Environmentalist Simone Mangal-Joly says that the data on which the decision was made by the EPA to waive an impact study for the 300-megawatt natural gas-fired power plant was deeply deficient and does not include critical information on potential impacts of the project.
In a written objection addressed to the Office of the President, Mangal-Joly stated that none of the six reasons provided by the Environmental Protection Agency (EPA) for waiving an impact assessment (EIA) are justified by the information contained in the Guyana Power and Gas Inc.’s application for an Environmental Permit, its accompanying Project Summary that was supplied by the Guyana Power and Light (GPL) Inc or the EIA for the Gas to Energy (GTE) project, inclusive of an Air Dispersion Modelling Report and Cumulative Impact Assessment (CIA).
According to Mangal-Joly, data needed to effectively assess air pollution impacts, or the adequacy of the Air Pollution Dispersion Modelling Report are absent and the information that is available is based on assumptions as there is no design information available.
“The Applicant does not yet know the design of the Power Plant and particulars relevant for assessing air impacts. It is stated on page 4 of the Project summary that the type of back up fuel would only be known at the end of the Engineering Procurement and Construction (EPC) bidding process. The Applicant does not yet know the height of the Power-Plant discharge stack. The Applicant failed to provide scenarios and a risk assessment regarding outages, when natural gas cannot be used, causal factors, emissions scenarios by back-up fuel type etc. These scenarios need to be assessed,” Mangal-Joly stated.
According to the head of the Gas to Shore project Task Force, Winston Brassington, the initial design of the power plant was changed after it was advised that it would be more viable to construct a combined cycle gas power plant.
Mangal-Joly went on to add that the EPA is in no position to conclude that levels of air pollution would be “within the World Health Organisation especially as it pertains to acute levels of exposure that could occur over a period of two to five days or more during outages that coincide with other upset conditions at the NGL plant.”
In addition, she said, Exxon’s Air Dispersion Modelling report does not disclose what the actual concentration of pollution would be at specific geo-referenced points locations from the site.
“We do not know for example, what combined concentration of pollutants from the NGL and Power plants will be reaching the downwind Indigenous community of Santa Mission/Aratak or the community’s acute and chronic exposure risk for the next 25 years?” she asked.
Aside from solid and liquid wastes, she states, the Power Plant will emit particulate matters such as nitrogen dioxide (NO2), Sulphur Dioxide (SO2).
Chronic exposure
“The health risks of these emissions are well established. Chronic exposure is linked to cardiovascular illness, asthma, and lung disease morbidity and mortality. Volatile Organic Carbons are carcinogens. Acute or short-term high-level exposure result in asthma and respiratory failure in vulnerable populations. In addition, Carbon Dioxide (CO2), which is responsible for warming the atmosphere will be emitted,” she stated.
Further, she said, the GTE EIA did not include the rate of consumption or total volume of water that would be consumed from the ground water aquifer over the 25-year life of the project and if it would affect water supply even though the environmental Act requires assessment of impacts of consumption of natural resources.
She noted that the impacts of drawdown on water availability from the A Sand aquifer, upon which most of the country’s population relies for industrial and domestic use, now and in the future, is a significant matter, but the EIA only considered groundwater drawdown for use for the NGL Plant at 378 m3 per day, and concluded that its impact would be low because there were no other uses within 1 km.
“Yet the Power Plant would be next door at the Wales site also drawing down groundwater from the A Sand Aquifer,” she stated, adding that the EIA did not address the impact of industrial pollution on agriculture or forests and land use downwind of the Power Plant as well as provide an assessment of likely impacts of essential infrastructure for linking the power plant to the existing grid.
Mangal-Joly added that contrary to the EPA’s claims that the impacts of the power plant were considered, the CIA only considered for air and noise pollution and a narrow set of socio-economic considerations and the GTE EIA did not provide information required to assess the likely impacts on human health, air, land, and water, and existing land uses of the Power Plant and power distribution infrastructure along with NGL Plant, pipeline, and any road and port infrastructure.
“In answering question after question in the Application Form, the Applicant repeatedly informed the EPA that the amounts of air, liquid, and other pollution and natural resource demands were unknown because the design of the Power Plant was not yet complete. Here we have a case where the Applicant doesn’t know how much pollution their project will generate or how much natural resources, such as water, would be consumed but the EPA says it knows that the impacts of the project would not be significant and therefore an EIA would not be required,” she said.
“The absence of critical information regarding the nature and amount of pollution that would be discharged into the environment makes it impossible to evaluate the likely environmental impact of a project. The evidence is overwhelming that the EPA had no way of determining that the impacts of the Power Plant would be insignificant when it waived the EIA. On the contrary, the evidence that the EPA uses to justify its decisions all point to the need for an EIA. The EAB must quash the EPA’s decision,” Mangal-Joly added.
The environmentalist also raised concerns that board members Dr Mahender Sharma and Joslyn McKenzie have direct and indirect conflict of interests in the project and therefore cannot lawfully preside over a hearing on the power plant. She also pointed out that when the EPA issued a Public Notice of the waiver of an assessment for the power plant, there was no legally constituted EAB and when a Board was appointed, they did not notify the public of the commencement of a lawful statutory 30-day period for submissions.
Instead, she said, the EAB called a Public Hearing, based on written submissions made by individuals who had assumed that they could send objections to the EPA while those who were awaiting the EAB to be constituted and initiate a lawful 30-day period for appeals, were deprived of the opportunity to submit written appeals.
Regarding the EPA’s decision to use the GTE EIA, she said while the Environmental Act allows for owners of different components of a project to apply together for a permit, it does not allow for a project to be chopped into its parts for separate impact assessments.
“The current ExxonMobil permit for the pipeline and NGL facility is an abomination of environmental governance,” she said.
The EAB held a hearing for the project on Wednesday where those who had made written submissions were allowed to make oral presentations. The EPA as well as Brassington made presentations to justify the waiver of an EIA.
