Your reports on fracking (‘Licensce not yet given for fracking', 4 August 2011) are timely not only because of the recently granted exploration licences to three companies over 1481 square kilometers and the National Trust's call for public debate, but also because of the recently released Commission for Energy Regulators [CER] ‘Consultation Paper On The High Level Design Of The Petroleum Safety Framework' [‘Oil and gas safety regime to include fines of up to €3m', 3 August].
This Report arises out of the ‘Advantica Report' on the Corrib Gas Pipeline. That recommended that a new risk-based safety framework for major hazard pipelines should be developed in Ireland; this has since been extended by legislation to 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' [CER].

In the case of the 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 a gross disproportion between the risk and the ‘scale of sacrifice' required to avert that risk (with the risk being the greater) to trigger expensive safeguards.

Because fracking uses many small ‘pods' containing multiple drilling rigs, the scale of sacrifice 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 fracking in Ireland.

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.

Yours etc.,
Tony Lowes
Friends of the Irish Environment
Co. Cork


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