figure 1.5 ricerca e cooperazione, accra, 20 october 2011 · 1.6 fpso prevents fish from following...

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TWENEBOA, ENYENRA NTOMME (T.E.N.) DEVELOPMENT 00002-E78-ES-RPT-0005 REV0 SCOPING REPORT AND TERMS OF REFERENCE 20/1/2012 C3-3 Figure 1.5 Ricerca e Cooperazione, Accra, 20 October 2011 Figure 1.6 Western Region Environmental protection Agency, Sekondi, 21 October 2011

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Page 1: Figure 1.5 Ricerca e Cooperazione, Accra, 20 October 2011 · 1.6 FPSO prevents fish from following ... 2.11 EIA should consider lessons learnt from ... projects in other Districts

TWENEBOA, ENYENRA NTOMME (T.E.N.) DEVELOPMENT 00002-E78-ES-RPT-0005 – REV0 SCOPING REPORT AND TERMS OF REFERENCE 20/1/2012

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Figure 1.5 Ricerca e Cooperazione, Accra, 20 October 2011

Figure 1.6 Western Region Environmental protection Agency, Sekondi, 21 October 2011

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Figure 1.7 Sekondi Takoradi Metropolitan Assembly, Sekondi, 21 October 2011

Figure 1.8 Ghana Ports and Harbour Authority, Takoradi, 21 October 2011

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Figure 1.9 Chief Fishermen of the Western Region, Takoradi, 22 October 2011

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Figure 1.10 Ahanta West District Assembly, Agona-Nkwanta, 24 October 2011

Figure 1.11 Ghana Tourism Board, Takoradi, 24 October 2011

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Figure 1.12 Ellembelle District Assembly, Nkroful, 25 October 2011

Figure 1.13 Nzema East Municipal Assembly, Axim, 25 October 2011

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Figure 1.14 Jomoro District Assembly, Half Assini, 26 October 2011

Figure 1.15 Ghana Conservation Society, Accra, 11 November 2011

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Figure 1.16 Friends of the Nation and Coastal Resources Centre, Sekondi, 26 October 2011

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Figure 1.17 Western Region Chiefs and Media, Sekondi, 27 October 2011

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Figure 1.18 Western Region Chiefs and Media, Sekondi, 27 October 2011

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Figure 1.19 Shama District Assembly, 24 November 2011

Figure 1.20 Western Region Fisheries Commission, 30 November 2011

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Annex D

Issues Trail

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Table1 Issues Trail for Scoping Consultations

# Issue Organisation

1. Interaction with Fishers and Fishery

1.1 Tension created between fishermen and Ghana navy / security personnel due to fishing in and around safety zone as fishermen

Environmental Protection Agency (EPA), Accra

Ellembelle District Assembly (EDA) Ghana Navy Marine Fisheries Research division (MFRD) Ghana National Canoe Fishermen Council

(GNCFC) National Fisheries Association of Ghana

(NAFAG) Friends of the Earth / Coastal Resources

Centre Nzema East Municipal Assembly (NEMA) Guinea Current Large Marine Ecosystem

(GCLME) Ghana Maritime Authority (GMA) Coastal Resources Centre – Ghana Fisheries Commission Western Region Fisheries Commission

(WRFC) Shama District Assembly (SDA)

1.2 Effect of project on reduction in fish catch rates

Ahanta West District Assembly (AWDA)

1.3 Seaweed substance in waters and coming on shore and hindering fishing activities. What can be done to remove it?

Environmental Protection Agency, Sekondi Ahanta West District Assembly (AWDA) Chief Fishermen of Western Region (CFWR) Jomoro District Assembly (JDA)

1.4 More frequent consultation of fishermen may help relieve some tensions about the safety zone as well as direct dealings with fishermen not those with higher authority

Environmental Protection Agency (EPA), Sekondi

Chief Fishermen of Western Region (CFWR) Ghana National Canoe Fishermen Council

(GNCFC) Fisheries Commission

1.5 Demarcation of safety zone to ward off fishermen

Jomoro District Assembly (JDA) Ghana National Canoe Fishermen Council

(GNCFC)

1.6 FPSO prevents fish from following natural annual migrations from west to east

National Fisheries Association of Ghana (NAFAG)

1.8 How does TGL intend to handle the notion held by fishermen that the FPSO attracts all the fish thus depriving them of catch

Sekondi Takoradi Metropolitan Assembly (STMA)

Friends of the Nation

1.9 Need for comprehensive Fisheries Impact Assessment for T.E.N.

Fisheries Commission Marine Fisheries Research division (MFRD) Chief Fishermen of Western Region (CFWR) Ellembelle District Assembly (EDA) Western Region Fisheries Commission

(WRFC) 1.10 Suggestions that developments in aqua /

mariculture may help fish stocks to recover

Guinea Current Large Marine Ecosystem (GCLME)

Fisheries Commission

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# Issue Organisation

1.11 Suggestion that an independent cost-benefit analysis of the oil industry and fisheries sector should be undertaken

Wassa Association of People Affected by Mining (WACAM)

1.12 Thinning out of fishermen will not work immediately as they will just return

Fisheries Commission

1.13 Concern that increased oil and gas support vessel movement will destroy fishing nets

Western Region Fisheries Commission (WRFC)

2. Consultation / Communication / Disclosure

2.1 Not all community members consulted for Jubilee Phase 1 EIA, hope for T.E.N. EIA to include all stakeholders

Ahanta West District Assembly (AWDA)

2.2 Public hearings should be made mandatory

Ahanta West District Assembly (AWDA) Jomoro District Assembly (JDA)

2.3 Hard copy of EIAs (including T.E.N.)

requested to assembly when completed Ahanta West District Assembly (AWDA)

2.4 How will stakeholder comments be addressed?

Friends of the Earth / Coastal Resources Centre

2.5 Suggest that a simplified version of EIA document devoid of technical expressions is prepared and given to the people. Summaries and key findings document would be useful

Friends of the Earth / Coastal Resources Centre

2.6 Complaint desk – Concerns that the TGL it is sited at Nkroful which is a long way for fishermen to travel. Complaint desk enables a two-way communication flow.

