Company details Who owns the company? Providence Resources PLC is a publically listed company whose shares are traded in Dublin (ESM) and London (AIM) stock markets. These are currently held by Institutions (65%), O’Reilly Family (20%) and Retail Investors (15%). Can there be sufficient public trust-in Providence? Providence has been operating safely and successfully in Ireland since 1981. Since 2000 we have successfully operated six offshore wells and associated site surveys and are presently operating a further well on the Barryroe licence in the Celtic Sea. P.R. Singleton, a wholly owned UK subsidiary of Providence Resources has also operated the onshore UK Singleton Oil field since March 2009, drilling successfully in the environmentally sensitive South Downs National Park. Both oil and gas are produced at Singleton and Providence has a very positive relationship with the local council and community. Who is the other partner in this project? (Star Energy Oil and Gas) The partner is silent in application one must surely wonder why that is and what pedigree the partner enjoys and what level of control, management etc. may ultimately devolve on that significant partner. At the time the licence was awarded the partner was Star Energy Oil & Gas, a subsidiary of PETRONAS, however, their interest in the licence is being assigned to PSE Seven Heads Limited which is an Irish based PETRONAS subsidiary and the operator of the Seven Heads gasfield in the Celtic Sea. Both licences operate their interest in the licence through a Joint Operating Committee and have Joint & Several responsibility for their obligations under the Licence; Providence, as the designated operator, manages day to day activities and organises the various service contracts required. What is status of the legal clause as part of any exploration licence, that any obligations/duties imposed on Providence be equally binding if Providence sell their rights to anyone else? If Providence were to sell all or any part of their rights in an exploration licence, Providence would first need to seek the consent of the Irish Government to such a sale. Each party to an exploration license will have joint and several liability to the Irish Government vis a vis its obligations and liabilities under the licence. Do Providence and their partner intend using sub-contractors? What are their (sub-contractors) action-plans to tackle any event that has potential to harm the environment? Who pays for any subsequent clean up? Subcontracting for specialist equipment and services is the norm in the oil industry. This includes procurement of survey vessels, drilling rigs and equipment utilised during the drilling process. The contractors are managed by the Operator (Providence) and are required to adhere to the Oil Spill Contingency Plan. Providence will be fully liable for any potential harm to the environment. 1 Who are the rig operators? What are the rig’s technical specifications, responsibilities and liabilities in the case of accidents? The rig has yet to be contracted and drilling is contingent on the award of a foreshore licence. Should a foreshore licence be awarded then the seismic and site survey will be acquired prior to drilling. Within a six month period of this data acquisition, the well will be drilled. Prior to any activity, the vessel and rig specifications along with the seismic and drilling programs and the Oil Spill Contingency Plan need to be approved by the Petroleum Affairs Division (PAD) of the Department of Communications, Energy and Natural Resources (DCENR). 2 Communication of information Suggestion that there has been insufficient information presented to public Our website (www.providenceresources.com/dalkeyisland.aspx)has been used to convey and update the schedule and information during the foreshore licence application and will be used during the project lifespan. A newsletter and non technical summary have been distributed for the general public along with contact details for any further information required. We have met with interested parties and continue to do so. We continue to encourage anyone who wishes to discuss our plans further to contact us to make an appointment to come in and meet us, Providence Resources Plc, Airfield House, Airfield Park, Donnybrook, Dublin 4, Ireland. Tel: +353 1 2194074 Fax: +353 1 2194006 Email: [email protected] or [email protected] Web: www.providenceresources.com have refused to come to many meetings or to respond to requests for media interviews reluctance to speak to the public from the people behind the project Providence Resources provided written information to organisers of Public meetings in Dalkey, Dun Laoghaire and Greystones. A representative of the company attended all three meetings to note issues raised. The company made it clear from the outset that is was available and willing to meet individuals and groups who had questions or an interest in its proposals. To this end, it met with a number of interested parties including representatives from the Dalkey Community Council, Dalkey Business Group and a delegation of local fishermen. The company also has a met a Probus group in Dun Laoghaire in the Royal St George Yacht Club and has made initial contact with local Diving Clubs. Meetings were also held with Green Party representatives a local TD. A number of email enquiries were received, all of which were responded to directly. This correspondence included Councillors, community representatives and local residents. Telephone enquiries were also taken from local residents. We have been in contact with a range of interested parties including local residents, local businesses and local interest groups. We have invited a number of groups and individuals to come in and meet with us to discuss the project. We remain open to this and welcome anyone to make an appointment to do the 3 same. We believe this approach is the best way to directly address individual concerns rather than in the format of a public meeting with many diverse and conflicting views. Information provided is too technical for the general public Providence Resources produced a newsletter explaining the proposals in layman’s terms, this was accompanied by a non-technical summary of the applications documents. Both of these documents were also placed in the Garda Stations as well as being made available on the company’s website for download and by telephone or email request. A visual display board detailing the proposal was also placed in both Garda stations. The company created a dedicated page on its website, which hosted downloadable application information and more supporting information including a Frequently Asked Questions page, photomontages illustrating how an exploration rig could look on the horizon, a video illustration of an exploration rig on the horizon, a PowerPoint presentation explaining the history of the project to date and what was proposed and downloadable copies of the newsletter and nontechnical summary. (www.providenceresources.com/dalkeyisland.aspx) This website has been regularly updated to reflect questions asked and issues raised. Public's lack of resources and expertise A great deal of public expertise and resources have been demonstrated by associations such as The Irish Whale and Dolphin Group, Birdwatch Ireland, Dun Laoghaire Fisherman's Group, Dolphin Days Ireland, Wild Ocean, An Taisce, The Irish Underwater Council and Coastal Concern Alliance among others. The Marine Licence Vetting Committee (MVLC) - a non-statutory body comprised of technical, scientific and engineering specialists from various relevant government departments, and with a remit to include additional expertise as required) reviews the application and any submissions and makes a recommendation to the Minister of the Environment, Community and Local Government. 