It’s Christmas… and Leitrim CDP time!

Leitrim County Councillors decide policies on fracking.  

Members of GEAI (in particular Aedín and Eddie) have been really busy this month. The first (pre) draft version of Leitrim County Development Plan, which was not at public consultation stage, was given by the officials to our Councillors and, needless to say, copies managed to find their way into the hands of some campaigners. We were dismayed – a whole section on “Hydrocarbon Exploration and Extraction” and the wording amounted to a pathway to fracking. No ban on fracking, emphasis on hydraulic fracturing rather than the whole life cycle of unconventional gas development and no mention of Health Impact Assessment (HIA).

What to do? Obviously, all campaigners against fracking would like to see a ban on the whole process. Many kept calling for this and said that nothing less would suffice. However, the Council officials, backed up by legal advice and the results of a court case in Mayo where a ban on mining was disallowed, insisted that the Plan could not include a straightforward ban.
So – members of GEAI and others went about the situation in a different way.

Campaigners insisting on a ban were asked to research the issue and come up with a way to include a complete ban in the Plan.
An alternative view was that if a ban could be included, that would be great. However, if a ban could NOT be included or could be overturned in the future by a Minister, policies had to be put in place that would, as much as possible, safeguard communities and the environment from any adverse impacts of Unconventional Gas Exploration or Extraction (UGEE).

 This major task was taken on – the background to the Development Plan was researched and a paper was produced that summarised the background to the situation in Ireland at the moment regarding shale gas and made sure everything relevant was included in the introductory section; various people and organisations were consulted and policies were then worded that, in the view of those involved, went as far as possible to prevent any UGEE projects taking place.

Information sessions and discussions were held with Councillors to make sure that they understood and agreed with what was being proposed.
The main policies proposed in the paper can be summarised as follows:

  • Precautionary principle on all proposals for UGEE projects/operations (this includes preparatory work and deep drilling) where risks are not “determined with sufficient certainty”.
  • Comprehensive HIA on national policy and on local UGEE proposals.
  • No UGEE projects/operations unless “it is scientifically and credibly demonstrated that those projects can be undertaken sustainably whilst also fully protecting the environment and human health”.

Constant contact was kept with Councillors from all parties throughout the process. The paper was also scrutinised by Council Officials.  Our understanding is that all the policies suggested may not be accepted (for various reasons) but significantly, a Health Impact Assessment may now be included. The final draft will be debated by Leitrim County Council on 16th January and will then go forward for public consultation.

The Public will have until end March 2014 to make submissions on the draft Plan.

Full text of submitted paper CLICK HERE

EPA Terms of Reference “Amended and Strengthened”

Terms of Reference of EPA research study on Unconventional Gas Exploration and Extraction (UGEE)

Making your voice heard matters!  In response to over 1,300 submissions, a ‘Health Expert’ is now on the Steering Committee for the research study.  The final Terms of Reference (ToR) for the EPA study were published on 22nd November. There are many amendments to the draft version, indicating the high quality and impact of the submissions.
Significant changes to the Terms of Reference include:

1. Human Health

• A new section has been added to the ToR to clarify and clearly define the scope of the proposed research in relation to Human Health.
• A Health expert has been invited onto the Steering Committee.
• The potential role of Health Impact Assessment in regulation of UGEE projects/operations is to be studied and recommendations made towards developing a protocol in the island of Ireland context.

2. Life Cycle of UGEE

• The full life-cycle of hydraulic fracturing activities, as well as off-site and other developments, is to be included in the study.
• The Key Research Questions have been amended to:

  • Can UGEE projects/operations be carried out in the island of Ireland whilst also protecting the environment and human health?
  • What is ‘best environmental practice’ in relation to UGEE projects/operations?”

• The cumulative environmental impacts arising from the entire lifecycle of UGEE projects/operations will be compared with those from other energy sources (including renewables).
• With regard to impacts, the assessment should take into account commercially probable scenarios.
• The Revised ToR now has a specific requirement to take account of the Irish context for references and comparisons to UGEE experience in other countries.

3. Water and Chemicals

• The Revised ToR have been extended to include surface waters and implications for local, regional and national resources, the water requirements for UGEE projects/operations is to be evaluated as well as groundwater and surface water resource availability.
• The Final Report should include a comprehensive list of all chemicals known to have been used in UGEE projects/operations.
• If chemical-free fracking is included in the research, it should be clearly pointed out where and for how long such methods have been used on a commercial basis, stating whether there are any peer-reviewed studies into the impacts associated with these methods to the environment and human health.

4. Monitoring

• A study on Air Quality monitoring requirements is to be included.
• The research will assess the concept of the monitoring to be carried out by State agencies versus by industries.