Chief Fishermen of Western Region (CFWR) Friends of the Earth / Coastal Resources

Centre

2.7 Request for a sustainable dialogue between operators and local communities to respond to issues and for communication of information.

Friends of the Earth / Coastal Resources Centre

2.8 The T.E.N. development BID was not received early enough. Some stakeholders were not consulted as a consequence.

Nzema East Municipal Assembly (NEMA)

2.9 The BID should include some information on planned prevention measures and contingency plans

Ricerca e Cooperazione

2.10 Communication with fishermen through NAFAG more effective than through central government

National Fisheries Association of Ghana (NAFAG)

2.11 EIA should consider lessons learnt from Macondo deepwater oil spill in the Gulf of Mexico

Wildlife department, Forestry Commission Friends of the Earth / Coastal Resources

Centre

2.12 Advice stating that TGL should help to manage the expectations of locals

Sekondi Takoradi Metropolitan Assembly (STMA)

2.13 Wider stakeholder consultations should be undertaken. Would more be undertaken?

Wassa Association of People Affected by Mining

Ellembelle District Assembly (EDA)

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# Issue Organisation

2.14 EPA should have been part of the consultations

Ellembelle District Assembly (EDA)

2.15 Request that the EIA team consult with the Ghana Museums and Monuments board and Tourism Board

Ricerca e Cooperazione

2.16 T.E.N development should not be executed without the full involvement and consideration of the plights of fishermen

Fisheries Commission

2.17 What would happen if the EPA rejects the EIA?

Western Region House of Chiefs (WRHC)

2.18 Requested more interaction between fishermen, government and oil and gas companies to disclose information about ongoing activities and discuss other issues

Western Region Fisheries Commission (WRFC)

2.20 Lack of interaction between TGL and the Fisheries Commission. Requests for ongoing consultation with the Commission.

Western Region Fisheries Commission (WRFC)

2.21 Confusion over the need for an EIA when and EIA had been done for the Jubilee Field which is geographically similar

Shama District Assembly (SDA)

2.22 Have any waste management companies been contacted in the EIA process?

Shama District Assembly (SDA)

3. CSR and Commitments

3.1 Concerns that TGL had not fulfilled promises made in Jubilee EIA. Requests that TGL honour their promises

Nzema East Municipal Assembly (NEMA) Chief Fishermen of Western Region (CFWR) Friends of the Earth / Coastal Resources

Centre

3.2 Boreholes which were constructed in the coastal districts - not functional

Ahanta West District Assembly (AWDA)

3.3 Why has Tullow not appointed a Fisheries Liaison Officers(s)?

Friends of the Earth / Coastal Resources Centre

Western Region Fisheries Commission (WRFC)

3.4 People of the Western Region do not

experience any benefits from the industry which causes discontent

Fisheries Commission Ricerca e Cooperazione District assemblies

3.5 Why are Tullow implementing CSR projects in other Districts and not our District?

Nzema East District Assembly (NEDA) Ahanta West District Assembly (AWDA)

3.6 Call for coordination between Tullow and respective District Assemblies on implementation of CSR projects

Friends of the Earth / Coastal Resources Centre

4. Education and Training

4.1 Concern about the training of youths. Why do they not get the jobs promised? Qualifications offered by training institutions not recognised.

Ahanta West District Assembly (AWDA) Ellembelle District Assembly (EDA) Jomoro District Assembly (JDA)

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# Issue Organisation

4.2 TGL to roll out capacity building programmes including workshops and seminars for assembly members to improve skills so that they can engage for effectively.

Ahanta West District Assembly (AWDA)

4.3 Need for scholarships to be given to children of fishermen in the district to educate children. Scholarships should be sent to education office to select the right beneficiaries.

Ellembelle District Assembly (EDA) Chief Fishermen of Western Region (CFWR) Jomoro District Assembly (JDA) Shama District Assembly (SDA)

4.4 Communities should be educated in the decline of fish stocks and made aware that it is not because of the oil industry to avoid future conflict

Friends of the Earth / Coastal Resources Centre

4.5 Training of youth should not just be in the oil and gas sector as there are no enough job in the oil and gas sector

Nzema East Municipal Assembly (NEMA)

4.6 Concerns about education with scholarships, social security etc

Nzema East Municipal Assembly (NEMA)

4.7 Education of fishers would help with enforcement of safety zone as fishermen would be aware of the hazards associated with their activities around the FPSO and disperse some of the issues.

