GEAI calls for study of Public Health impacts of Fracking

GEAI members are very concerned about the recent revelations concerning the main contractor (CDM Smith Ireland) of the EPA-led research on Fracking, as published in an article by Ronan McGreevy in today’s Irish Times.

“The confirmation of strong links between CDM Smith and the oil and gas industry calls into question the independence of the researchers and the trustworthiness of any research results,” said Dr Aedín McLoughlin, spokesperson of GEAI.  “This research study was initially proposed to assist Government to make policy decisions about fracking in Ireland.  Instead what we have is a study led by a company engaged in promoting fracking in Europe and focussed on developing regulations that could enable the fracking industry to operate in Ireland.  There is no policy dimension at all in the study.

The main issues of concern to us all are the impacts of fracking operations – exploration and development – on Public Health.  The vast majority of submissions to the EPA concerning this research demanded a full study of such impacts and only lip service is currently being paid to those demands.

We now call on the Government to immediately commission a full study of the Public Health impacts of Unconventional Hydrocarbon Exploration and Extraction, led by the Public Health Division of the Department of Health and HSE, including a review of all peer-reviewed literature on the subject such as was carried out in New York State recently.  Such a study is vital to the development of policy on Fracking. ”

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Wind energy essential for Ireland’s future, but communities must benefit

By John Arnold

By John Arnold

We in GEAI have published our position paper on Wind Energy with some controversial conclusions. Our main position is that “The development of wind energy is an essential part of the development of low-carbon energy generation in Ireland but such development must have genuine benefits for and buy-in from the Irish people.”

Our EVS volunteer and researcher Irina Tiugan explains, “We fully support wind energy development, on-shore and off-shore, but not the approach that has been taken so far to such developments; communities must be at the core of the planning process. If communities are involved in wind energy projects, they have more chance of success. In Germany, France and Scotland, we have seen that the involvement of the community in the development process has led to general acceptance and a faster implementation of the project. In other words, if people genuinely benefit from local wind energy projects, opposition to them is far less.”

The potential of wind energy to contribute to creation of a low-carbon Ireland is huge. Ireland is the second windiest country in Europe after Scotland, and it has a great potential for wind power. At present, wind produces less than 20% of Irish electricity consumption while the country spends billions every year importing fossil fuels.

GEAI fully supports and encourages community ownership of wind energy projects and small neighbourhood wind energy projects.  “Many studies show that if people have buy-in they will accept wind energy development”, said Irina.

We encourage Government to move effectively towards a collaborative planning approach in the development of wind energy as a national resource owned by and benefiting the Irish people. “With this Position Paper we want to contribute to a scientific-based debate around wind energy in Ireland, as well as to help in building a  sustainable, low-carbon and fair country,” Irina concluded.

Decisions on fracking in Ireland delayed until after 2016

drilling rigIn 2012, the Government decided that no decisions on granting exploration licences for fracking would be made until a comprehensive research study would be done, coordinated by the EPA. Public consultation on the Terms of Reference of this study was carried out in 2013 and over 1,300 submissions were received by EPA, largely coordinated by GEAI. This delayed the process considerably and the contracts to carry out the 24-months study on the “Environmental Impacts of Unconventional Gas Exploration and Extraction (UGEE)” were only issued last August. It is ironic that this is exactly the same month when Tamboran was stopped from drilling their first borehole in Fermanagh!

Interim reports on the research study will be given, possibly at 6-month intervals and definitely at the end of Year 1 and Year 2. These reports will be given at public events, giving an opportunity for public engagement and discussion. The final outputs of this research will not be published until end 2016. This means that no decisions on fracking can be made in the Republic before 2017.

The consortium that will carry the research is led by the management company CDM Smith Ireland LimitedQueens University BelfastBritish Geological SurveyUniversity College DublinUniversity of Ulster, AMEC, and Philip Lee Solicitors are also part of the consortium.

The 24-month research programme is composed of five interlinked projects and will involve field studies (baseline monitoring of water and seismicity) in Clare, Leitrim and Fermanagh, as well as an extensive desk-based literature review of UGEE practices worldwide. The ‘key questions’ the research programme sets out to answer are:

  • 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 campaign against fracking is, in general, not satisfied with those parameters. The majority of submissions asked for a Health Impact Assessment of proposals for fracking be carried out. This was not agreed and is not included in the final Terms of Reference. Also, the research is too much focussed on the capacity of regulations to limit the impacts of fracking.

However, the study will provide more scientific information on the geology of target sites and potential environmental impacts of fracking in Ireland. 

Fracking in the North 

Carrickfergus201409_07

Despite the delay in the South, fracking projects are still going through the planning process in Northern Ireland.

Tamboran Resources Ltd is seeking a judicial review of the Fermangh licence termination. The case has been listed in Belfast High Court for this month (November). Counsel for Minister Arlene Foster has asserted that an expired licence to carry out exploratory shale gas drilling cannot be reinstated through a legal challenge.

InfraStrata is ready to drill in Woodburn Forest in spring 2015, beside Carrickfergus (Co. Antrim). The company denies the use of fracking on the site because “geology is not suitable”. This means that hydraulic fracturing will not be used in the initial exploration drilling. This statement does not guarantee that fracking will not be used during its entire project. Any on-shore extraction of oil and gas has profound and extensive impacts on the environment and on communities.

