Download 10 Oil spill response planning

Taking action for a living planet
WWF response to the Woodside EIA for the Chinguetti Development Project
WWF welcomes Woodside’s request for comments on its Environmentsl Impact Assessment
(EIA).
WWF would like to work with the NGOs, Woodside and the Governments within the region to
help reduce the social and environmental risks of oil companies operating within the West
African Marine Ecoregion. (WAMER). WWF understand’s Mauritania’s desire to develop its
oil industry, and seeks to ensure that this occurs in a responsible manner, which maximises
the benefits for society. It is therefore essential to prevent damage to the environment which
so many rely on for their livelihoods.
WWF and its partners have been working in this region for many years and worked with the 6
governments and other institutions to put together the Regional Strategy for Marine
Protected Areas in West Africa. This document has been approved by Ministers from the 6
countries concerned. (It has been sent separately to Woodside as part of WWF’s
submission). WWF has also sent its Regional Conservation Programme for the Coastal and
Marine Zone of West Africa to Woodside as part of this submission.
Papa Samba Diouf, Head of WWF’s Regional Marine Programme based in Senegal, has
also submitted his comments on the EIA and this is attached as part of this report, pages 8-9.
WWF is fully aware that a number of its partners, including Sandra Kloff and FIBA, have
already, sent in their comments on the EIA. WWF has reviewed these and generally agrees
with them. The stakeholder workshop that took place in Mauritania in December also
identified many of the key concerns. WWF will therefore try to complement what has already
been written.
WWF has a number of major concerns
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Context in which the project is working
Woodside has collected a lot of good environmental data but in their reply, to the
Sandra Kloff and Tom van Spanje report, Woodside appears to indicate that the
Australian Enfield project is sited in a more significant environmental and economic
area than WAMER This is used to justify some of the differences in approach to the
two projects. WWF seriously questions this as the environmental and economic
importance of WAMER is on par with if not more important than the Enfield area.
WAMER is more vital for human survival for millions of poor people who depend upon
environmental resources for survival.
During our meeting on the 28th November 2003, Woodside committed to applying the
same standards in Mauritania as it would in Australia. WWF suggests that Woodside
informs its stakeholders of the relevant standards that will apply.
WWF would like to help establish more clearly the context within which this project
(and other proposed oil and gas projects) will be working. The project is sited with in
one of the 10 most important marine ecoregions in the world. It has global importance
for biodiversity and regional importance for fish.
WWF does not believe sufficient attention has been paid to transboundary impacts.
WWF also considers that given that activities such as fishing and oil developments
have both social, economic and environmental impacts, these issues need to be
considered together. A more detailed context is shown on page 6-7.
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Capacity Building
a. There is limited capacity to deal with the oil Industry in the region not just in
Mauritania. Other countries such as Nigeria have run into serious social and
environmental problems and have contributed to the “Curse of Oil “ and the
“Paradox of Plenty” as defined in the World Bank Extractive Industries Review
(EIR). WWF is sure that Mauritania and Woodside would wish to avoid these
problems.
b. There is a need to build the capacity of all the key stakeholders who are
directly or indirectly affected by Oil operations. This was really needed prior to
the EIA being reviewed. A capacity building programme must be started,
before the Environmental Management System (EMS) is developed, and
continued until the stakeholders are able to work with the Industry effectively.
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Strategic Environmental Assessment (SEA) for the oil and gas Industry
a. There is a need for a SEA to be done by governments at the National and
Regional level as all 6 countries are dependent on each other to maintain the
Marine eco system. Organisations like WWF, IUCN and the World Bank/IFC
can help Governments and companies to prepare SEAs.
b. Integrated EIAs and Social Impact Assessments (SIAs) are required by, the
main financial institutions such as World Bank/IFC and European Bank for
Reconstruction and Development (EBRD).
c. The SEA should provide the framework for integrated environmental and
social impact assessments (ESIA), and the EMS including integrated oil spill
response planning.
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National and Regional Legal Framework for dealing with the Oil and Gas
Industry
There needs to be an effective legal framework within which Woodside and
other oil and gas companies can work. Implementation and Enforcement of
this framework will also be necessary for it to be effective. Unless this is done,
some unscrupulous oil operators may take advantage and the environment
and society will suffer.
