Together we can do this!
The issue:
The Gas-to-Energy (GTE) pipeline, a project
between Government of Guyana and ExxonMobil Guyana- EEPGL/ExxonMobil,
is governed by the 1794/2016 Petroleum Agreement - please see it attached.
The developer EEPGL has submitted its
Environmental Impact Assessment (EIA) and Environmental Impact Strategy
(EIS) to the Environmental Protection Agency (EPA) on or about 20 April
2022.
There is by designation of the Environmental Protection Act a
60-days period for persons to submit concerns
which said period ends 18 June 2022.
There is an off-shore part where
the pipeline runs on the seabed and there is an on-shore aspect which
runs from Crane through Canal nos. 1&2 then into Wales somewhere,
they (EEPGL and its independent consultants ERM) were
not clear where their responsibility would end on terra firma, when I
asked at a public consultation meeting on 11 May 2022.
The terra firma aspect has serious issues with compliance to the Rule of Law in Guyana:-
- The residents described as "primary stakeholders" in Canal #1 as defined the Environmental Impact Assessment Plan in Environmental Impact Assessment (EIA) were not consulted prior to the submission of EIA/EIS. This is also a breach of S.11 of Environmental Protection Act (EPAct) and the Gunning Principles of consultations. Reference letter - Letter to Mr. Parsram & EDH - EPA -Repudiation EIA.
- The developer, EEPGL has not complied with the requirements of S.11(10) EPAct nor that of S.17 Regulations by providing the following which is not evidenced on the document -
- 17. (1) An application for an
environmental authorization shall be made to the Agency pursuant to
section 11, 19 or 21 of the Act. (2) An application for an environmental
authorization - Schedule. 10 (a) shall be completed
in triplicate and shall be submitted to the Agency together with the
fee as specified in the Schedule; (b) shall be in respect of one project
or facility; (c) shall contain the following information: . (i)
the company
or corporate name, the names of directors if any, the name and position
of the applicant, the name of the owner or occupier and exact location
of the facility; (ii) proof that the applicant either owns the facility
or has a lease or other agreement with the
landowner or occupier to enable the applicant to conduct the activity
on the facility or has the legal right or ability to conduct the
activity without the consent of the landowner or occupier;. Reference letter EDH-GTE&Uaru
- The developer EEPLG has not shown proof of having conducted a feasibility study as per S12.1 of 1794/2016 Petroleum Agreement. Reference letter: EDH-GTE&Uaru
- The developer EEPGL has publicly stated in press and in letter addressed to me that this process was complimentary to the process : Reference letter: Complaint under Stakeholder's Community Grievance Mechanism (CGM) and my response, Reference Letter: EDH-GTE ExxonMobil response to 11 May 2022; this led to clarification questions addressed to EPA. Reference Letter: EDH - EPA- clarifications EIA
Objective:
To have the EIA/EIS recalled and/or revoked before 18 June 2022
Attachments:
- Reference letter to EDH- GTE&Uaru EM - the letter addressed to the President of ExxonMobil states outstanding failures to comply with written instruments of Guyana.
- The letters to AG remain unanswered and unacknowledged. Reference Letters: EDH-GTE questions to AG & EDH- GTE interpretation to AG
- The letter to EPA remains unanswered and unacknowledged. Reference Letter: EDH - EPA clarification EIA
-
In the press today and yesterday there is a very duplicitous as well as confusing notice sponsored by ExxonMobil and its independent consultant ERM, as it has no date. Reference: Kaieteur News - www.kaieturenews.com Friday 27 May 2022 page 24 & Stabroek News www.stabroeknews.com Saturday 28 May 2022 page 13.
- The Moratorium to EM & the general one capture the outstanding issues to be addressed.
Outcome:
Should this EIA/EIS be allowed to stand Guyana will be in a Rule of Law conflict.
Requests:
Let's stand together to stop Guyana
falling into a Rule of Law conflict situation which may/could lead to
other issues including a Constitutional Crisis.
It would be highly appreciated if you
are willing to do any of the following before the closing date, 18 June
2022, for submissions of concerns to EPA - Environmental Protection
Agency:
- Share the precarious situation in which Guyana currently sits viz a viz respect to Rule of Law via your networks
- Alert international press and pressure group about the situation
- Write to ExxonMobil International alerting of the current situation - Good luck finding an email address
-
Write to Hess - www.hess.com - there is a contact info part where concerns may be addressed. I got an acknowledgement of receipt to my submission albeit a generic generated by AI.Hess announced an increase in the gross discovered recoverable resource estimate for the Stabroek Block offshore Guyana to approximately 11 billion barrels of oil equivalent, up from the previous estimate of more than 10 billion barrels of oil equivalent.
-
Write to CNOOC Nexem Petroleum Guyana at their parent company - www.cnoocltd.com - email: IR@cnooc.com.cnMay. Ranked #13 in "2022 Brand Finance Top 50 Most Valuable Oil & Gas Brands" List
- Write to EPA - to express concerns with the process - lack of adherence to Rule of Law.
- Write to EPA - submitting concerns with the GTE project as per Moratorium or letters to Attorney General or in letter to ExxonMobil's President before 18 June 2022
- Write to the International Press highlighting the potential crisis and quoting lack of adherence in Liza1, Liza2 & the very contentious Yellowtail - there is unregulated flaring and dumping of toxic waters into the seas and lack of releases to the public of Environmental Studies despite repeated request by many NGOs & individuals
- Write to EEPGL - guyanacommunity@exxonmobil.com or guyanastaff@exxonmobil.com with your concerns.
- Write & Circulate in your network letters of protest and resistance to these non-adherences to the Laws of Guyana.
- Any other ideas which inspire you to bring this to a halt.
Together we can do this!
If we do nothing we are left in non-adherence to Rule of Law with Constitutional Issues!
Let's put our energies together & stop this level of lawlessness!
1 People, 1 Nation, 1 Destiny!
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