The Environmental Assessment Board (EAB) while upholding the EPA’s decisions not to have impact surveys for ExxonMobil’s planned exploration in the offshore Canje and Kaieteur blocks, has ordered the oil company to conduct an environmental study looking at cumulative impacts of offshore activities.
The decision of the EAB was rendered on Wednesday more than one month after the June 30 hearing of the appeal.
Back in March, the Environmental Protection Agency (EPA) said it reviewed the company’s drilling programme for exploration and its appraisal of 12 wells in the Kaieteur Block and had concluded that there is no requirement for an Environmental Impact Assessment (EIA). Meanwhile, a similar notice in relation to the Canje Block exploration was published back on February 14, 2022.
“In accordance with Section 11(2) of the Environmental Protection Act, CAP 20:05, Laws of Guyana, the application for the project listed above has been screened by the Agency to assess the potential environmental impacts. It has been determined that the project will not significantly affect the environment or human health. It is, therefore, exempt from the requirement of an Environmental Impact Assessment (EIA),” the notice from the EPA had said in both instances.
It advised that ExxonMobil would have to submit an Environmental Management Plan (EMP) for the projects.
The decision was appealed by environmentalist Simone Mangal-Joly who argued that it was made in the absence of data. In a letter, dated March 11, 2022, Mangal-Joly wrote to the EAB stating that there is no recorded evidence in the already completed EIAs for Exxon’s activities offshore nor in the baseline studies conducted that pinpoints the locations of coral reefs and fish nurseries relative to existing drill sites and/or proposed exploratory drill sites. She added that there is no baseline information in any of the studies, to which Exxon’s applications refer, on fish and mammal life cycle and migratory patterns, and the extent and full economic and socio-economic value of offshore-related fisheries or near-shore fisheries affected by offshore oil and gas logistic activities.
She also blasted the EPA for not publishing its screening report despite being required to do so.
Just before the June 30 hearing of the appeal, Mangal-Joly wrote to Chair of the EAB, Pradeepa Bholanath advising that she was boycotting the hearing. She said that she does not “have confidence that the EAB can provide a fair and impartial hearing or an independent decision based on technical considerations. I am boycotting your hearing in protest for a fair and independent EAB.”
However, she clarified that her boycott of the hearing did not equate to the withdrawal of the objection to the EPA’s decision to waive EIAs for the Canje and Kaieteur blocks drilling. She informed Bholanath that the EAB is equipped with adequate technical information that ought to compel it to apply the precautionary principle enshrined in the Environmental Protection Act (EP-Act) in its assessment of the EPA’s decision to waive the EIAs.
The hearing went on with both the EPA and Exxon making presentations after which they were grilled by the EAB.
The EAB members are all employees of the government. Bholanath is the Senior Director for Climate and REDD+ (Reducing Emissions from Deforestation and forest Degradation) in the Ministry of Natural Resources while Joslyn McKenzie is the Permanent Secretary of the same ministry. Dr Garvin Cummings is government’s Chief Hydrometeorological Officer.
In its decision, the EAB said that it examined the information provided to the Board on this project, including submissions made at the public hearing. Is reasoned that over the years, Exxon has conducted a number of studies and environmental baseline surveys in the project areas offshore Guyana and as such would have gained knowledge from previously approved exploratory drilling campaigns in the Blocks – a three-well Environmental Assessment and Management Plan (EA&MP) in 2019 and one well EA&MP in 2020 in the Canje and Kaieteur Blocks, respectively.
The EAB added that baseline data has been provided for marine mammals, protected species, birds and marine fishes.
“In its review, the EAB found that EEPGL has conducted a baseline study of the fisheries sector (the ‘Participatory Fishing Study’) from January 2019 to 2020. This study was focused primarily on engagement with the fishing community and sought to supplement data collected during the ‘Nearshore and Offshore Fisheries Studies’ conducted from 2017 to 2019. The baseline data collected describes seasonal productivity, species diversity, biometrics, prices and markets, and fishing grounds,” the written decision said.
Localized
The EAB explained that the impacts will be localized and temporary since fishing nurseries are located outside of the project area, and the drillship will be stationary once operations commence – reducing the possibility of collisions with marine biological resources.
As it relates to marine water discharge, the Board said that discharges are expected to be short-term and previous wells drilled allows the EPA to expect that discharged volumes would be less than the stipulated discharge limits.
The Board said that it has thoroughly examined the assessment of the EPA in relation to Exxon’s applications, the scope of the previous studies conducted and the issues raised by Mangal-Joly. It noted that drilling campaigns and the associated passage of supply/support vessels have been executed by Exxon over the past few years and are currently ongoing. Further, it stated that the impact of these within the Stabroek Block has been examined over the years by Exxon alongside a number of studies that also targeted both the Canje and Kaieteur Blocks.
“These aided in providing initial baseline data that allow a forecast of expected impacts within each block and the needed mitigation measures. Considering the contiguous nature of Stabroek, Canje and Kaieteur Blocks, the EAB, agrees with the EPA that sufficient data exists to conclude that any negative impact of the proposed individual projects would be primarily local and short-term. The EAB, therefore, upholds the decision of the EPA that no EIA is required for the Projects.
“However, collectively, the impact of these projects needs to be further examined. Given the increasing drilling activity on the Stabroek Block and its proximity to the Canje and Kaieteur Blocks along with the number of wells proposed to be drilled, the EAB has decided that the Operator must conduct an Environmental Impact Assessment of the Cumulative Impacts of the activities within each project in keeping with Section 17 of the Environmental Protection Act along with an updated baseline assessment. In addition to this, the following recommendations are made: The project will see a number of wells being plugged and abandoned after drilling and this presents some risk as Green House Gas leaks from such wells are possible. The EPA should consider a Green House Gas (GHG) management plan in the permitting condition for these wells when they are plugged and abandoned,” the EAB said.
This now means that Exxon would have to conduct the EIA of the cumulative impacts and submit its findings to the EPA.
EEPGL, last year submitted an application to the EPA for environmental authorisation to drill 12 wells each in the Canje and Kaieteur blocks. According to the project description, the drilling of the wells is expected to commence in the 4th quarter of 2022 with the conclusion of the proposed drilling campaign expected by the first quarter of 2027.
Based on the water depths in the Kaieteur Block, multiple dynamically-positioned drill ships would be used to drill the wells. The Kaieteur Multi-well Programme aims to gather data on the reservoir characteristics, hydrocarbon presence, pressure, and temperatures. If the presence of hydrocarbons is discovered, wells will be tested to establish the limits of the reservoir.
Additionally, the productivity of wells and the oil or gas properties present will be tested. Once the proposed drilling operations are complete, the exploration well will be permanently plugged and abandoned.
The Canje Block is operated by ExxonMobil (35%), with Total Energies (35%), JHI Associates (17.5%), and Mid-Atlantic Oil & Gas Inc. (12.5%) as partners. Westmount holds a 7.2% interest in the issued share capital of JHI. While the Kaieteur Block is operated by ExxonMobil (35%), Ratio Guyana Limited (25%), Cataleya Energy Limited (20%) and Hess (20%).
In 2020, Exxon, the operator, made a non-commercial oil discovery at the Tanager-1 well in the Kaieteur block, failing to replicate a string of successes made in the nearby Stabroek offshore block, where it has so far found more than 11 billion barrels of oil.
The Tanager-1 exploration well, drilled by the Stena Carron Drillship, was the deepest well drilled in the Guyana-Suriname Basin to date. It was spudded on August 11, 2020, eventually reaching a total depth of 7,633 meters.
