INDEPENDENT STUDY OF MARINE ENVIRONMENTAL CONDITIONS IN GHANA

Transcription

1 INDEPENDENT STUDY OF MARINE ENVIRONMENTAL CONDITIONS IN GHANA JANUARY 2015 Performed in Collaboration with Sponsored by

2 Contents List of Acronyms Executive Summary Introduction Objectives Methodology and Schedule Report Organization Profile of Ghana s Coastal and Marine Environment Marine Environmental Conditions General Description Physical and Chemical Characteristics Biological Conditions - General Fishing Industry Overview Fishing Activities Fishery Resource Exploitation Illegal Fishing Existing and Planned Legislative and Management Actions Offshore Oil and Gas Industry Activities General Description of Activities Primary Sources of Potential Impacts Air Emissions Discharges Solid Waste Management Noise Generation Spills Safety Exclusion Zones Cumulative Effects Issues and Concerns Raised Regarding Changes to Marine Environment Fishery Decreased Fish Catch Exclusion Zones Vessel Conflicts and Collisions Whale Mortality Algal Blooms...41

3 4.4 Tar Balls General Marine Environmental Conditions General Socio-cultural Conditions Findings Fishery Whales Algal Blooms Tar Balls General Marine Environmental Conditions General Socioeconomic Conditions Recommendations and Next Steps Exclusion Zone Management Plan Strengthened Capacity for Governance of Fishing Activities Additional Measures to Minimize Harm to Whales Marine Noise Study and Management Practices Algae Study and Management Plan Tar Ball Fingerprinting Analysis and Management Plan Continuous Improvement in Waste Management Continuous Improvement in Oil Spill Prevention & Response Integrated, Participatory and Transparent Baseline Additional Measures to Minimize Impact to Fishing Activities Improved Land Use Planning/Governance for On-shore Projects Coordinated Consultation and Capacity Building Continuous Improvement to Promote Local Content Development Recommendations Prioritization and Action Plan Next Steps...63 Appendix A...65 Appendix A Appendix A Appendix B...79 Appendix C...80

4 List of Acronyms ALARP API CGG CNSOPB CO CRC DFID EIA EPA EC EEZ FAO FIA FPSO GIIP H2S IA IUU IMO KEG L-DEO MARPOL MCL MFRD MMS MOUs MSY As Low As Reasonably Practicable American Petroleum Institute CGG Global Data/map Canada-Nova Scotia Offshore Petroleum Board Carbon Monoxide Constitution Review Committee Department for International Development Environmental Impact Assessment Environmental Protection Agency European Commission Exclusive Economic Zone Food and Agriculture Organization Fisheries Impact Assessment Floating Production, Storage and Offloading Good International Industry Practice Hydrogen Sulfide International Association Illegal, Unreported and Unregulated International Maritime Organization Kosmos Energy Ghana Lamont-Doherty Earth Observatory International Convention for the Prevention of Pollution from Ships Maximum Contaminant Level Marine Fisheries Research Division Marine Mammal Survey Memoranda of Understandings Maximum Sustainable Yield

5 NO2 NOX NGOs OIW OOC OSPAR O3 PAHs PC PERF SFLP SO2 SOX TEN TRC USAID USDOI USEPA VOCs Nitrogen Dioxide Nitrogen Oxides Non-Government Organizations Oil in Water Oil on Cuttings Convention for Protection of the Marine Environment of the North-East Atlantic Ozone Polycyclic Aromatic Hydrocarbons Petroleum Commission Prepared for Petroleum Environmental Research Forum Sustainable Fisheries Livelihoods Programme Sulfur Dioxide Sulfur Oxides Tweneboa, Enyenra and Ntomme Truth and Reconciliation Commission United States Agency for International Development United States Department of the Interior United States Environmental Protection Volatile Organic Compound

