Dear Sir/Madam,

This submission is being made by nearby residents of the proposed LNG regasification terminal and by people with close family and economic ties to the area. We are totally opposed to the planning application in its present form and ask that An Bord Pleanála refuse planning permission to Shannon LNG.

It must be highlighted that there are serious environmental, safety, economic, residential-amenity and other concerns surrounding the proposed LNG terminal in Tarbert parish, which have not been raised at all to date. These concerns may be overlooked by the general public until it is too late as the decision by An Bord Pleanála on whether or not to grant planning permission will already have been made. This is because the new fast-track planning process allowed for this application means that all environmental, safety and development issues are being examined in parallel and by different government bodies without the right of appeal in the planning process that would exist if the application was first submitted to Kerry County Council. This is unacceptable because it is depriving the public of meaningful or effective participation in the planning process due to information not being disclosed in a timely manner and therefore removing the transparency that must continue to exist in the planning process. This is contrary to both the Planning and Development Act 2000 and the EU EIA directive. For this reason we herby insist on being allowed to make more submissions once this information has been obtained.

The primary concern is the lack of safety for nearby residents due to the fact that they live too close to the proposed site. Conservative scientific evidence provided below shows that it is unsafe to live within 3 miles of the site. This area covers the villages of Ballylongford, Tarbert and Killimer in County Clare. More seriously, the limited  QRA undertaken by Shannon LNG itself admits categorically that a vapour cloud from a leaked tank could travel as far away as 12.4 kilometers before being ignited (page 32). This will mean that the Kerry towns and districts of Asdee, Moyvane and Beal, the Limerick town of Glin and the Clare towns of Kilrush, Moyasta, Killimer, Knock and Kilmurry McMahon, as well as surrounding countryside, are in the possible fallout zone. This is from Shannon LNG’s own research.

This will therefore also prevent further use being made of the rest of the land bank due to the danger posed to people working nearby, if safety standards are in fact implemented.

The most serious environmental concern is that up to 100 million gallons of chlorinated seawater will be pumped into the estuary daily, causing serious environmental damage to the eco-system of this SAC area. The withdrawal and discharge of huge volumes of seawater would affect marine life by killing ichthyoplankton and other micro-organisms forming the base of the marine food chain unable to escape from the intake area. Furthermore, the discharge of cooled and chemically-treated seawater would also affect marine life and water quality.

The most serious economic concern is that the gas-industry’s own standard-recommended exclusion zone of 2 miles around an LNG tanker will stop shipping – including the Tarbert-Killimer car ferry - in the estuary every time an LNG tanker is in the area (and Shannon LNG plan up to 125 tankers a year) and prevent marine use of the rest of the land bank – if those safety standards are implemented.

Finally, whereas the developer emphasises that it is in the national strategic interest to have an LNG terminal in Ireland, we are of the opinion that only a strategic interest in LNG as another strategic alternative source of gas in Ireland has been accepted and that there has been no acceptance of the strategic need for an LNG terminal if no suitable site in Ireland is found. This distinction is very important because this need for LNG is already being met with the construction of the LNG terminals in the UK which can then provide LNG to Ireland via the existing gas pipeline from the UK. It must also be noted that the developer, in any case, does not guarantee supply of LNG via Tarbert. What is proposed is no more than a private storage and transhipment facility albeit on a very large scale. It does not purport to offer any strategic benefit to the country, nor in reality does the country gain any strategic benefit from it. On the contrary, it undermines the stated government policy. It does so in a number of respects -  in particular by entirely prejudging the outcome of the all-Island study and the strategic goal No. 2 in the government’s white paper on delivering a sustainable energy solution for Ireland.(See 17 below). On that basis alone the application is clearly premature and should be refused.

The methodology used in this submission is to support each topic with data from published scientific reports, governmental reports, decisions and strategy documents, statutory regulations (both Irish and European) and from standards produced by the Gas industry itself. Any reference to non-scientific based claims will be clearly stated. Data was collected initially by various members of the association individually. This was then followed on by a visit to the Dragon LNG plant at Milford Haven in Wales on October 13^th 2007 where the views of concerned residents were noted. Information was raised since then in contacts with Shannon LNG at their office in Listowel on October 15^th, with other local residents in Tarbert in meetings with Shannon LNG representatives on October 18^th and October 29th, and with various governmental, scientific, academic and voluntary organisations in Ireland and abroad. Our concerns were taken seriously by one and all but many questions were left unanswered. The overwhelming feedback has been that a submission of these concerns needs to be made to An Bord Pleanála,

For the reasons given below we submit that the Bord is obliged to refuse the application. We accept that the Bord may of course take a different view. While we reserve our rights to challenge such a view if necessary we make any comments on conditions that could be applied by the bord if it grants permission to the developer entirely without prejudice to our over-riding contention that this application should be refused.

STATUTORY REGULATIONS:

·                     Planning and Development Acts 2000 – 2006. This includes the Planning and Development (Strategic Infrastructure) Act 2006

·                     EU Habitats Directive 92/43/EEC  On the conservation of natural habitats and of wild fauna and flora– as 25 acres of the site is in a Special Area of Conservation (SAC)

·                     EU 1998 Aarhus Convention Directives, Directive 2003/4/EC and Directive 2003/35/EC – on the right of the public to be informed on the environmental impact and being provided with the opportunity to make comments and have access to justice

·                     EIA directive 87/337/EEC as amended by Directive 97/11/EC  - concerning the effects of certain public and private projects on the environment, the precautionary, preventative-action and polluter-pays principles

·                     Seveso II Directive 96/82/EC as amended by 2003/105/EC  – for placements of hazardous sites

·                     EU Water Framework directive 2000/60/EC

·                     Kyoto Protocol

·                     County Clare and County Kerry Development Plans

·                     European Convention on Human Rights Act 2003

·                     Planning and Development (Strategic Environmental Assessment) Regulations 2004

INVALID  APPLICATION

1. The developers in their planning application describe the 10 hectares to be developed offshore as zoned industrial. This is false as it is zoned Special Area of Conservation. We therefore object to this invalid and misleading application and want the whole application to be declared invalid – as would be the case if an individual made such a serious and misleading mistake in a planning application.

SAFETY ZONE

2. The evidence obtained from the Dr. Jerry Havens’ Report (see. attachment 1), prepared by the Public Utilities Commission of the State of California for the Federal Energy Regulatory Commission, highlights worrying scientific evidence. Dr. Havens, Distinguished Professor of Chemical Engineering at the University of Arkansas and Director of the University’s Chemical Hazard’s Research Center, concluded that people living within 3 miles of the proposed site would be in harm’s way (this radius covers the Kerry villages of Tarbert and Ballylongford and the Clare village of Killimer). “Dr. Havens is extremely qualified and has studied LNG safety issues for more than 30 years. His primary specialisation is in the analysis and quantification of the consequences of releases of hazardous materials into the environment, with emphasis on the consequences that can occur as a result of toxic and/or flammable gas releases into the atmosphere”. ”He has provided detailed analysis supporting his conclusion that there should be a minimum of 3 miles between an LNG terminal and a densely populated area. Anything closer than 3 miles could put the public in harm’s way.” This is based on a spillage of 3,000,000 gallons of LNG, which he claims is widely accepted as credible.