Action: WWF recommends that the World Bank team that is helping establish
the legislation for the Mining Industry be asked by the Mauritanian
Government to assist with the legislation for the oil and gas Industry. The
same action is probably needed in the other 5 countries in the WAMER.
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Transparent process.
Experience in Nigeria and elsewhere in the world has taught WWF that there
needs to be a completely transparent process for dealing with the oil and gas
industry and this is reflected in the World Bank EIR, OECD Guidelines for
Multi-National Corporations and UN Conventions.
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WWF notes that Woodside has not yet signed the EITI (Extractive Industries
Transparency Initiative). It has been signed by many major oil and Gas
companies including Shell and BP.
Action : WWF strongly recommends Woodside signs the EITI as a sign of
good faith
At present the terms of the Production Sharing Contracts (PSC) with the Govt
are treated as confidential.
Action : WWF strongly recommends that the Mauritanian government make
the PSC a public document. This is now best practice in other countries as
part of the transparency initiative.
WWF notes that the Mauritanian Government has not signed or ratified the UN
Convention against Corruption. Mali, Gambia and others have already signed.
Action : WWF would recommend that the Mauritanian government sign and
ratify the UN Convention on Corruption. This would increase confidence in
both the NGOs and the financial institutions.
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Consultation process
WWF has received a number of comments that whilst the process used by
Woodside was rated favourably by some stakeholders others complained. Key
fisheries stakeholders and key Governments departments in other countries
who were signatories to the Regional Marine Protected Area Strategy did not
feel that they were adequately consulted see the attached report by Papa
Diouf .
Consultation is required by the Abidjan Convention, on the potential
transboundary impacts of this project. Both Mauritanita and Senegal are
signatories to the Memorandum of Understanding concerning Conservation
Measures for Marine Turtles of the Atlantic Coast of Africa, which forms part of
the Convention on Migratory Species. WWF does not believe Woodside
consultation with stakeholders in Senegal has been sufficient to gain sufficient
understanding of the marine agreements.
Woodside should be aware that there is a major Global Environment Facility
(GEF) Biodiversity project with which Woodside needs to liase.
World Bank - GEF - Biodiversity:
Marine and Coastal Biodiversity Conservation, Senegal
The project will strengthen the conservation and management of globally
significant marine and coastal biodiversity, it will answer priorities identified in
the Action Plan.
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Coordination between main stakeholders
Based on experience of working with the oil and gas Industry in many
countries, WWF would recommend a high level National and Regional
committees be established to coordinate all the Ministries and key
stakeholders. In WWF’s experience this avoids a situation in which the role of
key Ministries such as the Ministries of the Environment and Fisheries is
marginalised.
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Under estimation of risks
WWF feels that the risks have been under estimated in the EIA. Banc d’Arguin
is only one of many critical areas that could be affected. The risks are to the
whole marine eco region. The World Heritage Site status of Banc d’Arguin
draws attention away from the rich biodiversity further south along the coast.
Woodside’s current modelling indicates that it is this area further south that is
most at risk. Pollution can be carried by currents, as is shown in the oil spill
modelling or by fish that have been affected to many parts of the eco region.
The most serious risks are to the fish stocks on which the economies of 6
countries largely depend.
Papa Diouf and others have already highlighted this problem. The long-term
environmental and social impacts of an oil spill can be enormous. In spite of
the millions of dollars that have been spent to clean up Exxon Valdez spill in
Alaska the seabed is still covered in oil over 10 years later. Companies are
usually forced to pay for the clean up costs but often these do not cover the
long-term damage done to the environment and the economy.
Visibility and the risk of ship collisons
The EIA page 57, rightly points out that visibility is chronically poor in the
region due to high levels of suspended dust and sand (Harmattan). However
the consequence of this were not adequately highlighted
All of the coast, but particularly of Mauritania, is littered with shipwrecks. WWF
has serious concerns about the risks to the Free Standing Operational
Platform (FSOP) and oil installations.
The EIA indicates that the odds of a collision is low. However given the poor
visibility in the area (due to cold upwelled water hitting tropical air), the
Harmattan winds, and the high number of vessels plying the local waters,
WWF believes the risks to be high. The shore between Nouakchott and
Maghar (at the south end of Banc d'Arguin National Park) is littered with
wrecks (indicating that sailing is treacherous and/or ships not well maintained).