6 Executive Summary BACKGROUND Ghana s offshore oil and gas resources offer the potential to increase the well-being of coastal communities fronting the production areas. The discovery of the Jubilee field in 2007 has attracted world-class oil and gas producers, injected billions of dollars into the national economy and brought sorely-needed investment in development for the communities of Ghana s Western Region. But many in the region worry about the possible environmental effects of oil and gas production, and wonder if the benefits outweigh these effects: Fishermen complain of dwindling catches, Residents fear that marine and coastal conditions may deteriorate, and Community leaders struggle to see the benefits of community investment programs accrue over the short term. Information generated by the press, non-government organizations and special interest groups has contributed to confusion around the effects of oil and gas activities. To date, government agencies have been hard-pressed to deliver public confidence regarding fiction and facts associated with local energy development and environmental impact. The Study In mid-2014 the Ghana Environmental Protection Agency teamed with Kosmos Energy to commission an independent study exploring the concerns of affected communities. The study was also designed to evaluate the extent to which there is evidence that the issues generating these concerns are attributable to, and can be mitigated by, the oil and gas industry. The joint international-ghanaian study team: Reviewed nearly 200 relevant studies, plans and documents Interviewed and consulted with over 100 stakeholders Independently analyzed information provided to form findings and recommendations Presentation and evaluation of initial findings and recommendations in consultation with stakeholders at 4 workshops in the Western Region and Accra (October) Conducted additional analysis based on input from stakeholders (November through January 2015) The study focused on six major issues that were raised by stakeholders as concerns relative to the potential or perceived effects of offshore oil and gas activities in Ghana: 1. Fishery and fishing 2. Whale mortality 3. Algal blooms 4. Tar balls 5. General marine environmental conditions 6. General coastal socioeconomic conditions 1

7 This report presents the vetted findings and recommendations of the independent study, with the intention of providing a platform for better understanding and cooperative decision-making about the important issues affecting use of marine resources offshore Ghana. Findings The study found that some of the concerns being raised do not appear to be directly attributable to the offshore oil and gas activities, while others do appear to be. The following table distinguishes those key issues within each of the six areas of concern for which the study found or did not find evidence of direct influence by the oil and gas industry. Table ES-1 Summary of Findings 2

8 Recommendations Upon analysis of the findings, the team offered thirteen general recommendations for addressing some of the issues of greatest concern to stakeholders, whether directly attributable to oil and gas activities or not. These were reviewed with stakeholders in workshops, then adjusted and prioritized to allow for more specific actions that might be taken within each of the identified focus areas. The recommendations are listed in Table ES-2 and prioritized recommendations 8, 9, 10 and 12 are described below. Table ES-2 Summary and Prioritization of Recommendations RECOMMENDATION 8: Continuous improvement in good international industry practice (GIIP) for spill prevention and response Oil and gas industry operators offshore Ghana are presently applying GIIP for preventing and responding to potential oil spills. However, given that an accidental oil spill could represent the single most damaging impact to Ghana s marine and coastal environment from oil and gas operations, continuous improvement in these practices must be an on-going priority interest for both operators and regulators. Recommendation 9: Integrated, participatory and transparent baseline study/information Ghana EPA has custody of environmental baseline for the marine zone, but few appear to have access to this data. This complication foments criticism and distrust between stakeholders, EPA and oil companies. The EPA should develop and consistently maintain a mechanism to share the baseline information openly for public review, query and understanding. 3

9 Recommendation 10: Continued awareness/capacity building for fishery management Fishermen report hardships from conflicts with oil and gas activities and a frustrated that oil extraction is now given priority over the fishing that has occurred in these waters for generations. To better address these concerns, the Ministry of Fisheries and Aquaculture Development should conduct further capacity building both within the Fisheries Commission and with fishermen and other stakeholders to apply management practices needed to minimize impacts to fishing. This includes management practices around navigation, evaluating fisheries impacts in project plans and promotion of mariculture development as an alternative livelihood. Recommendation 12: Coordinated consultation and capacity building programs Uncoordinated efforts by multiple parties to raise community awareness and build capacity about potential impacts and management practices may be contributing to misinformation, confusion and mistrust within affected communities. Oil and gas operators should take initiative to work with NGOs and community leaders to develop and deliver a more cooperative, integrated community liaison and capacity building program. Local governing bodies should actively support this initiative. Next Steps The value of this study will be determined by the extent to which the findings support continued and fruitful dialogue on the key issues of concern, and by the degree to which adopted recommendations are effectively implemented. Three actions forward are recommended to achieve these objectives: Implementation of a multi-stakeholder process to collectively develop, agree to and initiate implementation of a specific plan of action (an initial action plan is offered in Appendix as an example and starting point for the prioritized recommendations) Formation of a Steering Committee, establishment of a memorandum of understanding among key stakeholders and agreement of responsibilities for implementing and tracking the action plan forward Communication of the findings and recommendations of this study broadly and transparently to ensure all interested parties have the benefit of the same information as an even basis for promoting next steps. The ability of interested parties to agree on and implement these developments will be critical to determining the success of Ghana s plans to generate benefits from offshore oil and gas production. Effective implementation will require serious, cooperative and sustained effort by all of these parties. 4

