11 thoughts on “Your Submissions”

1. I’m really concerned that the government is considering allowing drilling 6km from the shore, especially in this beautiful place that should be made a protected national park, and somewhere so close to a million people with an enclosed bay and a tide that predominantly moves into it. The application seems to have been made at a time designed to bury it, the notice came out on Jan 5, when everyone was sleeping off the Xmas cheer! And with only 21 working days to reply?
   There’s so many protected species around, there, We need to look out for them.

   And no-one says much about what will happen if there’s a big find. Would they make a commitment to sell it here, and give us a good price for our oil? Or sell it elsewhere, and avoid any taxation? Will there be rigs scattered all over the bay?

   I’ve looked at the application, it’s a massive technical document. There should be a public enquiry to help us disseminate it clearly and simply, to ensure safety for the wildlife, and the local people.

   Thanks for this space to express my feelings and concerns.

2. Dear Sir/Madam,

   I am writing to notify you of my objection to the granting of the license application MS 51/4/541 and I call for a public enquiry at the bare minimum under Section 3.9 of the Foreshore Act 1933.

   It is my opinion that the proposed drilling inshore of the Kish Bank is far too high a risk to take given the number of environmental factors listed below:

   - The Proximity to the coast. The planned area is only 6km off shore.

   - The drilling and associated industrial activity will take place in proximity to several Special Protection Areas and Special Areas of Conservation.

   - The proposed site is in proximity to Wetlands of International Importance designated under the Ramsar Convention, proposed natural heritage sites and the UNESCO Heritage Site of North Bull Island.

   - Whelks, lobster and crab fishing take place in the area proposed for activity. Fishermen rely on these sources for their livelihoods. The seismic activity proposed by the company would have serious detrimental impact on these shellfish stocks.

   - 3 bottlenose dolphins have been living in the Bay consistently for the last 3 years according to the Irish Whale and Dolphin Group. These are an Annex II listed species of the EU Habitats Directive and need to be protected. These species WILL be affected by the seismic activity that is proposed to take place and there is no guarantee that they will return to these shores.

   - Arctic, Roseate and Common terns roost at the Kish bank where the proposed drilling is to take place. The Roseate Tern is an endangered species and is protected under the EU Habitats Directive.

   - There are major environmental concerns around the practice of Carbon Sequestration, or carbon dumping, which is part of the license application. Experts say that the leakage of buried carbon could change the biological balance of the sea and suffocate all Marine life.

   Furthermore upon looking into the financial aspects there appears to be little economic benefit to the country:

   - Drilling for oil or gas in Ireland under the current licensing and tax arrangements allow the exploration company to write off 100% of all costs against tax and after that pay the state 25%. This is one of the lowest tax rates in the world.

   - If oil is found, Providence and its partners would be under no obligation to guarantee supply to Ireland. It is highly likely that the oil or gas will be shipped to the UK for refining and sold on the open market for enormous profits.

   - There is no gain to the local economy from the proposed drilling. The rigs are usually staffed by skilled workers, most of which could be brought in from abroad.

   I ask that this submission be acknowledged in writing.

   Yours Sincerely,

   Helen Cantrell
   Zoology (BSc)
   Ecological Economics (MSc)

   • Well said Helen

3. Dear Sir/Madam,

   I would like to object to the above mentioned application for several reasons, as stated below, and call for a Public Enquiry under Section 9 (3) of the Foreshore Act 1933.

   1. The amount of time given for public consultation on this (21 Working Days) is inadequate considering the length and dense technical nature of the documents therein, and considering the potential environmental and societal repercussions.

   2. Providence’s Application document’s are not comprehensive or rigorous enough. They give scant treatment to contingency plans, for example there is no oiled birds or mammels clean up plan.

   3. Clean up is left mainly to and at the expense of the State once oil hits the coast, as Providence accepts no liability for it.

   4. In the event of a spill, Providence’s response team is based in England. Oil would be on the Dublin and/or Wicklow coast before they could take effective mitigatory action.

