Submission in relation to: Proposed Shannon Technology and Energy Park consisting of power plant, floating storage and regasification unit, jetty, onshore receiving facilities at the Townlands of Kilcolgan Lower and Ralappane, Ballylongford, Co. Kerry (Reference number PA08.311233)

As the authority charged with ensuring that physical development and major infrastructure projects in Ireland respect the principles of sustainable development, including the protection of the environment - we urge you to reject the planning application for the proposed Shannon Technology and Energy Park (Reference number PA08.311233).

Climate commitments
It is crucial that Ireland does not further lock-in its dependence on fossil fuels if we are to meet our climate targets under the Paris Agreement and the Climate Action and Low Carbon Development (Amendment) Bill 2021 - which legally obliges us to achieve a 51% reduction of our 2018 emissions levels by 2030 and net-zero by no later than 2050.

Less than 12 months ago, at COP26, Ireland signed up to the Beyond Oil and Gas Alliance (BOGA). As a member of BOGA, Ireland are committed to the phase-out of oil and gas.

Data centres
Instead of phasing out fossil gas, the Shannon LNG terminal would bring in more gas than Ireland currently uses in a year. [1] And these massive amounts of damaging methane gas would be used mainly to power unsustainable data centres owned by billion dollar corporations. [2]

CEO of New Fortress Energy, Wes Edens, owner of Shannon LNG was too blatant about this while discussing plans to build 8 data centres on the Shannon site. He said this in an Earnings call in August 2019:
“I can't emphasize enough, I think the downstream assets we develop around these terminals are, in many respects, our most important projects. We basically end up creating our own demand. We're, essentially, negotiating with ourselves, so we know the guy who owns the data centers if we're building data centers.” [3]
This clearly highlights the company's plan to use US LNG to power US data centres. This will do nothing for Irish energy security. We are nothing more than a dumping ground for data centres and fracked gas in this scheme.

If we allow this terminal to be built then the big tech data centre industry will be taking a larger piece of the emissions pie, leaving farmers and regular people to make up the difference in carbon budgets.

Methane emissions
LNG is 20% more emissions intensive than pipeline gas. [4] Furthermore, methane gas is 86 times more effective at trapping heat than carbon dioxide. [5] Methane leaks constantly from these LNG ships (as shown in the video below) yet the application fails to acknowledge emissions from methane leakage. [6] There is no such thing as ‘clean gas’. It is an advertising concept promoted by the fossil fuel industry as a way to prolong their damaging profit machine.

Energy security
Importing LNG will increase our long-term reliance on fossil fuels sold to the highest bidder in a volatile global market and only serve to delay the transition to renewables. [7] LNG is a bridge to climate chaos.

Building LNG terminals in an attempt to replace Russian supplies of natural gas would not support short term energy security as there is a 2 - 5 year lead time for approval and construction. [8]

To tackle these issues we need to look at energy demand through regulation of data centres and retrofitting of peoples' homes. LNG is not a solution to energy security concerns in the wake of the Russian war on Ukraine. LNG ships regularly change course mid-journey when they get a higher offer. [9] Building LNG terminals will just increase our reliance on fossil fuels, which are sold to the highest bidder in a volatile global market.

Fracked gas
Ireland banned fracking due to the earthquakes and other issues in places like Pennsylvania where people’s water is undrinkable and they are experiencing all kinds of cancers, birth defects and illnesses. [10] Ireland also issued a policy statement banning fracked gas imports. The Shannon LNG project application refuses to name a source for the LNG brought in. However, the application does mention the Marcellus shale formation in Pennsylvania. New Fortress Energy is also proposing to build an LNG export terminal there. For the Board to assume the gas will not be fracked when over 98% of gas produced in Pennsylvania is fracked would be a failing of its duties. [11] With no other source mentioned it must be assumed that the gas brought in through a Shannon LNG terminal will be fracked.
Approval should not be granted as per the Government Policy Statement on the Importation of Fracked Gas under Section 34 of the Planning & Development Act.

Damage and health risks to local area
Gases like methane, ozone and carbon dioxide have been shown to reduce crop yields in the local area. [12] Not only this but they can cause asthma and respiratory problems in children. [13] In addition the very real risk of pollution to the Shannon Estuary and the mitigation efforts to avoid this are underplayed in the submission.

The region of Kerry and Clare where this LNG Terminal is proposed to be built relies heavily on tourism. Badly needed tourism jobs will be damaged by huge dirty tankers in the Shannon Estuary. [14] It has been estimated that only 30 long term jobs will be created, while even the applicant only plans for a maximum of 67 staff working on the site at any period during operations. [15] In the short term, at most, around 270 temporary construction jobs may be created and these will mostly be given to specialised workers brought in temporarily by the company.

False claims about Hydrogen
Finally, it’s been said that an LNG terminal could be converted to process hydrogen. This is farfetched. The amount of money and effort required to make such a conversion is unfeasible. [16] It would mean essentially rebuilding a brand new terminal. This would take years. If An Bórd Pleanála want to see a hydrogen terminal in the area then a specific hydrogen terminal should be built. For the Board to approve a fossil gas plant on the weak assumption that it may be deconstructed and rebuilt as a hydrogen terminal is a false premise and should be discounted.

NOTES:
[1] New blow for US LNG in Europe as Irish court quashes Shannon LNG consents - S&P Global & Quantity of gas brought in by Shannon LNG - ENTSOG
[2] Data centre electricity demand - Buzz.ie
[3] New Fortress Energy LLC (NFE) Q2 2019 Earnings Call Transcript
[4] Natural Gas and Climate Change - FoE Europe
[5] IPCC’s Fifth Assessment Report (2013)
[6] Methane at Sea: Finding the Invisible Climate Killer - Transport & Environment
[7] LNG cargoes diverted toward Europe from Asia as gas prices soar - Reuters
[8] 5 Major LNG Projects to Keep an Eye on in 2022 - Energy Tracker Asia
[9] Eamon Ryan: LNG imports will not be needed for energy security - GreenNews.ie
[10] Pennsylvania Finally Reveals Fracking Has Contaminated Drinking Water Hundreds Of Times & Demonstrating Risks and Harms of Fracking
[11] Pennsylvania Department of Environmental Protection (5,360bcf / 5,456.5bcf)
[12] Spatial Patterns of Crop Yield Change by Emitted Pollutant - American Geological Union
[13] Reducing methane is crucial for protecting climate and health, and it can pay for itself
[14] LNG threat to Kimberley tourism
[15] Shannon LNG Protestor: ‘We don’t need LNG. There would probably only be 30 odd jobs for local people’ - Irish Independent
[16] LNG infrastructure ‘unlikely’ to support hydrogen - Riviera Maritime Media