Green Party Leader Eamon Ryan's proposal to construct an LNG US fracked gas import terminal in Ireland's Energy Security Strategy needs to be stopped because it  is based on outdated and unrealistic assumptions, raises serious legal concerns about its feasibility and  ignores viable alternative solutions.

Outdated: 
Legally Compromised:

Deceptive:

Minister Ryan is to bring a memorandum to Government for decision in Quarter 2, 2024 following a detailed examination by Gas Networks Ireland of LNG scenarios that do not increase the supply of gas available on the market - an impossible task. The Government must reconsider this outdated plan and instead prioritise genuine measures to enhance energy security while safeguarding the environment and upholding Ireland's commitment to climate action.

Click here to read the full briefing document prepared by Safety Before LNG and Love Leitrim on Time to why it is time to call a halt to outdated Plans for an Irish LNG Fracked Gas Import Terminal proposed by Minister Ryan in the Energy Security Strategy 2 months before the announcement of Corrib Extension, 42 % increase in Moffat capacity and twinning of the gas interconnectors.

Main Issues

• Breaking his party’s “green” red line for going into a coalition government in 2020, it is now the Irish Green Party Leader himself, Minister for Energy Eamon Ryan, who has actually proposed building an LNG terminal in Ireland in the Energy Security Strategy published on November 15th, 2023 - in breach of the world’s only published policy against the importation of fracked gas and the construction of LNG terminals and in breach of Minister Ryan’s own pre-government promise to “implement the policies which will see an end to the importation of fracked gas via any LNG terminals in Ireland".
• The LNG terminal proposal was proposed by Minister Ryan two months before news emerged that he extended an exploration licence at Corrib in County Mayo at the huge Inishkea West site, which could see gas flowing within 2 to 4 years from the Corrib Site.
• The pretext used by Minister Ryan for proposing a new entry point for gas into Ireland was that Corrib gas production was running out and the need to address the unlikely event that two undersea gas interconnectors of Norwegian and British North Sea gas from Scotland to Ireland are out of action at the same time, a 1 in 1,600 year event the Energy Strategy itself found.
• However, after the Energy Strategy -  which identified the highest risk to neutral Ireland’s gas system was damage to a pipeline, valves or compressors -  was published,  Gas Networks Ireland (GNI) confirmed that it is “eliminating the presence of a single point of failure” making the two pipelines from Moffat in Scotland entirely independent of each other - undermining the entire basis on which the proposal to build an LNG terminal was made by the Minister.
• GNI has also confirmed that its reinforcement of the existing infrastructure in Scotland will lead to a massive 42% increase in gas capacity from Moffat to Ireland  by 2026/27 to 428 GWh/d to deal with a maximum peak forecast of 323 GWh/d in 2030, concluding that the country will have adequate import capacity from Moffat for all predicted gas demand.
• The Energy Strategy declares that an LNG terminal would still not be acceptable to the government because it would import fracked gas, the embedded emissions would exceed pipeline gas and availability of gas at a time of crisis was not guaranteed. To circumvent opposition,  Minister Ryan has conjured up a  proposal that the country could build a state-led, strategic, back-up, unused LNG terminal to store gas as an emergency reserve which would not be commercial.
• However, as shown in this document, there is no such thing as a non-commercial LNG terminal because all LNG terminals are commercial LNG terminals, because the energy strategy admitted that no such strategic LNG terminal exists anywhere in the world and that it is not technically feasible to hold LNG for extended periods in a strategic back-up, unused LNG terminal (with, as the ESB explained, 73% of the gas boiling off  in a year for floating LNG terminals which are a transportation technology rather than a storage technology), because Gas Networks Ireland said that a  floating LNG terminal (FSRU) “would normally be used for commercial gas sales”, because Minister Ryan told the Dáil that it would be used "for periods when the wind is not blowing" and because the Taoiseach even confirmed in the Dáil that the LNG terminal would be replenished “every couple of months”.
• In addition, the Energy Strategy has not even confirmed if the European Commission would allow an exemption preventing 3rd party fracked gas importers from accessing any LNG terminal in Ireland.
• The Energy Strategy has, furthermore, not confirmed if it has legal certainty that it can prevent the construction of other LNG terminals in Ireland if it allows one LNG terminal to be built - which would signal the end of the ban on fracked gas imports.
• The Energy Strategy even found that Ireland can still meet its gas needs if the largest piece of infrastructure - interconnector 2 (IC2) - fails for a period of 30 days, by using Interconnector 1 (IC1), Corrib and the buildup of the volume of gas already in the network (linepack).
• Ireland only meets at 65%  the EU infrastructure standard N-1 value, last measured in 2022, which requires that there must be enough gas to meet peak gas demand if the largest piece of infrastructure (IC2) fails, without including linepack. However, with its reinforcement of the existing infrastructure in Scotland which will lead to a massive 42% increase in gas capacity from Moffat to Ireland  by 2026/27, GNI says that the N-1 value now needs to be re-calculated.
• The Energy Review has not considered the feasibility of GNI further increasing capacity on the interconnectors  by decoupling the more than 80 GWh/d  Scotland to Northern Ireland pipeline (SNIP) from IC1 in Scotland - comparable to the twinning of the interconnector in Scotland completed in  2017 at a cost of approximately €100 million.
• Ireland and Malta were the only two EU Member States increasing gas demand from August 2022 to March 2023, at a time of war, in breach of EU Regulation 2022/1369 obliging countries to reduce gas use, while GNI says gas demand actually reduced by 7% in 2023.  Even so, Ireland is now attempting to create a new gas entry point under the guise of energy security to feed this demand in gas consumption.
• A legal loophole which allows islanded data centres (not connected to the electricity grid) to apply for gas grid access must be closed as this automatically transfers their security of supply risk from electricity to gas and increases the overall peak day demand for gas. 25 islanded data centres have contacted the energy regulator (CRU) regarding grid access for a power generation capacity of 9,000 megawatts - which is almost equal to the entire dispatchable electricity on the island of Ireland.
• The international context changed dramatically when, on January 26th, 2024, the US Government, on the grounds of the perilous impacts of methane,  announced a pause in the approval of LNG export terminals.
• It is clear that the energy strategy proposed by Minister Ryan based on full disruption of gas imports from Scotland is now outdated . The shortlisted gas mitigation package rejected by the Energy Review, with the now-enhanced capacity  advantages of the elimination of the single point of failure on the interconnectors, the decoupling of the SNIP from IC1, the closing of islanded data centre loopholes and further gas demand reduction, must now be brought back onto the table for re-appraisal  based on the outage of only one of the interconnectors.

Click here to read the full briefing document prepared by Safety Before LNG and Love Leitrim on Time to why it is time to call a halt to outdated Plans for an Irish LNG Fracked Gas Import Terminal proposed by Minister Ryan in the Energy Security Strategy 2 months before the announcement of Corrib Extension, 42 % increase in Moffat capacity and twinning of the gas interconnectors.

End.
Contact:
John McElligott
Safety Before LNG
(087-2804474)
[email protected]
https://twitter.com/SafetyBeforeLng