4 Location of survey Why is it so close to land? The subterranean geology dictates where oil companies drill. The Kish Bank Basin is very similar geologically, to Liverpool Bay (also close to shore) offshore North Wales, where there has been significant oil and gas discoveries and production for c. 20 years. We have identified only one similar geological target in our licence area which has the potential for oil/gas. Is there precedence for exploration so close to shore? All over the world, there are examples of near shore exploration and production activities. On the other side of the Irish Sea, in Liverpool Bay, there is a producing oil field, the Lennox Field, 6km off the Liverpool Coast. The Wytch Farm oilfield in Dorset, UK is operated by Perenco and is located in the Jurassic Coast World Heritage Site. The area is also a nature reserve and a popular birdwatching area. The field straddles the coastline, both onshore and offshore. Siting of this exploration exposes Ireland to a security threat as a soft target to those that want to undermine European stability All Providence operated project both onshore and offshore maintain strict security in terms of access to seismic vessels and rigs. This project would be no different, and would therefore not provide a security threat. There is concern that the location of the survey is close to the shore and close to a populated area. All over the world, there are examples of near shore exploration and production activities. On the other side of the Irish Sea, in Liverpool Bay, there is a producing oil field, the Lennox Field, 6km off the Liverpool Coast. The Wytch Farm oilfield in Dorset, UK is operated by Perenco and is located in the Jurassic Coast World Heritage Site. The area is also a nature reserve and a popular birdwatching area. The field straddles the coastline, both onshore and offshore. Although the first exploration activities by Providence in the area, this would be the fifth oil and gas exploration well to be drilled in Dublin Bay since the 1970s, with no commercial discovery to date. It is the first that has sought a foreshore licence. In addition, a seismic survey was conducted in 2008 and 2 coal boreholes were drilled in the Kish Bank Basin in 2010 with little to no impact on daily life. representation of densely populated area on maps is not accurate, omits Greystones, closest to licence area This has been amended and the www.providenceresources.com.aspx. maps are available on our website A suggestion that the proximity may be a cynical ploy to get a licence granted further offshore We have identified only one geological target in our licence area which has the potential for oil and gas; this is within the area for which we have applied for a 5 foreshore licence. The area further offshore to the east of our acreage is already held as a Licensing Option by another company - Albativ Resources. Is planning permission is required - Dun Laoghaire-Rathdown Development Plan 2010-2016? Planning Legislation extends to the Low Water Mark on the seashore only. In marine areas Foreshore Licences are required for the positioning of temporary or permanent structures or other activities. This licence application represents the application under the relevant legislation. In addition, all activities relating to extraction of Natural resources are subject to additional licensing and permissions under the Department of Communication Energy and Natural resources. The map extends over the Dublin and Wicklow coast; are there also plans for more widespread drilling? At this stage we have only identified one geological target and the foreshore licence under application only allows for the drilling of one well, which must be within the 3*3km site survey area, as applied for in the foreshore licence. Health and Safety What safety measures will be put in place? A well specific project HSA Health and Safety plan will be produced and approved prior to the commencement of any operations. Providence, as operator has the responsibility for safety, health and welfare at work and adheres to the Safety, Health and Welfare at Work Act 2005. Providence, the rig operator and HSA work in partnership with employers and employees, with the responsibility to ensure that safety and health in the workplace is a key priority for everyone. emergency services not have reaction time or the capacity to deal with a serious accident All emergency services will be approved by the relevant authorities prior to commencement of operations. All emergency services in relation to Oil Spills will be covered and signed off on in the Oil Spill Contingency Plan (OSCP) which is authorised by PAD, Coastguard, MSO, in total 20 plus consultees. An emergency response vessel will be on site at all times for drilling operations. A medevac agreement and facility will be set up with specialised companies. 6 Local Activities The Environmental Area Assessment (EAA) failed to adequately address the disruption to shipping routes and leisure activities. The physical presence of the rig and the requirement for safety zones has the potential to conflict with the usage of the area with fisheries and shipping. Due to the short duration of the operation (30-60 days), this is not considered to be a significant impact; however, measures will be taken to consult and alert fisheries, shipping and recreational vessels of the survey activities and rig presence. Notice to Mariners and a guard vessel will be employed to mitigate interactions. A Fisheries Liaison Officer (FLO) will be contracted to conduct communication between the operators of the survey and local fishermen. The area is adjacent to areas of heavily trafficked waters in the approaches to Dublin Port; however the proposed drilling location is outside the main shipping lanes and transit areas. Concern that there might be increased traffic due to survey activities There will be some increase in traffic associated with the survey vessels, however this will be of a temporary nature. The traffic associated with the survey operations will be accounted for within the approval process, and will require sign off by the Dpt. Transport, the Coastguard and PAD, which are just three of the 12 bodies which will review the seismic and site survey final submission documents. Concern over the proximity of the survey area to a busy sea traffic area EAA: The area is adjacent to areas of heavily trafficked waters in the approaches to Dublin Port; however the proposed drilling location is outside the main shipping lanes and transit areas. However prior to operations commencing, the appropriate notifications will be made and maritime notices posted. A Notice to Mariners will be issued during the survey and appropriate navigation aids will be used to ensure other users of the sea are made aware of the presence of the vessels. A guard ship will be on hand to notify vessels of the survey locations. Around the drilling rig a 500m safety zone will be set up and a safety vessel will be on standby. Concerned that re-routing shipping lanes may cause erosion of the coast and have potential dangers to swimmers and small sea craft EAA: The area is adjacent to areas of heavily trafficked waters in the approaches to Dublin Port; however the proposed drilling location is outside the main shipping lanes and transit areas. There will be no need to re-route shipping lanes. Concern that a number of boats have already been diverted as a result of the presence of the survey ship Providence has carried out no survey activity, or any operations in the area to date. Recreation and tourism There is popular use of the sea front for recreational activities, including swimming at the beach; will the survey have an impact on this? 7 The survey activity will all be conducted at sea, more than 2.5 km offshore; there will be no activity onshore. No impact onshore of the area with regards to recreation and tourism is foreseen, including swimming at the beach. There is a potential impact of seismic survey work on scuba divers in the area- an assessment of the potential impacts on divers should be given and a protocol for ensuring that divers are made aware of the survey and given an opportunity to exit the water prior to the start of seismic operations should be provided. Providence has made contact with scuba diving