Environmentalist Simone Mangal-Joly has objected to the decision of the Environmental Protection Agency (EPA) to not require an Environmental Impact Assessment (EIA) for an ExxonMobil-led 12-well oil exploration programme in the offshore Kaieteur Block.
According to Mangal-Joly, who has objected to a similar Exxon-led campaign in the offshore Canje Block, the EPA’s conclusion that the impacts would not be significant is “unsound and irrational.”
On September 24, 2021, the EPA had posted a public summary of the proposed activities by Exxon affiliate Esso Exploration and Production Guyana Ltd (EEPGL) on its website. In the interest of sound environmental management, the EPA said while the project would not require an EIA, it would require an Environmental Assessment and Management Plan and a Cumulative Impact Assessment considering possible impacts on the environment and/or human health, and detail specific mitigation measures to be undertaken in order to ensure that the proposed project is implemented in an environmentally-sound and sustainable manner. In providing the rationale for its decision against requiring an EIA, it cited: (1) Review of existing environmental baseline information of the Kaieteur Block. Environmental baseline information on the Kaieteur Block has been collected via two separate assessments in 2019 and 2020, respectively; and (2) Conduct of similar campaigns in the Stabroek, Canje, and Kaieteur Blocks.
In a letter to the Chairman of the Environmental Assessment Board Omkar Lochan, dated October 22, 2021 and seen by Sunday Stabroek, Mangal-Joly said it was unclear whether the EPA’s reference to “similar campaigns” was in relation to gathering of environmental baseline information, or well drilling campaigns conducted elsewhere. “In any case, the presence of baseline data is not sufficient reason to exempt activities with potentially significant risks from an Environmental Impact Assessment,” she argued.
The Environmental Assessment Board hears appeals against EPA decisions and Mangal-Joly voiced her hope that it is committed to having “a fair and equitable public engagement” on the case and will endeavor to ensure that the EPA meets all statutory requirements for information provision prior to scheduling a public hearing.
In her letter, she also highlighted what she said were “significant omissions” in the Project Description. Among them is the location of the proposed activities. She said Section 36 as well as Section 11(1)(i) of the Environmental Protection Act requires an applicant to disclose the location of the activities for which it is seeking an environmental permit. “The Applicant proposes to drill and perforate the seabed, emit toxic pollution to the waters and air, create centers of oil spill risks, and surely would require an exclusion radius prohibiting other users at 12 unidentified sites in Kaieteur Block. This Block is some 13,500 km2, an area larger than the country of Jamaica. The locations of the actual drill sites (GPS coordinates) are missing. These locations are material to determining the significance of likely impacts on the natural environment as well as other users, and whether an EIA should be required,” she said.
In addition, Mangal-Joly said that also omitted is the issue of the durations of each seabed perforation activity, season of the year when each will be conducted, and how the noise of drilling and supply vessel activities as well as toxic water and air emissions could affect the migration and feeding habits of marine mammals as well as commercially and ecologically important fish species. “The Applicant must surely be in a position to state the potential effects of its proposed activities in these areas,” she noted.
Other key omissions, according to her, are the purpose, scale, duration, specification, and possible effects of the seismic activities mentioned on marine life, mention of other marine users that could be affected, and the essential shore-based activities that would support each seabed perforation exercise, including types of activities, wastes generated or that would be handled on shore, how they will be disposed, and frequency of movement of material to and from drill sites etc. “The [Board] would appreciate that the drilling proposed offshore cannot occur without shore-based components. The complete set of activities must be considered when determining the likely significance of impacts,” she wrote.
She said the description also omitted an indication of potential types of risks, affected parties, measures in place for avoidance, mitigation, compensation, and restoration for negative impacts specific to the identified locations and durations of activities.
Against this background, Mangal-Joly argued that EEPGL has made a case for why an impact assessment is in fact needed and that the EPA has been in no position to conclude that the likely impacts would not be significant enough to warrant an EIA.
In the Project Description, she noted, EEPGL states clearly that Kaieteur block drilling activities will have to be assessed “to identify potential hazards to personnel, facilities, the public, and environment.” “Isn’t the purpose of an EIA to identify the hazards of an activity and whether and how they could be mitigated?” she questioned, while citing EEPGL’s full statement on the issue in its Project Document.
The Kaieteur Block, which is located in deep water offshore Guyana, was awarded and licensed on April 28, 2015, to Ratio Guyana Limited and Ratio Energy Limited, now known as Cataleya Energy Limited, by the Government of Guyana. EEPGL farmed into the Petroleum Agreement and the Petroleum Prospecting Licence for the Kaieteur Block and assumed operatorship in February 2017. Through the farm-in and approval of the relevant transfer of interest to EEPGL by the government, EEPGL became a participant in the Petroleum Agreement and the Petroleum Prospecting with Ratio Guyana Limited and Cataleya Energy Limited. In April 2018, 15% of participating interest in the Kaieteur Block under the Petroleum Agreement and the Prospecting Licence was transferred from EEPGL to Hess Guyana (Block B) Exploration Limited.
