ENVIRONMENTAL MANAGEMENT CHALLENGES OF OIL DEVELOPMENT IN GHANA

1. ENVIRONMENTAL MANAGEMENT CHALLENGES OF OIL DEVELOPMENT IN GHANA

2. ENVIRONMENTAL MANAGEMENT CHALLENGES OF OIL DEVELOPMENT IN GHANA JONATHAN A. ALLOTEY ENVIRONMENTAL PROTECTION AGENCY P. O. BOX M.326 ACCRA  TEL : 662693 Email: jallotey@epaghana.org/jan_allotey@yahoo.com

3. Introduction: • The national petroleum organization, Ghana National Petroleum Corporation (GNPC) and her partners announced in June 2007, the discovery of light crude oil in commercial quantities in the offshore waters of Ghana’s continental shelf – named the Jubilee Field. • Since the initial discoveries, appraisal work conducted has estimated core reserves of oil at June 2008 of about one billion barrels by with substantial associated natural gas reserves.

4. The Ghanaian Coastline

5. Concerns: • The discovery raises a number of concerns which include: • the environmental impact of the development of the resources due to problems associated with petroleum development in other countries. • A legitimate question which requires an answer is: • How will Ghana develop and manage its petroleum resources and revenue streams in a transparent and environmentally responsible manner for the benefit of Ghanaians now and in the future?.

6. Impacts • There are negative impacts on ecosystems and Livelihoods at all stages of petroleum development – prospecting, exploitation, and transport from offshore production, maritime traffic, and terrestrial installation. • Direct impacts from project activities include national habitat fragmentation, pollution and accidents. • Indirect Impacts are triggered by projects presence include migration, destabilization of local economic, insecurity, opening access for other developments, conflicts with other activities, conflicts between companies and governments

7. Impacts cont’d • Negative impacts on environment may also impact people through lost of livelihoods of economic opportunities, communication, constraints, poverty increase and social changes. Negative long term impacts include: • Depletion of other sectors (fisheries, tourism, agriculture--) • Pollution (seas, mangroves, beaches…) • Reduction of food security • Conflicts • Waste of natural and economic resources

8. Fish Landing Site - Djomba

9. Key Challenges and Issues Environment Weak institutional capacity to manage the environmental, health and safety challenges posed by the petroleum sector. • Weak compliance and enforcement mechanism. • Absence of existing baseline data both offshore and onshore. • Absence of proper mechanisms for coordination and monitoring of petroleum related and induced activities. • Absence of logistics and capacity in managing oil and chemical spills. • Absence of systems for the disposal of hazardous wastes. • Inadequate data infrastructure to ensure timely information access an quick decision making. • Lack of capacity in petroleum sector related health and safety management

10. Health • Inadequate sanitation systems. • Inadequate health management system • Inadequate health personnel Safety • Inadequate standards and regulations • Inadequate navigational aids

11. Community • Management of high public expectations and responsibility of industry players. • Weak civil society organizations to play advocacy role on behalf of communities. • Absence of appropriate compensation regime for legitimately affected operation of the petroleum industry. • Potential conflict between petroleum operations and other sectors, eg. fisheries, marine, transport etc. • Inadequate capacity to deal with transboundary issues. • Inadequate human resource due to high staff turnovers and exodus of professionals in these areas

12. Measures to Address Concerns • Since the announcement of the discovery, a number of measures has been taken to meet the changes in the development of oil and gas resources: • Holding a national forum • Formulation of Fundamental Petroleum Policy for Ghana • Preparation of Ghana Petroleum Development Master Plan. The plan is to provide a road map for future development of oil, upstream gas, transportation and processing, proper generation and transmission and petrochemicals. • All these measures cover environmental aspects of petroleum developments. 

13. National Forum • The National Forum discussed potential problems and solutions. The environmental management of oil development was one of the issues discussed. Policy • The Fundament Petroleum Policy for Ghana, states that: • “Government shall promote sound and sustainable environmental practices in the management of petroleum operators and ensure compliance with national health and safety regulations and standards”. • The policy expects all players in the oil industry to recognize that • “Achieving excellence in environmental management, health and safety, and relating well with community in which it operates not only contributes to business results by safeguarding people and conserving resources, but also serves as a useful indicator of effective management systems”.

14. Preparation of Draft Master Plan The environmental component of the plan includes framework for mitigation, management, monitoring and institutional measures during petroleum resource development. • Long Term Vision The environment, health and safety and community issues component envisions ‘a petroleum sector that contributes to the present and future needs of the Ghanaian, while keeping a balance between economic development, environmental protection, social responsibility and safe and good conditions of work’.

15. Goal To mainstream environmental management, health and safety and communities into the petroleum sector operations. • The Master Plan is intended to provide the framework for rationally and systematic allocation of resources to address the potential impacts of the development of petroleum resources on the population and the environment. • One important component of the master plan is on environmental management, health and safety and community issues which are considered an integral part of the management of the petroleum resources of Ghana. • This component of the plan aims to minimize adverse environmental health and safety and social impacts of the petroleum resources development and maximize benefits to Ghanaians and other key stakeholders.

16. International Conventions and Agreements Ghana is signatory to a number of United Nations and Regional Cooperation Conventions and multi-lateral agreements which will help in managing environmental impacts. Some of these conventions include: • International Convention for Prevention of Pollution of the Sea by Oil London, 1954 (as amended in 1962 and 1969). • Convention on Fishing and Conservation of the Living Resources of the Seas, Geneva, 1958. • Convention on the Continental Shelf, Geneva 1958 • International Convention for the Conservation of Atlantic Tunas, Rio de Janeiro, 1966. • International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Casualties, Brussels, 1969

17. Convention on Wetlands of International Imperative Especially as Water fowl Habitat, Ramsar, 1971. • International Convention on the Establishment of an International Fund for Compensation for Oil Pollution Damage, Brussels 1971 and the 1976 Protocol. • International Convention for the Prevention of Pollution from ships and Protocl (MARPOL 73/78) • Protocol concerning cooperation in combating Pollution in cases of Emergency, Abidjan, 1981. • United Nations Convention on the Law of the Sea, Montego Bay, 1982. • Convention for cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region, Abidjan 1981.

