Kevin Moore’s Report

Selections from Kevin Moore’s Report to An Bord Pleanala 2002Kevin Moore is a Senior inspector at An Bord Plenala

National Need & Local Benefits

1. There is no actual need for the exploitation of the Corrib Gas Field at this time as there is a second interconnector being developed by Bord Gais, a new ring main is being put in place to allow for planned expansion of gas supply in the State, and a reservoir has been developed at Kinsale Head. These principal developments will meet the medium-term gas needs of the country.
2. In light of these provisions, and in terms of need, the supply from the Corrib Field can only be viewed as a back-up supply or an alternative competing resource with the resource to which Bord Gais has committed itself to.
3. In accommodating the Corrib supply, the link from the terminal to Craughwell, Co. Galway would be constructed at a cost to Bord Gais.
4. The development would take place at a time when there is no commitment to the expansion of the pipeline network to towns in the region such as Ballina, Castlebar, Sligo, etc.
5. The development, which in effect would derive from the Border Midlands West (BMW) Region, would offer little benefit to this Objective 1 EU region and would be allowing a valuable natural resource, with a very limited lifespan, to be virtually wholly used outside of this disadvantaged region, entering a ring main designed to function primarily as a security of supply for the Cork-Dublin gas distribution system.
6. There is a commitment to only 60% of the resource being sold to Bord Gais.

Thus, in my opinion, the exploitation of this very valuable natural indigenous resource is premature because, with a short 15-20 year lifespan, the region would lose out significantly in the potential to expand the gas distribution network in the region, the potential to facilitate the region's energy infrastructure, and in the potential to create substantive socio-economic spin-offs for the region. The draining of this resource to a national network through the West Region (outside of Galway), without tangible, definitive benefit to the region and to the north-west is unacceptable in the knowledge that such benefits could fall to these regions when appropriate commitments are in place and when there is a need to exploit this resource. [Ref. pp. 58-9]
Offshore Processing

I find it difficult to move away from a now informed opinion that the choice of the preferred option [ie. Land-based processing plant] is primarily based upon the cost difference between it and other offshore options such as the shallow water fixed steel jacket option rather than the environmental or technical constraints. In my opinion, the development of a shallow water fixed steel jacket option appears a better option from an environmental perspective, based upon the developer's own assessment criteria. It allows the developer to utilise proven technology to exploit the gas resource, to process gas offshore, in waters less hostile than the other offshore options. In utilising this ''proven technology'' (as accepted by the applicant) there should be no reason to suggest that there would be any significant adverse effects on the marine environment nor should there be any reason to believe that discharges and potential spillages would be any less stringently controlled. While offshore processing may be considered more complex, I would be comforted by the fact that the method of processing that would be undertaken would be by, what the Managing Director of Enterprise described in his submission to the Oral Hearing as, large, reputable companies with good track records in the industry with a strong commitment to safety and the environment. Furthermore, on this issue of complexity, it has been continuously submitted that Corrib gas in its raw form is dry. Being so pure, the 'conditioning' required to satisfy Bord Gais export gas specification has been described by Mr. Easey, on behalf of the applicant in his submission to the Oral Hearing entitled ''Terminal Overview'', as ''very simple''. The complexity of conditioning dry gas in comparison with a wetter raw gas would appear to be significantly reduced whether such conditioning would take place onshore or offshore. Also, and extremely significant, is that while a subsea pipeline to shore is common to all options, offshore processing would allow dry conditioned gas to be transported long distances (over hundreds of kilometres as described by the developer). This would be a significant advantage in considering alternative locations for landfall as it would eliminate the concerns of transporting gas that has not been conditioned over a lengthy distance of 92km to a terminal onshore. [Ref. pp 69-70]
The Board determined that, based on the submissions made, ''in regard to the development concept proposed, it has not been demonstrated that the remote siting of an onshore processing terminal eight kilometres inland from the landfall constitutes the best alternative''. One could only reasonably conclude that the issue of concern is the remote siting of a processing terminal inland, away from the landfall. At no time in the submissions now before the Board and since the Board's request was issued is this concern redressed. This consideration by the Board is the basis upon which it goes on to lay out its specific request. It would have to be apparent (indeed there could be no confusion) that the Board wanted a comparison of an alternative to that which was proposed, i.e. an alternative that was not a remote inland gas processing terminal. What the applicant has done is to undertake a comparison of two remote inland terminals, one a processing terminal and one a reception facility associated with a shallow water platform. Furthermore, and to an even greater extent incomprehensible, the applicant has utilised the same site for this comparison process. I put it to the Board that the applicant has failed to address the further information request. What was offered in the form of a response, and which was defended at the re-opened hearing, was that the shallow water platform option was eliminated early in the selection process because it was considered to be not economically viable. The applicant was questioned by most of the third parties at the re-opened oral hearing on the failure of its response to what the Board had asked by way of further information. The response of the applicant at the hearing is notable on this issue when questioned about what further investigations and further submissions were made to the Board relevant to the alternative option. The response given by Mr. David Taylor, one of the applicant's main expert witnesses on the issue of alternatives, on the last day of the re-opened hearing is telling when he stated ''we have not made any because in our opinion the consideration of alternatives in the EIS and as discussed at the oral hearing in February was perfectly adequate.'' I put it to the Board that this shows that despite specifically being requested to address an alternative option that this item of the further information request was at best ignored. When further questioned about the Board's requirement to address the reference to Killala/Ballina and Westport/Castlebar and compatibility with current development strategies for Mayo, Mr. Taylor responded ''that was covered in the EIS and in the previous oral hearing.'' This is further indication that the applicant did not seek to address what the Board actually asked. In my opinion, the request for further information on this issue, resulting in no response to the request actually posed, allowed the applicant to present further documentation that sought to justify its method of development. The issue of the siting of a gas processing terminal in a remote location, inland at a significant distance from the landfall, was avoided in my opinion and I would be strongly of the view that any review of the documentation submitted would justify this conclusion. [Ref. pp. 207-8]
Pipeline Route through Rossport