   5.1 There are three Bottlenose Dolphins Living between Dalkey Island and Bray Head. They are resident there, according to different reports from the Irish Whale and Dolphin group, for at least 18 months (http://www.iwdg.ie/iscope/sightings/default.asp?dataset=sightings&county=1185&resultsFormat=table&location=703&species=2251&search1=Search&page=5)
   Providence denies this: ‘ no semi-resident marine mammals have been identified in
   proximity to the survey area. As a result any impact identified is not deemed to be
   significant, and therefore an Annex IV Species (European Protected Species) Impact
   Assessment is not considered to be required. ‘ (p54 Environmental Risk Assessment [herein ERA])
   Here is some further documentation of their presence in the area ranging from August 2010. A detailed search of photographs, videos, sightings and anecdotal evidence proves this area to be their permanent home.
   -’The dolphins, all adults, first appeared in the Bay in August 2010 and have been recorded swimming and feeding in the area every month since. It now appears that they’ve made the Dalkey-Killiney area their permanent home.’ Irish Times (http://www.irishtimes.com/newspaper/features/2011/0614/1224298859267.html)
   -Nov 2010 http://www.flickr.com/photos/johncoveneyphotos/sets/72157625369191431/
   -March ’11 http://www.boards.ie/vbulletin/showthread.php?t=2056029211
   March ’11 http://www.youtube.com/watch?v=lvdzZnuXEIs
   -June 5/11 http://www.irelandswildlife.com/2011/06/bottlenose-dolphins-making-a-splash-at-dalkeykilliney-bay/
   -Sept’ 11 http://www.youtube.com/watch?v=FGsShQadyXw
   -December 2011 http://www.rte.ie/news/av/2011/1221/media-3148668.html

   These dolphins are nationally known and loved.They live and hunt not only in proximity to the Marine Survey Area, but in it. Under European law, as this species is an Annex ll protected mammel, this area should be a Special Area of Conservation. This would effectively signify that Providence should by law not work within a significant distance of the area. ‘bottlenose dolphin and harbour porpoise; are Annex II species (i.e. animal species of Community interest,
   whose conservation requires the designation of Special Areas of Conservation) (pp20/21 Environment Area Assessment [herein EAA])
   5.2 The presence of these Dolphins controverts the following statement, as Providence itself states that there may be Avoidance displayed by them’Under the Habitats Directive (and the European Communities (Natural Habitats)
   Regulations 1997 and Wildlife (Amendment) Act 1976 & 2000), specific species, which
   includes all marine mammals, are prohibited from the deliberate capture, killing, injury or
   disturbance[...] Given the short duration of the operations, which are likely to occur outside the peak
   period of cetacean presence in the area (summer months) and the implementation of the
   Code of Practice and industry best practice, there is minimal risk of any impacts to
   individual animals and no significant risk to marine mammals and therefore further
   assessment is not considered to be required. (pp v/vi (EAA))

   5.3 At the very least, short of the area being an SAC as of now, the law demands that Providence completes an Environmental Impact Statement for it. Providence does not recognise that these mammals live in the survey area, in their 2D Survey Environmental Risk Assessment:
   ‘ no semi-resident marine mammals have been identified in
   proximity to the survey area. As a result any impact identified is not deemed to be
   significant, and therefore an Annex IV Species (European Protected Species) Impact
   Assessment is not considered to be required. ‘ (p54 Environmental Risk Assessment [herein ERA])

   5.4 The proposed lines on the 2D survey come too close to the shore for the boat to do a full soft start coming onto the line. They would be forced to do it on the turn, but on a turn you would most likely have to bring in the arrays, or at least two of them (they do not specify if its a 2 or 4 gun array). The array could not fire because they would be too close to the boat and it would be dangerous. So the soft start would be done with only two arrays, or one, for the correct duration, but this would prevent the correct ramping up…so the “intensity” of the firing would go from 50% to 100% in one second, although the “duration” of the firing would be the correct time. I would not trust the MMO onboard to understand this fine but important distinction. The only way to over come this (from the information i have, which is not all of it) would be to come onto the lines from the northeast and head towards land, but they would not do this voluntarily as it forces them to double their standby time. If this scenario occurs, any dolphin, whale, seal or turtle within a couple of kilometres might be physically disabled. (See Injury Thresholds p44 EAA) ‘
   There are essentially three ways in which seismic acoustic emissions may affect
   cetaceans and these are outlined below:
   • Physical damage to hearing as a result of the intense acoustic signals;
   • Interference with daily activities by impairing the ability to navigate, find food, or
   communicate;
   • Indirectly by affecting behavioural patterns in food source e.g. by scaring, scattering
   or physically causing damage to prey species. (ERA)