clubs in the area to discuss the proposed activity for the survey, and hopes to meet with various clubs to discuss the proposed operations. Notification prior to the start of the seismic survey will be provided to ensure scuba divers are made aware of the timing, duration and areal extent of the survey. How will recreational sailing in surrounding waters be affected? Providence has made contact with the sailing clubs in the area to discuss the proposed activity for the survey, and hopes to meet with various clubs to discuss the proposed operations. Prior to operations commencing, the appropriate notifications will be made and maritime notices posted. A Notice to Mariners will be issued during the survey and appropriate navigation aids will be used to ensure other users of the sea are made aware of the presence of the vessels. A guard ship will be on hand to notify vessels of the survey locations. Around the drilling rig a 500m safety zone will be set up and a safety vessel will be on standby. Request for a more open discussion with divers and water users in the vicinity of the proposed activity Providence plan to meet with marine communities to discuss any relevant survey and drilling activity. Fishing There is some concern over effect on the fishing community and a lack of consultation with the fishing community Providence has already established consultation and communication with the relevant fishermen in the area and a local fisherman will been designated as a Fisheries Liaison Officer (FLO) to facilitate further communication. Providence has also met with Bord Iascaigh Mhara (BIM) and will continue to communicate and update them with information on the proposed activities. The effect on marine wildlife would be detrimental to the fishing industry There has been consultation with The Department of Agriculture Fisheries and the Marine, Inland Fisheries Ireland and Sea Fisheries Protection Authority and mitigation measures have been agreed upon to reduce any potential effects. The details on fishing is deemed to be limited and inaccurate The fishing information summarised in the ERA and EAA is subject to review and consultation with a number of bodies. Under the Foreshore Licence Application 8 representatives from government departments and the inshore and offshore fishing representatives may be consulted in order to determine the licence. Under the PAD permitting system the SFPA, Sea Fisheries Control, Marine Institute and DoECLG. In addition to these, Providence will appoint an independent Fisheries Liaison Officer, who will report the fisheries in the vicinity (included in the Foreshore Licence Application and a requirement of the PAD approval system) and will assist in the liaison with the industry over the operation duration. Drilling seems to coincide with harvesting – main season Feb – July At the present time, timing of operations is contingent on rig and vessel availability. As far as possible this will avoid breeding and nursery periods and peak fishery periods. previous seismic surveys has caused a collapse in the whelk fishery resulting in economic hardship to fishermen There is no recorded or scientific literature noting impacts from seismic surveys on whelks. There is some evidence that seismic surveys passing over gastropods or other shellfish may affect a predation avoidance response, however there is no recorded short or long term impact to these species from the surveys proposed. The Marine Institute research papers 1 2 3 make no correlation with seismic activities. Should additional information be available, please forward for review. At this time there are between 5-7 thousand whelk pots and 12 thousand lobster and crab pots in the area where the proposed acoustic survey will take place. All the whelk gear is laid east-west in strings of 40-50 pots approximately .25 miles long with and anchor at both ends and 5060 fathom dahn lines with double markers each end. The lobster/crab pots are laid north-south using the same set up. It would be impossible to tow acoustic survey gear in this situation In the event that this foreshore license is granted there needs to be put in place an agreed compensation fund to cover for lost fishing time during operations, loss of gear? Loss of earning and loss of catches due to the damage caused be the acoustic survey and drilling operations All operations will be undertaken with the support of a fisheries liaison officer and with the consultation of relevant government departments. At a suitable time prior to operations Providence will discuss the operations with a fisheries industry representative(s). Suitable notification will be issued prior to operations to inform fishermen of the areas, duration and location of safety zones. Fahy E., Masterson E., Swords D. and Forrest N. (2000) A second assessment of the whelk fishery Buccinum undatum in the southwest Irish Sea with particular reference to its history of management by size limit. Irish Fisheries Investigations No. 6: 67 pp. 2 Fahy, E., Yalloway G. and Gleeson P. (1995) Appraisal of the whelk Buccinum undatum fishery of the southern Irish Sea with proposals for a management strategy Irish Fisheries Investigations Series B, Marine 42: 26 pp. 3 Fahy, &., J. Carroll, et al. (2005). ‘Fishery-associated changes in the whelk Buccinum undatum stock in the southwest Irish Sea, 1995-2003’. Irish Fisheries Investigations (New Series), No. 15: 1-26. 1 9 Environment & Wildlife There are Annex II and IV species in the area of the survey and in 1991 the Irish government declared all Irish waters extending to the continental shelf a whale and dolphin sanctuary; there is concern that Providence may be unaware of this and there is concern over their welfare during the survey works. Providence is aware of the presence of many protected and unprotected species in the area. As with all past surveys; we will implement the strictest operational guidelines and regulations. We have also been given advice from National Parks and Wildlife Service, Inland fisheries Ireland, Sea Fisheries Protection Authority, The Department of Agriculture Fisheries and the Marine, and Dun Laoghaire – Rathdown County Council. Mitigations to be in place include The survey operation will be fully compliant with the Code of Practice for the Protection of Marine Mammals During Acoustic Seafloor Surveys in Irish Waters (August 2007) Dedicated, trained and qualified Marine Mammal Observers (MMOs) will be present onboard the survey at all times during the survey. Marine Mammal Observers (MMO) The MMO must advise the works superintendent 1 hour before scheduled activity if environmental conditions (e.g. sea state, light, visibility) are insufficient for effective visual monitoring. In such conditions, the activity of concern will be postponed until acceptable conditions prevail. The shooting power of the air source array will be maintained to a minimum necessary level. No shooting will be released unless necessary for survey purpose As the survey is being undertaken in water depths less than 200m, Providence will ensure that any marine mammals are at a safe distance of at least 1000m from the centre of the array/sound before ant activity commences. MMOs will survey the area for the presence of cetaceans 30 minutes before the onset of the start. A minimum distance of 1000m will be ensured between the centre of the array/sound source and the nearest cetacean before survey activity will commence. Acoustic deterrent devices will not be used as a method to prevent animals from entering or remaining within the exclusion zone. If marine mammals are seen within 1000m of the centre of the sound source, the start of the sound source(s) will be delayed until they have moved from the area, allowing adequate time after the last sighting for the animals to leave the area (30 minutes). If the cetaceans do not leave the area it is recommended that the survey vessel alters course to ensure that the animals are outside the 1000m exclusion zoned when soft start* commences. 