"The Government have clearly sent the message to Shell, ‘you can do whatever you want’. Fortunately due to protest, the refinery remains unconnected to the gas field. If, as Shell planned, gas had been flowing by now, we would potentially all be dealing with a gas leak and explosion.”
Below is a sample submission to John Gormley, Minister for the Environment regarding the Shell's Foreshore Licence Application to construct a 4.9km tunnel that is 4.2 meters in diameter under Sruwaddacon Estuary.
We're trying to keep track of how many submissions are being sent in so if you can copy email@example.com if your emailing it in or else send us a email afterward to let us know.
You can read the technical details of what Shell propose here: http://www.corribgaspipelinefs.ie/
To: Minister John Gormley
Department of the Environment, Heritage and Local Government,
RE: Submission on Shell E&P Ireland Ltd (SEPIL) Foreshore Licence Application on the Corrib Gas Pipeline to the Foreshore Unit of the Department of Environment.
I request that you reject SEPIL's Foreshore Licence Application to build a 4.9km tunnel under Sruwaddacon Estuary.
In the event that you, Minster Gormley don't see fit to reject this destructive application outright then I request that an oral hearing be held into the giving of this Foreshore Licence.
I request that you reject Shell's application for the following reasons:
- You, Minister Gormley speaking regarding a directive covering Special Areas of Conservation (SAC) and Special Protection Areas (SPA) are quoted on the 2nd of August 2010 as saying “Ireland has designated certain areas for nature protection and, in those areas, that must be our priority. Many people, indeed, find recreation in the enjoyment of undisturbed nature”. You are now being asked to allow Shell to drill for a 4.2 meter diameter tunnel that is 4.9 km long through an area that has been designated both an SAC and a SPA. If you grant permission for this tunnel, you will be proving that these environmental designations are meaningless in reality.
- Shell state that they may possibly have open a pit from the top of the water should they have trouble boring through the material. Shell fail to cover the consequences that creating an intervention pit (or pits) would have in the estuary sufficiently, and this is unacceptable given that this could potentially destroy the estuary to much marine and other wild-life for many years.
- Shell admit that it will probably take about 15 months of actual tunneling 24 hours a day (thats over 10,000 hours of the 4 diesel generators (combined power of 3 Mega Watts) running right beside the SAC). 68,000 cubic meters of material will be removed from the estuary during the tunnelling process.
- Shell admit to putting 2.5km of 3m high fencing up to secure their compound in Aghoos for the 26 months that it will take for them to complete their work. To have such a disruption right next to the SAC will further diminish the integrity of the area.
- It is outrageous that Shell are asking for permission to drill this tunnel before they have even done the necessary survey work to ascertain the conditions in which they would be working. In effect, they are asking for carte blanche to drill under the estuary, even if it is the area is totally unsuitable. How can they state that they are unlikely to need intervention pits if they don't know what they will be drilling through?
- The new proposed pipeline route is actually closer to the area under Dooncarton Mountain that was devastated by over 40 separate landslides on 19th September 2003. In the EIS, in the section dealing with the potential for landslides, geological consultants AGEC admit “Where debris becomes channelised it will flow for a greater distance and could possibly reach the proposed route of the pipeline”. The tunnel is proposed to run about 40 metres away from a section of land on which there still exists a 6 foot crater left from the landslide. Shell don't adequately deal with possiblity of a landslide hitting the pipeline route at the various stages of construction.
- Shell also admit that that groundborne vibrations could be felt by people in their homes close to the shore. Will these vibrations increase the chances of landslides in the area? Shell state that these vibrations will be most noticeable in the area around Glengad. This also corresponds with the areas directly affected by the landslides in 2003.
- Shell state that the vibrations from the tunneling will generate sound within the water body. It is accepted that this sound will disrupt marine life. It is stated that the Salmon smolt heading to sea that are turned back by the noise of the tunnel boring machine (TBM) are expected to leave when the TBM is turned off. How are these Salmon expected to know when tunnellers choose to operate or not? Also what about the adult Salmon returning up the river? If they are turned back by the noise of the TBM could they choose not to return?
- The political interference that has been exerted by those in power with regard to the progress of this project has been a telling indication on what money can buy in Ireland today. In 2005, Eamon Ryan accused Bertie Ahern of putting undue pressure on ABP to force the project through. Yet in 2010, the now Minister Eamon Ryan allowed his Chief Technical Officer Bob Hanna to lobby An Bord Pleanála to not seek some of the safety requirements they were looking for with regard to the onshore pipeline.
- The EIS does not show that any perceived benefits for the community or the country are worth the risks being taken. We all have a responsibility towards sustainability and future generations.
- It is another step in facilitating the rip-off of Ireland of its oil and gas by multinational companies, contrary to our Constitution. Getting the gas ashore is not of strategic importance in providing extra revenue for the State. The total State take will be small, limited to the 25% profits tax, and will be long delayed since taxable profits will only be declared after all the exploration and development costs have been written off. Given that other exploration costs in the Irish offshore areas can also be written off, there may never be taxable profits from Corrib.
- That the whole progress of this project thus far has undermined representative democracy which is vastly more important than any of the limited benefits that will accrue from this project.
- During peak construction the EIS states that there will be '472 daily two way HGV trips and 662 daily car/bus trips' . This would significantly disrupt normal life in the area. The construction work on the pipeline will take an estimated 26 months to construct. It is unacceptable that local people will be disturbed for 26 months.
- The community have continuously stated that the pressure in the experimental pipeline places the community at unacceptable risk. Previously Shell have been unable to state what the Maximum Allowable Operating Pressure will be. However the latest EIS offers figures of 150 bar to the LVI and 100 bar to Ballinaboy. How is it that it is possible to state the MAOP now when it wasn't previously possible?
- The pipeline will run close to a school, church, graveyard and a public house and also crosses a road. Local families will be put at unnecessary risk while going about their daily lives.
- Shell's track record on safety, environmental and human rights is well-documented world-wide and should mean that they are unfit to carry out this experimental project so close to our community.
If you sign off on this permission to construct this tunnel you will be proving that the Special Area of Conservation and Special Protection Area designations are meaningless. You will certainly cause the further degradation of flora and fauna of this beautiful area.
You will also be putting the human life around the area of the tunnel in totally unnecessary danger.
Please give my concerns higher priority than the profits of Shell, Statoil and Vermilion.