10 1 Introduction Throughout the six coastal districts of the Western Region of Ghana, fishermen and fishing groups have reported concerns about degradation of the marine environment, which many have attributed to oil and gas exploration and production activities in the region. Direct complaints have been received across the industry and including by both Kosmos Energy Ghana (KEG) and Ghana s Environmental Protection Agency (EPA). KEG has sought a qualified contractor to objectively evaluate existing information and present its independent findings to stakeholders. The study was performed by a team of international and Ghanaian specialists with deep experience in evaluating impacts of oil and gas activities on the marine and coastal environment on behalf of industry, governments and financial interests. Appendix A provides a summary of team members and qualifications. 1.1 Objectives This study has four main objectives: To conduct an independent study of available information concerning public allegations that offshore oil and gas activities have caused degradation of the marine environment off the coast of Ghana To summarize global good practice in terms of addressing real and perceived challenges of offshore discharges on the marine environment To engage key stakeholders in gathering and sharing relevant information To provide an objective summary of the information, evidence and stakeholder views and facilitate an open but structured discussion focused on potential areas of consensus on the issue 1.2 Methodology and Schedule The study team carried out its work by collecting and reviewing nearly 200 documents, engaging in conversations with more than 100 stakeholders, evaluating information gained from the literature review and consultations, vetting initial findings at stakeholder workshops, and completing findings and recommendations for documentation in this report. Table 1-1 shows the schedule of these activities. Table 1-1: Study Schedule of Activities Activity Date ( ) Review available documentation and literature related to the issue Conduct approximately 20 informal interviews with government, industry, and community stakeholders in Accra and Takoradi Evaluate and organize findings Facilitate meeting/workshop with key stakeholders to review findings Complete analysis and issue report June June July August September October November January Literature reviewed included plans and other documents related to Ghana s marine environment, offshore oil and gas exploration impacts, relevant environmental trends and industry management practices worldwide, and other relevant topics. Stakeholders interviewed included national government officials from relevant agencies, 5

11 representatives of district assemblies in the Western Region, non-government organizations, fisher associations and fishmongers, oil company representatives and both national and international experts on marine and coastal environmental conditions. Appendix B presents a list of references and stakeholders engaged. Throughout this study the team refers to evidence that it was able to collect from its research, interviews and prior knowledge and experience. In reporting findings, the team has stated whether or not it found credible evidence that oil and gas industry activities offshore Ghana are responsible for the issues and concerns that have been raised by stakeholders. Where it is stated that no such evidence was found, the team is not stating there is no possibility of such an impact from oil and gas activities. Rather, the statement indicates that the information available within the scope of this review did not reveal credible evidence of such impacts. The independent study was performed to verify the extent to which marine environmental concerns are attributable to the oil and gas industry a team of international and Ghanaian specialists reviewed nearly 200 documents and interviewed >100 stakeholders. The study was primarily sponsored by KEG, and performed independently in cooperation with the Ghana EPA and with involvement of a range of stakeholders. KEG and EPA allowed the study team full independence in accessing information, conducting interviews, evaluating results and formulating findings and recommendations. 1.3 Report Organization This report presents the primary findings and recommendations of the study. Chapter 2 provides an overview of environmental conditions and trends in and affecting the coastal and marine zone of Ghana. An overview of fishing activities is included as an important element of these conditions. Chapter 3 describes the oil and gas industry activities offshore Ghana, noting typical impacts and management practices and summarizing the results of environmental performance monitoring. Chapter 4 discusses the key concerns that have been raised about conditions in the marine environment relative to oil and gas industry activities offshore Ghana. Chapter 5 presents the study team s findings regarding the extent to which evidence has shown that these conditions are attributable to oil and gas activities. This section seeks to separate key issues that warrant priority attention relative to potential industry impacts from those that may be based on misperceptions. Chapter 6 offers recommendations for a multi-stakeholder approach to managing key issues, as well as suggestions regarding next steps for managing the concerns that have been raised. In sum, the report is intended to highlight activities that are verified as having a potential impact on Ghana s coastal and marine environment and to offer steps that can be taken cooperatively by the industry, government and civil society to help ensure sustainable development of the country s marine resources. 6