However, he also examines the consequences of a vapour cloud fire which could result if the LNG spill vapours were not immediately ignited and a vapour cloud formed. The cloud thus formed would drift downwind until it reached an ignition source or became diluted below the flammable concentration level - after which time it would not constitute a hazard. In his opinion, the maximum distance downwind to which portions of a cloud (sufficiently large to constitute a severe fire hazard) formed from the rapid spillage onto water of 3,000,000 gallons of LNG could be ignited is approximately 3 miles.  If the vapour cloud were ignited as it drifted downwind, those persons in that area or immediately adjacent (thermal exposure could occur at some distance beyond the edge of the fire) who could not gain protection could be killed or seriously injured.

In any case, he states that such fires cannot be extinguished and would just have to burn themselves out.

Havens also deals with the explosion hazards of confined vapour cloud explosions, unconfined vapour cloud explosions, boiling liquid expanding vapour explosions, Toxicity hazards, Cryogenic (“cold” burn) hazards and Rapid phase transition (flameless explosion) hazards. Their importance in the public safety context lies in the potential for RPT’s to cause secondary damage which could lead to cascading failures and further releases of LNG.

Dr. Havens’ report is based on a spill of 3 million gallons. The EIS submitted by Shannon LNG proposes (volume 1 page 3) to design a jetty capable of taking ships with a capacity of up to 265,000 m3 of LNG. This is equivalent to 58 million gallons approximately.

The distance of the proposed site from vulnerable residential areas must therefore be taken into account by An Bord Pleanála.

3. The limited QRA implemented by Shannon LNG goes even further than the Havens’ report when it admits that a vapour cloud could travel up to 12.4 kilometres before being  ignited:

 “A rule-set has been created for the QRA by considering the development of the largest cloud produced by the consequence analysis, that for catastrophic failure of a full tank in F2 weather. This cloud has a maximum downwind distance to LFL [lower flammable limit] of 12.4 km.” (they do not state how far the cloud could travel beyond this distance before it meets the upper flammable limit – the level at which the oxygen mix with the gas is so high that the gas can no longer be ignited).

            LNG FIRE HAZARDS

4. A report by the IoMosaic Corporation – “Understand LNG Fire Hazards” (see attachment 19 page 15)  found that the maximum impact hazard footprint of a 200,000 m3 LNG tanker will result from a pool fire leading to a fatality limit of 50 percent at a distance of  3.7 kilometres from the leak.

5. The safety zone of 3 miles conservatively required by the Havens’ report has implications for further residential development in the area surrounding the gas terminal. It will potentially have the effect of sterilising residential areas (stopping any new houses from being built on safety grounds)  and it will also prevent other areas of the landbank from being developed as the levels of risk increase with more complex developments side by side. Shannon LNG  proposes in the EIS (volume 1 page 5) that the remainder of the site may be used for a gas-fired power station , but the exclusion zone of 3 miles will make this proposal untenable. The Bord is asked to take these issues into consideration and issue an opinion on them as they will have serious social and economic long-term consequences on the area. In any case, 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”.

6. SIGTTO (The Society of International Gas Tanker and Terminal Operators Ltd) is a non profit making company, formed to promote high operating standards and best practices in gas tankers and terminals throughout the world. It provides technical advice and support to its members and represents their collective interests in technical and operational matters. To become a full Member of SIGTTO it is necessary for a company to have equity interest in or to operate a gas tanker or terminal. Two of the company’s published works are

- “LNG Operations in Port Areas : Essential best practices for the industry” (see. attachment 2) which SIGTTO describe as follows: "This document draws on this collective experience in setting out guidance to best practice for managing gas shipping operations within ports. It also illuminates the profile of risks attaching to gas operations, for the information of those who administer", and

-    “Site Selection & Design (IP no.14) for LNG Ports & Jetties” (see. attachment 3) which SIGTTO describe as follows: “Information Paper No.14: Bearing in mind the high consequential risks of a serious accident in the LNG trade, this publication has been prepared for port developers as a guide to the minimum design criteria considered necessary when a port is to be built or altered to accommodate LNG carriers.” Although HESS is not a member of SIGTTO, in the absence of direct Irish or EU regulation on the matter, it is only reasonable to expect that HESS would follow the standards set by its own industry.

In the public meeting held at the “Lanterns Hotel” in Tarbert on October 29^th 2007, Shannon LNG stated that the SIGTTO standards were “a wish list for the ideal site, which was not, in any case, binding on Shannon LNG”. We object extremely strongly to this claim because the Gas industry’s own standards should be a minimum that the Kilcolgan Residents Association would expect to be applied. The Bord is fully entitled to regard that response from Shannon LNG as an admission that the present application does not match what they accept is “a wish list for an ideal site”. There is no objective reason why the Bord should depart from that standard when assessing this application. The Bord has the opportunity, as well as the Statutory obligation to maintain the highest possible standard and the Company’s statement eloquently describes exactly what that standard is

RISK ASSESSMENT

7. a) SIGTTO clearly state in “LNG Operations in Port Areas:Essential best practices for the industry” that risk exposures entailed in an LNG port project should be analysed by a Quantitative Risk Assessment (QRA) study which “must involve the operations at the terminal and the transit of tankers through the port” (Section 2 page 5).

Shannon LNG  have only undertaken a QRA  for the storage tanks on the shore, but no QRA has been done on the marine side of the operation. This is not in line with the industry’s own best practice guidelines. The QRA includes a tanker on the jetty but it does not consider ship collision between two ocean-going vessels. It should be bourn in mind that tug boats themselves can also be a cause of collision

b) The SIGTTO standards also clearly state (page 7) that any risk-mitigating factors introduced - such as traffic control, exclusion zones around transiting tankers, tug escorts and specified limiting operating conditions of wind speed and visibility – should also be used in the QRA. This has not been done.

c) No QRA of intrusive risk exposures has been undertaken either. There are two categories of intrusive risk; that arising from intrusions threatening the physical integrity of the terminal and berthed tankers (e.g. heavy displacement ships), and that arising from the introduction of uncontrolled ignition sources.

d) Shannon LNG (in EIS Volume 2, section 3.10.2.3) states that “Shannon LNG understands that a more detailed Quantitative Risk Assessment (QRA) covering all navigational aspects of shipping will be undertaken by Shannon Foynes Port Company during development of the project”. This splitting of risk assessment responsibility is not acceptable and indeed dangerous. Furthermore this is contrary to the EU 1998 Aarhus Convention Directives, Directive 2003/4/EC and Directive 2003/35/EC which declare the right of the public to be informed on environmental impact and to be provided with the opportunity to make comments and have access to justice.