Rathlin Energy is also ready to drill in Ballinlea, near the Giant’s Causeway. They have completed their Environmental Impact Statement (EIS) and will be submitting that to the Council. They also plan to commence drilling in early 2015.

Leitrim County Development Plan 2015 – 2021

Leitrim is in the middle of making its Plan

The making of the Council Development Plan is one of the most important functions of the County Councillors as responsibility for making the Plan, including the various policies and objectives contained within it, rests with the elected members as a reserved function under section 12 of the Act.

Because Leitrim is targeted for unconventional gas exploration using hydraulic fracturing (fracking), the making of the County Development Plan 2015 – 2021 is of great interest to GEAI, other organisations campaigning against fracking, and the wider public.

It is vital that the section on Hydrocarbon Exploration and Extraction reflects the concerns of the public concerning unconventional gas developments. The Councillors have been advised by the officials that a simple ban on fracking cannot be put into the Development Plan; this is being disputed, especially as Donegal County Councillors have already inserted a ban in their Plan. Advice given to the council is that a ban can be overturned by the Minister. Also, the case of Mayo County Council is also quoted, where a judge ruled against a blanket ban on mining.

GEAI considers that, whether or not a ban on fracking is specifically included in the Development Plan, it is essential to also include some very strong policies to safeguard Leitrim communities from fracking. Such processes as Health Impact Assessment and the application of the Precautionary Principle can be used to prevent short-term proposals to exploit shale gas, causing contamination of our air and waters and damaging the health of people and animals.

Leitrim County Councillors have a difficult task ahead of them. The section on Hydrocarbon Exploration and Extraction must satisfy the public’s need for protection from the environmental and social damage caused by unconventional gas development while “taking on board and implementing relevant national and regional policies” (see below).

WE WISH THEM EVERY SUCCESS IN THIS ENDEAVOUR!

Progress of the Plan is as follows:
December ‘13:
The Plan is at first draft stage – the officials have produced a first draft which can be considered and amended by the Councillors, but must be voted on by mid-January.
Late January ’14:
Officials prepare draft with amendments
February:
Draft goes for public consultation, submissions invited from public (10 weeks)
April:
Officials prepare Managers Report on any submissions or observations
July:
Councillors consider Managers Report. Councillors may accept or amend the draft.
September:
Advertise any material alteration of draft
October:
Submissions on material alterations invited. (4 weeks)
November:
New Manager’s Report prepared
December:
Councillors consider Manager’s Report
January ‘15: Plan published.

BACKGROUND TO THE COUNTY DEVELOPMENT PLAN

The Department of Environment “Guidelines for Planning Authorities, June 2007” provides a good overview of the purpose of the Development Plan and the role of elected members and Local Authority officials. The following gives short snapshots of some content of interest to us:

Role of Development Plan

“The plan creates the vision for the area it covers, specifies the type, amount and quality of development needed to achieve that vision and seeks to protect and enhance the environment and amenities.”

Role of members (Councillors):

“Members must have an active and driving role in the entire process, from its inception to its finalisation. They must listen to and take account of the views and wishes of the communities they represent. They must adopt the development plan at the end of the process. ..Crucially, there is an onus on elected members and the executive to fulfil their responsibilities and functions in the common interest, adhering to proper planning principles and facilitating the sustainable development of their area.”

Supporting National Policies

“Development Plans should take on board and implement relevant national and regional policies in a manner consistent with the NSS and regional guidelines if the planning system as a whole is to function effectively. The Development Plan must be part of a systematic hierarchy of land use and spatial plans, including the National Spatial Strategy and regional planning guidelines. It must also be informed by the plans and strategies of the Government and other public agencies in general.”

“It is important that development plans fully support national policies so that all local authorities play their full part in the achievement of national objectives.”

Protecting the Environment

“The Development Plan will set out policies for the protection of the environment and heritage and is an important source of information for landowners, developers, communities and members of the public in this regard.”

“Local authorities have a key role to play in regard to preserving the natural heritage of their areas arising from the legal responsibilities placed on them and from the increasing public awareness of the importance of nature conservation at local level.”

Sustainable Development

“Sustainable development means ensuring that all development is sustainable in economic, social and environmental terms. As such, the development plan must offer clear guidance on sustainable development policies and objectives, both national and local, which address the various issues involved, such as climate change, waste management, transport, urban development, sustainable communities, use of natural resources etc.”

“Accommodating new development needs in an environmentally sustainable manner is a key way in which development plans can contribute to the achievement of sustainability.”

Public Consultation

“Councils should also actively involve citizens in the whole process of making the plan, especially those who may not normally contribute or engage in the process. Councils should consider innovative methods to encourage as wide a public consultation as possible. It is vital that, from an early stage, as much public and political consensus is built around the strategic direction the new plan is to take.”

“While section 11(2)(c) of the Act does not specifically require the preparation of background papers at the pre-draft stage, the compilation of a single, over-arching and concise “Issues Paper” to accompany the initial notification that a new development plan is to be prepared, is strongly recommended at that stage as a means of presenting key information on strategic planning and heritage issues and inviting public submissions on differing policy approaches.”

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

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