12 2 Profile of Ghana s Coastal and Marine Environment The health of the coastal and marine zone offshore Ghana depends on existing conditions and threats as well as regional and global trends. This section of the report addresses existing marine environmental conditions (2.1), provides a focused view into fishing and fisheries (2.2), and summarizes regional and global threats to the health of Ghana s marine environment (2.3). Much of this profile relies on information provided in sampling studies performed by oil companies operating in the oil exploration and production zone offshore Ghana s Western Region. Anecdotal reports from fishermen, international scientists, non-governmental organization (NGO) representatives and marine observers have also been included. Ghana EPA has environmental baseline documentation covering the Western, Central and Eastern coasts as well as the Deep Water Tano/Cape Three Points offshore area, surveys conducted in 2009, 2010, 2011 and 2013/14 respectively. EPA reports that it intends to perform updated baseline sampling programs to characterize the physical, biological (including bottom sediment/fauna) and chemical conditions of the entire Ghana coastal and marine zone, in 2015 and every three years thereafter. 2.1 Marine Environmental Conditions General Description Ghana lies along the Gulf of Guinea in West Africa, with a coastline of 550 km, including approximately 90 lagoons and river estuaries. The geographical scope of Ghana s coastal zone is defined formally to include a land area extending to the 30 meter contour, and a coastal offshore shelf area to the 200 nm depth. Ghana s coastal zone comprises only 6.5 percent of the country s area, yet 25 percent of the nation s population lives in this area (EPA/ World Bank, 1997). Figure 2-1: Marine and Coastal Zone of Ghana and Neighboring Countries Source: Google Earth 7

13 The coastal waters of Ghana are influenced by three current systems: The eastward flowing Guinea Current, which occurs on the surface from the coast to about 370 km offshore; A small westward counter current, which lies beneath the Guinea Current; and The westward flowing South Equatorial Current, located offshore beyond the Guinea Current (i.e., at a distance greater than 370km) Physical and Chemical Characteristics The water off the coast of Ghana is generally low in primary productivity, evidenced by low suspended solids and chlorophyll-a, resulting in oligotrophic conditions. This is likely due to low levels of nutrients, such as nitrates. This is common in tropical and sub-tropical marine environments. Fishermen interviewed for this study indicated that their nets catch a high volume of plastics, sometimes as much as 80 percent of the catch. Fishing gear deployed deeper in the water column can also catch less buoyant items, such as metal cans for soft drinks and tinned meat. The source of this waste is unknown, but the lack of sufficient waste management facilities and the common practice of littering and indiscriminate rubbish disposal both at sea and on land contribute to trash in the sea, or washed or blown out to sea. Some of this waste makes its way back onto the shores of Ghana and can litter or choke important breeding habitat for fish, birds and other coastal wildlife. Sampling performed by Ghana EPA with the Norwegian Institute of Marine Research during 2010 offshore Ghana s Western Region found low levels of contamination in seafloor sediments except for arsenic levels at three near-shore stations. All concentrations of heavy metals were low. An exception was a shallow station of the westernmost transect and two shallow and intermediate stations at the easternmost transect, which were considered as moderately to severely polluted by arsenic. The source of this contamination is unclear, but is most likely from activity at the shoreline or from the Volta River. Most of the metals had increasing concentrations with depth, while zinc and lead were found in higher concentrations near shore and near the outlet of Volta River. Hydrocarbon levels were low at all stations. The highest values were detected at 5 m depth near the Volta River, however these concentrations correspond to a good sediment quality. The bottom fauna show no signs of disturbance by human activity. Shallow areas were generally rich in both species and individuals, while few were detected in the deepest sites. (Institute of Marine Research, 2010). In contrast, an undated report by the Centre for Environmental Impact Analysis cited results showing elevated levels of contaminants around Jubilee Field platforms and other offshore/estuarine locations of the Western Region (Centre for Environmental Impact Analysis, undated). The report cites elevated levels of certain metals in all points (including in estuarine and nearshore sampling stations) as well as elevated levels of oil and grease in the sampling locations around Jubilee Field platforms and in other locations distant from the platforms. The Centre for Environmental Impact Analysis study appears to present different indications of marine 8