Ghana Navy (GN) National Fisheries Association of Ghana

(NAFAG) Ghana National Canoe Fishermen Council

(GNCFC)

4.8 Suggestions for some form of financial aid be injected into the adult education programme already in place by the Ministry of Education

Ellembelle District Assembly (EDA)

4.9 Providing youth with better education and opportunities could help with alternative livelihoods to fishing

Marine Fisheries Research division (MFRD) Ghana Maritime Authority (GMA)

4.10 Raising awareness and consultation with the fishermen would help disperse some of the issues

Guinea Current Large Marine Ecosystem (GCLME)

Friends of the Earth / Coastal Resources Centre

Fisheries commission

4.11 Investment in education of technical skills may make local people more employable

Ricerca e Cooperazione

4.12 Chiefs need to be consulted in the selection of youth to be trained

Western Region House of Chiefs (WRHC)

5. Employment

5.1 Concerns over employment and TGL employing people from outside the region and/or Country

Jomoro District Assembly (JDA) Ricerca e Cooperazione

5.2 Preference should be given to employing people from the Western Region.

District Assemblies

5.3 Suggested that Tullow manage expectation of people in terms of employment as few job opportunities exist the oil industry

Ellembelle District Assembly (EDA)

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# Issue Organisation

6. Waste Disposal / Discharges at sea

6.1 Concerns over what happens to drill cuttings and mud during well development. TGL should consider cleaned drill cuttings for alternative uses.

Chief Fishermen of Western Region (CFWR) Ghana Maritime Authority (GMA) Shama District Assembly (SDA)

6.2 Concerns about how waste is transported from the FPSO for disposal

Ellembelle District Assembly (EDA) Sekondi Takoradi Metropolitan Assembly

(STMA)

6.3 Concerns about discharges at sea and consequently the impacts on marine biodiversity

Nzema East Municipal Assembly (NEMA) Jomoro District Assembly (JDA) Western Region Fisheries Commission

(WRFC) Shama District Assembly (SDA)

6.4 Concerns about ballast water discharge and the effect of micro-organisms and on marine biodiversity. Needs to be addressed in EIA

National Fisheries Association of Ghana (NAFAG)

Guinea Current Large Marine Ecosystem (GCLME)

Friends of the Earth / Coastal Resources Centre

Chief Fishermen of Western Region (CFWR) Ghana Wildlife Society (GWS)

6.5 Does GPHA monitor ballast water discharge of vessels queuing in anchorage?

Ghana Ports and Harbours Authority (GPHA)

6.6 Concerns about the effects of the disposal of water produced during operation on marine biodiversity

Ellembelle District Assembly (EDA)

6.7

Request that waste management practices comply with international standards

Sekondi Takoradi Metropolitan Assembly (STMA)

6.8 Concern about the management of oil waste in the Jubilee and T.E.N. development and how TGL monitor vessels

Environmental Protection Agency (EPA) Sekondi Takoradi Metropolitan Assembly

(STMA)

6.9 Concerns about waste management and capacity of waste disposal contractors need to be enhanced to deal with waste from the T.E.N. or involving more waste disposal contractors involved

Environmental Protection Agency (EPA) Ghana Ports and Harbours Authority

(GPHA) Guinea Current Large Marine Ecosystem

(GCLME) Sekondi Takoradi Metropolitan Assembly

(STMA)

6.10

No mention in T.E.N. BID about expected volumes of wastes produced daily

Ricerca e Cooperazione

6.11 Request that EIA team consider waste management issues due to limited facilities available in Western Region

Ricerca e Cooperazione

6.12 Waste management companies need to work in conformity with international standards

Shama District Assembly (SDA)

7. Air Emissions

7.1 How will air emissions be mitigated to prevent associated health issues?

Jomoro District Assembly (JDA)

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# Issue Organisation

7.2 How far may the air emissions reach? Western Region House of Chiefs (WRHC)

7.3 Concerns of the effects of air emissions on birds? Mitigation measures need to be looked at

Ghana Wildlife Society (GWS)

7.4 Concern that air emissions is causing health problems such as rashes and swelling of eyes.

Jomoro District Assembly (JDA) Nzema East District Assembly (NEDA) Chief Fishermen of Western Region (CFWR) Shama District Assembly (SDA)

8. Oil Spills – Contingency Plans

8.1 Ghana Navy play a role in National Oil Spill and Contingency Plan (NOSCP) in regards to coordination of operation in the event of a spill and make their vessels available.

Ghana Navy (GN)

8.2 Concerns on how the EPA would make sure mitigation measures are binding on operator so that they would not be able to spill.

Ellembelle District Assembly (EDA)

8.3 Concerns over the impact of a potential oil spill on marine and coastal fauna especially with regard to coastal RAMSAR sites.

Wildlife department, Forestry Commission

8.4 Need for a comprehensive contingency plan for oil spills which clearly details different roles

Ghana Ports and Harbours Authority (GPHA)

Environmental Protection Agency (EPA) Chief Fishermen of Western Region (CFWR)

8.5 Oil spills and their impacts, should be adequately addressed in the EIA

Guinea Current Large Marine Ecosystem (GCLME)

Ricerca e Cooperazione

8.6 Concerns about the effect of potential oil spill on fishermen

Ghana National Canoe Fishermen Council (GNCFC)

Guinea Current Large Marine Ecosystem (GCLME)

8.7 Suggestions that a percentage of oil

revenue reserved as part of an oil and gas fund to assist the fishery in this event.

