Environmental Impact Assessment Of Jubilee Field And Matters Arising

By: Richard Ellimah

The public hearings which are a mandatory part of the processes towards securing a permit to start oil drilling are almost over. At least, all the oil affected districts – Jomoro, Ellembele, Nzema East, Ahanta West, Shama and Sekondi-Takoradi – have had the opportunity to interrogate the Environmental Impact Assessment (EIA) of Tullow Oil and her partners.

Judging from press reportage of the hearings, some critical issues need addressing. First of all, it is obvious that people within the six districts that will be affected barely have enough information about the oil that has been discovered close to them. They therefore are incapable of participating in processes that would help them deal with any possible impacts that will occur. The information they have does not go beyond the rudimentary chorus of “Ghana has discovered oil”. Information is absolutely necessary to enable affected people make crucial choices. Absence of information produces half-truths. As people who will suffer potential impacts of the oil industry, they have a democratic right to information. For instance, to what extent has the district assemblies been updating communities on the impacts of the oil discovery to enable a more coherent response to be prepared? Already, fisher folk in these districts have started suffering some impacts. They have been instructed to steer clear of a particular radius of the oil rig. Incidentally, all the fish appear to have taken cover in areas close to the rig, making it difficult for the fishermen to get them without incurring the displeasure of the navy that patrols our territorial waters.

Furthermore, the public hearings have re-opened debate about environmental impact assessments. Judging from what happens in the mining sector, these are highly technical reports which even the average educated person cannot read and understand, let alone interrogate. The Non-Technical Executive Summary alone of the Jubilee Field EIA is 62 pages. Public hearings are supposed to be an avenue for the oil companies to tell the people how their operations will impact them and the measures that have been proposed to deal with these impacts. At these hearings, the public can question portions of the report that, in their opinion, are unsatisfactory and proceed to make inputs into it. These inputs are then taken onboard in the design of an Environmental Management Plan which the companies are expected to submit to the Environmental Protection Agency (EPA). Unfortunately because capacity is low at the local level, the public most times, make little or no inputs at all into the process. Sometimes, the few educated people may also raise issues which are either over-blown because they have not had time to look at the report and make informed comments, or simply make comments out of ignorance. Probably this calls for a review of the design process of the EIA so that it can be disseminated to community groups in a language they understand, over a period of time so that they will be fully armed to question the process. These one-day public hearings where uninformed people are expected to comment on technical documents do not help. One is tempted to describe the process as being only cosmetic. Simplifying the process is critical to enlightening affected people on the potential benefits and problems. When actual drilling begins, they would therefore have been armed and well prepared for the impacts.

Another major concern is the over-concentration of all activities in the Sekondi-Takoradi Metropolis. Curiously, all literature about the oil find acknowledges Takoradi as potentially the most impacted community. Indeed, the non-technical executive summary of the EIA of the Jubilee Field only acknowledges Takoradi Metropolis and Shama District as the most impacted communities. A comprehensive population profiling has been done for these two communities in the document, curiously leaving out the three Nzema Districts and Ahanta-West District. Though attempts have been made to address this in the main technical document, it is still not enough to assuage this unpardonable error. At this stage of project development, it is dangerous to give any group of people the impression that they are being marginalised. As a result of the undue emphasis on Takoradi and Shama District, interventions have been narrowly designed to address their socio-economic problems. It is undisputable that Takoradi is the major urban centre with all the facilities and services that can support the industry. It also does not take away the fact that other satellite communities need to be developed. The best way to do this is to re-locate some of the functions and activities concentrated in Takoradi to communities like Axim, Essiama, Agona Nkwanta and Half-Assini. This, apart from decongesting the Metropolis will also lead to a spread of infrastructural development in the other districts. This requires a concerted policy direction from government to address the imbalances in settlement development in the region.

The oil companies have committed themselves to undertaking rigorous corporate social responsibility (CSR) as a way of ameliorating the impact of their activities on the communities. There is no doubt that oil drilling will have some socio-economic and environmental impacts, though much of the drilling will take place offshore. Designing a comprehensive, community-sensitive and coordinated corporate social responsibility programme will go a long way to help. Historically, CSR has been a voluntary initiative by industry. Current practice has called for a radical review of the way CSR is conceptualised. For instance, in the mining industry CSR has been used as a balm for soothing community demands for fairness in their dealings with the mining companies. More often than not, companies have undertaken social responsibility projects more as a deliberate attempt at boosting their corporate image rather than a genuine effort to address community concerns about their operations. To make it more practical and relevant, I propose that legislation on social responsibility should be passed. Like happens in the forestry sector, companies wishing to undertake oil exploration and drilling should be compelled to sign social responsibility agreements with their catchment communities. This initiative will serve two purposes. Firstly, it will ensure bottom-up development planning by encouraging the fullest participation of ordinary community people in deciding what kind of development they want. Doing this will ensure that resources are channelled to areas where they are specially needed. Besides legislating CSR in the oil sector, there is also the need for a more coordinated approach to providing projects within the oil catchment areas. The district assemblies in these areas should not under any circumstances be sidelined in the provision of CSR. I propose that every CSR endeavour must find space in the Medium Term Development Plans of the district assemblies. This way, development will be better coordinated and ensure that resources are channelled to priority areas of development.

The other concern that the EIA presents is the human resource requirement for the project. According to the report, 760 people will be employed in the initial development phase of the project. This figure will however, drop to 300 during actual drilling. My concern is not with the number but the fact that 50 percent of this 300 will be expatriates before the percentage drops to 10 percent within four to eight years. What this effectively means is that between 4 – 8 years of the project life, only 150 Ghanaians can be employed in the oil business. The 50 percent expatriate participation is extremely high considering that Ghana has enough capacity to handle some of the middle-level positions that the companies will be requiring. The Ghana National Petroleum Corporation (GNPC) that has been in the oil business for more than 20 years has enough trained Ghanaians who can handle any position in the companies. Some of these Ghanaians have even supported the oil sector of countries like Qatar, Gabon, Angola, Nigeria, United Arab Emirates and Mozambique. We do not need to wait for eight years to put Ghanaians in positions where their expertise can be utilised.

Finally, there is the absolute need for transparency in the oil industry. Transparency here does not only refer to revenues that will accrue to government and other stakeholders but also includes transparency in terms of the disclosure of the content of all agreements our governments have signed with the companies. Full disclosure will clear doubts that the country’s interests have been sacrificed for a pittance. This is where civil society groups must be more proactive. They should not wait for these agreements to be signed and operationalised before raising the red flag. Right from the beginning they should engage the stakeholders to ensure that the country is not short-changed.

Ghana cannot afford the luxury of waiting for another generation to correct mistakes that it has committed in the prudent management of her resources. Next door neighbour Nigeria has a lot to teach us about what can happen if the right structures are not put in place in the management of oil. If Nigeria is too extreme an example, let us consider what over a century of mining has done to the country.

The author is a Development Practitioner and resides in Obuasi. He can be reached on Post Office Box UPO 853, KNUST-Kumasi; or on telephone 0244-514559; and by email on richellimah@yahoo.com.