e) The Quantitative Risk Assessment is based on “Land-use Planning Advice for Kilkenny County Council in relation to Grassland Fertilisers (Kilkenny) Ltd at Palmerstown”. This is completely inadequate for a risk assessment of an LNG installation because the chemicals are different and the manner in which they leak is completely unique to LNG because it is at such a low temperature (-160 degrees).

f) One obvious and questionable claim in the QRA undertaken by the developer can be seen where only one of the four LNG storage tanks is covered by the inner zone contour in Figure 6.2 of the QRA on page 59. This means (using the criteria of table 5.1 on page 49) that it would be acceptable to build residential houses up against the remaining 3 LNG storage tanks even if the first tank leaks. This does not make sense and can only lead to the conclusion that the contours have been unrealistically tightened so as not to encompass current residential areas. We therefore object to this QRA which has not been made available to the general public.

h) We request more time from An Bord Pleanála to get our own independent technical assessment of the QRA undertaken by the developer because it has only been made available to us a very short time ago and is still not available to the general public.

i) Misapplication of Risk Assessment: Recently it has become popular on the international front to apply risk assessment to justify otherwise poor decisions not necessarily in the best interest of the public or the country.  RA can be a very unwise tool to force the will of a powerful few on the uninformed public.  One factor signalling some very poor applications of RA is the comparison to other risks that in a technical reality are not really related, especially as to consequences.  Some consequences are so great that no matter what the probability the risks cannot be justified, especially if economic benefit to the decision makers is actually driving the poor application of this tool.  A reality test in such poor applications is to ask what the real liability of the organisation is, if their risk call (aka their key technical “facts” assumptions) should prove wrong.  Are their liabilities, both economic and criminal, for reckless decisions shall we say, limited by layers of attorneys citing loopholes, are the real assets moved off shore or to another country?  What are the real corporate risks here if the RA is incomplete, inaccurate, or poor?

SITE SELECTION

8. SIGTTO clearly state criteria which must be followed in “Site Selection and Design for LNG Ports and Jetties”. These include (page 12):

-          Find a location suitably distant from centres of population

-          Provide a safe position, removed from other traffic and wave action. For an “LNG carrier of about 135,000 m3 capacity, the waves likely to have such effects are those approaching from directly ahead or astern, having significant heights exceeding 1.5 metres and periods greater than 9 seconds” (page 7). The EIS submitted by Shannon LNG proposes (volume 1 page 3) to design a jetty capable of taking ships with a capacity of up to 265,000 m3 of LNG so the port criteria must satisfy this capacity of ship

These criteria seem to be unobtainable given the proximity of the villages of Ballylongford, Tarbert and Killimer (all 3 miles from the proposed gas terminal) and the huge amount of ships using the estuary already.  Also, windage  has to be accounted for because the specific gravity of LNG is a lot lower than oil and so the ship runs a lot higher on the water.

MOVING SAFETY ZONE

9. SIGTTO clearly state in “Site Selection and“LNG Operations in Port Areas:Essential best practices for the industry”, that it is sound practice to establish a cordon sanitaire or exclusion zone around a transiting gas tanker. “Where traffic is proceeding in the same direction as the tanker the zone may extend some 1 to 2 miles ahead of the gas carrier, a distance determined by the distance required to bring the following gas carrier safely to a stop. Traffic following the gas carrier should be excluded for a similar distance, allowing scope for the gas carrier to slow down to manoeuvre without it being impeded by the approach of following ships. In general, traffic should not cross closer than 1.5 miles ahead or 0.5 miles astern of a gas carrier” (page 15).

a) These conditions have therefore an effect on the traffic moving through the estuary towards Tarbert, Moneypoint, Foynes, Aughinish and Limerick, especially since Shannon LNG have plans for 125 ships a year coming to the gas terminal

b) This also has an effect on the Tarbert-Killimer car ferry.

c) This also has an effect on all leisure boats using the estuary, including dolphin watchers in this SAC area of the Lower Shannon and the boats from Saleen Pier.

d) Furthermore, the exclusion zone will prevent other sea-based industries setting up in the land bank as they will not be able to access the site when LNG tankers are at port.    

ENVIRONMENTAL  POLLUTION: SEAWATER USE POLLUTING THE SHANNON ESTUARY:

10. Intermediate Fluid Vaporizer (IFV) technology using the Shannon seawater as a heat source is the intended method by which Shannon LNG will convert the liquid LNG to gas. The EIS (volume 2 page 63, section 3.6.3.2), notes that up to 5 pumps will be used to circulate up to 20,000 cubic metres of water per hour. This equates to 4.4 million gallons per hour.  To prevent marine growth (bio-fouling) within the system, sodium hypochlorite (bleach, an oxidiser) will be added to the seawater on a continual basis. As it exchanges heat with the glycol solution, the seawater will be cooled such that at discharge it is cooler than the ambient seawater.

The withdrawal and discharge of huge volumes of seawater (over 100 million gallons on a daily basis) would affect marine life by killing ichthyoplankton unable to escape from the intake area (see attachment 4) . Further, the discharge of cooled and chemically-treated seawater would also affect marine life and water quality. For this reason, open-loop technology (and the Shannon LNG proposal is still an open-loop seawater technology even if it is using a closed-loop glyclol system) has been successfully opposed continuously by government bodies due to its negative environmental impact. This is because IFV technology poses the same environmental problems faced by Open Rack Vaporiser (ORV) technology which also relies on huge quantities of seawater (see attachment 7, section 3.5.2.3). It must be remembered that the Lower Shannon waters (including the 25 acres offshore of the proposed LNG site) are in a Special Area of Conservation (SAC) designated area (see attachment 6) – therefore constituting waters that must be protected under the EU habitats directive.

The waters of the Shannon can be protected using an alternative heating solution e.g. a  closed-loop vaporiszer but this will prove more costly for Shannon LNG.

Concern also has to be expressed on the effect of the additional surface water runoff from the site and water supply to and from the proposed new pond (EIS volume 1 page 21) as well as the chemically-modified cooler seawater discharged from the vaporising process on the wetland habitats to the north-west of the site.

THE EU HABITATS DIRECTIVE

11. The Bord is bound to uphold the previsions of Art. 6 of the Habitats Directive and of the Irish implementing measures. It is plain that the provisions of Art 6(3) apply to this development. It is also plain that the development will by definition have negative implications for the lower Shannon Estuary candidate SAC. The Bord therefore has no basis for finding that the development will in the words of the Directive, “ not adversely affect the integrity of the site”.

The applicant itself does not purport to claim that the development comes within the provisions of Art. 6 (4) of the Directive and in our view they are quite correct not to attempt to make any such claim.

It is therefore not open to the Bord to grant permission.

We also rely on the protection afforded under European and Domestic law to the Ballylongford Bay proposed Natural Heritage Area and the Shannon-Fergus Special Protection Area in submitting to the Bord that the impacts of the development also mandate the Bord to issue a refusal.

12. The ecological sensitivity of the area has been recognised in the Kerry County Development Plan (see appendix 22) in declaring both Ballylongford Bay and Tarbert Bay as areas of Ecological Importance. For this reason we object to any environmental damage to this area.