Ghana National Canoe Fishermen Council (GNCFC)

8.8 Although the project is located offshore coastal sites could be impacted in the event on an oil spill.

Ricerca e Cooperazione

8.9 How far would a potential oil spill reach?

Western Region House of Chiefs (WRHC)

8.10 What is the capacity of TGL to respond to oil spill hazards?

Chief Fishermen of Western Region (CFWR) Shama District Assembly (SDA)

9. Compensation

9.1 Compensation to fishermen from TGL in the worst case scenario oil spill.

Chief Fishermen of Western Region (CFWR) Jomoro District Assembly (JDA)

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# Issue Organisation

9.2 There is no contingency plan for managing emergencies such as oil spills, fires etc

Sekondi Takoradi Metropolitan Assembly (STMA)

9.3 Some NGOs and all fishermen in the region demanding for a clear compensation package for fishermen and local communities

Friends of the Earth / Coastal Resources Centre

Environmental Protection Agency (EPA) Marine Fisheries Research division (MFRD)

9.4 Local people are losing land to GNPC without proper compensation

Wassa Association of People Affected by Mining (WACAM)

9.5 Effects of air emissions on people. What will be done for them in terms of compensation?

Ellembelle District Assembly (EDA)

10 Production and revenue

10.1 Production capacity of T.E.N. development

Marine Fisheries Research division (MFRD) Ahanta West District Assembly (AWDA) Western Region House of Chiefs (WRHC)

10.2

Would the district assembly also benefit directly for the tax revenue generated to the government

Jomoro District Assembly (JDA)

11. Impacts and Mitigation

11.1 Mitigation measures should be explicitly provided in the EIA and linked to implementation timeframes

Friends of the Earth / Coastal Resources Centre

Ellembelle District Assembly (EDA)

11.2 Mitigations must be separate from CSR Friends of the Earth / Coastal Resources Centre

11.3 Have TGL done any environmental

monitoring since their operation started?

Jomoro District Assembly (JDA)

11.4 Will Tullow implement an Environmental, Health and Safety Plan?

Guinea Current Large Marine Ecosystem (GCLME)

11.5 TGL to maintain and deal with service providers who have environmental approval / permits

Environmental Protection Agency (EPA)

11.6 Noise impacts should be considered

Shama District Assembly (SDA) Western Region House of Chiefs (WRHC)

11.7 Concerns over the age of the data usually used in the EIA. Implementation of independent environmental assessment and monitoring

Ghana Wildlife Society (GWS)

11.8 Suggestions that oil companies work in collaboration with the government to institute a program to build the capacity for effective offshore monitoring

Ghana Wildlife Society (GWS)

11.9 How does the EPA monitor limits of emissions and waste from FPSO operations?

Ellembelle District Assembly (EDA)

12. Alternative Livelihoods

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# Issue Organisation

12.1 Establishment of art and craft centre to train fishermen and fishmongers in artefacts production

Chief Fishermen of Western Region (CFWR)

12.2 Suggestions of alternative livelihoods for fishermen

Ghana Maritime Authority (GMA) Nzema East Municipal Assembly (NEMA)

12.3 EIA to address issues regarding capacity building for youth and adult alternative livelihood program

Nzema East Municipal Assembly (NEMA)

12.4 Farmers may be tempted to go into other businesses therefore less food would be grown

Ellembelle District Assembly (EDA) Nzema East Municipal Assembly (NEMA)

12.5 Alternative livelihoods need to be addressed in the EIA

Shama District Assembly (SDA)

13 Cumulative Impacts

13.1 Concern about the cumulative impacts of the project, other oil and gas activities, future activities and operational activities (eg Port)

Friends of the Earth / Coastal Resources Centre

Ellembelle District Assembly (EDA) Guinea Current Large Marine Ecosystem

(GCLME)

13.2 Ghanaians are concerned that oil activities could result in a similar situation to Nigeria

Marine Fisheries Research Division (MFRD)

13.3 Concerns about future developments and the cumulative impact on fishermen

Ghana National Canoe Fishermen Council (GNCFC)

14. Incremental Development and Increased Pressure on Infrastructure

14.1 GTB should have a say in regulating development in the Region to prevent developments in unsuitable locations

Ghana Tourist Board (GTB)

14.2 Concerns that the oil and gas industry is putting pressure on social services and amenities, port and port services and that the new project will increase pressure.

Friends of the Earth / Coastal Resources Centre

Ghana Tourist Board (GTB) Ghana Ports and Harbours Authority

(GPHA)

14.3 Increase in vehicle movements causing congestion

Ghana Tourist Board (GTB) Sekondi Takoradi Metropolitan Assembly

(STMA) Western Region House of Chiefs (WRHC)

14.4 High demand for short term accommodation

Ghana Tourist Board (GTB)

14.5 Rapid deterioration of roads due to the increase in heavy duty vehicular movement

Sekondi Takoradi Metropolitan Assembly (STMA)

Western Region House of Chiefs (WRHC)

14.6 Plans to expand Takoradi port to enhance port capacity and operations

Ghana Ports and Harbours Authority (GPHA)

14.7 Plans to redesign road network leading to and from the port and for a new railway system

Ghana Ports and Harbours Authority (GPHA)

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# Issue Organisation

14.8 The development of the oil industry is attracting further development to the Western Region

Ricerca e Cooperazione

14.9 Lack of developmental plans and controls poses a threat to the natural and cultural heritage of the region

Ricerca e Cooperazione

14.10 TGL should integrate its activities in the local economy to avoid inflating local prices

Ricerca e Cooperazione

15. Socio-economic effects

15.1 Negative social impacts associated with an influx of people into the region

Environmental Protection Agency (EPA) Western Region House of Chiefs (WRHC)

15.2 Socio-economic issues should be incorporated in the EIA

Guinea Current Large Marine Ecosystem (GCLME)

15.3 Development in the region has resulted in significant inflation of rental prices amongst others

Ricerca e Cooperazione Ghana Tourist Board (GTB) Ricerca e Cooperazione Western Region House of Chiefs (WRHC)