Full Terms of Reference document

“What You Said and how We Responded” – EPA responses to Public Consultation Submissions

Synopsis of Responses with Comments by AMcL

A serious gap in the decision-making process on fracking

How fracking transforms land (Photo: Huffington Post)

Minister for Energy, Pat Rabbitte, gave a speech on 17th April in Royal Irish Academy which confirmed that, despite 1,300 submissions being made to the EPA, the majority of which demanded a study of the health impacts of fracking, the proposed research study on fracking is confined to identifying “best practice in respect of environmental protection for the use of hydraulic fracturing techniques”.
This excludes the stages of pad construction, drilling of wells, gas extraction and treatment, gas transport and site reclamation, all of which add their own risks to communities and to health.  It is therefore far too restrictive.  Many submissions made to the EPA pointed out this fact.  Why is the Minister not listening to the people?
It is also extremely disturbing that no health study is proposed despite the clear wishes of the people.  The EPA study, as described, appears to be an exercise designed to pave the way for fracking.  The project proposed for Leitrim would take over vast tracts of land and industrialise them, changing the landscape and way of life for its communities forever.  No regulations or “best practice” would be able to prevent contamination risks to ground and surface water, air pollution, noise, disturbance and accidents.
Minister Rabbitte went on to state that “The shale revolution is a game-changer”.  We dispute this.  Shale gas does not change the game of burning fossil fuels; it is not clean energy, despite the propaganda of the oil/gas industry; it is not a sustainable source of energy, disappearing once the gas is extracted; the gas produced would belong to the industry, not to the people, and would be sold on the international market at the market price.  Fracking will NOT bring cheap gas to Ireland, nor will it make us energy-secure.
Good Energies Alliance Ireland believes that we should be moving forward on the path towards making Ireland carbon-neutral by 2050 and ensuring that all decisions made on energy sources, uses and allocation of resources reflects this priority.  Shale gas is not the answer!
The International Energy Agency (IEA) said in a recent report that “Governments have the power to create markets and policies that accelerate development and deployment of clean energy technologies, yet the potential of these technologies remains largely untapped.”
Ireland has a choice – to go down the fracking route and destroy our rural communities and international reputation or be a world leader in the move away from fossil fuels and towards renewable energy sources.

Will the EPA include a Health Impact Assessment in the new research study?

Glass of milky brown water in DimockOver 1,300 submissions were received by the EPA concerning the proposed Terms of Reference for their new Research Study on fracking. The majority of those demanded a study on the impacts of Health on the whole process of fracking.
Among many other individuals and groups, GEAI demanded a full Health Impact Assessment (HIA). We believe that only this can give a true picture of the impacts of fracking on health and the community. Attention is now turning to the process of scoping and carrying out this study. One of the rights of individuals under the Aarhus Convention (ratified by the Irish Government last year) is public participation in environmental decision-making:
Arrangements are to be made by public authorities to enable the public affected and environmental non-governmental organisations to comment on, for example, proposals for projects affecting the environment, or plans and programmes relating to the environment, these comments to be taken into due account in decision-making, and information to be provided on the final decisions and the reasons for it.”
Two conclusions can be reached:
1. Since most of the submissions received looked for Health impacts to be studied, the EPA now has to either agree to this, or give the reasons why not.
Indications are that they have agreed to include some form of Health study but the public must be informed as to what kind of study is proposed and we can demand input into this decision as well. Nothing less than a full Health Impact Assessment would be adequate.
2. There are fundamental flaws in the process by which this study is being managed.
  • There is no representation from the target communities on the Steering Committee managing this study; neither are there members from the Departments of Health or Agriculture.
  • There is no accountability to the public since the EPA and associated organisations have immunity from prosecution.
  • There are no further proposals to enable the public affected to comment on amended Terms of Reference, the scope of the research study, or draft reports.
The “public consultation” we have had, although a step in the right direction, is not enough. The public MUST be involved at every stage of this extremely important study. We have seen how public opinion and lobbying can influence Government decisions. We now must demand input into the research study process.
Picture: Glass of milky brown water in Dimock, Pennsylvania (From Marcellus Protest)

[Press release] EPA proposed fracking research ignores public health

Press release 03.02.13

“Public Health is an essential aspect of any research study on fracking,” states Dr Aedín McLoughlin of Good Energies Alliance Ireland (GEAI). “Whereas globally, attention is focussed on the environmental impacts of fracking, health does not depend on a clean environment alone; social and economic factors are also important, e.g. living conditions, a feeling of belonging, social justice, community and culture, social services, good jobs and fair wages. A major study on shale gas development from New Brunswick* recommends the submission of a Health Impact Assessment (HIA), which includes all the above factors, on proposed shale gas projects.
The EPA proposed Terms of Reference for an extended study on fracking shows a lack of concern for Public Health. There is no representative from the Department of Health on the Steering Committee to oversee the study and no proposal to include a Health Impact Assessment (HIA) in the Terms of Reference. The New Brunswick report clearly shows the importance of having Public Health as a central element in any study on the impacts of fracking.
Whereas an Environmental Impact Assessment (EIA) is proposed, we say that this is not enough. An EIA assumes that if regulations are put in place to protect the environment, then health will also be protected. Clean air and water are indeed important for health. However, only a HIA will include study of social and economic impacts, equally important for community well-being.
We know from the exploratory company Tamboran Resources what is planned for Leitrim in the first phase of shale gas extraction2. 50,000 acres of rural Leitrim to be industrialised; 60 x 7-acre mining pads constructed with up to 24 wells drilled and fracked per pad, 1,500 wells in total over 15 years; enormous volumes of water used and wastewater produced; access roads, heavy traffic and gas-pipe networks throughout the area.
GEAI demands that the EPA research study includes a Health Impact Assessment using this scenario of gas extraction. The EPA has invited submissions on the proposed Terms of Reference, with a deadline of 8th March. We call on all concerned citizens to join with us and to send submissions to the EPA demanding such a Health Impact Assessment.”
Download a submission template as a word document [doc].
* Chief Medical Officer of Health’s Recommendations Concerning Shale Gas Development in New Brunswick. (September 2012)

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