Paul Kenny and Eamon Ryan. Source:
https://www.linkedin.com/posts/paulgkenny_an-incredible-four-years-working-as-advisor-activity-7217454220113756161-jyXC
Paul Kenny was Green Party Leader, Eamon Ryan's special advisor for
4 years and
strong supporter of the State-led LNG terminal proposed by Minister
Ryan, who was then Minister for Energy in Ireland. His answers at the
Oireachtas
Committtee
hearing
on the proposed Strategic Gas Emergency
Reserve Bill 2025 appeared almost Machiavellian to us and
contradictory. We decided to put them through ChatGPT to confirm that
we were not mistaken in how he seemed to structurally undermine
environmental goals of energy policy in Ireland in a really devious
way, almost like the enemy from within, while, we felt, trying to give
the
impression that he was for the environment. A master in gaslighting was
our conclusion, and we thought that it was no wonder so many
naive environmental organisations and Green Party supporters were taken
in by the
tactic of changing the label of a US fracked gas LNG import terminal to
a nonsense label of temporary, strategic, non-commercial,
non-entry-point, third-party-access-prevented,
emergency-use-only gas reserve even though it would supply 13% of the
gas
market. In other words, a commercial LNG terminal masquerading as a Gas
Storage facility. In this vein, we were disappointed, but not
surprised
with his misleading statements such as "
From a climate impact
perspective, if this terminal is built and, true to what the Department
actually says, it stays as a strategic reserve; if gas is not used to
accelerate the regasification; and if we literally stay on boil-off
gas, it will not make a very large difference to the global climate" and "
we
could use the legislation to state that any use of gas in an emergency
situation would be outside the sectoral emissions ceilings and the
national carbon budget"!!
We asked ChatGpt two questions on the
submissions by Paul Kenny to the
Oireachtas Committee on Climate Change pre-legislative scrutiny
hearings.:
Outline
the contradictions in Paul Kenny's statements to the oireachtas
committee on climate change here, and
What
if we add the arguments from safety before LNG's
submission 1 and
submission 2. What would
be the weaknesses in Paul Kenny's position then?
The
answers and conclusions are amazing and show the clear contradictions
in his position - and ultimately the position of his political master
at the time - the Green Party Leader Eamon Ryan.
Answer to first question:
Here is a structured outline of tensions and contradictions in
Paul Kenny’s statements to the Oireachtas committee. These are not
necessarily logical impossibilities, but areas where his position
shifts, qualifies itself, or pulls in different directions.
1️⃣ “We should not focus on gas” vs “This FSRU is the right solution to the hybrid attack risk”
Statement A:
He repeatedly argues that Ireland’s real energy security solution is:
Statement B:
When pressed specifically on the single hybrid attack risk (interconnector sabotage), he states:
“In short, no” — there is no better alternative than the FSRU in the timeframe available.
Tension:
He
criticises the FSRU as addressing only a narrow risk and not broader
security threats, yet concedes that for the specific risk identified in
the Energy Security Review, it is the correct mitigation.
This creates a dual position:
2️⃣ “This will not improve broader energy security” vs “It is exactly the right solution”
He says:
The FSRU does not address European LNG vulnerability
It does not protect against broader geopolitical conflict
It does not reduce systemic dependence
Yet he also says:
“If we were concerned about a boat dropping an anchor… this is exactly the right solution.”
Contradiction tension:
He
downplays the security value of the FSRU at a macro level but
simultaneously affirms it as the correct response to the most clearly
identified near-term physical threat.
The inconsistency lies in framing:
3️⃣ “We could meet demand through acceleration” vs “No, we cannot build renewables as fast”
When discussing whether renewables and interconnectors could substitute for the FSRU:
He says:
“Honestly, the answer is yes.” (We could meet N-1 standard if accelerated.)
Later, when asked whether renewables can be built in the same timeframe as the FSRU:
“The answer is ‘No’ because it is one project versus 50 projects.”
Contradiction tension:
So the feasibility shifts depending on whether he is speaking:
4️⃣ “This could cost €1 billion for only 3–5 years of risk mitigation” vs “We need it because renewables will be delayed”
He argues:
Offshore wind and demand reduction will reduce gas need by early 2030s.
Therefore, the FSRU could be obsolete after only a few years.
It could be €1bn for a narrow and temporary risk.
But earlier he acknowledges:
Planning and delivery delays are real.
Renewables are already years late.
The State cannot mobilise fast enough.
Tension:
If
renewables are structurally delayed and the State cannot accelerate
delivery, the FSRU may not be short-lived. His own diagnosis of
systemic delay undercuts his suggestion that the facility would only be
needed briefly.