13. The Environmental Protection Agency, in its 2006 report on water quality in Ireland (see attachment 23) emphasised the need to have, under the Water Framework Directive (WFD)(2000/60/EC) all waters, both surface and groundwater in good or higher status by 2015. We therefore object that the use of the Shannon waters as proposed in this planning application directly ignore or obligations under the Water Framework Directive.

PROJECT SLICING

14. Shannon LNG is artificially cutting this LNG project into pieces for the purpose of winning legal approval. Through this process, known as “salami-slicing”, sections of this project will be assessed and permitted. The idea is that the less environmentally-questionable parts of the project are authorised and built first, making continued development of the project a virtual fait-accompli, even if the latter sections of the project seriously violate environmental regulations. This is contrary to, among others, article 2.1 of the EIA (Environmental Impact Assessment ) directive, which requires that “projects” likely to have significant effect on the environment – not parts of projects – are subject to the assessment.

Shannon LNG has made only vague reference to the pipeline from the proposed gasification terminal to Foynes even though this pipeline could also pose serious environmental and safety risks depending on the pressure of the gas in the pipeline.

It has only made vague references to its plans for the rest of its site on the land bank. They suggest maybe a gas-fired power station which would, they say, “be the subject of a separate planning application and EIS” (EIS volume 1 page5).

Shannon LNG also states (EIS volume 1 page5) that electricity to be supplied via 110kv lines from the ESB network at Tarbert will also “be the subject of a separate planning application”.

Shannon LNG goes on to state (EIS volume 1 page5) that Kerry County Council will upgrade the coast road from Tarbert which “will also be the subject of a separate planning application”.

It is to be feared that, due to the necessary exclusion zone required for LNG tankers, the land bank will only be fit for other “dirty” projects, which, if assessed along with the LNG gasification terminal, would almost certainly be denied planning permission.

This piecemeal approach to the planning process is extremely questionable as it does not deal with the sustainable development of the area.

LIMITED GAS SUPPLY

15. The justification for the project being that the supply of gas to Ireland is not assured must be questioned and it cannot be assumed that the proposed gas terminal is of overriding national interest. Reference has been made to the threat from the Russian pipeline. It must be pointed out that

-          A gas pipeline also exists from Norway to the UK (see attachment 8). After the start up of the Langeled pipeline from Norway’s  Sleipner platform to the UK in the autumn of 2006, shockwaves were sent through the  market. “History was made when over-the-counter prices fell to negative territory for the first time”.

-          LNG terminals in the rest of Europe provide an indirect source of gas through the European network.

-          Gas has been discovered off the coast of Ireland

-          Shannon LNG is giving no guarantees of supply whatsoever. It is assumed that the intention of the gas industry is to make LNG a commodity product where more gasification terminals increases liquidity in the market and the LNG tankers can change routes more easily if the spot price of LNG changes. From the Poten & Partners report (see attachment 8) Ofgem, the UK regulator, had to invoke use-it-or-lose-it provisions to stop BP and Sonatrach from diverting cargoes elsewhere to take advantage of price movements. Shannon LNG do not want the same types of provisions as can clearly be seen from the pre-planning consultation documents from An Bord Pleanála.

-          Gas is still a fossil fuel and when the whole supply chain of LNG is considered from the extraction, liquefaction, transport and gasification stages it is thought that LNG is no cleaner than coal. This contradicts our national commitments signed up to in the Kyoto Protocol

LNG: UK Gas Sellers Face Looming Supply Glut

16. Poten and Partners have issued a report on their website of a looming glut of LNG in the UK market which should guarantee the supply of LNG to Ireland (see attachment 8). They state that a rapidly expanding import infrastructure in the UK threatens to outstrip requirement by a large margin. “In addition to Langeld, operation of the BBL and Tampen pipelines from the Netherlands and  Norway will add 100 Bcm/y of new import capacity by 2010, equivalent to half the country’s demand.” The report also claims that “LNG import capacity will grow ten-fold during the same period”. “This is thanks to the new dockside regasification facility at Teesside in northeast England and two grassroots terminals under construction at Milford Haven in Wales, known as Dragon LNG and South Hook”, they add.

17. The Government White Paper, “Delivering a Sustainable Energy Solution for Ireland”, the Energy Policy Framework from 2007 -2020 (see attachment 9 section 3.3.2), states that in implementing strategic goal 2 (ensuring the security and reliability of gas supplies):

“The UK is now the source of some 87% of our natural gas and the UK’s own demand for imports is growing strongly. Norway will remain a significant supplier of gas to UK in the medium term. Ireland’s location in Europe from the view-point of gas supply sources is becoming less peripheral. In the last 12 months the UK has achieved a significant increase in gas import capacity through accelerated infrastructure developments with resultant benefits for Ireland. Both pipeline and LNG capacity has increased significantly. These include the Langeled pipeline from Norway, the new pipeline from the Netherlands and new LNG terminals at Milford Haven. Further expansion of LNG capacity and gas interconnection is underway in the UK and Europe which will benefit Ireland in terms of security of wholesale gas supplies within this regional market… the prognosis for gas supplies is relatively secure as a result”. 

            The White paper goes on to state:

“We will put in place an all-island strategy by 2008 for gas storage and LNG facilities in light of the outcome of the all-island study”. This would represent an independent strategic view of LNG facilities, rather than depending on the non-independent representation by Shannon LNG. “He who pays the piper, calls the tune”.

Therefore, while awaiting the government’s all-island strategy for LNG facilities and while noting that “the prognosis for gas supplies is relatively secure”, we strongly bring to An Bord Pleanála’s attention that there is no over-riding urgent, strategic imperative or immediate need for an LNG terminal in Tarbert and that therefore, the “National Interest” cannot be used as an excuse to prime over and ignore the dangers being posed to the safety of the nearby populations in Clare and Kerry  and the environmental damage that will be suffered on the SAC waters of the Lower Shannon which must be protected under the EU Habitats Directive if the development is given the go-ahead.

ALTERNATIVE LOCATION FOR AN LNG TERMINAL

18. The Second International Conference of Renewable Energy in Maritime Island Climates held in University College Cork in April 2006 suggested that Cork, close to the Kinsale Gas Field,  would be an ideal site for an LNG terminal (see attachment 10):

“In the longer term it is important to fully explore and maximize geographical diversification in gas supply. One potentially promising option is through LNG (liquid natural gas) trade. This would provide give possibility to transfer gas from remote countries (Algeria, Nigeria, Malaysia, Trinidad and Tobago, United Arab Emirates and Qatar), without using pipelines, which are not economically viable. 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. 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.”

19. The Second International Conference of Renewable Energy in Maritime Island Climates held in University College Cork in April 2006 also noted (see attachment 10) that:

 “Germany has already started the construction of a gas pipeline from St-Petersburg to Germany under the Baltic Sea, avoiding borders. This is expected to provide more reliable supply from Russia to the West by 2010”.