15.4 Need for an assessment of positive and negative impacts that are directly related to the evolving oil and gas sector within the past 2-3 years

Coastal Resources Centre (CRC)– Ghana Ricerca e Cooperazione

15.5 Security issues from influx of people to the region eg higher crime rates

Nzema East Municipal Assembly (NEMA)

15.6 Suggestions that health issues should be investigated and measures put in place to address issues

Ellembelle District Assembly (EDA)

16. Flaring

16.1 Concerns about the absence of a gas infrastructure – flaring would still go on

Nzema East Municipal Assembly (NEMA) Ellembelle District Assembly (EDA)

16.2 Is flaring currently occurring at the Jubilee? To what extent? Is it allowed in international circles?

Ellembelle District Assembly (EDA) Sekondi Takoradi Metropolitan Assembly

(STMA)

16.3 Will there be flaring in the T.E.N. development

Environmental Protection Agency (EPA) Marine Fisheries Research division (MFRD)

17. Emergencies and health Infrastructure

17.1 Hospitals in every district should be upgraded and well equipped to handle accidents and fire victims in the case of emergencies

Nzema East Municipal Assembly (NEMA) Jomoro District Assembly (JDA) Ellembelle District Assembly (EDA) Sekondi Takoradi Metropolitan Assembly

(STMA)

17.2 What would be the extent of the likelihood of an accident?

Western Region House of Chiefs (WRHC)

18. Jubilee field

18.1 EPA has not done much to disseminate monitoring information regarding the Jubilee and should have

Nzema East Municipal Assembly (NEMA)

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# Issue Organisation

18.2 Advice to TGL to strengthen local content policy

Nzema East Municipal Assembly (NEMA)

18.3 Complaint about Jubilee operators not consulting with GTB about licensing for vehicles

Ghana Tourist Board (GTB)

18.4 Are any challenges in the Jubilee production not known to the public?

Sekondi Takoradi Metropolitan Assembly (STMA)

18.5 Initial Jubilee report was too bulky and many communities members could not read or could not understand technicalities

Jomoro District Assembly (JDA)

19. Navigation and safety

19.1 EIA must address: Presence of small vessels

destroying fishing nets; Increased risk on sea due to

presence of oil companies Standby rescue equipment

made available

Chief Fishermen of Western Region (CFWR)

19.2 Concerns in the increase in vessel movements and the potential for accidents with artisanal fishing boats

Chief Fishermen of Western Region (CFWR)

19.3 Concerns over safety risks from piracy instances in Togo and oil bunkering at Exo Terra

Friends of the Earth / Coastal Resources Centre

Ghana Ports and Harbours Authority (GPHA)

Environmental Protection Agency (EPA)

19.4 Concerns for safety of staff in rough conditions when inspecting oil shuttle tankers

Ghana Maritime Authority (GMA)

20. Transboundary Issues

Transboundary issues to be well addressed in EIA

Nzema East Municipal Assembly (NEMA) Guinea Current Large Marine Ecosystem

(GCLME)

Any maritime boundary disputes will be dealt with by the boundary working group in Ghana before any issues arise

Ghana Navy (GN)

Will Transboundary issues be considered in the EIA?

Guinea Current Large Marine Ecosystem (GCLME)

21. Sea level rise and Coastal Erosion

21.1 Opinion that oil production would result in sea level rise and exacerbate the coastal erosion problem in the district

Jomoro District Assembly (JDA) Ellembelle District Assembly (EDA) Shama District Assembly (SDA)

22. Tullow operations

22.1 Possibility of TGL extending its operation into downstream oil activities?

Ellembelle District Assembly (EDA)

22.2 Why the T.E.N. names were given to the new fields as they do not portray anything from the region

Western Region House of Chiefs (WRHC)

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# Issue Organisation

22.3 Concern with the fact that people keep stating the oil find was in the western region but thoughts were that it was not exclusive

Ghana Wildlife Society (GWS)

23 Decommissioning

23.1 Any decommissioning plans for the T.E.N development

Ellembelle District Assembly (EDA)

24. International Conventions

24.1 Indications that the Government of Ghana will likely ratify 2 conventions (Control and management of ballast water and removal of wrecks)

Ghana Maritime Authority (GMA)

25. Positive Impacts

Further oil field development will result in more revenue and if a fund is set up more will be available for fishermen

Ghana National Canoe Fishermen Council (GNCFC)

26. Fauna and Flora

26.1 Concerns over wildlife hunting by expatriates in the Western Region

Wildlife department, Forestry Commission

26.2 Suggestions that the EIA should consider impacts of lighting on migratory birds and turtles

Wildlife department, Forestry Commission

26.3 Concern about safety of marine fauna for consumption

Nzema East Municipal Assembly (NEMA) Ghana Wildlife Society (GWS)

26.4 Suggestions that the EIA considers the impact of helicopter transit on important bird habitats

Wildlife department, Forestry Commission

26.5 Suggestions that marine mammal sightings should be recorded during the project. Is there information on cetacean migration routes?

