Public Communication

Oct 24, 2021 Letters

---

Simone Mangal-Joly
Friday October 22, 2021

Mr. Lochan
Chair
Environmental Assessment Board
c/o The Environmental Protection Agency

Dear Sir:

RE: Esso Exploration and Production Guyana Ltd. – 12-Well Exploration Campaign, Kaieteur Block Offshore Guyana

I object to the EPA’s decision to not require an Environmental Impact Assessment (EIA) for the above proposed activities on grounds that the Agency’s conclusion that the impacts would not be
significant is unsound and irrational.
On September 24, 2021, the EPA posted a public summary of the proposed activities on its website and provided the following two reasons for its decision:
“1- Review of existing environmental baseline information of the Kaieteur Block. Environmental
baseline information on the Kaieteur Block has been collected via two separate assessments
in 2019 and 2020, respectively.
2- Conduct of similar campaigns in the Stabroek, Canje, and Kaieteur Blocks.”
It is unclear as to whether reason No. 2 – “similar campaigns” is referring to gathering of
environmental baseline information, or well drilling campaigns conducted elsewhere. In any case, the presence of baseline data is not sufficient reason to exempt activities with potentially significant risks from an Environmental Impact Assessment.
As the EAB considers objections and contemplates scheduling a hearing on this matter, please note significant omissions exist in the Project Description. These include but are not limited to:
• The location of the proposed activities. As you are aware, Section 36 as well as Section 11(1)(i)
of the Environmental Protection Act, requires an applicant to disclose the location of the
activities for which it is seeking an environmental permit. The Applicant proposes to drill and
perforate the seabed, emit toxic pollution to the waters and air, create centres of oil spill
risks, and surely would require an exclusion radius prohibiting other users at 12 unidentified
sites in Kaieteur Block. This block is some 13,500 km2, an area larger than the country of
Jamaica. The locations of the actual drill sites (GPS coordinates) are missing. These locations
are material to determining the significance of likely impacts on the natural environment as
well as other users, and whether an EIA should be required.
• The durations of each seabed perforation activity, season of the year when each will be
conducted, and how the noise of drilling and supply vessel activities as well as toxic water and
air emissions could affect the migration and feeding habits of marine mammals as well as
commercially and ecologically important fish species. Given, that baseline surveys have been
completed, these must have characterised: the migratory and feeding behaviour of marine
mammals such as whales and dolphins; commercial fish migratory routes for spawning and
feeding at juvenile and adult stages; specific dependence of near shore and offshore fisheries
sector on these patterns and marine life; sensitive seabed locations with yet unstudied
biodiversity associations, including those with coral and non-coral reef habitats that can
potentially be impacted given seabed topography and currents affecting the perforated
areas, that could transport discharges to sensitive reef communities, etc. The Applicant must
surely be in a position to state the potential effects of its proposed activities in these areas.
• The purpose, scale, duration, specification, and possible effects of the seismic activities
mentioned on marine life.
• The essential shore-based activities that would support each seabed perforation exercise.
There is no information on shore-based service locations, types of activities, wastes
generated or that would be handled on shore, how they will be disposed, frequency of
movement of material to and from drill sites etc. The EAB would appreciate that the drilling
proposed offshore cannot occur without shore-based components. The complete set of
activities must be considered when determining the likely significance of impacts.
• Mention of other marine users that could be affected such as those involved in shipping,
fishing or stakeholders that could be impacted by land-based activities, including increased
frequency of helicopter traffic noise over residential areas, etc.
• Indication of potential types of risks, affected parties, measures in place for avoidance,
mitigation, compensation, and restoration for negative impacts specific to the identified
locations and durations of activities.
Indeed, one could not make the case better than the Applicant itself has done that (1) An impact
assessment is in fact needed; and (2) The EPA has been in no position to conclude that the likely
impacts would not be significant enough to warrant an EIA. In its Project Description (p.g. 13 Section 5.2.2. Risk Assessment and Hazards Recognition), the Applicant states clearly that Kaieteur Block drilling activities will have to be assessed “to identify potential hazards to personnel, facilities, the public, and environment.” Isn’t the purpose of an EIA to identify the hazards of an activity and whether and how they could be mitigated? Exhibit A is an excerpt of the Applicant’s full statement on this matter in its Project Document.

I trust that the EAB is committed to having a fair and equitable public engagement on this matter
and will endeavour to ensure that the EPA meets all statutory requirements for information provision prior to scheduling a public hearing.
Thank you for your kind attention.

Yours truly,
Simone Mangal-Joly
cc. Executive Director, Environmental Protection Agency

---

---