10 Activity will only proceed on positive confirmation with the MMO *Soft Start Procedure Power will be built up slowly to give adequate time for marine mammals to leave the vicinity where possible If a low intensity start can be undertaken it will be included before test firing of the sound source, even if no marine mammals have been seen Stars will occur when MMOs can carry out the required pre-soft start scan To minimise additional noise in the marine environment, a start (from commencement of the start to commencement of the line) will be minimised as far as possible If for any reason, firing of the sound source has stopped and not restarted for at least 5 minutes a low intensity start will be carried out After a break in firing of any duration a visual check will be made for marine mammals within the exclusion zone. If a marine mammal is present then the recommencement of the shooting will be delayed as per the instructions above. Reporting The MMO must submit a report within 30 days of completion of the survey to PAD and copy the report to the NPWS. The survey team will use standard forms to record marine mammal sightings, marine mammal sighting efforts and technical details of operations as recommended in the NPWS Code of Practice Providence will insure that a report (including a daily log) is maintained on the operation of the seismic equipment that will indicate the soft starts and their duration to the MMO. This information will be forwarded to the NPWS A Providence representative will be on-board the survey vessel at all times to ensure compliance with approved operating procedures concerning environmental protection. Dublin Bay is an environmentally sensitive area and there are areas within the bay which are nature reserves and conservation areas. Providence is aware of the sensitivity of the area and will implement the strictest regulations and guidelines appropriate to preserve this; Providence has always adhered to the National Parks and Wildlife’s guidelines in past surveys. The survey area incorporates a proposed Natura 2000 area. The National Parks and Wildlife Services has noted that the proposed survey and exploratory well drilling will not occur within or immediately adjacent to any currently designated Natura 2000 sites as notified pursuant to Council Directive 11 92/43/EC. However Providence will still ensure to abide by firm guidelines and practices to protect the survey area. impact on feeding birds could be minimised if drilling took place in the winter months or early spring, in addition cormorants and shags roost on the Muglins over the winter so work at this time should include mitigation to minimise disturbance to these species At the present time, timing of operations is contingent on rig and vessel availability. As far as possible, the scheduling will avoid peak summer sensitive periods. Will the project be closely monitored? Permission to conduct the seismic survey needs to be granted by 13 state bodies. During the planning process there will be discussion with the Maritime Safety Directorate, the MRCC of the Irish Coast Guard, the Dublin Port Harbour Master and the Sea Fisheries Protection Agency of the Department of Communications, Energy and Natural Resources and there will be good communication maintained throughout the survey. On board the vessel will be a Fisheries Liaison Officer, a Marine Mammal Observer and a representative of Providence. The movement of the vessel will be tracked and this tracking will be broadcast. There will be regular updates provided to the Irish Coast Guard and the Petroleum Affairs Division. For permission for drilling to be granted the program has to be approved by 23 state bodies. 16 state bodies will be kept continually updated during the drilling operations and regular Special Oversight of Well Operations Committee meetings will be held. A Providence representative will be on board the rig or support vessel at all time to ensure compliance with approved operating procedures. Seismic/drilling sound and its effect on wildlife Drilling: the implementation of a static acoustic monitoring programme to assess the pre-during-post operation levels of cetacean activity in the vicinity of the rig would be a very worthwhile measure While not a requirement Providence have used supplementary acoustic monitoring, PAM, during survey works at Barryroe survey offshore Cork during June 2011. We will consider using this program for the Kish Bank survey. Will Providence conduct an assessment of the acoustic profile of the drilling rig in operation at the first available opportunity and assess the appropriated mitigation zone for marine mammals to be implemented? There have been previous studies and published scientific work on the acoustic profile of drilling. The final Environmental Area Assessment (EAA) to be submitted to the government will include details on the noise levels, relevant to the rig used. Can the survey not be conducted during April/May as minke whale come to feed on herring in the area? At the present time, timing of operations is contingent on rig and vessel availability. As far as possible, the scheduling will avoid peak summer sensitive periods. 12 Can the consultants provide expected sound pressure attenuation curves relevant to the substrate type? levels and Providence will comply with all regulations and conditions set out by governing bodies. Concern about sound from the seismic disorientation/death/deafness to marine wildlife survey causing All operations will be conducted in accordance with the Code of Practice (National Parks and Wildlife Services, 2007) which was developed to minimise any such disturbance and prevent harm to marine mammals and will be run in accordance with industry best practice. Mitigations to be put in place have been detailed by NPWS and will be adhered to by Providence. A Providence representative will be on-board the survey vessel at all times to ensure compliance with approved operating procedures concerning environmental protection. What will be the effect of the drilling sound on the marine wildlife? Due to the localised impact from noise associated with the proposed Kish Bank well, the overall impacts on cetaceans are expected to be negligible. Studies from drilling / production platforms off California have indicated that the noise emitted was low frequency and was so weak as to be virtually undetectable from alongside the platform during sea states greater than three on the Beaufort scale (Gales, 1982 in Richardson et al. 1995) Would like further study conducted into the overlap of frequency of the seismic survey and that of the harbour porpoise and the bottle nose dolphin to insure adverse impacts are avoided The Code of Practice for the Protection of Marine Mammals during Acoustic Seafloor Surveys in Irish Waters (August 2007), which has been developed to minimise disturbance and prevent harm to marine wildlife, is based on such scientific studies which have already been conducted. EIA Requests for a more detailed Environmental Assessment. There is a Drilling Environmental Assessments and a Survey Environmental Assessment within the application documents; why is there not an Environmental Impact Assessment (EIA)? For this stage of the process the Environmental Area Assessment and Environmental Risk Assessment submitted cover the requirements of the foreshore licence application process. These documents will be expanded and finalised when a seismic survey vessel and a drill rig have been contracted to include the rig and vessel specifications. Concerns related to marine and wildlife as submitted by Birdwatch Ireland and the Irish Whale and Dolphin group as well as those of the fishing community have not been addressed 13 Concerns related to marine and wildlife as submitted by Birdwatch Ireland and the Irish Whale and Dolphin Group as well as those of the fishing community have been addressed by communications with Marine Vetting Licence Committee, including, The Department of Arts, Heritage & the Gaeltacht, The Department of Agriculture, Fisheries and the Marine, Inland Fisheries Ireland and Sea Fisheries Protection