Wildlife department, Forestry Commission

26.6 Concerns on the effect of oil activities on marine mammals in Ghanaian waters

Ghana Wildlife Society (GWS)

26.7 Will old baseline information be used for the project?

Friends of the Earth / Coastal Resources Centre

26.8 Suggestions that Tullow consider beneficiating biodiversity conservation initiatives

Wildlife department, Forestry Commission

26.9 Concerns that oil and gas activities have influenced marine mammal stranding in Ghana

Wildlife department, Forestry Commission Environmental Protection Agency (EPA) Ghana Wildlife Society (GWS)

26.10 Guidelines for biodiversity offsets are being developed for Ghana

Wildlife department, Forestry Commission

26.11 Algal bloom and sea weed on some beaches causing them to be unsuitable for leisure activities

Ghana Tourist Board (GTB)

26.11 Nansen fish biomass survey is routinely conducted to monitor fish stocks

Guinea Current Large Marine Ecosystem (GCLME)

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# Issue Organisation

26.12 Issue of independent monitoring of the effect of oil activities on marine biodiversity. Findings should be made available to the general public

Ghana Wildlife Society (GWS)

26.13 Concerns over the introduction of invasive species from vessels other than in ballast water (eg Indian Myna bird)

Ghana Wildlife Society (GWS) Western Region Fisheries Commission

(WRFC)

26.14 What will the effects of the Jubilee operations on marine biodiversity be?

Western Region House of Chiefs (WRHC)

26.15 Concerns on the lack of information on marine biodiversity and the impact of oil activities (especially on birds)

Ghana Wildlife Society (GWS)

27. Cultural Heritage

27.1 Western Region has a rich cultural heritage, requests that the EIA considers potential impacts on these sites

Ricerca e Cooperazione

27.2 Incremental development has negative impacts on cultural world heritage sites.

Ricerca e Cooperazione Ghana Tourism Board (GTB)

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Annex E

Impact Assessment Methodology

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E1 IMPACT ASSESSMENT METHODOLOGY

E1.1.1 Introduction

The impact assessment process will follow four main steps. 1. Prediction of what will happen as a consequence of project activities. 2. Evaluation of the importance and significance of any impacts. 3. Development of mitigation measures to manage significant impacts where

practicable. 4. Evaluation of the significance of the residual impact. Where significant residual impacts remain, further options for mitigation will be considered and impacts re-assessed to see if they can be reduced further within the context of what is technically feasible and cost-effective. The following sections describe the general principles that underpin the assessment approach.

E1.1.2 Impact Prediction

The impact assessment describes what will happen by predicting the magnitude of impacts and quantifying these to the extent practicable. The term ‘magnitude’ covers all the dimensions of the predicted impact to the natural and social environment including: the nature of the change (ie what resources or receptors are affected and the

size, scale or intensity of any changes); the spatial extent of the area impacted or proportion of the population or

community affected; its temporal extent (ie duration, frequency, reversibility); and where relevant, the probability of the impact occurring as a result of

accidental or unplanned events. Magnitude therefore describes the actual change that is predicted to occur in the resource or receptor (eg the area and duration over which disturbance of the seabed will occur; the degree of impact on the livelihoods of local fishermen; the probability (likelihood) and consequences in terms of accidental events). An assessment of the overall magnitude of an impact will, therefore, be provided that takes into account all the dimensions of the impact described above to determine whether an impact is of small, medium or large magnitude. The prediction will consider mitigation measures that were already an integral part of the project.

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The impact magnitude is also defined differently according to the type of impact. For quantifiable impacts, such as the produced water plume extent, numerical values can be used whereas for other topics (eg socio-economics) a more qualitative classification is necessary. The prediction takes into consideration any uncertainty about the occurrence or scale of the impact. The details of how magnitude will be predicted and described for each impact will be in the EIS. Some project activities will result in changes to the environment that may be immeasurable or undetectable or within the range of normal natural variation. Such changes can be regarded as having no impact or to be of negligible magnitude. The impact prediction also takes note of inter-relationships between different resources and receptors and the potential for secondary impacts (eg changes to water quality with impacts to marine fauna or impacts to air quality with impacts to human health). Aspects of the environment considered in the EIA, to the extent they may be applicable to the project, include the following. The physical environment includes: geology and sediments; coastal land;

marine water resources and air. The biological environment includes: marine habitats; flora and fauna;

biodiversity and protected areas. The human environment includes people and their resources; public

welfare, amenity; employment and incomes; business and economic activity, including tourism, fisheries, navigation and industrial/energy infrastructure; and sites and features of archaeological, historic, cultural or aesthetic interest.

E1.1.3 Types of Effects Addressed

The assessment will consider positive and negative impacts of the project on physical, biological and human resources and receptors. Negative (or adverse) impacts are those which are considered to present a

deterioration to the existing conditions or to introduce a new undesirable factor.

Positive (or beneficial) impacts are those which are considered to present an

improvement to the existing conditions or to introduce a new desirable factor.

The assessment considers the geographic scale of impacts as follows. Local – impacts that are limited to the T.E.N. development area or Takoradi

onshore base and the surrounding area.

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Regional – impacts that are experienced beyond the local areas to the wider region, eg Western Region or the Deepwater Tano block.

National – impacts that are experienced at a national scale. Transboundary/International – impacts that are experienced at an

international scale ie affecting another country. The assessment considers impacts in terms of duration being either temporary or permanent. Temporary impacts are predicted to be reversible and will return to a previous state when the impact ceases or after a period of recovery. These can be further defined as follows. Short-term - predicted to last only for the duration of the drilling or

installation operations (ie up to approximately two years). For example, flaring for well testing, construction vessel movements).

Medium-term - predicted to last from two years to the end of the project life

(ie 20 years). For example, footprint impacts of the offshore facilities, marine discharges).