20. In 2006, a natural gas storage licence was granted to Marathon Oil Ireland Limited at parts of the Kinsale facilities (including the Southwest Kinsale Resevoir and wells, offshore platforms, pipelines, compression, processing plant and the shore terminal) used from time to time to inject, store and withdraw natural gas (see attachment 21, schedule 1 page 19) . This would seem to suggest that the Kinsale Resevoir would be a more ideal site for strategic gas storage than Kilcolgan.

PUBLIC ACCESS TO INFORMATION, PUBLIC PARTICIPATION AND ENVIRONMENTAL IMPACT ASSESSMENT

21. Shannon LNG submitted a risk assessment to the Health and Safety Authority on the same day it submitted the planning application to An Bord Pleanála. The HSA will make a recommendation to An Bord Pleanála based on its own examination of the risk assessment.

However, the risk assessment has never been made available to the general public and neither has it been submitted to An Bord Pleanála. This means that the public will not have access to vital environmental information (e.g. the environmental impact of an LNG leak) before the deadline of November 16^th and people who would make a submission based on the risk assessment are now being illegally deprived of participation in the planning process. This is contrary to Article 6 of the EU EIA directive.

This issue can be solved by an order that the HSA or Shannon LNG produces both the Risk Assessment submitted  and the HSA  assessment to an Bord Pleanála and that this information be disclosed to the general public. Further submissions will have to be allowed from the general public – not only oral (for example in an oral hearing) but more importantly in written submissions. This is to take into consideration people who would be unable to speak at an oral hearing but who would have serious concerns they could put in writing.  These written submissions will therefore have to be allowed from all members of the public who have not made a submission before November 16^th in order to maintain transparency in the planning process.

We object that the division of responsibility for the Environmental Impact Assessment across a number of bodies including, but not limited to, An Bord Pleanála and the EPA is not clearly defined because the general public does not have all the environmental impacts before planning permission is applied for in order to participate fully in the planning process.

We as members of the public concerned have been given 7 weeks to prepare this submission to the bord. In that time we have faced a literally impossible task. We have been denied access to critical documentation including the materials submitted to the HSA and the HSA’s own documents and reports on that material. Yet that material and the HSA analysis of it will without doubt form the basis of the HSA’s opinion and the Bord in turn will rely on that opinion in the context of the Seveso II Directive. By the time we are eventually able to access the material to examine it further the Bord may have already dealt with the application on an erroneous assumption about the contaminants in the LNG. The Bord will have closed the door to further submissions from us. That is a clear example of one of the ways in which we are being shut out from meaningful participation in the process in flagrant breach of our rights under Irish and European Law. Our rights in this regard are guaranteed by the provision of the European Convention on Human Rights as adopted and as further made binding on An Bord Pleanála by the European Convention on Human Rights Act 2003 as well as by the principles of natural justice and the obligation on the decision makers including the Bord to apply fair procedures. There are several other aspects which are in breach of our rights including: 

a)      The complete inequality of arms between us and the applicant. This is accentuated by the ability of the applicant to engage in pre-application consultations with the Bord so that it can be advised on how to present the application. The Bord has concluded, with no public input, that the application is one fit to be dealt with as Strategic Infrastructure and has literally pre-judged that vital issue. That in turn puts the Bord in a position of objective Bias when it comes to assessing our contention that the application is no such thing and should not be considered as such.

b)      The Applicants have been granted ample time to liaise privately with the Bord, to compile their material, to liaise with other Statutory bodies and to finalise this application. It has done so over a period in excess of 12 months. By contrast the local residents and other members of the public have been given no access to the statutory decision makers and instead are expected to convey our concerns in one fell swoop within 42 days of being granted sight of some, but not all, of the necessary documentation. This is fundamentally unjust.

      QRA NOT DOWNLOADABLE

22. In a public meeting held by Shannon LNG on October 29^th 2007, it was stated that the QRA would be available to the general public over the Shannon lng website. However, this has never been downloadable and has therefore never been available to the general public. This was reported by Catriona Griffin to An Bord Pleanála and was noted by the Bord.

      BUILDINGS  TO BE DEMOLISHED

23. We object to old buildings being demolished as they represent a history of all the people that lived there over the centuries. The old stone buildings also represent our national heritage as they are built in the style of the region.  As these houses are also used by bats, we object that the homes of the bats will be destroyed, contrary to the Wildlife Act 1976/2000 and the EU Habitats Directive.

RESIDENTIAL AMENITY

24. We object to the detrimental affect of the proposed development on the lives of the nearby residents and general public.

                     i.            The Environmental Impact Statement anticipates (EIS volume 1 page 17) that construction work will take up to 4 years

                   ii.            The Environmental Impact Statement anticipates (EIS volume 1 page 17) that construction activities will require 24-hour working at the site.

                  iii.            Added  to this are the  enormous changes to the visual landscape proposed (EIS volume 1 page 11).

                 iv.            The noise and vibration impacts from construction traffic and blasting (EIS volume 1 page 17 and 18) are expected to be within the EPA limits. However, this does not take account of the fact that this area currently has hardly any noise whatsoever as it is on a lonely coastal country road and that the changed level of noise over many years is unacceptable.

                   v.            In addition, Ballylongford village is not designed to take the huge increase in construction traffic expected.

                 vi.            Trucks will come from Tarbert to the site but workers cannot be prevented from approaching the site from Ballylongford and no upgrade of the road between Kilcolgan and Ballylongford is proposed. This very winding road is therefore going to prove to be a death trap for the many people that currently walk on this road as a leisure activity.

                vii.            We are afraid that children might cut themselves on the barbed wire fencing proposed around the site.

              viii.            We object to the storage tanks proposed at 50 metres height and want them put underground on visual impact and safety grounds

                 ix.            We object to the blight on the landscape from the water.

                   x.            Tourists visiting the County of Kerry after crossing over the Shannon on the Ferry from Killimer to Shannon will not want to pass a dangerous industrial zone as proposed and this will have a hugely negative impact on the tourism sector in the north Kerry coastal regions beyond Ballylongford (Asdee, Beale, Ballybunnion). Furthermore, the site will not be in keeping with the county’s reputation as one of outstanding beauty and will destroy our image.

                 xi.            The environmental damage to the water caused by 100 million gallons of cooled, chlorinated water being daily discharged into the estuary will have a negative impact on the oyster farming on Carrig Island at the other side of Ballylongford Bay as well as the reputation of Ballylongford as it hosts the Ballylongford Oyster Festival every year (see attachment 18).

                xii.            The residents in the area surrounding this proposed development will have to live with the constant fear that an accident may happen at any time and this will be a constant source of worry and fear, no matter how long the terminal works without an accident. This is unfair to burden an innocent population with this threat and residual risk.

              xiii.            The EIS does not include the 2.9 metre barbed wire fencing in the photo montages and this is giving a misleading image of the full visual impact of the proposed development

              xiv.            The EIS does not include the proposed gas power station in the photo montage and this is also giving an extremely misleading image of the full visual impact of the proposed development.

               xv.            We object that the photo montages in the EIS do not represent the true size of the tanks and ask that this be confirmed independently.

              xvi.            We object that the huge construction traffic will effect the safety of the children on the school bus routes

RIGHT OF WAY

25. The EIS (volume 2 section 15.5.2) states that the right-of-way on the farm track at the western boundary of the LNG terminal site used by anglers to access the shore “will not be accessible to anglers when the LNG terminal is operational”. We object to this.