Authority and Dun Laoghaire-Rathdown County Council. There will mitigation methods in place to minimise the any potential impact of the survey and drilling activities. Providence has experience of working with the Irish Whale and Dolphin Group from previous survey operations in offshore Ireland. The Marine Mammal Observer (MMO) to be on-board the seismic survey vessel will likely be from the Irish Whale and Dolphin Group. We have met with local fishermen and there will be a Fisheries Liaison Officer on-board the seismic survey vessel to augment the communication between Providence, the relevant regulatory bodies and the fishing community. concern that "Environmental objectives set out in our County Council Development Plans would be blatantly unheeded if this licence was to go ahead and European directives with regard to the Environment underlying these objectives would be disregarded" Providence is aware of the local County Council Development Plans and will diligently comply with all the applicable local or EU statutory requirements for the protection of the environment. Providence is used to working with local councils and communities to help to protect sensitive environments. Effects on Local Area public safety and health Oil and Gas exploration is a highly regulated industry, and in particular European standards rank among the highest in the world. No impact on public health and safety are foreseen. Visual impact Will there be any visual impact of the rig and anything associated? The rig may be visible on the horizon from certain viewpoints; this would not be any more noticeable than a ship on the horizon. We have produced a number of visual representations and an interactive Google Earth tour that can be seen on our website http://www.providenceresources.com/Foreshore%20Application.aspx Local Economy What would be the benefit to Ireland? website : 100% of Ireland’s oil and 95% of its gas is currently imported yet, much of the energy potential of offshore Ireland remains unexplored. Exploration is expensive, discovery is not guaranteed and the timelines from discovery to production are typically five to seven years. Yet the implications of discovering and utilising such a natural resource, and potentially becoming self-sufficient in energy terms, would be of significant economic benefit for Ireland Inc. in terms of taxation, employment, security of supply and skills development. 14 Up to 40% (a sliding scale of 25-40%) of profits from production of such a commercial discovery would accrue to the State over and above the employment that would be created in support of these activities. as exploration will be serviced from Dublin port and airport there will be no local spend Will there be any local employment created? Our most recent Barryroe drilling operations (2011) offshore Cork have injected ~€3million into the local economy – this includes food, accommodation, office space, vessel hire and fuel, airport charges, logistics, to name but some of the beneficiaries. A request that all refining of the oil/gas is done in RoI to maximise the job potential A request that all oil/gas discovered be brought ashore in Dublin (or at least RoI) to maximise the job potential The feasibility of this is dependent on the type, quality and amount of oil or gas found as it has to be suitable for the refineries in the Republic of Ireland. There is currently only one oil refinery in Ireland at Whitegate in Cork. A request that all support services for the exploration be sourced in Dublin and not in Liverpool or Milford Haven to maximise the job potential Sourcing of services where available in Dublin/Ireland is most likely; Providence is an Irish company and supports Irish employment. It is also more convenient for Providence to source services in Dublin area. Will the survey affect property prices At this early stage the proposed activities are very temporary will have little or no impact on property prices one way or the other. Industrialisation Would like to know the risks associated with the industrialisation of the area Concern about the industrialisation of the immediate area and of the eastern coast / unsuitable area This is an exploratory survey, with temporary structures. The seismic survey will take 10 – 15 days and the drilling operation 30-60 days after which all equipment will be removed. There will be no impact to onshore day to day life. A well was drilled as recently as 1997 in this area, and 2 coal boreholes in 2010 and with little to no impact on the immediate area or the East coast. In the event of a discovery of oil or gas, before a development/production structure would be put in place for the purpose of oil/gas extraction, further foreshore and government consent will need to be submitted to the relevant departments for such a licence to be granted. This licencing procedure also 15 applies to the drilling of any subsequent “appraisal” well and the development concept of the field. It is envisaged that oil would be transferred to tankers and shipped to shore, perhaps to the Whitegate refinery in Cork (should the oil type be compatible) and gas being potentially piped to the gas infrastructure at Loughshinny. 16 Drill specific Queries Will there be any ‘fracking’? Providence does not intend to use Hydraulic Fracturing (fracking). Such operations are not applicable or required for this project. What will be the impact of drilling exercise? Impact will be minimal. Drilling will be offshore, 6-8km away. Traffic associated with survey will not affect the local area, Dublin Port, Dun Laoghaire and Dublin Airport will be used as applicable. Additional impacts of the drilling are discussed in the Drilling Environmental Assessment, available at http://www.providenceresources.com/Foreshore%20Application.aspx Will the oil rig be the same size at that off the coast of Liverpool? Yes it will be a similar size. The jack-up drilling rig to be used during the exploration phase will be smaller than the producing installations in place off Liverpool, although similar rigs would have been used during the exploration phase of that field Request for a more precise location of the well The exact well location will be based on the site survey; it will be located within the proposed 3x3km survey area. Our preferred location is X: 302 129; Y: 5 904 406, ED_1950_UTM_Zone_30N. However this will be contingent on site survey results for clearance of seabed and rig positioning. Which is more likely oil or gas as technical challenges of each are different? Either oil or gas or both are possible; however following recent geochemical work and the presence of oil seeping along faults, we consider that oil is the most likely hydrocarbon phase to be present if any. What will be the depth of drilling? The primary target for drilling is Upper Sherwood Sandstone at c. 4500 ft with a secondary target in deeper Carboniferous deposits at 9000ft – 11000ft, below sea level. How will the materials for the building of the rig be brought to or removed from the site? The rig would be floated into position already built. Any additional support equipment would be shipped in from Dublin Port and Dun Laoghaire Port A request that the transport of personnel and supplies to and from the exploration site not be done via helicopter but solely by boat. At this stage no flight paths have been finalised. From a HSA objective the availability of a helicopter facility will most likely be required for medevac at the 17 very least. It is also industry practice to utilise helicopters to transfer crew and supplies. noise pollution from helicopters Any noise from helicopter usage will be temporary and kept to a minimum. There will be scheduled flights required to mobilise personnel and equipment. How/where from/how often will personnel be brought to and from the rig? Personnel will be transported by helicopter to and from the rig from Dublin Airport or boat, most likely from Dublin Port or Dun Laoghaire harbour. It is anticipated that there would be 2-3 helicopter trips per week, which is typical for this type of operation. Will