To: Mr. Ian Douglas, Planning Office, Mayo County Council.
Re: Gas Terminal Planning Application, Bellanaboy, Co. Mayo.
Date: January 29th, 2004.
Dear Mr. Douglas,
The following is a brief submission by Feasta on the application by Shell E. and P. to construct a Gas Processing Plant at Bellanaboy Bridge, Co. Mayo. Feasta, The Foundation for the Economics of Sustainability, was established in 1998. It aims to explore and promote the characteristics – economic, cultural and environmental – that a society must have in order to be truly sustainable.
While there are many issues of concern regarding this application, Feasta’s primary focus in this submission is on questions of sustainability, specifically that of energy. The applicant is asserting that there is a need for the project; that the project is consistent with government policy; and that the proposal amounts to ‘sustainable’ development. For the reasons briefly outlined below, Feasta submits that none of these assertions are valid and that, accordingly, you reject the planning application.
1. The proposal by Shell is to construct a gas processing plant in order to exploit in full reserves of natural gas off the Mayo coast. Feasta’s submission is that there is no demonstrable national need to do this; that the proposal conflicts with stated government, European and international policy on fossil fuel use; and that the national need is not served by an immediate exploitation of the gas supply.
2. There is no demonstrable national need to exploit the Corrib gas reserves at this time. On the contrary, the construction of a second natural gas Interconnector between Ireland and Britain has ensured a continuity and security of supply. This is stated clearly in Bord Gas Eireann’s Annual Report for 2002. No threats to supply exist at present or for the foreseeable future. The applicant’s styling of the Corrib Gas reserves as ‘indigenous’ is irrelevant due to this gas having to be purchased at full market price by any prospective local buyer. The consequence of the exploitation of the Corrib reserves is simply to grossly over-supply an already replete Irish gas market. Corrib gas is simply not needed at this time.
3. The policy framework for any planning decision, including one on the exploitation of fossil fuels, is outlined in a number of documents. It includes international commitments entered into by Ireland and the European Union. These are comprised of, among others, the United Nations Framework Convention on Climate Change which includes the Kyoto Protocol and the Agenda 21 commitments made in Rio in 1992. Also relevant is the Gothenburg Protocol to the Convention on Long-Range Transboundary Air Pollution. Additionally, EU law and policy including the 6th Environmental Action Plan and the Gothenburg Process must be considered. At national level, the National Sustainable Development Strategy, the National Climate Change Strategy and the National Spatial Strategy give significant national policy guidance. We believe that the implementation of the principle of Sustainable Development, which underpins all of the laws and policies referred to above, means not extracting the gas now.
4. The critical policy context within which this application should be examined is that of climate change and future fossil fuel depletion. Both of these factors combine to impose upon us the obligation now to develop new, renewable forms of energy. Indeed, government policy as stated in the National Climate Change Strategy gives full support to this approach. The immediate exploitation of natural gas supplies would merely continue the country’s reliance on fossil fuels and further postpone our necessary transition to renewable energy sources. To this extent it is in conflict with the thrust of national and international energy policy. The argument of the applicant that natural gas is ‘environmentally friendly’ because it is a source of less carbon gases than coal or oil misses the point completely.
5. A transition to sustainable forms of energy use is a core national policy. Extracting the gas and feeding it into the current system will merely prop up that system. However, because of the extent of the changes needed to move to a different energy system, there would be a significant role for this gas to be invested in fuelling aspects of the transition to sustainable patterns of energy use. Accordingly, the national need and the agreed national policy goals would be better served by either of the following positions:
5.1 The Corrib gas supply should be retained by the State as a strategic reserve against a future, sudden loss of fossil fuel supplies.
5.2 The Corrib gas supply should be retained until it can be utilised as part of a transition process to construct and create new structures for the generation and dissemination of renewable energy and renewable energy systems. That is, it should only be invested in effecting a transition to wider energy sustainability.
It is not of course for the Council to make national policy. But in arriving at a planning determination, you are obliged to take account of national policy and wider national needs. In this submission, Feasta argues that these are best served by a rejection of Shell’s application. The Corrib gas supplies are a precious resource that should be used wisely and sustainably in the interests of all the people of Ireland rather than being squandered for the short-term interests of a global oil and gas corporation.
Yours sincerely,
Mark Garavan and David Healy,
Feasta,
159 Lower Rathmines Road,
Dublin 6.
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