5️⃣ “Commercial LNG would damage renewables” vs “If limited to reserve use, climate impact is small”
He makes two distinct arguments:
A. Climate/system risk argument
Commercial LNG would undermine renewables
It would divert investment
It would increase gas dependence
B. Climate accounting argument
If used only as a reserve
If limited to boil-off gas
If it displaces UK-regasified LNG
→ “It will not make a very large difference to the global climate.”
Tension:
He
shifts from strong structural opposition (commercial LNG undermines
renewables) to a more neutral climate accounting position (limited
reserve use makes little difference).
The contradiction lies in:
6️⃣ “The State is under-resourced” vs “The Department can do this”
He argues:
CRU is 10 years late
Planning bodies are under-resourced
NPWS lacked mapping capacity
REPowerEU transposition took four years instead of six months
Resource allocation is the core problem
But when asked if the Department can handle the bespoke planning process for the FSRU:
“The Department would be well capable of doing that.”
Then he qualifies:
“But those resources will then not be working on the things we need…”
Tension:
He criticises systemic under-resourcing but affirms capacity for this emergency project — implying:
7️⃣ “FSRU does not reduce systemic LNG risk” vs “It displaces UK LNG”
He says:
But also:
It would displace LNG currently regasified in the UK and sent to Ireland.
This suggests:
The tension is subtle but present.
8️⃣ “We should stop digging” vs “This is physics, Corrib decline is inevitable”
He argues strongly for:
Yet when Corrib decline is discussed, he dismisses it as irrelevant to energy security.
This underplays the domestic supply decline that partly drives the emergency reserve argument.
Overall Pattern
Paul Kenny’s position is not outright contradictory, but layered and conditional:
Strategic Position | Operational Concession |
|---|
Long-term answer = renewables + demand reduction | Short-term hybrid attack risk = FSRU |
Systemic LNG risk not solved | Single interconnector sabotage risk solved |
Acceleration could work | Realistically too slow |
Climate impact limited (if restricted) | Commercial LNG would be damaging |
He holds:
The tension comes from oscillating between those frames without always clearly distinguishing them.
Core Contradiction Summary
The central contradiction is this:
He
argues the FSRU is strategically misaligned with Ireland’s long-term
energy security and decarbonisation goals — yet simultaneously concedes
it is the correct and perhaps only realistic short-term mitigation for
the specific hybrid interconnector risk identified by the State.
That dual stance makes his evidence nuanced — but also internally strained.
Answer to 2nd question:
If you layer Safety Before LNG’s arguments on
top of Paul Kenny’s evidence, the weaknesses in his position become
more structural and legal rather than just strategic.
Kenny’s argument is primarily:
The FSRU is justified only as a narrow N-1 contingency.
It must be tightly limited.
It must not become commercial.
It must not expand gas demand.
It should have sunset clauses.
It should not undermine renewables.
Safety Before LNG’s submissions attack the assumption that such tight limitation is legally and politically possible.
When you combine both, here are the main weaknesses that emerge in Kenny’s position:
1️⃣ His argument depends on a legal assumption that may not hold
Kenny repeatedly says:
If robustly limited to emergency use only…
If it is not a commercial terminal…
If gas use is capped…
If commercial LNG is prevented…
Safety Before LNG argues that under EU gas market law:
LNG terminals are entry points.
TSOs (like Gas Networks Ireland) must grant non-discriminatory third-party access.
Exemptions require structural separation from the TSO.
A State-owned LNG terminal operated by GNI cannot legally deny access to commercial suppliers.
If that legal interpretation is correct, then Kenny’s central condition collapses:
The FSRU cannot be “emergency-use only” in the way he assumes.
Weakness in his position:
He does not address EU third-party access law at all.
His
entire support for the FSRU rests on it remaining non-commercial. If
that is legally impossible, his conditional support becomes internally
unstable.
2️⃣ He treats commercialisation as a policy risk — not a structural inevitability
Kenny says commercial LNG would:
But he treats this as something the committee can “scrutinise away.”
Safety Before LNG argues:
Commercial access may not be optional.
The Bill allows private entities to apply.
Ministerial powers override planning.
There is no structural safeguard against market entry expansion.
Once built, the terminal creates de facto market capacity.
Weakness:
Kenny assumes commercialisation is avoidable through good drafting.
Safety Before LNG suggests it may be legally unavoidable once infrastructure exists.
If true, then Kenny is underestimating path dependency and regulatory lock-in.