there be a “large flame at night from gas burn-off and smoke in the day, should deposits be located”? The well will only be tested if oil/gas is encountered. It would occur between a 6 – 24 hour period for two testing periods. The statement “30-60 days of well operation (drilling) up to a maximum of 90 days” is unclear. Are these consecutive days or not and are the 90 days the maximum length of time from the first day drilling? The well operation is due to take 30-60 consecutive days, up to a maximum of 90 consecutive days from the first day of mobilisation of the rig. Is night time drilling part of the plan? The rig operations are planned on a 24/7 basis so this would include drilling through the night. Will there be noise pollution from the rig? EAA: The noise levels of a jack-up drilling rig are comparable to those of a typical fishing vessel with levels of 140-160 decibels and 150-160 decibels respectively. The site could easily be subjected to extreme weather events such as hurricane Charlie in the 1980's A site specific location analysis is carried out to ensure the rig and its foundations can withstand extreme weather conditions; the analysis will incorporate 100 year weather data. Drilling Environmental Assessment: During the survey operating criteria for weather conditions (e.g. wind, waves and visibility) would be established and operations suspended if the criteria are exceeded. What is the location clean up plan? Once completed the area should be made good - with some benefit to the local community 18 After drilling, all equipment is removed from the site. EAA: “If the well encounters no hydrocarbons the well will be plugged and abandoned with cement. If the well is successful and oil or gas is present then the well may be suspended for reentry at a later date; in this case a metal trawl resistant cap is placed over the head of the well by a remote operated vehicle. Ultimately the well will be abandoned a minimum of 3 metres below the seabed to prevent interference with the bottom fishing equipment. A remote operated vehicle will be used to inspect the seabed prior to leaving the location. A post operation sampling acquisition is required to ensure that the site is left in its pre-operation state. Providence have invested ~ €3million into the local community during operations of the Barryroe well of the coast of Cork (2011 drilling). Concern that once the oil rig is there its there forever. No, this is a temporary structure which would be removed after the drilling operation. Will the rig be dismantled at the end of exploration? No the rig will not be dismantled but will be demobilised from the location to go an work for another operator most likely offshore UK. Is the building and dismantling of the rig within the 90 days or in addition to it? Yes the mobilising and demobilising of the rig is within the 90 days. concern about sound vibrations travelling through the granite bedrock and effect people with sensitivity to low frequencies Emissions from a seismic source are low frequency in the range of 0 to 250Hz. These frequencies would be attenuated quickly within the water column (and geological formations). At the significant distances (6km) from the source to receptors (households) it is not anticipated that any noticeable effects would be discernible. It should be noted that geological investigations of this type have been ongoing in this area since 2008 (and similar operations including oil and gas exploration occurred previously within Dublin Bay) and to date we are not aware of any issues identified or raised in this regard. Use and disposal of chemicals and waste No details on the chemicals PR intend to use including industrial chemicals necessary to the construction and drilling processes The chemicals intended to be used are discussed in the Drilling Environmental Assessment and the Oil Spill Contingency Plan. Before any drilling operation the selection of chemicals will be submitted to Petroleum Affairs Division in an application for a Permit for Use and Discharge of Added Chemicals (PUDAC). DEA: It is expected that the top hole sections of the well (36 and 17 ½ inch) will be drilled using Water Based Mud (WBM). The lower sections (12¼ and 8 ½ inch) of the well will be drilled using either Water Based Mud (WBM) or Low Toxicity Oil Based Mud (LTOBM) 19 In addition to the mud chemicals, cementing chemicals will also be used to seal the well casing in place; cement is comprised mostly of PLONOR (Pose Little or No Risk to the Environment) chemicals. Other contingent chemicals may be required if problems or emergencies are encountered during daily drilling. The vast majority (by volume) of planned chemicals have a UK OCNS (Offshore Chemical Notification Scheme) category of E and are naturally occurring products (e.g. barite and bentonite) that are either biologically inert or readily dispersible or biodegradable. All chemicals will be used in accordance with the OSPAR approved PLONOR (Pose Little or No Risk to the Environment) chemicals list and will be notified to the DCENR (PAD). How is the drilling oil and sludge to be disposed of? All disposals are covered by a Permit for Use and Discharge of Added Chemicals (PUDAC) and signed off by Department of Communications, Energy and Natural Resources. DEA: Water Based Mud (WBM), will be discharged into the marine environment. Low Toxicity Oil Based Mud (LTOBM), if used, will be collected in skips and taken back to shore, in the UK (as no suitable facility currently exists in Ireland), for disposal and processing. No LTOBM will be discharged to sea. On completion of the drilling operation a mud audit will be prepared showing the quantity of mud brought to the offshore facility, the quantities returned to shore, the quantities left downhole and the quantities discharged. concern over waste disposal The management of waste, including hazardous waste is regulated under the Waste Management Act 1996 and Amendment 2003. All disposal requirements will also be included in the PUDAC application and approved by Department of Communications, Energy and Natural Resources. An observation that “The spill contingency plan outlines procedure for accidental release of Oil based muds which are not outlined for use in the environmental assessment to the drilling procedure”. Reference to oil based muds in the Drilling Environmental Assessment are on page 11, section2.2.1 “The lower sections (12¼ and 8 ½ inch) of the well may be drilled using either Water Based Mud (WBM) which will be discharged or Low Toxicity Oil Based Mud (LTOBM), which will be collected in skips and taken back to shore for disposal and processing. No LTOBM will be discharged to sea”. This is also covered in the OSCP. “any chemicals with substitution warnings will be substituted where practicable"-What happens when it is not practicable? Best endeavours will be taken to ensure that environmentally safe chemicals will be used in accordance with and under approval of the PUDAC which will be regulated by the PAD. 20 “Would the applicant please indicate where and how this Low Toxicity Oil Based Mud will be disposed of and/or processed?” If Low Toxicity Organic Based Mud (LTOBM) are used, these will be taken back to shore for processing and disposal. As per our most recent operated Barryroe Well, offshore Cork, drilling slops of LTOBM will most likely be disposed and processed in purposed facility in City West, Dublin. LTOBM cuttings will be disposed of in the UK as no suitable facility currently exists in Ireland. No LTOBM will be discharged to the sea. carbon sequestration/ carbon dumping: experts say that the leakage of buried carbon could change the biological balance of the sea and suffocate all marine life. Worry that the plan is to use the drill holes as carbon dumps. The issues of dangerous chemical seepage are compounded when one considers the projects chosen method of carbon capture sequestration. Carbon capture sequestration is not applicable to this project. It is not in any of Providence’s plans and is not covered or included in the foreshore licence application. Structural Disturbance Will drilling cause shifts in the sea bed? The hole sizes created by drilling vary from 30” to 8.5” and these are highly unlikely to cause shifts in seabed. Would there be subsidence of the area that would circumscribe the oil/gas field? There will be no empty voids created in the reservoir as oil or gas extracted from pores would be replaced by water. As stated above, the drilling operation only creates a very small hole in the seabed and would not affect a significant area. Any production of hydrocarbons during a development would be designed to avoid any wider seabed subsidence. Would there be gradual or sudden eventual collapse of the seafloor Oil/gas extracted from pores in the reservoir would be replaced by water, therefore there would be no empty voids created in the subsurface. Concern that exploration drilling could seriously compromise the economic feasibility of using the adjacent sandbank as electricity - generating windmill farms Providence is liaising with Saorgas on its planned operations. 