Timely report on Ailwee Caves and stalactite threat

YOUR report on the warning about the danger to Ailwee Caves and the Pol an Ionáin stalactite (Tourist sites under threat from extraction of resources, August 5) on fracking is timely, not only because of the recently granted exploration licences to three companies over 1,481 sq kms and the call for a public debate, but also because of the recently released Commission for Energy Regulator’s Consultation Paper On The High Level Design Of The Petroleum Safety Framework.

This report arises out of the Advantica Report on the controversial Corrib Gas Pipeline.

That recommended a new risk-based safety framework for major hazard pipelines. This has since been established by legislation to include oil and gas extraction.

Safety is not defined in any legislation regulating safety in Ireland. Safety is therefore given its ordinary meaning, and dictionary definitions generally define safety as the absence of danger.

In the case of nuclear energy, the only way to ensure the absence of danger is not to proceed, the course that Ireland is wisely pursuing.

Unfortunately, fracking danger will come under the ALARP standard of danger — As Low As Reasonably Practical. Legal interpretations of ALARP require gross disproportion between the risk and the scale of sacrifice; required to avert that risk — with the risk being disproportionately greater — to trigger expensive safeguards.

Because fracking uses many small pods containing multiple drilling rigs, the scale of sacrifice (read ‘cost’) by the developers will be weighed against a relatively limited risk in each case — compared, for example, to BP’s Deepwater Horizon.

This problem supports the call for a national debate to frame the overall issue of the suitability of Ireland for fracking.

The CER document is available from their website for comment by 27 September. An underlying critical issue raised is if there is to be public access to agreements between the CER and other agencies — the Environmental Protection Agency and the Health and Safety Authority, to name just two — as well as their incident reports to the minister.

Tony Lowes

Friends of the Irish Environment

Eyeries

Co Cork