Long-term - predicted to continue beyond the project life but will cease in

time (eg oil spill impacts on coastal habitats). Permanent impacts are predicted to cause a permanent change in the affected resource or receptor that endures substantially beyond the project lifetime (eg construction of new roads or buildings). Impacts can also be defined by their frequency: as follows. Continuous - occur continuously or frequently. Intermittent - occasional or occur only under specific circumstances (eg

during only a particular migratory season, or delivery of oversized loads by road transport).

The assessment includes direct impacts arising from activities associated with the project (primary impacts) and impacts that follow on as a consequence of these (secondary and higher order impacts) (for example increase cost of living due increased demand for good and services by growing oil and gas sector). The project will be taking place at the same time as other developments leading to impacts affecting the same resources or receptors, such that there will be cumulative impacts with the proposed project. The impacts on the existing environment of developments already operating will be, to the extent practicable, addressed in the baseline. The cumulative impact assessment will

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consider other existing development and any consented new plans, projects or proposals to the extent that they may be relevant. Finally the EIA will assess both: routine impacts resulting from planned activities of the project; and non-routine impacts arising from unplanned or accidental events within

the project.

E1.1.4 Quality/Importance/Sensitivity of Resources and Receptors

The significance of the impacts resulting from an impact of a given magnitude will depend on the characteristics of resources and receptors to that impact in terms of their quality, importance or sensitivity. For ecological resources importance or quality can be assigned as low, medium or high based on the conservation value (including protection status) of habitats and species and their ecosystem functions. For habitats these are based on factors such as naturalness, extent, rarity, fragility, diversity and importance as a community resource. For species, protection, conservation status and ecosystem role are considered. For socio-economic receptors, sensitivity is based on individuals’ ability to adapt to changes and maintain their livelihoods and health.

E1.1.5 Evaluation of Significance

Virtually all human activity imposes some disturbance to aspects of the natural and social environment because of physical impacts on natural systems or due to interactions with other human activities and human systems. To provide information to decision makers and other stakeholders on the importance of different project impacts an evaluation of the significance of each effect will be made by the EIA team. As there is no statutory definition of significance, the evaluation of significance in the EIA will be subjective. The evaluation of impacts presented in the EIA will be based on the judgement of the EIA team, informed by legal standards, national and regional government policy, current industry good practice and the views of stakeholders. Where specific standards are either not available or provide insufficient information on their own to allow grading of significance, evaluation of significance will take into account the magnitude of the impact and the quality, importance or sensitivity of the affected resource or receptor. The quality or importance of a resource will be judged taking into account, for example, its local, regional, national or international designation, its importance to the local or wider community, its ecosystem function or its economic value.

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The assessment of the sensitivity of human receptors, for example a fishing community or wider social group, will consider their likely response to the change and their ability to adapt to and manage the effects of the impact. Magnitude and quality/importance/sensitivity are looked at in combination to evaluate whether an impact is, or is not, significant and if so its degree of significance (defined in terms of Minor, Moderate or Major). Impacts classed as Not Significant include those that are slight or transitory, and those that are within the range of natural environmental and social change. This principle is illustrated schematically in Figure E1.1.

Figure E1.1 Evaluation of Significance

E1.1.6 Mitigation Measures

One of the key objectives of an EIA is to identify and define socially and environmentally acceptable, technically feasible and cost effective mitigation measures. Mitigation measures are developed to avoid, reduce, remedy or compensate for the potentially significant negative impacts identified, and to create or enhance positive impacts such as environmental and social benefits. In this context the term mitigation measures includes operational controls as well as management actions. These are often established through industry standards and may include: changes to the design of the project (eg changing the development

approach);

Magnitude of Impact

Qua

lity/

Impo

rtan

ce/S

ensi

tivity

of R

esou

rce/

Rec

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Small Medium Large

Hig

hM

ediu

mLo

w

Not Significant

Minor

Moderate

Major

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engineering controls and other physical measures applied (eg use of effluent treatment equipment or spill prevention technology);

operational plans and procedures (eg notifications to other users, navigation safety plans or waste management plans);

the provision of like-for-like replacement, restoration or compensation (eg for accidental damage to fishing gear from supply vessels).

For impacts that are initially assessed to be of Major significance, a change in design is usually required to avoid or reduce these, followed by a reassessment of significance. For impacts assessed to be of Moderate significance, the EIS will explain the mitigation measures that have been considered, the ones selected and the reasons (in terms of technical feasibility and cost-effectiveness) for that selection. Impacts assessed to be of Minor significance are usually managed through good industry practice, operational plans and procedures. The mitigation measures developed during the EIA process, as well as standard industry practice measures, will be presented in the EIS as project commitments. The EIA process is intended to ensure that decisions on projects are made in full knowledge of their likely impacts on the environment and society. As noted below, the residual impacts and their significance reported in this EIS will be based on the project as described, ie inclusive of all proposed mitigation. Measures to enhance positive impacts, such as economic benefits, are also mitigation measures.

E1.1.7 Residual Impacts

A residual impact is the impact that is predicted to remain once the agreed mitigation measures have been designed into the intended activity. The significance of the residual impact is evaluated against the criteria established for the assessment and reported in the EIS. The degree of significance attributed to residual impacts is related to the weight the EIA team considers should be given to them in making decisions on the project. It should be noted that mitigation often leads to a reduction in the magnitude of impacts rather than the removal of the source of the impact.

