Open letter to EPA on lack of regulatory mechanism for offshore oil & gas industry in Guyana

May 30, 2025 Letters

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Dear Editor,

On April of 2025, General Manager of Pritipaul Singh Investments (PSI), Pritipaul Singh, reported a 77% decline in fish catches and revenue by his company since 2019 and a reduction in profits since the operator of the Stabroek Block, ExxonMobil Guyana Limited (EMGL), commenced oil production in 2019.

PSI reported owning 107 fishing vessels equipped with food, fuel and other supplies for the fishermen and prior to oil production, fisherfolk spent three to four days offshore but this has increased to as much as 15 days at sea and exports have decreased from 20 containers to 2 containers a month.

In 2022, Professor at the University of British Columbia, Dr. Janette Bulkan pointed out that ExxonMobil and other operators are being “given free rein” by the Guyanese Government to dominate the country’s marine space, superseding the legal and customary rights of fishers, resulting in a decline in fish catches affecting approximately 5,000 fisherfolks. According to Dr. Bulkan, EMGL activities in Guyana’s Exclusive Economic Zone (EEZ) are contributing to not only low catches but also disrupting the vibration routes of the fish, shrimp and large marine mammals including Red Snapper, Trout, Bangamary, Seabob and Shrimp.  Guyanese would be “naïve to think that there is no impact on marine life, sea life within our ocean,” when tonnes of toxic waste being discharged into the ocean.

Dr. Vincent Adams, former head of the EPA in 2023, revealed that while he was head of the EPA, the Payara environmental permit required that produced water be reinjected back into the reservoir. With a change of Government and the non-renewal of Dr. Adams’s contract, this requirement was removed and produced water was once again allowed to be dumped into the ocean. Dr. Adams also calculated that because of the permitted oil in produced water, 29 to 40 barrels of oil are being discharged into the ocean for every million barrels of produced water.

Considering the 77% reduction in fish exports reported by PSI, the reduction in fish catches by artisanal fisherfolk and the tonnes of discharges, and chemicals used by EMGL the concerns below are even more relevant:

1. EMGL operations expose the lack of an established regulatory mechanism in Guyana for many waste materials and chemicals associated with offshore oil and gas production. After approximately five years of operation, Guyana as a country has failed to pass legislation and adequate regulations for standards to which oil and gas companies can be held legally accountable, neither has it developed independent ability to monitor and ensure safe practices and failed to produce verifiable monitoring information.
2. In the absence of the Guyana’s lack of capacity, EMGL enjoys the role of both operator and regulator with wide discretion for voluntary industry standards that do not often adhere to the stringent protection standards of international guidelines.

 

3. Produced water is typically the largest effluent by-product from oil & gas operations and is regarded as a high-volume toxic waste. According to leading authorities on oil and gas including OSPAR (The Convention for the Protection of the Marine Environment of the North East Atlantic), the most environmentally sound system for produced water is re-injection back into an appropriate reservoir or well. OSPAR sets the goal for produced water as follows- they “should ensure that plans to construct new offshore installations, or to modify substantially existing offshore installations should take as a point of departure the minimization of discharges and … the achievement of zero discharges of oil in produced water.” Additionally, according to OSPAR’s produced water discharges from offshore oil and gas installations 2009-2019 – “since 2009, there has been a 16% reduction of dispersed oil discharges in produced water ranging from 12.4 mg/L to 14.1 mg/L”.  Despite this, EMGL’s standards for the oil in produced water discharges continues to be a daily maximum of 29 mg/L and monthly average of 42ml.

 

4. EMGL and the EPA also fail to use updated and relevant information for the analysis of impacts and risks. For example, samples of produced water should be taken, analysed and characterized to determine radionuclide activity, suspended solids, oil ratio, PHA and chemicals and this should be publicly available. Five years into ExxonMobil/EEPGL production, there is still a lack of relevant data even though four (4) oil projects are in production and an additional three (3) others are being approved and planned.
5. Despite the vast quantities of chemicals that are to be used in offshore oil and gas operation, there is no chemical use and monitoring plan in place for drilling fluids and other production chemicals in keeping with international best practices, including OFC, World Bank, OSPAR and IOGP guidance. Such a plan should not only quantify but assesses the environmental risk of each chemical used or proposed to be used during the entire life of the project – exploration, drilling, production, and decommissioning of wells. This is a glaring and unacceptable gap. Additionally, only approved chemicals should be used, but Guyana’s regulatory agency the EPA seems to not only lack the expertise but also the regulatory systems to do this. Chemicals should be tested for toxicity, bioaccumulation, and biodegradability by the EPA. https/www.ospar.org
6. Naturally Occurring Radioactive Material (NORM) wastes have not being giving sufficient attention in EMGL’s operations. This is even more alarming as exposure to radiation and radiation hazards is one of the most harmful hazards to the health of humans and the environment even in small doses. Levels of radionuclides toxicity also tend to increase the older the offshore wells.

 

7. Hydrocarbon contaminated solids/sand from production, contaminated brine, mercury equipment and NORM contaminated solids, waste mineral oil drilling additives lack EPA hazardous regulations. These are all major hazardous wastes and should have written EPA regulations, but without waste profile sheets it appears this data is not being collected and categorized for the past 5 years.
8. The sheer volume of hazardous discharges into Guyana’s ocean are not well known. Daily discharges from produced water from Liza 1, Liza 2 and Payara adds up to 18,750 bpd (barrels per day), 562, 560 bpd for 30 days and 6,750, 720 bpd per year. Based on Dr Adams calculations that for every millions of barrels of produced water 29 – 40 barrels of oil will be discharged into Guyana’s ocean, a total of 174 to 240 – barrels of oil are being dumped into Guyana’s aquatic environment every year with the produced water. If we calculate for 4 years, this adds up to 696 – 960 barrels of oil.

 

Recommendations:

• The EPA should stop processing permits for new offshore oil and gas production until Guyana as a country has both the legal and technical capacity in place to manage impacts and regulate the industry.
• The Data Visualization Centre of the Petroleum Institute together with the EPA needs to expand its data collection to include oil not only in produced water daily/ monthly but data on bilge water discharged in Guyana’s marine environment and which include oil residues and other hazardous wastes, data on drill cuttings including water based and non-aqueous drilling fluids on drill cuttings discharged to the seabed and quantities of chemicals used and discharged into Guyana’s marine environment. This must also be made available publicly and in a user-friendly format.
• The EPA should develop waste profile sheets for Naturally Occurring Radioactive Materials NORM wastes and all other wastes as indicated in paragraphs 7 and 8.
• The EPA must develop a chemical use and monitoring plan in place for all chemicals used in its operations in keeping with international best practices and which assesses the environmental risk of each chemical used during the entire life cycle of oil & gas exploration, production and decommission in Guyana.
• We remind the EPA and EMGL of their responsibility to guarantee and ensure the constitutional rights of Guyanese to a safe and healthy environment (article 149), the duty of citizens to participate in activities for the improvement of the environment & to protect the health of all Guyanese (article 25) and the right to access environmental information, right to public participation in environmental matters, right to a healthy environment, safe and enabling environment for environmental defenders, free from threats, restrictions, and protection and promotion of environmental defenders in environmental matters (Escazu agreement). A similar submission was sent to the EPA re UARU’s EIA with a request for an EAB hearing before an environmental permit was issued to EMGL. No response was ever received from the EPA.

Yours sincerely,

Danuta Radzik

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