Submission against Shell EIS and CAOs

Below you can find the two community submissions
1. against Shell's EIS pipeline application.
2. against Shell's application for Compulsory Acquisition Orders

Feel free to print off and send as your own or write your own version.
Deadline is this WED 28th July 5.30pm.
Case reference: PL16 .GA0004

To: An Bord Pleanala,
The Board,
64 Marlborough St,
Dublin 1.

Re: Re-routing Of Onshore Upstream Gas Pipeline Relating To Corrib Gas Project, Co. Mayo

Case reference: PL16 .GA0004

We would like it to be put on record that we strenuously object to the granting of this experimental pipeline and corresponding works on the following grounds:

1.This project has never had the consent of the local community; our concerns and suggestions have continuously been ignored. We believe Shell is in breach of EU Directive 85/337 on environmental impact assessment, and its amendment Directive 97/11.
Human Concerns:

2.The overall danger of this experimental raw gas pipeline running through our community. Our concerns regarding the running of this high pressure gas pipeline close to houses through an area with a history of landslides have not been addressed.
3.In the An Bord Pleanala letter of the 2nd November 2010, the Board stated that traffic flow for the previous route in Rossport “would constitute a traffic hazard and obstruction of road users”. The community in Glengad, Pollathomais, Aughoose, Leenamore and Bellanaboy deserve the same consideration. At its peak there would be 236 truck round trips from the proposed compound at Aughoose. 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.
4.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?
5.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.
6.The LVI still puts people in unnecessary danger. We have recently seen with the BP disaster in the Gulf of Mexico what happens when supposedly fail-safe devices fail to operate. Shell are now relying on the subsea installation that Transocean have installed to limit the pressure coming to landfall. Transocean's reputation is currently under serious scrutiny.
7.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.
Environmental Concerns:

8.Shell previously ruled out the route of the tunnel on environmental and technical grounds. If Shell are ruling something out on environmental grounds then it has to be really environmentally devastating. If what they are proposing to do is at the edge of technical possibilities then this community should not be used as an experimental location. The proposed tunnel is highly unacceptable on environmental grounds as it traverses two Special Areas of Conservation and one Special Protection Area.
9.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.
10.The EIS admits that the 15 month long tunnelling operation will cause vibrations that will be felt in surrounding houses. They 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. The tunnel will run about 40 metres away from a section of land on which there still exists a 6 foot crater left from the landslide.
11.There is reference to an intervention pit which would be used in the ‘unlikely’ event of ‘obstacles’ being encountered that would inhibit the progress of the TBM. Considering that the area of construction is within a SAC and that very few details are given on this possible intervention pit ( ‘sheet piled/cofferdam’ is all that is mentioned), it is highly worrying that such a damaging construction method could even be considered within an SAC.
National Concerns
12.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. We deserve a chance to question both Bob Hanna and Eamon Ryan on their interference in the planning process and also to seek answers on the effect these representations have had on the Board.
13.The continued wasting of taxpayers’ money in supporting this fundamentally flawed project (including illegal aspects of it), especially at a time of grave economic need. Corrib Gas should be of benefit to the whole country, but because ownership of Corrib gas was given to Shell and Statoil, it will mean that the country will receive virtually nothing from it as well as having no claim or right to this gas and consequently all future oil and gas finds.
14.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.
15.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.
16.That this is just part of a much bigger project (some of which is not in the public domain) and, as a whole, is the antithesis of “proper planning and sustainable development”. It seems to be commonly presumed wider afield that Bellanaboy will be used for further gas and oil finds, yet Shell keep repeating the mantra that the Corrib Gas Field is the only gas field that will be connected at the moment. Currently Shell and Transocean are drilling for oil & gas close to the existing Corrib Gas Field.
17.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. With regard to potential supply issues, in essence the gas is no longer ours, it belongs to Shell and its partners. In the event of supply difficulties across Europe, they and the EU will decide what happens to it.
18.How is it possible for Shell to submit the pipeline tunnel application without knowing the results of the relevant survey work in the estuary? This application should be submitted once the results of the survey work are completed in October 2010. If it is not necessary to have these results then why have Shell been allowed to conduct this invasive and damaging work to the Special Area of Conservation and Special Protected Area? This again cannot be called “proper planning and sustainable development”.
We the undersigned, strongly urge you to reject this experimental project.

Against CAOS
To: An Bord Pleanála,
The Board,
64 Marlborough St,
Dublin 1.

Re: Community Submission Against Compulsory Acquisition Orders Relating To Corrib Gas Project, Co. Mayo

We the undersigned object to An Bord PleanPleanála issuing Compulsory Acquisition Orders against local landowners for the following reasons:

The community has not been properly consulted and does not consent to the project. 
The compulsory acquisition of our neighbours' land will contravene Article 43 of the Irish Constitution in that:

1.Our neighbours have the right to the private ownership of land.
2.The state cannot pass a law that attempts to abolish this right.
3.It is not in the interests of social justice for the state to forego this right and have land compulsory acquired from members of our community for the use and profits of Shell. The primary and immediate benefits of this compulsory aquisition order will be to Shell who will get land that is not available on the open market. 
4. It is not in the common good or national interest to compulsory acquire our neighbours land; it is purely for the good of Shell.

We remember the brave stance of our neighbours in Rossport who received CAOs and were jailed for refusing to allow Shell on their land.

We therefore support our neighbours in objecting to these compulsory acquisition orders.

Yours sincerely,