climate threat in Europe is fracked gas. Cornell University's Professor Robert Howarth, a leading scientist in this area, states that this is no bridge fuel, that switching from coal to shale gas is accelerating rather than slowing global warming, that methane's impact on climate over 10 years is 105 times more potent than carbon dioxide, that one half of Methane emissions in the US is coming from Shale Gas Leakage and that, to put it simply, fracked gas is the dirtiest of all fossil fuels with a bigger climate footprint than coal.[2] This was not the thinking over 10 years ago when the Shannon LNG project initially obtained planning permission.

Indeed, DG Trade, in its final Trade Sustainability Impact Assessment (SIA) on the Transatlantic Trade and Investment Partnership (TTIP) between the EU and the USA in March 2017[3], citing the UN Framework Convention on Climate Change (UNFCCC), the Kyoto Protocol and the Paris Agreement found that while a shift to gas away from coal in the EU could lead to some environmental gains "locally", "environmental benefits from LNG over coal (which are debatable due to methane leakage during extraction and energy needed during production, conversion and transport) are perhaps even negative if a combination of LNG+coal crowded out ‘greener’ energy sources such as renewables in the global energy mix".

However, The European Commission is proceeding, nevertheless, with the implementation of the Energy Plan to import fracked US gas[4] announced by President Juncker in July 2018[5] following his visit to President Trump in the USA through multiple LNG terminals and countries and imposed via the PCI procedure. We assert that this represents unlawful State Aid and Misuse of aid at each Member State Level and is also a breach of the SEA Directive, which requires an assessment of reasonable alternatives before a plan. A project is not allowed to have the PCI status unless it is approved by the Member State because Article 3.3(a) of Regulation 347/2013 states "each individual proposal for a project of common interest shall require the approval of the Member States, to whose territory the project relates". The current PCI list was approved by Ireland on 17th October 2017[6].

Shannon LNG is applying once more for inclusion on the 4th PCI list on the grounds that it promotes diversification and gives security of supply to Ireland. However, this criteria is not fulfilled since the N-1 condition through a joint risk approach where Ireland and the UK are treated as a single region was already achieved[7] and will be enhanced with the completion of the construction of the twinning of the second independent interconnector from Brighouse to Cluden in Scotland (PCI 5.2). The PCI 5.2 Twinning of the Interconnector for the final 50km in Scotland already brings security of supply to Ireland with 2 completely independent interconnectors, representing 2 separate pieces of gas infrastructure. In addition, the European Commission itself recognises that Ireland and the UK represent the one "area" in the gas region that is the North-South gas interconnections in Western Europe (‘NSI West Gas’) priority corridor[8]. The UK already has access to US fracked gas imports with the first fracked gas imports arriving to the UK in September 2018. This also means that the security of supply and competition criteria put forward by Shannon LNG will not be met technically because the UK already has access to appropriate connections, diversion of supply sources, supplying counterparts and routes .