   5.5 The residency of the Bottlenose Dolphins implies Special Area of Conservation value status:
   ‘Harbour Porpoise, bottlenose dolphin, grey seal and common seal are all classified under
   Annex II of the Habitats Directive as a marine species whose conservation requires the
   designation of SACs. It is unlikely that any of the species will meet the criteria for site
   designation within, or adjacent to the proposed site survey and exploration well location. ‘

   8. it is likely that full scale high energy surveys would clear seals from large sections of their feeding areas. In the case of central place foragers such as
   Common (Harbour) Seals during the breeding season this may effectively prevent feeding
   at least for the duration of the surveys.
   Given the offshore location of the survey area, however, it is unlikely that Grey and
   Common Seals will be present in any great numbers’ The survey area is not offshore, it is in the foreshore area, and goes within 6 kilometers of the Seals beaching area. There will likely be many seals in the Survey area. They are also vulnerable to injury in scenario 5.4 above.

   9. Local Fishermen state that they have not been consulted by Providence, whose plan will exclude them from fishing in their only grounds.

   10.1 The proposed drilling area is 6km from the coast. due to the dominant direction of the tides, any spill would hit the coast in hours; with fast currents one hour. This is the closest proposed drill to land in Ireland thusfar, and that several kilometres from the most densely populated and valuable area in the State.

   10.2 The Norwegian Directorate of Nature Management, an official advisory body to the Norwegian Government relating to oil licencing policy, recommends no drilling in coastal areas: ‘Oil spills in coastal waters can have serious consequences for seabirds. Therefore the Directorate for Nature Management recommends that the government does not provide licenses for oil exploration in the most vulnerable areas closest to the Norwegian Coast.’

   http://translate.google.com/translate?sl=no&tl=en&js=n&prev=_t&hl=no&ie=UTF-8&layout=2&eotf=1&u=http%3A%2F%2Fwww.dirnat.no%2Fcontent%2F500043872%2FAdvarer-mot-oljeboring-nar-kysten&act=url

   Thank you for your consideration of these points.

   Best Regards,
   etc

4. Dear Sir/Madam,

   I am writing to notify you of my objection to the granting of the license application MS 51/4/541 and I call for a public enquiry at the bare minimum under Section 3.9 of the Foreshore Act 1933.

   It is clear to me that this would take away from the beauty of the bay.

   Also, Providence and its partners would be under no obligation to guarantee supply to Ireland.

   Your sincerely,

   David STANLEY

5. Please reconsider the granting of the licence for the above drilling for oil of the east coast. This is a beautiful part of Ireland, there is no guarantee there is oil and it will ruin the wild life in this area. I live in Co Kildare and often take a drive up to Sandymount, Dunlaoghaire, Killiney, or Dalkey and take a lovely walk there. Please don’t destroy this area such a beauty spot so close to our Capital City.

6. Refuse permission for Foreshore Licence for well drilling at Kish Bank

   Greetings,

   I just signed the following petition addressed to: Minister for the Environment, Community and Local Government.

   —————-
   Refuse permission for Foreshore Licence for well drilling at Kish Bank

   The public has been given a three week window to view and possibly object to the application. An independant assessment is necessary to ameliorate concerns in several areas: environmental, economic, health and safety, and legal.

   The proposed exploratory drill is the closest to land of the company’s marine drills, and happens to be next to the highest and most most densely populated region in the country. We understand that the applicant has done research and will do its best to avoid it, but in the event of a worst-case spill (which Providence say would have 1,000 tonnes of diesel heading towards the coastline from several kilometres away at 30 knots) the confined nature of Dublin Bay and the Liffey mean that the applicant may be unable to effectively contain the spillage in time, leading to environmental and human catastrophe. The Norwegian Directorate for Nature Management recommends that drills take place a minimum of 25km from shore, as ‘any emissions in such areas means that the consequences are worse for the environment than if it happens elsewhere.’

   Further, as the waters of Dublin Bay and Dalkey Island have been designated as Special Protection Areas under EU regulations by the Ministry for the Environment, there are concerns about pollution from chemical effluent or diesel spillage from the drilling and the heavy traffic to and from. There is an abundance of wildlife attached to this area including several endangered species such as humpback and fin whales, and the sooty shearwater and razorbill avifaunae. Notwithstanding any spillage, there is in any case considerable toxic chemical effluent from offshore drills.