26. The EIS (volume 2 section 16.14) claims that there are no registered rights of way or wayleaves on the site. We object to this because the site has always been used to access the shore for swimming, for angling etc by all the Kilcolgan residents, and to access the site owned by Stevie Lynch and John O’Connor of Lislaughtin.

      HESS LNG’s OTHER  LNG TERMINAL REFUSED PERMISSION  IN THE USA

27. The Weaver’s Cove site ( see http://www.weaverscove.com/aboutus.html )describes Hess LNG as follows:

“Weaver’s Cove Energy, LLC, is owned by Hess LNG, LLC, which is a joint venture owned equally by Poten & Partners and Amerada Hess Corporation. A team of professionals that are among the most experienced and reputable executives in the global LNG and energy industry manages Weaver’s Cove Energy. The project team members have decades of experience in the design, development and operation of large energy projects around the world, as well as right here in Massachusetts.”

One newspaper article described it as follows:

“The river that runs past a proposed liquefied natural gas terminal in Fall River isn't safe for frequent traffic by massive LNG tankers, the Coast Guard ruled Wednesday in what could be a fatal blow to the controversial project (see attachment 11 )”

And another paper said:

“BOSTON --A proposed liquefied natural gas terminal in Fall River may have been dealt a fatal blow.

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The Coast Guard has ruled the river approaching the Weavers Cove Energy project is unsafe for navigation by massive LNG tankers.

The decision affirms concerns the Coast Guard expressed last year. The agency has since done an extensive review of the project.

A major problem is the relatively short distance between two bridges on the Taunton River. The Coast Guard found the safety risks of the 700 foot long, 80 foot wide tankers navigating the 1,100 foot gap were too great.

A Coast Guard spokesman says the ruling "kills the project, as proposed."

Weavers Cove officials did not immediately return calls for comment on the ruling” (see attachment 12 and 13).

The real lesson to be learned from the debacle at Weaver’s Cove is that Hess LNG were stopped from building an LNG terminal on safety grounds even though they claimed that what they were proposing to do was safe. Our interpretation of this is that, no matter what the obstacle, Hess LNG will claim that they can make it work and ignore their own standards of Best Practice and put people’s lives at risk in order to “clinch the deal”. This further proves that Hess LNG is not capable of self-regulation and the independence of their own risk and environmental assessments have now to be seriously questioned. Furthermore, the increase in LNG traffic all over the world will only increase the risk of an accident and this only accentuates the need for the implementation of the strictest safety standards. We therefore implore An Bord Pleanála to refuse planning on safety grounds.

ACCOUNTABILITY

28. Shannon LNG is described as  a wholly-owned subsidiary of Hess LNG Limited in the Environmental Impact Statement submitted by Shannon LNG to An Bord Pleanála (Volume 1 page 1). However, it has not been pointed out to An Bord Pleanála that Hess LNG is an offshore company incorporated in the Cayman Islands (see attachments 15 and 16). In the event of an environmental disaster at the plant Shannon LNG would be liable for the costs of any loss to property and human life. However, Shannon LNG has no assets of note. This can lead to problems in litigation where cases can go on for decades as attempts are made in the courts to apportion blame and liability. Companies can deny liability by creating shell companies in different jurisdictions, where ownership of the land is shared among some companies and ownership of the operations is shared out among other companies – all in different jurisdictions with different litigation laws.

Hess Corporation itself has never proposed that it could accept from the outset all responsibility for any environmental or human losses at the site for which Shannon LNG itself (or any other related companies) could be held liable as if it still owned the site and operations and that this liability would not be given away or sold without the express permission of the local planning authority in Ireland (Kerry County Council). This would have had the added advantage of creating an incentive for Shannon LNG to maintain the highest environmental and safety standards.

However, we object to the fact that an offshore company controls the private company that is applying for planning permission to construct this dangerous LNG terminal in Tarbert.

LNG  CONTRIBUTING  TO  GLOBAL  WARMING

29. In its report on LNG (see attachment 17), Greenpeace found that the use of natural gas that has been liquefied and transferred across the Pacific reduces the difference between natural gas power plant CO2 emissions and coal power plant emissions by nearly half. However, it also found that the development of LNG terminals would open up nearly limitless quantities of natural gas to the energy markets and that this shift threatens to turn natural gas, previously viewed as a “transitional” fuel, into a permanent source of global warming gases. This surely goes against the spirit of the Kyoto Protocol and we therefore ask An Bord Pleanála to note this and refuse planning permission for the project.  Furthermore, this trend towards an increased dependence on LNG increases reliance on environmentally destructive fossil fuels and significantly delays the possibility of moving towards renewable energy sources by creating a costly infrastructure for LNG.

Furthermore, the idea of building a Gas Power station on the site (EIS volume 1, page 5) will increase the dependency on LNG as a permanent fuel rather than a transitional fuel and we object to this result.

      DISAGREEMENT  AMONG  EXPERTS  ON THE DANGERS OF LNG

30. A report for the US Congress was undertaken by the United States Government Accountability Office (see attachment 14) with advice from 19 of the world’s top international LNG experts. The startling findings from this report was that even they seem unable to agree, hence the reports conclusion that the US DOE should carry out further tests on spills of LNG. We therefore also feel that due to the uncertainty in judging the risk to people’s safety, An Bord Pleanála should apply prudence and rule against this planning application.

31. In The GAO Report for Congress (see attachment 14) the section on Cascading Tank failure is illuminating as it states that the worst case scenario is a small hole in an  LNG carrier’s containment; this is because the LNG Pool Fire will last longer close to the ship; so giving more time to heat the adjacent tank. A big hole allows the LNG to empty quickly from the tank in question so limiting the time any fire has to heat the adjacent tank. For this danger posed to the nearby residents we ask once again that An Bord Pleanála should apply prudence and rule against this planning application.

      HOUSES NOT DISPLAYED ON SITE MAP

32. On the site map made available to the public, there are 6 houses missing – namely those of Raymond O’Mahony, Adam Kearney, Geraldine Carmody, Mrs. Kathleen Finnucane  and two other houses belonging to the Finnucane family. We object that this is distorting the number of homes immediately adjacent to the site and question if this is also distorting the QRA.

      NO BENEFIT TO KERRY

33. There is no plan to send any of the gas imported to Kerry. The only monetary benefit to Kerry shall be the rates that will be charged to the terminal and we object that this should influence the submission from Kerry County Council.

