With the Environmental Impact Assessment (EIA) for the US$900 million gas-to-shore project set to begin in the near future, participants in the public scoping meetings currently being held by ExxonMobil are of the opinion that the EIA should be halted until the withdrawn 2020 guidelines are reinstated and more details about the project are disclosed.
On June 22, the EPA announced it had withdrawn the revised EIA Guidelines (2020) for Mining, Forestry, Hydropower, Thermal Power, Electricity Transmission, and Offshore Petroleum Exploration and Production, to facilitate broader consultations.
The EPA had further advised that the EIA Guidelines (2000), Volumes 1-5 (Generic; Forestry; Mining; and Electricity Generation), would be in effect until further notice.
On June 25, the EPA notified the public that Esso Exploration and Production Guyana Limited (EEPGL), the local subsidiary of ExxonMobil, had submitted an application requesting environmental authorisation to construct and operate an offshore and onshore pipeline, natural gas liquids (NGL), and natural gas processing plant, along with a temporary material offloading facility.
Thereafter, ExxonMobil commenced public scoping meetings which are intended to craft the terms of reference for the EIA. It was at those fora – both virtual and in-person – where participants expressed their dissatisfaction with the Project Summary and the withdrawal of the 2020 guidelines.
During the first virtual consultation, Simone Mangal questioned if the withdrawal of the guidelines and the announcement by the EPA that an EIA would get underway for the project, was coincidental. She stated that an EIA cannot be conducted if the only relevant guidelines relating to the project have been withdrawn. She suggested that EIA be halted until more detailed information is provided on the project.
Mangal was not the only one who expressed concern with the 2020 guidelines withdrawal as another participant, Jocelyn Dow, followed up with her own concerns. She wanted to know how an EIA for such a massive project is being undertaken without the 2020 guidelines. Several other participants urged that those guidelines should be used.
Similar opinions were expressed by several participants who wrote an article published in the Stabroek News’ ‘In the Diaspora’ column (July 20, 2021) which stated “The EPA must not be allowed to keep the clock ticking down to the end of the public comment period. We call on the government to place this EIA on hold until such time that consultations are held on changes in our national development plan and the EPA reinstates the 2020 EIA guidelines or completes the consultations it says are required for improved guidelines.”
The column was authored by Alfred Bhulai, Janette Bulkan, Jocelyn Dow, Danuta Radzik, Vanda Radzik, Troy Thomas and Maya Trotz
Rationale
They wrote that there has been no substantial explanation of the rationale for the withdrawal and noted that there is no reference to ‘petroleum’ in the EPA Act of 1996, or in the 2005 revision, nor in the Regulations therein, which ExxonMobil said it intends to comply with.
The EPA has since denied any connection between the withdrawal of the 2020 guidelines and the gas-to-energy project.
“The new set of Environmental Impact Assessment (EIA) guidelines were retracted pending more extensive consultation to adequately reflect the contributions from diverse stakeholders through wider public participation. This action is not related to any project seeking environmental authorization from the Agency,” declared a statement from the EPA.
It was noted that the 2020 guidelines were not restricted to oil and gas, but were relevant to a number of sectors, including mining, forestry, hydropower, thermal power and electricity transmission.
The EPA also said that guidelines are not mandatory for the conduct of EIAs and that the retraction of the 2020 guidelines will in no way affect the quality of the EIA.
“The EPA is working assiduously to have additional consultations on these guidelines before they are finalized,” the statement said.
Another area of concern regarding the project is its lack of details, participants wrote, especially considering that Guyana is new to the oil and gas industry.
Basic information
“It does not even provide the public with basic information on the volumes of different products and wastes that would be produced at planned and maximum capacity. Information contained in the document has been contradicted by both EEPGL and Government representatives in oral consultations. Yet, with only a few days left for the statutory deadline to submit comments, the EPA has not updated the public register to reflect the true purpose of the development and correct erroneous information. The countdown will reach zero on July 25 with the public deprived of knowledge of relevant matters to inform their written inputs,” they wrote.
They also pointed out that relevant details missing from the project summary include capital investment and the annual turnover; alternative sites; operating processes and the raw materials used in the operation; the quantity and rate of consumption of process related chemicals; a list with characterization and quantification of process related solid waste, and the method(s) and location for the disposal/reuse/recycling of solid waste; a listing of the hazardous waste and the quantities to be used or stored; the source, composition, discharge rate and the final effluent points of related effluent; and the source and consumption rate of processed water.
In addition, the different types and sources of air pollution; an estimated emission rate or loading, and mitigation measures; a map showing surrounding land uses; identification of receiving water(s) and the location of any existing or proposed intake and discharge structures and the location of any discharge; the related flaring and quantity of CO2 emissions that will be discharged into the air related to the drilling and extraction of the natural gas and its insertion into the proposed pipeline; details and specifications of the underwater pipeline and the on-land pipeline, and the levels of produced water and frequency of discharge related to this project and the impacts on our marine resources that will occur from this ongoing and cumulative pollution, are all missing from the EIA.
Meanwhile, the EPA explained that meetings currently being conducted for the project are public scoping meetings the primary purpose of which is to obtain from members of the public, those questions and matters which they require to be answered or considered in the EIA.
It was pointed out that the Environmental Protection Act states: “The Agency after consultation with the person chosen to carry out the environmental impact assessment, sets the terms and scope of the environmental impact assessment, taking into account any submissions made from members of the public.” The EPA stated that it always ensures that EIAs are conducted by independent and suitably qualified persons or entities approved by the Agency.
EEPGL and its co-venturers submitted an application to the EPA in June this year for an environmental authorisation. The company notes in the summary that it entails the construction and operation of a 12-inch pipeline, approximately 220 kilometers long, from the Liza Phase 1 and Liza Phase 2 Floating, Production, Storage and Offloading (FPSO) vessels in the offshore Stabroek Block, to an onshore NGL and natural gas processing plant located at Wales. The pipeline is expected to transport up to approximately 50 million standard cubic feet per day (MMSCFD) of dry gas to the natural gas liquid plant but has a maximum flow of approximately 120 MMSCFD.
With the impact assessment for the Wales gas-to-shore project imminent, the EPA has invited public submissions on the scope of the study for the project which is expected to begin operations in 2024. In a public notice, the EPA stated that the project, with attendant onshore and offshore components, could have possible effects on the environment, including impacts to marine water quality, air quality, marine and terrestrial flora and fauna, and socio-economic resources, among others
As a result, it has been determined that an EIA must be undertaken before the project is approved. Members of the public have been invited to make written submissions to the agency within 28 days of the EPA notice, setting out those questions and matters which they require to be answered or considered in the EIA.
The planned government-owned power plant is not included in the scope of the project’s application, except for its consideration when addressing cumulative impacts for the project.
Persons have until July 24 to send questions or submissions to the EPA so that their concerns may be considered in the EIA.
EEPGL will stand the costs for the environmental and social impact assessment (ESIA) and other studies. It will also be selecting the consultant for the project since, according to this country’s current EPA Act, the contractor has to choose the consultant from an EPA-approved list of persons.