A realistic system to avoid and if necessary deal with a collision - either
between a tanker and an "outsider ship" or between "outsider ship" and the
FSOP - must be in place before drilling starts.
Free Standing Operational Platform (FSOP)
WWF supports the use of a FSOP in preference to a fixed platform. However
WWF agrees with Sandra Kloff and others that this should be a doubled hulled
boat as the risks are very high. WWF does not follow Woodside’s argument
that the short life of the oil field (8-15 years) would not justify a doubled hulled
boat as the cost of the boat does not need to be charged out over the short life
of the field and can be used again and again.
PSSA (Particularly Sensitive Sea Areas)
WWF supports the need for a protected area around the FSOP and is willing
to work with others on the development of a protected area system in
accordance with the regional strategic marine plan (attached). WWF is not
sure that areas set up to protect the FSOP can be called PSSA. PSSA
legislation would probably not permit tanker traffic.
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The impact on fishing of creating protected areas needs to be studied but
WWF would expect it to be positive.
WWF would also point out that there is a contradiction between Woodside
acknowledging the importance of the area by suggesting the creation of a
PSSA (as discussed on 28 November 2003), but then rebuffing the suggestion
of many of the measures that are applied for PSSAs. These include exclusion
of certain vessels (such as single-hulled tankers), and restricting discharges
(such as produced water).
WWF expects all the seabed oil installations to be removed once oil extraction
has been completed.
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Produced Water and Drilling Muds
WWF agrees with other comments on this. WWF has already sent Woodside
the Norweigan report on the damage done to Fish stocks by chemicals in
produced water. This subject is well described by Dr Stanislav Patin
“Environmental Impact of the Offshore Oil and Gas Industry”
WWF’s concern is not just about water from Woodside it is also about the
cummulative impact of produced water from all the oil exploitation in WAMER
and from the diposal of drilling plugs.
WWF would prefer to see the water reinjected but if this can not be done then
it must be cleaned adequately on the FSOP, given the significant volumes and
the increasing concentration of pollutants over the lifetime of the project.
Adequate monitoring must be set up by Woodside and this must be checked
independently.
10 Oil spill response planning
WWF supports Woodside’s wish to ensure that adequate oil spill equipment is
put in place and recommends that the equipment is available within the
Region at the start of operations to deal with spills as soon as they occur.
National and Regional Oil spill planning still has to be done. At present the
Southampton Oil Spill responce team will be the main organisation dealing
with a major spill. This is not adequate.
The management systems with clear lines of responsibility must be in place.
Too often oil spill response plans have not been backed by good management
systems e.g Exxon Valdez. It took nearly 36 hours before there was a effective
response, partly because the lines of responsibility had not been clearly
established.
11 Independent review of the EIA
WWF agrees with others that there should have been a comprehensive
independent review of the EIA by an organisation specialising in standards for
the Oil and Gas Industry working in a marine environment.
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CONTEXT
The Western African Marine Ecoregion (WAMER)
The Western African Marine Ecoregion (WAMER) spans 3,500 kms of coast in western
Africa and includes six countries - Mauritania, Senegal, The Gambia, Cape Verde, Guinea
Bissau, and Guinea. These coasts present a wide variety of habitats from rocky cliffs, broad
sand beaches, and extensive sea grass prairies in the north to dense mangrove forests and
well-developed estuaries in the south. Among its most striking features are the unique coral
reefs of Cape Verde and the powerful coastal upwellings of cold water that support one of
the most diverse, and economically important fishing zones in the world.
The upwellings are primarily the result of the year-round trade winds that push surface
waters away from the coast and draw cold, nutrient-rich waters from deep in the ocean up to
the surface. These rich waters meet the tropical sun and create the perfect environment for
photosynthesis - the foundation of a tremendously productive food chain that supports
incredible biodiversity. Over 700 species of fish have been identified, as have several
species of cetaceans including dolphins and whales, 5 species of endangered marine turtles,
and a colony of 100 Monk Seals- the largest breeding colony left on the face of the earth.
While the continental upwellings support their characteristic floral and faunal diversity, the off
shore the archipelago of Cape Verde harbours one of the most important coral reefs in the
world. Recently published studies have identified Cape Verde as both a centre of
endemism- because of its unique and rare species- and as a top 10 global hot spot for coral
communities- where conservation action is most needed and could have the greatest
benefits.