   Providence Resources states that some species particular to this region are ‘very vulnerable to oil pollution.’ Spawning fish within the proposed well area include haddock, blue whiting, horse mackerel and cod. The waters of the area also act as a nursery ground for mackerel, squids, octopuses and cuttlefish. There is a moderate abundance of dolphins, porpoises, whales and seals which forage in the area. The harbour porpoise (HP) and bottlenose dolphins (BND), are both Annex II species (top conservation priority in EU),which include the nationally popular dolphins living off Killiney beach. A major spill would destroy all marine life in this rich and sensitive area.

   Whilst recognising that I may use any or all of this information in separate legal action, I petition that it is incumbent on you as legislative protector of this land’s people and other inhabitants, to not grant this application until comprehensive independent assessments have been finished, and can guarantee safety and comfort for the local people and wildlife.
   —————-

   Sincerely,
   Lyndsay Di Felice

7. Drilling for oil on any stretch of the east coast would effect the entire east coast, from fish stocks to marine life as a whole
   The future for our fuels is in renewable power sorces.

8. My main objections concern the lack of clarity in the information, and the shortness of time to consider the implications to the area of Killiney #Bay – surely one of the most beautiful in the country. As I live on the other side of Dalkey, this does not concern me personally – viewwise – but as a national amenity I would object to the proximity of the drilling to Dalkey Island, in addition to the lack of information as to various aspects of forshore activity.

9. Dear Sir / Madam.

   I wish to object, in the strongest possible way, to the application for exploratory oil drilling made by Providence Resources, and call for a Public Enquiry under Section 9 (3) of the Foreshore Act 1933.

   The coastal region surrounding south Dublin is literally culturally sacred. Over multiple generations, both myself, my parents, and their parents have enjoyed this coastline, and it has played a key part in peoples lives as a place for recreation, swimming and sailing. For example, on the night my parents got married, they and their friends swam in the forty foot.

   As we are reminded on a regular basis, the risk of oil related issues is significant.

   Despite near unlimited funding, in practice, the oil industries worldwide have repeatedly been the central source of environmental (and often social and economic) disaster. They may lay blame upon third parties, technologies, captains of ships, in ways that seek to isolate them or limit them from liabilities. But in no uncertain terms, they are for profit ventures, who do business in a way they can get away with. They do not act as social entrepreneurs, but as for profit businesses. As numerous events in our living history demonstrate, there is a notable risk, sooner or later of oil, via a well, drill, or transport vessel of causing a major calamity. Ireland, being relatively inexperienced in this area, lacks experience in even enforcing best practice in oil related matters.

   Thus, I seek to object to this application on many fronts:

   1. An oil related disaster could render untold harm upon the morale of the people of Dublin, who use the coastal region as a place for recreation, relaxation, to deal with the pressures of everyday life. Their right and opportunity to enjoy this coastal region is of profound importance, and the consequences of disaster unimaginable. Whole ecosystems and economic systems would be irrevocably desecrated in the event of an accident.

   One of my favourite beaches, in Curracloe in Wexford, to this day has oil stains related to a spill that took place in Wales. The consequences of a more local spill are frightening.

   If oil is found, risks are multiplied, as more oil explorations will occur throughout the east coast, and highly funded lobbyists will do everything in their power to push an application through with for profit motives. This is not in the interests of the people of Ireland who love this coastal city.

   2. The time given for public consultation on this (21 Working Days) is vastly inadequate when considering:
   - the length and dense technical nature of the documents therein
   - the potential environmental and societal repercussions.
   - the level of specialist knowledge required to appraise the risks associated with this explorative drilling.
   - the learning curve in even reasonably appraising the issues at stake
   - the fact that a Dublin politician is working, on a for profit basis, to use his reach and know how, to make this application succeed
   - the application was announced in the first few days of January, during a time when people have to catch up with matters followed the longest national holiday of the year. I suspect this timing was not accidental.

   3. Providence’s Application document’s are not comprehensive or rigorous enough.
   - They give scant treatment to contingency plans

   4. Clean up is left mainly to and at the expense of the State once oil hits the coast, as Providence accepts no liability for it.

   5. In the event of a spill, reland possesses neither the expertise nor resources to deal with such an event, and the facilities to do so are located in other territories. Time is against the Irish people in this regard. Providence’s response team is based in England. Oil would be on the Dublin and/or Wicklow coast before they could take effective mitigatory action.

   Thank you for your consideration of these points.

   best regards,

   Thomas O’Duffy
   Dublin 4.

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