E1.1.8 Uncertainty

Even with a final project description and an unchanging environment, predictions of impacts and their effects on resources and receptors can by definition be uncertain. Predictions can be made using varying means ranging from qualitative assessment and expert judgement through to quantitative techniques (eg discharge modelling). The accuracy of predictions depends on the methods used and the quality of the input data for the project and the environment. Where necessary, the limitations to certainty are described and the consequence for confidence in predictions is stated. Where assumptions have been made, the nature of any uncertainty which stems from the prediction process is presented.

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Where uncertainty affects the assessment of impacts a conservative (ie reasonable worst case) approach to assessing the likely residual impacts is adopted with mitigation measures developed accordingly. To verify predictions and to address areas of uncertainty, monitoring plans are proposed.

E1.2 MANAGEMENT PLANS AND MONITORING

A wide range of different measures to mitigate impacts will be identified through the EIA process and the project will commit to the implementation of these measures as an integral part of the project. These measures will be set out in the project description and other chapters of the EIS and the key measures will be summarised in the mitigation and management measures chapters of the EIS.

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Annex F

Proposed EIS Report Structure

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F1 PROPOSED EIS REPORT STRUCTURE

1. INTRODUCTION 1.1. PURPOSE OF REPORT 1.2. PROJECT BACKGROUND 1.3. OVERVIEW OF PROJECT 1.4. THE PROJECT TEAM 1.5. PURPOSE OF EIA 1.6. EIA METHODOLOGY 1.7. STRUCTURE OF THIS REPORT 2. LEGAL AND POLICY FRAMEWORK 2.1. INTRODUCTION 2.2. ADMINISTRATIVE FRAMEWORK 2.3. NATIONAL LEGISLATION 2.4. STATE, CONVENTIONS AND CLASSIFICATION REQUIREMENTS 2.5. RELEVANT INTERNATIONAL AGREEMENTS AND CONVENTIONS 2.6. GOOD PRACTICE STANDARDS AND GUIDELINES 2.7. PROJECT ENVIRONMENTAL STANDARDS 2.8. PROJECT HSE POLICIES AND STANDARDS 3. PROJECT DESCRIPTION 3.1. INTRODUCTION 3.2. PROJECT OVERVIEW 3.3. PROJECT ALTERNATIVES 3.4. OFFSHORE FACILITIES AND EQUIPMENT 3.5. ONSHORE SUPPORT OPERATIONS AND ONSHORE BASE 3.6. MAIN PROJECT ACTIVITIES 3.7. PERSONNEL REQUIREMENTS 3.8. EMISSIONS, DISCHARGES AND WASTES 3.9. PERSONNEL HEALTH AND SAFETY 4. ENVIRONMENTAL BASELINE 4.1 CLIMATE AND METEOROLOGY 4.2 AIR QUALITY 4.3 HYDROGRAPHY AND OCEANOGRAPHY 4.4 BATHYMETRY AND SEABED TOPOGRAPHY 4.5 WATER AND SEDIMENT QUALITY 4.6 MARINE HABITATS AND SPECIES 4.7 NATURE CONSERVATION AND PROTECTED AREAS 5. FISH AND FISHERIES BASELINE 5.1 FISHERIES REGULATION 5.2 FISH ECOLOGY 5.7 COMMERCIALLY IMPORTANT FISH 5.5 FISHING FLEETS 5.3 FISHERIES INFRASTRUCTURE 5.3 FISH LANDINGS 6. SOCIO-ECONOMIC BASELINE 6.1. ADMINISTRATIVE STRUCTURES 6.2. CIVIL SOCIETY

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6.3. DEMOGRAPHICS 6.4. ECONOMIC ACTIVITY 6.5. EDUCATION 6.6 HEALTH 6.7 SOCIAL INFRASTRUCTURE AND HEALTH 6.8 TRANSPORT 6.9 WASTE MANAGEMENT 6.10 SERVICES AND COMMUNICATIONS 7. IMPACT IDENTIFICATION AND ASSESSMENT 7.1. ASSESSMENT METHODOLOGY 7.2. ENVIRONMENTAL IMPACTS 7.3. FISHERIES IMPACTS 7.4. SOCIO-ECONOMIC IMPACTS 7.5 ONSHORE PROJECT ACTIVITIES 7.6. CUMULATIVE AND TRANSBOUNDARY IMPACTS 8. MITIGATION AND MANAGEMENT MEASURES 8.1. INTRODUCTION 8.2. SUMMARY OF MITIGATION AND MANAGEMENT MEASURES 9. MONITORING PLAN 9.1. INTRODUCTION 9.2. MONITORING APPROACH 9.3. MONITORING PLAN FOR SPECIFIC MITIGATION MEASURES 10. DECOMMISSIONING 10.1. INTRODUCTION 10.2. REGULATIONS AND AUTHORITY 10.3. APPROVAL PROCESS 10.4. DECOMMISSIONING METHODS 11. ENVIRONMENTAL MANAGEMENT PLAN 11.1. OVERVIEW AND SCOPE 11.2. GENERAL REQUIREMENTS 11.3. PLANNING 11.4. IMPLEMENTATION 11.5. CHECKING AND CORRECTIVE ACTION 11.6. COST ESTIMATES 11.7. COMMUNITY DEVELOPMENT 11.8. GRIEVANCE PROCEDURE 12. SUMMARY AND CONCLUSIONS 12.1. EIA PROCESS 12.2. SUMMARY OF IMPACTS AND MITIGATION 12.3. OVERALL CONCLUSION ANNEXES ANNEX A CONSULTATION REPORTS ANNEX B BASELINE DATA REPORTS ANNEX C OIL SPILL AND DISCHARGE MODELLING REPORTS ANNEX D AIR QUALITY MODELLING REPORT

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