Yet, even with this enormous diversity of habitats and species, the ecoregion forms one
ecological unit. Fish that spawn in northern nurseries seasonally migrate southwards and
feed human fishing communities along the way.
Conversely, recent satellite tracking has confirmed that Green Turtles lay eggs along the
remote beaches of Guinea Bissau and travel northwards through Senegalese, and Gambian
waters to graze in the rich sea grasses of Mauritania. The fact that so many species pass
different phases of their life cycles in different WAMER habitats underscores the need to
understand and manage the ecoregion as a whole.
The ecoregion’s importance also extends from Africa to other continents. Over 10 million
migrating birds from Europe feed in the rich coastal waters before beginning their homeward
trek in the northern spring. Commercial fleets from distant countries in Europe, Asia, and the
Americas also depend on the rich fishing grounds and the fish they catch provides food for
millions of people around the world. In short the unique combination of climate and
upwellings supports species and habitats that, represent critical resources locally, nationally,
regionally, and across the globe.
From the socio-political perspective, the area is calm. Over the past three years, Mauritania,
Senegal, the Gambia, and Guinea Bissau have all had democratic elections, which have
even led, in the case of Senegal, to a change of ruling party.
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For Millions, Fishing is Life
Fisheries in this ecoregion generate some $400 million annually, which makes it the single
most important source of foreign exchange in the region and a key source of revenue for
economic and social development. Nearly 8 million people live along the WARMER coast
and, in Senegal alone, a country of 9 million, the jobs of over 600,000 men and women
depend directly on fishing and fisheries related industries.
The profile of the WAMER nations’ fishing fleets differs dramatically. In Mauritania, for
example, where landings top 400,000 tons annually, the industrial fishing fleet catches about
80% of the fish and the smaller scale, artisanal sector catches around 20%. The opposite
holds true in Senegal, where the artisanal fishers land 80% of that country’s 400,000 tons per
year catch.
In addition to domestic industrial and artisanal fishing fleets, many foreign powers- in
particular the EU, Japan, and China- have negotiated important fisheries agreements to
allow their boats access to waters of WAMER countries.
Threats to resources endanger fragile economies
Although access agreements with foreign countries bring much needed income, they also put
unsustainable pressures on limited stocks leading to conflicts between local and foreign
users. This is further exacerbated by recent improvements in fishing gear that increase
fishing efficiency, but also increases fishing pressures. The result is a vicious cycle. More
pressure means fewer fish, which in turn drives the need to develop ever-more effective
gear, which further threatens stocks. Unfortunately, given the serious economic constraints
facing the developing countries of the ecoregion and a lack of alternatives, many countries
find themselves caught between the development needs of their people and the need to
ensure the integrity of their natural resources.
While more and more boats search for fewer and fewer fish there has been a dramatic
increase in the use of destructive, habitat-destroying fishing techniques like dynamite, bottom
trawling, and beach seining. It has also led to increased capture of endangered marine
turtles and juvenile fish, and a massive expansion of the trade in shark and ray fins.
The latter is particularly destructive as sharks and rays are at the top of the marine food
chain - the lions and leopards of the sea- and stabilize whole marine communities. They
reproduce very slowly and have already disappeared from some areas and are seriously
depleted in others. Pirate fishing is also on the rise.
As the amount of available fish goes down, the frequency and severity of conflicts between
users go up leading to serious social as well as economic and ecological problems. But the
governments and artisanal fishers’ groups have inadequate resources to cope with the
trouble. Traditional management methods like surveillance patrols, ecological monitoring, or
measures to address pollution from both land and sea have met with only limited success
because they are simply too costly for the region’s cash strapped institutions. Clearly, while
these efforts continue, other complimentary and innovative approaches are urgently called
for.
Now a new risk Oil and Gas exploration is being introduced and this needs to be managed in
a very environmentally sound way to minimise potential damage to this vital eco region. Parts
of the area are already being affected by oil pollution from Oil tankers.
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COMMENTAIRES SUR L’AVANT PROJET D’ETUDE D’IMPACT DU PROJET
DE MISE EN EXPLOITATION DE CHINGUETTI
par
Papa Samba Diouf
WWF WAMER
Sacré Cœur 3, n° 9442
Dakar, Sénégal
Tél. : 221 869 37 00
Fax : 221 869 37 02
[email protected]
La zone allant de la Mauritanie à la Guinée fonctionnent comme une unité écologique.