      COMMUNITY  ENGAGEMENT  IN PLANNING

34. The final Report from the APaNGO project entitled ‘community engagement in planning exploring the way forward’ (see attachment 20)  was launched at the international APaNGO closing conference in Brussels at the end of October 2007. The APaNGO project is one of the first studies of community engagement and involvement at the European level, covering findings from the seven Member States in North West Europe (Belgium, France, Germany, Luxembourg, the Netherlands, the Republic of Ireland, and the UK). It noted that the “legitimacy of any planning decision will vitally depend on the quality of democratic input to the process; without that input, decision-making itself will be discredited.

For this reason, and from the Aarhus Convention Directives on the right of the public to be informed on the environmental impact and being provided with the opportunity to make timely comments and have affordable access to justice, we therefore object that we do not have the financial means to challenge the EIS and QRA presented by the developer who has access to unlimited resources through Hess Corporation. This EIS and QRA are not independent. We need funds to challenge this with our own safety and environmental experts and therefore request that An Bord Pleanála puts those funds at our disposal in order to maintain transparency and equality in the planning process, given that this is for a complex chemical installation in a SEVESO II site.

      QUESTIONABLE REZONING BY KERRY COUNTY COUNCIL

35. We object that the development is proposed on a green field site – even if it has recently been zoned industrial (EIS volume 2, section 4.6.3). In march 2007, the LNG site was rezoned from “Rural General” to Industrial (see attachment 29)

“The stated purpose of the variation was as follows:

The purpose of the variation is to facilitate consideration of suitable development of these lands in accordance with the provisions of section 5.2.9 of the Kerry County Development Plan 2003-2009 which states: ‘lands have been identified at Ballylongford/Tarbert as suitable for development as a premier deep-water port and for major industrial development and employment creation’. The adoption of this variation gives effect to objective ECO 5-5 of the Kerry County Development Plan 2003-2009 which states: ‘It is an objective of Kerry County Council to identify lands in key strategic locations that are particularly suitable for development that may be required by specific sectors. Land in such locations will form part of a strategic reserve that will be protected from inappropriate development that would prejudice its long-term development for these uses.”

a)      If the LNG terminal goes ahead then the landbank will not be a deep-water port as all other ships will be forbidden and unable to use the port.

b)      The creation of 50 long-term jobs does not constitute “major employment creation”.

c)      The LNG terminal is in actual fact a hazardous chemicals installation, defined as the most dangerous of sites in EU legislation – a Seveso II site. This does not fall under the type of installation to be considered for the rezoned site because if it was the intention of Kerry County Development Plan to include hazardous sites within the landbank then Kerry County Council would never have given planning permission for the new houses currently being built (such as that of Jayne Kearney) less than 900 metres from the LNG tanks. Any new houses built after the LNG terminal is constructed would constitute “inappropriate development” which means that hazardous sites were never to be considered as appropriate development within the landbank.

d)      This Seveso II site will sterilise the remainder of the site which means that the aim in the Kerry County Development Plan of “major industrial development and employment creation” cannot be fulfilled.

e)      The County Manager stated that sufficient natural amenity lands had been reserved to the west of the site which included a walking route to Carrig Island. However, Carrig Island is at the other side of Ballylongford Bay and takes several miles by car to reach by driving through Ballylongford.

f)       The County Manager went on to state that “the impact of development on the residential amenity of houses in the vicinity of zoned industrial land will be dealt with at the planning stage”. This clearly shows that the site is not intended for a SEVESO II development.

g)      More importantly Clare County Council objected to the rezoning on the grounds that:

“the proposed rezoning is likely to have a significant impact on the future development of the region, and will have a direct impact on the planned objectives for the Mid West Regional guidelines for the Shannon Estuary and in particular the Planning, Economic and Service Infrastructural development objectives for zone 5 of the plan. Any industrial development including the construction of a deepwater harbour will have a major impact on both the visual and ecological amenities of the area, and potentially on the Lower Shannon Estuarine Environment, including the foreshore of County Clare. Clare County Council would like an appraisal of any SEA investigation which may have been undertaken in respect of the proposed variation”. The Kerry County Manager replied: “Any future application of these lands will be subject to an Environmental Impact Assessment. This process will ensure that any proposals will take into account impacts on the visual and ecological amenities of the area. A copy of the SEA screening report for the proposed variation will be forwarded to Clare County Council.”

This is reprehensible. There is no evidence of an SEA having been undertaken as required for a variation to a development plan under Statutory Instrument No 436 of 2004 Article 7 section 13K and article 12 schedule 2A of the same Statutory Instrument (http://www.irishstatutebook.ie/2004/en/si/0436.html#article12 ). Without any information in the public domain regarding the scoping or the actual execution of an SEA (see attachment 32), this rezoning is fundamentally unsound and invalid. Clare County Council does not even know that this is a SEVESO II development. This rezoning process is also being brought to the attention of the relevant authorities as we object that the variation and rezoning of this site has been undertaken in a highly questionable and indeed invalid manner. We therefore object to the planning application because we maintain that this land is not zoned industrial.

These points mean that An Bord Pleanála should rule that the proposed development does not conform to the Kerry County Development Plan for the site, nor to the Planning and Development Act and should therefore be refused planning permission.

      OTHER  ISSUES

36. We object to any possible movement by road of LNG, due to the dangers and want this to be confirmed by An Bord Pleanála.

37. We need An Bord Pleanála to rule clearly on the use that may be made of the rest of the landbank if planning permission is given to the developer. We object that the rest of the landbank will be sterilised. It must be remembered that if the Bord allows other installations be built on the site near the gas terminal then they will have an influence on the risk of an accident at the regasification terminal. A clear ruling on this matter must be made.

38. We need An Bord Pleanála to rule clearly on how close residential property may be constructed to the site. We object that people will not be allowed to build on their own property close to the site due to the dangers.

39. We need An Bord Pleanála to rule clearly on the exclusion zone it recommends for boat users on the Shannon Estuary and object that use of the Shannon will be hindered by LNG tankers.

40. We object that most of the statutory bodies informed of the planning application will not have time to make detailed submissions to An Bord Pleanála due to the minimum time scale of 6 weeks from the date of planning application. This is such a serious installation that considered opinions cannot be given in this short timescale.

41. Under Seveso II regulations, we insist that An Bord Pleanála, if it decides to accord Planning permission to the developer, gives a detailed ruling on the type of emergency plan to be put in place, both onsite and offsite, and insist on the implementation of an early-warning system to all residents within 12.4 kilometers, including (but not limited to) a form of public siren and information to be given to the same residents on how to react to this siren.

42. The Tarbert Development Association and The Ballylongford Development Association do not speak for the residents surrounding the Kilcolgan site and we object to any attempt to claim anything to the contrary as this does not represent local consultation as far as we are concerned.

