The statutory 60-day scrutiny process for ExxonMobil and partners’ offshore Yellowtail Project in the Stabroek Blocks recently came to an end but questions about the work of consultancy firm and local affiliate of the United Kingdom-headquartered Environmental Resources Management (ERM) remain unanswered.
“How could the ERM have possibly done a credible EIA study according to statutory provisions of the Environmental Protection Act within one month of the issuance of the Final Terms and Scope for the study?” a number of citizens calling for a re-do of the impact survey of the Yellowtail Project queried in a letter to the Environmental Protection Agency and the Environmental Assessment Board.
Their questioning of the works of ERM follows the sequence of events leading up to the company informing that it had undertaken the Environmental Impact Assessment Document for the project.
“The EEPGL applied for an Environmental Permit for the Yellowtail Development on April 1, 2021. On May 9, 2021 the EPA indicated that an EIA was required. On June 28, 2021, the ERM was approved as the consulting firm to carry out the study, and on September 10, 2021, the EPA issued the Final Terms and Scope for the Yellowtail Development Environmental Impact Assessment. One month later in October, 2021 the ERM submitted its EIA document for the statutory 60-day public scrutiny process, which commenced on October 15, 2021,” the citizens wrote.
The terms and scope of works for the Development EIA have not to date been made public.
The Stabroek News reached out to the company, located at 210 New Market Street, North Cummingsburg, Georgetown and was told to email two of its officials: Todd Hall and Camilo Gaona. An email was sent requesting an interview. A response was received from Tim Cooper who identified himself as the Global Director of Communications and he asked “what specifically” the newspaper was interested in learning more about. A subsequent reply was sent and Cooper replied, “Thanks for your interest in ERM. At this stage I don’t think this [the interview] is something we’ll pursue but of course that may change. Perhaps we can reconnect in the New Year once holidays are over and people are back working.”
The citizens questioning ERM’s work noted that that the public relies on knowledge of the Final Terms and Scope for the Yellowtail DEIA to make an informed decision on the adequacy of the EIA presented by the company and without this, the 60-day public comment period would be useless. Yet, they said, the Terms and Scope of the DEIA cannot be found anywhere. “Further, contrary to basic professional practice it was not disclosed in the EIA submitted by ERM” .
“Why is this information being withheld from the public by EEPGL and its firm ERM, and the EPA?” they asked in the letters seen by Stabroek News.
They argued that the EAB cannot possibly consider that the current 60-day period for public scrutiny of this EIA is valid when the Final Terms and Scope remains hidden from the public.
“In fact, we submit that that entire process has been miscarried and call upon the EAB to declare it null and void and reset EEPGL’s application for Environmental Authorisation. The ERM’s professional capacity, ethics, and independence from EEPGL are in serious doubt and is evidenced in the poor-quality EIA study that lacked original research on impacts, and the contempt ERM has shown for the people of Guyana by cobbling together … a lengthy EIA document in a mere month without even regard for disclosing the Terms of Scope for works in the document.
‘Engaged’
ERM Guyana Inc is an affiliate of UK-headquartered multinational consultancy firm, ERM, which provides environmental, health, safety, risk, and social consulting services and sustainability related services, and it says it has some 5,500 employees based in over 40 countries. Guyana is not listed as a place where the firm has a company.
This newspaper found no website for the local company and the Georgetown Chamber of Commerce and Industry lists the global website under the company’s profile.
However, under its list of projects, the company states that it does work for ExxonMobil and that in 2016, “ExxonMobil engaged ERM to help obtain Guyana’s first offshore environmental authorization for the Liza Phase 1 development project, which is expected to generate the country’s first oil in early 2020.”
“Since that time, ERM has continued to serve as ExxonMobil’s lead environmental and social consultancy, working alongside Guyanese environmental companies and local experts, for subsequent Guyana offshore developments. The Environmental and Social Impact Assessments for these projects included extensive, multi-season and multi-year field studies to characterize the baseline conditions along the coast and as far as 200 km offshore for birds, fish, marine turtles, and ecosystem system services,” the website states.