Plusieurs faits attestent ceci. De nombreuses espèces utilisent cette zone comme espace de
migration. C’est le cas des tortues marines qui utilisent la Guinée-Bissau et le Sénégal comme
zone d’alimentation et la Mauritanie comme zone de reproduction. De même plusieurs
espèces de poissons se déplacent sur toute cette zone de l’Afrique de l’Ouest.
Par ailleurs, cette zone abrite des nurseries et des zones de reproduction importante pour des
oiseaux provenant d’Europe et d’Asie.
Il apparaît donc que cette zone a une importance cruciale pour la biodiversité mondiale et les
pêcheries régionales.
Etant donné l’importance de cette zone, il est essentiel que les standards internationaux les
plus exigeants soient adoptés. C’est ainsi que le choix d’une coque simple (même si des
mesures complémentaires sont prises pour minimiser les risques) ne devrait pas être envisagé.
En outre, l’importance du trafic dans le sous région, le rôle écologique joué par plusieurs
habitats de la région, le faible développement technologique des différents pays et surtout
l’absence de dispositifs efficaces de lutte contre la pollution rendent indispensable la mise en
place de PSSA non seulement pour la zone proche du Parc National du Banc d’Arguin, mais
également pour les parties sénégalaises, gambiennes et bissau-guinéennes abritant des aires
marines protégées.
En ce qui concerne la concertation avec les acteurs, il me paraît indispensable d’associer les
les structures techniques (Ministères de l’Environnement et de la pêche) au moins du Sénégal
et de la Gambie et idéalement de toute la sous-région. Ceci pour deux raisons :
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le nord du Sénégal et peut-être la Gambie (même si l’étude d’impact ne
l’indique pas pour la Gambie) peuvent être directement touchés par une
pollution liée à l’exploitation ou au transport du pétrole (surtout en hiver;
période durant laquelle les courants peuvent permettre une telle chose) ;
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d’autres pays de la sous-région sont en train de faire des explorations
pétrolières. Ils pourraient profiter de l’expérience et l’exemple de
transparence de Woodside.
Le corps diplomatique sénégalais a été associé aux consultations, mais ceci est insuffisant. En
effet, le cloisonnement et la faiblesse de la circulation des informations entre différents
départements ministériels dans les pays de la sous région, font que la probabilité pour que les
structures techniques en charge de l’environnement et de la pêche soient correctement
informées par le corps diplomatique est faible.
Une attention particulière doit être accordée aux pêcheries de mulets qui ont une grande
importance économique et sociale dans la sous-région et notamment en Mauritanie.
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Il est fort probable que la qualité gustative des mulets va se déprécier. Les rejets chroniques
surtout, et d’éventuelles pollutions accidentelles pourraient être responsables de ce
phénomène.
Il est bien établi que même quand il y a l’épanchement de petites quantités de pétrole
(exemple au niveau des ports), les mulets ont un goût de mazout. Vu l’importance des
pêcheries de mulets en Mauritanie, un tel phénomène serait catastrophique.
Un examen attentif des relations upwellings (qui font remonter les eaux du fonds où se
concentrent certains polluants) et pollution devra être réalisé pour évaluer l’impact combiné
de la pollution et des upwellings. Ceci me fait penser que l’EIE n’a pas bien pris en compte
l’impact de la pollution sur les processus écologiques (à l’exception de la migration des
espèces).
L’interférence pêche - exploitation du pétrole sera certainement un risque élevé comme l’a
souligné l’EIE. Il faudra une très bonne sensibilisation et information des pêcheurs
(notamment les chalutiers) pour minimiser la probabilité d’accident.
Les risques de pollution du Parc National du Banc d’Arguin sont presque toujours sousestimés ce qui est inquiétant quand on connaît l’importance et le fonctionnement comme une
unité écologique de toute la zone qui l’entoure.
En conclusion, nous saluons le processus de concertation initié par Woodside. Toutefois, il
nous semble qu’une EIE indépendante aurait été plus appropriée.Les risques encourus pour la
sous-région (de la Mauritanie à la Guinée) sont élevés, si l’on considère les menaces sur la
pêche et la biodiversité.
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