43. Morgan Heaphy, Glencullare, asked Shannon LNG to elaborate on the exclusion zone in a written comment on one of the information days (see EIS Volume 4 , Appendix 1F) and this has never been answered in any format (other than the words “limited exclusion zone” (EIS volume 4 appendix 3c) ) and therefore this does not represent  consultation with the nearby residents. We object that the developer has always maintained that the site is safe and has kept such a low profile in discussing safety issues that the general public has been completely unaware of the issues in the euphoria of having new industry and jobs coming to the area. This is completely against the spirit of the planning process and we object to this serious misrepresentation of the installation to our detriment and the developer’s economic advantage.

44. We object to the application of the Strategic Infrastructure Act 2006 as it applies to this application as we are extremely worried about the possibility of “agency capture”. By this, we mean that we are extremely worried that An Bord Pleanála may inadvertently become compromised by having too close an interaction with the developer during the decision making process. We expect An Bord Pleanála to maintain a professional distance from the developer and to inform us of all negotiations it has with the developer and to give us a right of reply to all correspondence between the developer and the Board. In the interest of public safety in this Seveso II development we require that all new information be disclosed to the public and that the public be allowed sufficient time to analyse the data and make further submissions, both written and oral.

45. A report on the LNG blast in Algeria (see attachement 24) mentions the contaminant gases that Lng is made up of. Note that when HSE ,Sandia and other regulators do tests with LNG, it is with 100% pure Methane. We object that the level of contaminant gases to be shipped by Shannon LNG have not been disclosed and request that An Bord Pleanála ask the developer to state the level of contaminant gases they expect to have in the LNG shipments and whether they will vary depending on the origin of the LNG in order that a QRA be undertaken and analysed with this information in mind:

“A 1980 Coast Guard study titled "LNG Research at China Lake," states that LNG imported into this country is often far from pure, and it reveals that vapour clouds made from "impure" LNG actually explode as readily as the highly volatile LPG. When natural gas is super-cooled and turned into a liquid, as much as 14 % of the total cargo shipped as LNG may actually be LPG or other hydrocarbon fuels, according to the Coast Guard report. Natural gas contains these other fuels when it is pumped from the ground.
LNG containing these so-called "higher hydrocarbons" is known as "hot gas" and has a higher energy content than pure methane. The Coast Guard report reveals that vapour clouds of LNG containing at least 13.6 % of these other fuels can detonate just like pure propane gas. The agency concluded in its report that this deserves "special consideration, as the commercial LNG being imported into the US East Coast has about 14 % higher hydrocarbons." “

46. Is the limited exclusion zone proposed by Shannon LNG around the LNG tankers taking into account the risk of an ignition source as well as the risk of a collision?

47. Lloyds Casualty Week dated September 16 2005 (see attachment 25, page 11/12) noted an LNG fire from a pipeline leak in Kalakama, Nigeria started a wild fire covering 27 square kilometres. We object that the developer has not included pipeline incidents in the QRA because the pipeline EIS has not even been completed. This shows the dangers in slicing a project into several separate projects for planning purposes.

48. What is the thermal flux that An Bord Pleanála would determine as acceptable? Is it 1.5 kw/m2.?

49. We object that the State does not determine the most suitable site in Ireland for an LNG terminal, rather than a biased private-sector company applying for planning permission.

50. We ask that An Bord Pleanála take account of the  Buncefield Reports (http://www.buncefieldinvestigation.gov.uk/index.htm ).

51. From speaking to people in Milford Haven it was noted:

a)      Jobs increased initially but the unemployment rate increased when the jobs finished as some of the workers had settled down in the area

b)      Rental costs were high during construction which made life more expensive for locals

c)      Skilled labour (such as welders) were attracted away from local industry so some local business suffered as a result

d)      There are other construction works on top of one of the tanks equivalent in size to a five-storey building. Will that be the same in Tarbert?

e)      Dolphins used to be resident in the Haven but left and never came back

52. We object that this LNG terminal would increase or dependency on the Opec nations – contradicting Energy independence objectives (e.g. windfarms where we have best windspeeds in Europe )

53. We object that the permanent jobs to be created will not be for unskilled labour (see attachment 27), which means that it is likely that many will not be filled by locals.

54. We object that since the government is still giving licences for exploration that must mean more gas exists in the country

55. We want all archaeological sites protected  (including the one near the jetty)

56. We object that the bird and sea life will be seriously impacted by the lights and the sounds

57. We object that the gas tanks will be visible from county Clare as that county will be expected to get all the disadvantages and none of the advantages (rates) from this development.

58. We object that we do not know if Shannon LNG has options to buy more land but need to know this as it would be an indication of their real intentions.

59. We object to the idea of dumping soil and stone from the site near to Scattery Island.

60. The Climate Protection bill on the 3^rd October was in the senate and it refers to a 3 % decrease per annum. Facilitating the importation and dependence on more fossil fuels like LNG goes against the spirit of the Climate Protection bill.

61. We object that an offshore location for a terminal would be safer than the onshore one proposed.

62. We object that the terminal could hit house prices. An article in the Kerryman newspaper dated October 17^th 2007, page 5 predicts a 29% drop (see attachment 28).

63. No Material Safety Data Sheets ( MSDS) have been supplied with the EIS and we object that these have not been provided. We ask that An Bord Pleanála obliges the developer to provide these and allow us sufficient time to analyse them.

64. While all chemistry is dangerous, we agree that it is also feasible it the hazards can be contained. However, we object to the real problem here which is one of scale. 4 tanks of LNG represent 2400 tanks of gas.

65. We object that the HAZOP study is not available to enable us and the general public participate fully in the planning process as required by the EU EIA Directive. We ask that An Bord Pleanála obliges the developer to put it at our disposition.

“A HazOp study identifies hazards and operability problems. The concept involves investigating how the plant might deviate from the design intent. If, in the process of identifying problems during a HazOp study, a solution becomes apparent, it is recorded as part of the HazOp result; however, care must be taken to avoid trying to find solutions which are not so apparent, because the prime objective for the HazOp is problem identification. Although the HazOp study was developed to supplement experience-based practices when a new design or technology is involved, its use has expanded to almost all phases of a plant's life. HazOp is based on the principle that several experts with different backgrounds can interact and identify more problems when working together than when working separately and combining their results. “

The risks we are especially interested in examining in closer detail include (but not limited to);

a)      Static electricity and how to control it.

b)      Catastrophic damage in the pressurisation process.

c)      Catastrophic damage at the stage where odours are added to the gas with mercaptons.

d)      Catastrophic damage at the stage where the glycol reheats the LNG

66. We object that no trucks should be travelling to or from the site for 5 minutes before and after a ferry boat lands because it has been noticed that the existing road network in Tarbert cannot take ferryboat traffic as it is at the moment.

67. We object that the full height of the storage tanks was lied about. The EIS (volume 1 page 4 ) clearly states: “The tanks will be a low-profile design and will be approximately 96m in diameter and approximately 50.5m high”. This is extremely misleading as this EIS volume 1 – the non-technical summary – was widely distributed to the general public. From the drawings submitted to An Bord Pleanála (see attachment 31) it can be clearly seen that only the top of the concrete is 50.5 metres in height; the top of the tank elevation is 60.5 metres and