3️⃣ He underestimates the “entry point” problem
Kenny says:
It would merely displace UK-regasified LNG.
Climate impact would be marginal if restricted.
It does not increase supply if controlled.
Safety Before LNG argues:
6 tankers per year = 13% of national demand.
That constitutes a new entry point.
Under EU law, that changes market structure.
It creates rights for private operators.
It may undermine refusal of Shannon LNG.
Weakness:
Kenny treats physical gas flows as neutral if limited.
Safety Before LNG treats infrastructure as structurally transformative.
He focuses on emissions and contingency logic.
They focus on market law and precedent effects.
If the infrastructure legally becomes a market entry point, his “limited impact” framing becomes weaker.
4️⃣ He does not address governance concentration risks
Kenny’s focus:
Resource constraints.
Planning delays.
Implementation capacity.
Safety Before LNG’s focus:
Minister self-approval.
Disapplication of planning law.
Deemed climate compliance.
Override of An Coimisiún Pleanála.
Reduced judicial review access.
Kenny does not meaningfully engage with the governance architecture of the Bill.
Weakness:
His
support for the FSRU as a narrow emergency measure ignores whether the
governance mechanism is proportionate or constitutionally robust.
He treats it as a technical energy question.
The submission frames it as a democratic power-concentration issue.
5️⃣ He does not reconcile Climate Act compliance with “deemed compliance”
Kenny argues:
The Climate Act should not be disapplied.
Emergency use could be placed outside sectoral ceilings.
There should be airtight limitations.
Safety Before LNG argues:
The Bill “deems” compliance.
That bypasses actual compatibility.
Operating 13% supply increases emissions materially.
€8–26bn EU exposure risk exists.
Weakness:
Kenny suggests legal drafting fixes (sunset clause, emission carve-outs).
But he does not address whether emergency LNG use could legally sit outside EU obligations or effort sharing targets.
His argument is practical.
The submission frames the issue as financial and EU law exposure.
6️⃣ His “short-term only” framing becomes unstable if emergency lasts years
Kenny says:
Safety Before LNG points out:
LNG tankers require constant replenishment.
Boil-off means continuous operation.
It cannot simply sit unused without import cycles.
Weakness:
If
technically the FSRU must import periodically to remain viable, then
the line between “emergency reserve” and “operational entry point”
blurs.
Kenny does not deeply engage with operational mechanics.
7️⃣ He concedes no better alternative — which strengthens the case against his broader critique
Kenny admits:
No better short-term mitigation exists.
Renewables cannot be built in time.
Interconnectors take longer.
If Safety Before LNG’s legal argument blocks emergency-only operation, then:
Either:
This traps his position:
He supports it conditionally but does not offer a viable alternative within the timeframe.
8️⃣ He does not engage with litigation risk symmetry
Safety Before LNG raises:
If the State operates LNG commercially,
How can it refuse private LNG terminals?
Could refusal trigger trade/investment litigation?
Kenny argues:
Weakness:
He does not examine whether the State can both:
Under EU competition and internal market law, that may be harder than he assumes.
9️⃣ His argument relies heavily on political good faith
Kenny’s position works if:
The Department strictly limits use.
Sunset clauses are enacted.
Third-party access is blocked.
Planning safeguards are restored.
Commercial LNG is legally prevented.
Safety Before LNG’s submission assumes:
Institutional drift.
Power expansion.
Legal ambiguity.
Market pressure.
Ministerial discretion.
Regulatory capture risk.
Kenny’s model assumes disciplined governance.
The submission assumes institutional opportunism.
The Core Vulnerability in Kenny’s Position
His argument is coherent only under these conditions:
Emergency-only use is legally enforceable.
Third-party commercial access can be prevented.
The facility does not become a market entry point.
Climate compliance can be preserved.
The governance model is constitutionally sound.
Safety Before LNG challenges all five simultaneously.
If even one collapses (especially EU third-party access), then:
The FSRU becomes structurally commercial.
Gas demand likely increases.
Private LNG becomes harder to block.
Climate exposure increases.
Kenny’s “narrow contingency tool” framing breaks down.
Final Synthesis
Without Safety Before LNG:
Kenny’s position is nuanced but defensible.
With Safety Before LNG’s legal and governance critique added:
His position appears:
Technically literate
Strategically cautious
But legally under-developed
Institutionally optimistic
And dependent on assumptions about regulatory control that may not hold
The biggest weakness exposed is this:
Kenny treats the FSRU as a controllable policy instrument.
Safety Before LNG treats it as a structural market intervention that cannot be neatly constrained once built.
That is the fault line.