21 In The Event of Oil or Gas find There is a need for details on how Providence will deal with finds. Website: If the results of this exploration are positive, further evaluation and appraisal would be required, which would require further foreshore and DCENR licensing consents. Although we are encouraged by our research to date, oil and gas exploration is a highly technical activity and no significant development or production operation would begin without completing a number of intervening technical and commercial assessment stages. Further consultation would be undertaken if this were to be the case. Would granting of an initial licence lead to a presumptive right to a second licence? NTS: No, the current foreshore application made by Providence is to carry out a seismic survey and drill a single exploration well. This operation is purely for exploratory (information gathering) purposes. Any further appraisal drilling will require additional licensing from the PAD and foreshore unit. Concerns about landing and storage of oil/gas finds o Finds will require a pipeline to an onshore terminal or the construction of a marine based terminal with loading facilities for very large vessels. As the drilling site is close to a shipping land it is unlikely that sea based facilities will be provided o We are told that Dublin port or further points northwards would be possible landing points for any gas pipe lines. Can we be sure that no hard beach shore area in Dun Laoghaire Rathdown will be requisitioned for this purpose? o Will there be local storage, transport and refining of oil? Although it is too early to give details, the most likely outcome of a commercial oil discovery would be that it would be shipped in tankers from a rig to an oil refinery, preferably Whitegate in Cork; this can only be done if the oil is compatible with their processing refinery. If not to Whitegate, it is likely to be brought elsewhere. A commercial gas find would most likely be connected into the national grid using a pipeline, possibly at Loughshinny where a gas interconnector already exists. What will be the containment protocols is oil or gas is found? Any oil or gas found will be developed in accordance with strict international standards and any production operations will require a Safety Permit from the CER. 22 Oil Spill Concern that there about a possible oil spill Website: To date, there have been no major oil spills associated with this type of exploratory activity offshore Ireland. Providence operates to the highest environmental and safety levels in all of its operations and it will be no different for the proposed activities. In the highly unlikely event of a spill, contingency plans are in place which would be implemented in accordance with Irish and European standards, which rank among the highest in the world. Why is the Oil Spill Contingency Plan not completed? A full and final Oil Spill Contingency Plan will be submitted and will need to be approved by the Irish Coast Guard prior to the start of any drilling operations. The OSCP now available does not cover the likely nature of the reserve, detail of the drilling programme, and the specifics of the vessels and rig; this information will be available following the Site and Seismic Survey in 2012. Submission of this document is part of the PAD application process and is forwarded to all relevant (20 plus consultees) government bodies. From their review, details such as a master action plan and thresholds of reporting will be finalised. What action is taken in the event of spills due to loading directly from derrick to container ships? OSCP: Whatever the size of the oil spill the incident is to be reported to drilling contractor Duty Manager by the OIM and the Providence Duty Manager by the Offshore Drilling Supervisor, by telephone, immediately. There is also a requirement to report the incident to Irish Coast Guard (ICG) and the Petroleum Affairs Division (PAD). Any such spills are identified as a moderate risk but the expected volumes of hydrocarbon released would be generally small (0.6 tonnes) (HSE, 1995). Such a volume would disperse rapidly and will not impact along the coast. In addition the rig will be supported by a standby (guard) vessel with oil recovery capabilities. Additional information is provided in the Oil Spill Contingency Plan information document available at http://www.providenceresources.com/Foreshore%20Application.aspx Concern that leakages cannot be guaranteed against. OSCP: Providence’s policy is that operations will be conducted in such a manner that will minimise the risk of oil spillage and pollution On board the drilling rig (rig to be confirmed) basic oil spill clean-up training and drills will be carried out i.e. use of equipment held on board together with in house training. A suggestion that the “applicant’s documents are biased and lack quantitative objective analysis of contingencies there are many unsupported assertions and assumptions and reliance on statistics but failure to refer to source material” 23 The Oil spill contingency Plan (OSCP) has not yet been finalised as details from the site and seismic surveys are needed to cover the likely nature of the reserve, detail of the drilling programme, and the specifics of the drill rig. Once the site survey has been completed, this OSCP document would be updated and details of the specifics of Dublin Bay finalised. In addition, submission of this document is part of the PAD application process and is forwarded to all relevant government bodies. From their review, details such as a master action plan and thresholds of reporting will be finalised. Where specific information is not available, this document discusses the methods employed or provides examples from previous Providence experience in Ireland. The OSCP follows the recommended format proposed in the Oil Pollution Preparedness, Response and Co-operation Convention 1992. Has the chain of command to determine exactly who calls a halt to the work in the event of an oil spill been determined by the Irish authorities? The approval process through the OSCP will clearly outline a roles and responsibilities matrix. There is a general concern about who is responsible for the remediation in the case of an oil-spill; is this the responsibility of Providence or the local authority or the Coastguard? All financial responsibility for clean up rests with Providence Resources and its partner. OSCP: Providence recognises that as the Operator and concession owner it has operational and financial responsibility for cleaning any oil spills during the course of its operations. If an oil spill was to occur during operations, the fundamental legal responsibility for clean-up would rest with Providence as the Operator. Government authorities would, in most cases, monitor the clean-up activities while reserving the right to intervene actively if the operations were not being appropriately carried out, or if it became apparent that the problem was beyond Providence’s capability to