18. National Policies and Legislation National Environment Policy • The environmental impacts of petroleum development can be handled within the framework of the National Environmental Policy (NEP) which has the ultimate aim : • “To ensure sound management of the environment and the avoidance of exploitation of resources in ways that may result in irreparable damage to the environment” • Some of the principles relevant in this regard are : • Use of most cost-effective means to achieve environmental objective. • Use of incentives in addition to regulatory measures. • Delegation of decision-making and action to the most appropriate level of government.

19. Polluters pays for the cost of preventing and eliminating pollution and nuisances caused by him. • Public participation in environmental decision-making. • International cooperation. The Policy puts emphasis on prevention and sustainable development through objectives which seek to : •  Maintain ecosystems and ecological processes essential for the functional of the biosphere.

20. Adequately protect humans, animals and plants, their biological communities and habitats against harmful impacts and destructive practices and preserve biological diversity. • Guide development in accordance with quality requirements to prevent, reduce and as far as possible, eliminate pollution and nuisance. • Ensure sound management of national resources and the environment. •  Integrate environmental considerations in sectoral, structural and socio-economic planning at the national, regional, district and grassroots levels.

21. Legislative and Regulatory Framework • The Environmental Protection Agency Act 1994, Act 490 and the Environmental Assessment Regulations 1999, LI 1652 provides the legal and regulatory mechanisms for ensuring adequate safeguards are incorporated into planning and development of any activity that has the potential to cause significant environmental impacts. • The Environmental Protection Agency is primarily responsible for regulating the environment and ensuring the implementation of Government policies on the environment. The functions of the Agency as stipulated in Act 490 include:

22. Issues environmental permits and pollution abatement notices. • Prescribe environment standards and guidelines. • Ensure compliance with any laid down environmental impact assessment procedures. • Develop a comprehensive database on the environment. • Co-ordinate with relevant institutions. • Monitoring and compliance enforcement under Environmental Assessment

23. Under the Environmental Assessment Regulations LI 1652, environmental impact assessment (EIA) is required for all new undertakings (project level). For which a permit is issued prior to commencement for oil and gas development experience will be drawn from handling major projects in mining, energy and transportation. • A number of existing environmental management tools applied at different phases of project development:

24. Strategic Level • Strategic Environmental Assessment is applied to policies plans and programmes to mainstream environmental issues to ensure sustainable development. • Project Development Phase. • Environmental Impact Assessment • Project Operations Phase • Environmental Management Plans • Environmental Monitoring Plans • Environmental Performance Rating Disclosure (Akoben Scheme) • Oil Spill Contingency Plans • Project Closure • Decommissioning and Closure Plans • Reclamation Bonds (for extractive industries)

25. National Oil Spill Response Systems (National Spill Contingency Plan) • The Agency realizing the susceptibility of the country to the risk of oil spill due to the transport of oil from surrounding countries to Europe, initiated measures in 1986 to develop a National Oil Spill Contingency Plan. The Plan provides the framework for coordination of an integrated response, definition responsibilities, reporting and alerting procedures and means of communication, training and exercises, equipment etc. • Environmental Sensitivity Map of the Coastline of Ghana. The Agency has developed environmental sensitivity indices along the coast of Ghana. This will help in determination of action required in the event of oil an spillage.

26. Environmental Sensitivity Maps • GIS Based • Covers the Whole Coastline • 96 Maps in the Atlas • Main Features & Ranking • Coast type • Economic • Ecological

27. A Very High Risk Area

28. Low Risk Area

29. High Risk Area – Turtle Nesting Site

30. Way Forward • To complement and augment the limitations of the current environmental framework and management tools, the following is required. • Development of petroleum industry specific environmental protection guidelines and appropriate regulatory infrastructure, including monitoring equipments, compliance enforcement networks and also a sanctions regime. • Development of national emergency response capacity for spills, blowers Explosions, fires, natural disasters etc.

31. Way Forward cont’d • Development of proper consultations and partnerships with local communities in relation to proper environmental management and proper settlement development planning to accommodate requirements and changes induced by the petroleum industry. • Support the environmental management framework in terms of capacity building equipments standards, management system sanctions and enforcement, reviews and permitting. • Decommissioning and rehabilitation and after care guidelines and agreements. • Conduct of strategic environmental assessments of the oil industry

32. References • Fundamental Petroleum Policy for Ghana, June 2008 • Task Team on Environmental Management. Health and Safety and Community Issues. October 2008 – Final Draft of Environmental Management, Health and Safety and Community Issues Component of the Ghana Petroleum Development Managements. • Garreau J. – 2008 – ‘Oil and Gas Environmental Management: Towards a Balanced ‘People, Plant, Profit Approach’ – Paper prepared at Ghana national Forum on Oil and Gas 25-29 February 2008. • Environmental Protection Agency Act, Act 490 1994 Part I • Environmental Assessment Regulations, 1999 – LI 1652 • Allotey J.A. 2008 – Application of Ghana’s Environmental Policies and Regulations to Oil and Gas Development. Paper presented at the Ghana National Forum on Oil and Gas, 25-29 February 2008

33. THANK YOU