Its approach to the work, the company states, was leveraging technology throughout the project to ensure safe, timely and accurate results.
“With specially adapted tablets, the team produced real-time data analytics in the field. Connecting with geospatial specialists located in ERM offices, local team members were able to conduct extensive and precise coastal mapping that was critical to the integrity of the biodiversity and socioeconomic studies,” it stated while highlighting ongoing field studies.
Those included: “The Turtle Tagging and Telemetry Program, conducted in partnership with the Guyana Environmental Protection Agency and the Protected Areas Commission, [which] contributed a wealth of new data about the at-sea behaviors of Guyana’s nesting green and leatherback turtles” and “The Ecosystem Services Study [which] documented the relationship between coastal ecosystems and local human populations and was the first study of its kind to be conducted coast-wide in Guyana. Over 700 community leaders and members participated.”
There is also, “The Coastal Sensitivity Analysis [which] mapped and measured the environmental receptors along 427 km of Guyana coastline, including over 59,000 hectares of coastal mangroves” and “Coastal Bird Studies, which included data collection at over 100 pre-determined survey points along Guyana’s entire coastline from Suriname to Venezuela. Overall, 230 species and over 69,000 birds were observed during five surveys; nine of which are recorded as bird species of global and regional conservation interest.”
In addition, ERM states that it also did, “Marine Bird Studies [which] included the first offshore bird surveys of Guyanese waters. The nine surveys documented seven bird species not previously documented in Guyana. Data from the surveys increased the number of bird species confirmed to occur offshore Guyana from 28 to 35.”
A study of fishes is also mentioned, “The Nearshore and Offshore Fisheries Study was the first fish study of its kind in Guyanese waters in over 50 years. Several species that have never been recorded in Guyana’s waters were documented during the surveys.”
‘Partnership’
In late July of last year, the company had announced that it had entered into a partnership with local company Environmental Management Consultants (EMC), founded by Shyam Nokta, who has had close ties to the People’s Progressive Party/Civic (PPP/C).
EMC would subsequently also announce the partnership saying it was formed “to formalize the relationship between the two entities to provide environmental and socioeconomic support in Guyana, with a particular focus on the oil and gas industry.”
“ERM and EMC have a long history working together and the organizations have most recently collaborated on a number of environmental impact assessments for new oil and gas developments in Guyana, as well as several multi-year environmental and socioeconomic studies.”
Quoting Nokta, EMC’s then Managing Director, the company’s website currently states, “As Guyana’s oil and gas sector grows and expands, it is essential that international experience is combined with local knowledge and expertise to provide the support and services needed. This partnership between ERM and EMC provides this opportunity,” and Carlos Pereyra, ERM’s Latin America & Caribbean CEO and President of ERM Guyana, Inc said, “ERM and EMC have successfully partnered for many years and we now want to build on that success together for the benefit of our clients and the local economies such a partnership will help develop.”
Questioning the selection of ERM for all of ExxonMobil’s Environmental Impact Assessments and management plans to date the citizens group called on the EPA to show evidence of an open process.
The letter to the EPA and EAB has also pointed out that ERM admitted in an apology letter carried in the Kaieteur News on November 28, 2021, to placing Nokta’s name on the cover of the public summary of the Yellowtail EIA without his knowledge or consent.
“How does the EPA view the ERM’s credibility considering this serious breach of professional ethics and public trust?” the citizens further queried.
ERM earlier this month issued an apology to Nokta through his attorney saying among other things, “In conduct of the EIA, ERM did not engage with or involve Mr Nokta or EMC. ERM has no current relationship or engagement with Mr Nokta or EMC to provide support to any EIA concerning the Yellowtail Development Project or otherwise.”
Further, it added, “It is with deep regret that Mr Nokta’s electronic signature was inadvertently included by ERM on the cover of the version of the EIA non-technical summary for the Yellowtail Development Project that was posted on the EPA’s website. ERM extends an unreserved apology to Mr Nokta for this error and the ensuing commentary.”