resolve. Infrastructure for oil spill What safeguards will be put in place to limit effects of accidents? Safeguards to be put in place are detailed in Sections 4 and 5 of the Oil Spill Contingency Plan which can be found at http://www.providenceresources.com/Foreshore%20Application.aspx Concern that there is no comprehensive quick strike emergency force in place to deal with such an environmental catastrophe How far away will the specialised clean-up equipment be sited? Will it have to come from Scotland or England and how many hours will it take to move in, especially in stormy weather conditions? Concern that the response team is based in England and would therefore not be quick enough 24 The PAD Rules and Procedures for Offshore Petroleum Exploration and Appraisal Operations specify that, for a drilling operation less than 55 km from the coast, "At Sea" response equipment must be held either ashore at the nearest port to the site area or on board a support vessel at the drilling. In addition, a full suite of response equipment will be available for mobilisation from OSRL’s base in Southampton, and called upon depending on the extent and requirements of the spill. Will Dun Laoghaire Rathdown CC & Dun Laoghaire Harbour Board to be formally consulted in relation to the "Oil Spill Contingency Plan" Both Dun Laoghaire Rathdown CC & Dun Laoghaire Harbour Board are consultees on the Marine Vetting Licence Committee for the foreshore application which includes the Oil Spill Contingency Plan. Environmental issues A suggestion that the Oil Spill Contingency Plan (OSCP) does not list the authorities responsible for nature conservation or environmental issues (National Parks and Wildlife Services or Department of Environment Communities and Local Government) The Department of Environment, Community and Local Government are listed as an interested party in the Oil Spill Contingency Plan; they would be involved in the event of onshore impact by oil on or near the coastline. (Page 7, Section 1.8.3). Indirect impacts on prey abundance and foraging activity The assessments have considered indirect impacts on prey abundance and foraging areas under the environmental risk assessment, and direct assessment of related fish species etc to the proposed operations. In all cases the potential impacts are minor, cover a small area of the total resource available and the operations proposed are of short duration. Financial Will the company involved lodge extra emergency funds in advance with the Irish Government to meet the costs of any spillage? Will these be fully secure and guaranteed? Would like details to underwrite costs involved in the cleaning of any leakages Insurance to cover the cost of potential accidents spillage could bankrupt the co and leave expenses to Irish state including capping well It is not standard practice to lodge emergency funds in advance to meet costs of any spillages. Providence is a member of OPOL (Offshore Pollution Liability Association Ltd.), and will also have insurance in place. 25 Other No objection provided the work does not compromise the Dublin array Project now or in the future. Map enclosed (Saorgas) Providence will continue to liaise with Saorgas throughout operations. Did the licence for this area not expire August 2011? NTS: The Dalkey Island partners have recently converted Licence Option LO 08/2 which was awarded by the PAD in 2008 into a Standard Exploration Licence SEL 2/11. SEL 2/11 carries a committed future work programme which includes the drilling of one exploration well, subject to foreshore licence being awarded. As part of these activities, the partners have commenced the application process for a foreshore licence over the area in order to carry out well site survey and drilling operations. Has there been any risk assessment? The required documentation on risk assessment includes a Drilling Environmental Assessment, Survey Environmental Assessment and Oil Spill Contingency Plan (OSCP); these have been carried out by a third party consultant, RPS. They are available at http://www.providenceresources.com/Foreshore%20Application.aspx. The use of a grab to sample the sea bed is not representative of the larger area, also by its nature it destroys the habitat it is sampling. Seasearch are willing to conduct dives on the area in a non destructive manner but neither Seasearch nor Comhairle FO-Thuinn has been approached about this by the applicant. The grab sample is used to assess local habitat to minimise disturbance when locating the site for the jack up rig legs. This type of sampling technique is widely used, for example, by the Marine Institute. Providence has been in touch with local diving clubs and plans to meet with these clubs to discuss potential future operations. What exactly will be the outcome of the survey? Website: Ultimately, the purpose of the exploration is to identify whether there are commercial quantities of oil or gas in the Kish Bank Basin. What time of day will the surveys be conducted; will they be tidal based or daylight based? Tides will have no impact on the timing of either survey operation; however we would monitor the tides for the seismic survey. The survey will continue to operate 24/7 through hours of darkness in compliance with current regulations, as is typical of such operations. Request that all exploration activities are restricted to reasonable working hours as for any land based developments 26 This is not standard practice for these types of operations Noise pollution: need to know the frequency or character of the noise and its effects over large distances The frequency of the air source for this seismic survey would be a low frequency ranging from 0-250Hz. The drilling noise levels would be 140-160 dB, which is similar to the noise of a typical fishing vessel. 27 Government Issues State Involvement State bodies which should be involved Dept Communications, Energy and Natural Resources. The Dept of the Environment, Community and Local Government. The Irish Coast Guard. The Defence Force. The National Parks & Wildlife Services. The Health & Safety Authority. The Marine Institute. These state bodies are all notified of relevant intended survey operations. Most have been involved as part of the Marine Vetting Licence Committee during the first step of the process; to apply for a foreshore licence. The next step of the process requires government sign off on the drill and seismic final programmes. For permission to drill the exploration well permission has to be ultimately granted by the Department of Communications, Energy and Natural Resources, following consultation with a group of 23 state bodies. To conduct a seismic survey 12 government bodies will need to be consulted before permission can be granted by DCENR. Monitoring Will there be a monitoring mechanism set up to address issues that may arise during the process of drilling that will include representatives from the wider community and environmental experts? licence to report within the hour to the department and to the company concerned in that order any deviation from the conditions. The cost of this commission to be an attachment to the licence and to be a charge on the licensee. Good communication with the relevant authorities will be maintained throughout the operations. Seismic Survey: the approval of 12 statutory bodies is required for the permission to conduct a seismic survey. In addition to that on board the survey vessel will be a representative of Providence, a Fisheries Liaison Officer and a Marine Mammal Observer. A weekly update report is provided to the DCENR (PAD). Drilling: Providence requires the approval of 23 statutory bodies to undertake a drilling operation and need to report to 16 of those bodies during drilling. There will be a Providence representative on-board the drill rig. A daily update report is provided to the DCENR (PAD) which is distributed to the 16 aforementioned bodies. In addition Special Oversight of Well Operations Committee meetings will be held. 28
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