[T]he pipeline would commence at Dooncarton in Broadhaven Bay, a proposed Candidate Special Area of Conservation and a designated Area of Special Scenic Importance. It would cross Sruwaddacon Bay twice, a Special Protection Area and a proposed Candidate Special Area of Conservation. The beaches on both sides of this Bay over which it would be laid are designated Areas of Special Recreational Importance. The pipeline would also traverse Glenamoy Bog Complex, a Special Area of Conservation before entering the proposed terminal site. Over the length of the route it would also cross other areas of peatland occasionally. Indeed, Geological Survey of Ireland information available to the applicant in the preparation of the environmental assessment of the proposed pipeline route suggests that the ground between the proposed terminal site and the Glenamoy River and that bordering the eastern half of Sruwaddacon Bay is underlain by blanket bog. The peat between the river and the terminal site has a thickness of between 2.5 and 4.5m. Along the shoreline thin topsoil overlies a metre or so of sand and gravel which in turn overlies weathered bedrock. It should be noted that the working width of the pipeline trench would be 40m and the trench depth would have a minimum cover of 1.1m to the top of the pipeline in agricultural land and 1.5m below the clean bed of streams and ditches. The applicant also submits in Section 11.5.1.4 of Appendix A of the EIS that there will be a need for blasting over a number of rocky areas to allow for the development of the route. The criteria used to determine a suitable route for the pipeline from landfall to terminal have been seriously breached in my opinion.

It is apparent that the development concept that has been decided upon has limited the serious consideration of alternative landfall locations, restricting landfall to the Dooncarton area in general. Following on from this, the selection of the terminal site some 8km inland has created a very limited spatial corridor through which a pipeline would have the ability to traverse. This narrow assessment of alternatives is seriously deficient in my view. Once again, I would stress the importance for the Board to give serious consideration to each of the alternatives to onshore processing as each alternative concept clearly determines the type of facility which would be developed onshore and, obviously, the potential routing of a raw gas pipeline, if any, from landfall to terminal site.

In conclusion, I would draw the attention of the Board to a response by Mr. Taylor in cross-examination by me at the Oral Hearing when asked is the crossing of an untreated gas pipeline, umbilical system and discharge pipe through a terrestrial corridor of 8km or more unprecedented. He submitted that it is the only one of a kind that he is aware of. [Ref. pp. 75-6]

Department of Marine Report April 2002 – Marine Licence Vetting Committee (MLVC)

There are two of points of particular relevance that must be aired at this stage on this issue:

1. How the MLVC came to its conclusions would appear to be beyond the realms of a rational approach to the planning of this major infrastructural development and exhibits nothing short of prematurity, in my view, when the decision of the Board on the critical issue of where best to locate a terminal had not been made in April, 2002. The determinations of the MLVC are not specifically relevant to the planning appeal on the terminal site and are clearly significantly premature in the context of determining whether planning permission should be granted at Ballinaboy or not. Their determinations should not be utilised as a stick for driving the Board in the direction of a grant of planning permission in this way. Their deliberations are not the determinants on whether the development should be granted planning permission or not. In effect, if this was to be the case, the Board's function has been undermined in determining the proper planning and sustainable development of this area.

