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No provision exists for post audit of flaring activities, operator only needs to keep records for three years – Ram
ExxonMobil’s modified Permit…
Chartered Accountant, Chris Ram
Kaieteur News – Following his perusal of the recently modified Environmental Permit on matters of flaring for ExxonMobil’s Liza Phase One operations, Chartered Accountant and Attorney-at-Law, Christopher Ram, has found some troubling loopholes that could very well perpetuate further destruction of the Nation’s pristine environment.
In a letter to the press, Ram said the Permit exposes that the Environmental Protection Agency (EPA) is relying entirely on ExxonMobil’s subsidiary, Esso Exploration and Production Guyana Limited (EEPGL), to provide reports on flaring since it will have no presence or equipment at the Stabroek Block operations to verify any information it receives after the event. What was also troubling to the Chartered Accountant is the fact that the modified Permit contains no provision for any post-audit of flaring activities while adding that the operator needs only to maintain records for three years.
Speaking to another area of concern in the Permit, Ram said he observed that flaring or venting is strictly prohibited, “except when it is permitted” for commissioning of the operations and during start up of operations. The former he noted has no specific time or flaring volume limitation while the latter is permitted for up to 60 days but without a volume limitation.
Ram then placed the spotlight on the fact that there are special circumstances for which flaring can be approved. These circumstances are: (i) Emergencies arising from any unavoidable, expected event requiring flaring, including weather; Safety Response to maintain the safety of the flaring system and pilot flame. (ii) Inspections, planned and unplanned maintenance, etc.; and (iii) Re-start, defined as the “instance of resumption of oil production following a shutdown event.”
Ram further noted that if any of the special circumstances exceed 14 calendar days, the Permit holder must seek approval from the EPA within the first 48 hours of the commencement of flaring. The application must be supported by a number of documents and the EPA can request further and additional information. On being satisfied, the EPA can allow flaring for up to 60 days, subject to further extensions and any conditions the EPA deems appropriate.
To explain in simpler terms, Ram alluded that ExxonMobil will be allowed to flare any quantity of gas for 60 days with possible extensions from the EPA at no cost. The only time it pays is when flaring is not considered part of the Start-up and Special Circumstances periods. In such instances, ExxonMobil will pay a ‘paltry’ sum of US$30 per tonne of Carbon Dioxide equivalents (C02e) emitted as a result of flaring.
Considering the foregoing loopholes, among others, Ram said one thing is clear, “…exploration in the petroleum sector under successive administrations is designed to serve the interest of the oil companies.”
He further asserted that the consequence for Guyana is the “raping” of the Nation’s natural resources, the accompanying destruction of its pristine environment and the deterioration of its reputation as a responsible petroleum producing country.
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