2. 
   The MLVC compared the treatment of gas at source with the treatment of gas onshore. It did not compare the treatment of gas onshore with a shallow water option, i.e. offshore but not at source. The utilisation of the findings of the MLVC are not appropriate in this instance when considering what was asked of the applicant by way of further information. Furthermore, the applicant appears to be seeking to use the findings of the MLVC to undermine the deliberations of the Board on the suitability of the Ballinaboy site from a planning perspective. The Board are obviously aware that it is the Board that takes the planning decision on whether planning permission should or should not be granted for a terminal at the Ballinaboy site and that it is not the responsibility of the MLVC. The determinations by the MLVC on the suitability or otherwise of Ballinaboy as an appropriate location from a planning perspective is not particularly relevant and is misplaced by the applicant in this context as the MLVC was comparing a gas processing facility at source compared with an onshore facility, not the comparison which the Board sought. In addition, emphasis placed on decisions by the Minister for Marine on pipelines, development concepts, etc. should not pre-empt, or override any planning function of the Board, most particularly its decision-making process on the planning appeal for a gas terminal. The approval of the overall Corrib Plan of Development and the construction of the pipeline from the field to the proposed terminal site could reasonably be determined as being premature, in my opinion, when no planning decision has been made on the planning application for a gas terminal. It may be construed by some observers as potentially undermining independent decision-making in the planning process. The approval of the Plan has emphasised a perception to some degree that the granting of planning permission for the processing terminal at the Ballinaboy site is a fait accompli. To concur with this view would be to disarm the Board of its planning function. [Ref. pp. 212-3]

Alternatives

• 
  Fundamentally, the applicant failed to respond to the Board's request set out in the Section 10 notice.
  
• 
  The development of a gas processing terminal at Ballinaboy is not inherent in any national, regional or local policy documents, inclusive of the National Spatial Strategy.
  
• 
  The deliberations by other parties on other elements of the Corrib gas field development, inclusive of the Corrib Plan of Development, should not undermine decision-making in the planning process relating to this gas processing terminal.
  
• 
  The proposed subsea tie-back would be the second longest in the world. The subsea development as proposed raises notable issues relating to system reliability based upon information now before the Board.
  
• 
  From the details provided by the applicant on existing subsea tie-backs around the world that are regarded as similar in principle to Corrib, all are tied back to offshore processing platforms, not land-based terminals. This is notwithstanding varying available reserves.
  
• 
  What is known of proposed subsea tiebacks, their proposed processing terminals on land would be sited in coastal areas and not inland in remote rural locations.
  
• 
  The applicant's limited number of gas field to landfall studies failed to investigate approaches along the west coast such as Clew Bay and Galway Bay. A route to Killala, however, was identified.
  
• 
  The decision to pursue a subsea tie-back development option significantly undermined serious consideration of other development options.
  
• 
  The developer has not proved that the alternative option is unviable. The applicant's own gas field to landfall studies and the earlier option to provide a dedicated pipeline to Dublin at the developer's expense would indicate that the available reserves in the Corrib Field allow for serious consideration of alternatives beyond that which is proposed.
  
• 
  There is no evidence in the totality of the documentation now before the Board that specific alternative terminal sites were seriously investigated.
  
• 
  Despite the gas field to landfall studies showing an acceptable pipeline route to Killala, no development details on a terminal at Killala were presented.
  
• 
  The environmental impacts of the two alternatives on the local community, i.e. the people most greatly affected by the development concept chosen, have not been addressed in the applicant's submission on alternatives.
  
• 
  The value of the Corrib gas resource has not been quantified in any of the information now before the Board. Thus, the considerations on the cost of the proposed development compared with the alternative cannot be determined.
  
• 
  While the applicant submits that the proposed development will result in an acceptable economic return, nothing is known of the scale of the economic return that would derive from the alternative.
  
• 
  The issue of benefits and disbenefits to the Erris community and to the BMW region has not been considered by the applicant despite the very significant socio-economic implications in the choice of development option.
  
• 
  From the perspective of the strategic planning of infrastructural development for the BMW region and, having regard to prospectivity in the area, the proposed siting of a remote, inland, rural-based processing terminal, with its significant tie-back constraints, imposes limitations on achieving the objectives for the BMW region for balanced regional development. The development does not present itself as the optimum solution for the betterment of the region in seeking to achieve the proper planning and sustainable development of the area.
  
• 
  The claim by the applicant that Corrib gas would provide in excess of 50% of the country's gas requirements in its key production years must seriously be called into question as a consequence of the control and method of gas sales by the three individual partners who are developing the Corrib Gas Field. [Ref.350-1]