14 environmental quality than the EPA/Norwegian Institute studies, perhaps suggesting a need for further studies to verify indicators of marine environmental quality offshore the Western Region Biological Conditions - General Ghana s marine zone does not support coral reefs1, and no extraordinary seafloor features or biodiversity hot spots have been observed that have attracted international interest for preservation. Ghana currently has no Marine Protected Areas existing in its fisheries and coastal management regime. Five Ramsar sites have been designated along the coast in the Central, Greater-Accra and Volta Regions. Interviews with oil and gas industry operators in Ghana indicate that limited fish tissue sampling performed reveal levels of metals that are within MCL limits for safe human consumption. The seafloor does not exhibit sensitive features or rare species habitat, but overall Ghana s marine environment is healthy and supports a high biodiversity. Other baseline studies by the operators indicate that the seafloor conditions in the exploration area are homogeneous, lacking special environmentally sensitive features that might support rare species habitat. Despite this condition, and not withstanding a variety of environmental threats to the health of the marine environment (see Section 2.4), the marine waters offshore Ghana support important marine life and biological conditions Marine Mammals and Turtles The Gulf of Guinea and waters offshore is believed to be an important migration and calving habitat for whales, other marine mammals and marine turtles. A 2013 study by Dr. Carolyn Weir 2 reviewed historical sighting records and habitat conditions for marine mammals and turtles offshore West Africa. This study identified the presence of several species of whales offshore Ghana, including Bryde s, sperm and dwarf sperm, humpback (between September and December), Cuvier s beaked, killer (in August), short-finned pilot, and melon-headed whale. The study found little information regarding breeding periods and migration range within the region, although it concluded that some species (such as the sperm and Cuvier s beaked whales) are likely to be present year round in this area. (Weir, 2013). Marine mammal observers employed on recent seismic surveys performed by oil and gas industry operators reported sighting more than 200 marine mammals and turtles in oil exploration areas offshore Ghana s Western Region during seismic survey cruises conducted between January December An abrupt increase in the number of dead whales washing up on Ghana s shores between 2009 and 2014 led the Ghana EPA to commission a study into the likely causes of death (Ghana EPA, 2014a.) The study was not able to find a reason for the increase in whale mortality, in large part because many of the carcasses observed were in such an advanced state of decomposition as to prevent meaningful analysis. However, the study did reveal that a number of the dead whales had ingested plastics and other trash, and some showed evidence of being struck by boats both of which, along with natural causes, are potential causes of death. Many of the carcasses observed were in such an advanced stage of decomposition that the whales would likely have died and been floating at sea for days or weeks prior to landing on Ghana s shore. 1 A Strategic Environmental Assessment performed by Ghana EPA in 2013 states that researchers aboard the Fridtjof Nansen research vessel had identified live coral reef offshore Ghana s Western Region in 2012 (EPA, 2013). A K Armah, a senior lecturer of the Department of Marine and Fisheries Sciences at the University of Ghana, and a member of the study team for this report, subsequently confirmed that in fact what was found were occasional individual corals, not a reef structure. 2 Weir, C.R. (2013). A review of marine mammal and sea turtle occurrence in Liberia and surrounding waters. Report to Acorn International. 19 October pp. 9

15 Figure 2-2: Whale Carcasses on Ghanaian Beach Source: Tullow Ghana Limited Annual Monitoring Report, 2014 Worldwide, marine mammal mass mortality events have been a serious concern due to their severity and frequency since These coincide with an increase in reported events involving a variety of other marine species (SeaWeb, 2014). There were an unprecedented number of sperm whales strandings along the European coast between 1994 and 1996, and more than 150 highly endangered monk seals died off the northwest African coast in Mass mortality events of the past two decades have been most commonly linked to algal toxins, disease caused by morbilliviruses, chemical contaminants (PCBs and DDT) that compromise the animals immune systems, and climatic conditions that cause changes in prey availability (ultimately leading to starvation). An unprecedented number of dead whales washed up on Ghana s shores between 2009 and 2014 a 2014 EPA study attributes this to a variety of causes. On top of the concern over whale carcasses washing up on beaches in Ghana is another local concern the killing of cetaceans (whales and dolphins) as by-catch or targeted catch by fishermen. A study from recorded 743 cetacean 3 landings over a year (263 monitoring days) at a single fishing port in Ghana s Western Region. This is a high catch rate of 2.82 individuals/day. Most individuals that were landed were either sub-adult or juvenile. A similar study over the period of found a by-catch rate of 0.74 animals/day (Van Waerebeek, Debrah, & Ofori-Danson, 2014). Cetaceans are landed year round with little seasonal variation. Most of the individuals were likely caught by drift gill nets. However, the several of the lethal injuries were inflicted by hand-held weapons such as harpoons and spears, suggesting that capture was deliberate in those cases, rather than as by-catch. Interviews with Ghanaian marine scientists and members of fishing communities supported the view that there has been an increase in the targeting of cetaceans, particularly dolphins, for sale as marine bushmeat Algal Blooms In recent years Ghana has experienced an unprecedented increase in the presence of a seaweed known as Sargassum (a genus of free-floating algae). The Sargassum has been particularly present in the Western Region where it has affected livelihoods of fisher-folks and other community members (Ghana EPA, 2014b). In fact the increase in Sargassum along Ghana s shores is part of a regional and global trend. For example, the photo below shows Sargassum covering beaches in Sierra Leone in 2011 (Sources: The New York Times, 13 October, 2011 and image and accompanying text on Google Earth, accessed 19 September 2014). 3 The great majority of these individuals were dolphins not more than eight were whales. 10

16 Figure 2-3: Sargassum on Beach in Sierra Leone, 2011 Sargassum is common to and abundant in the Gulf of Mexico and Sargasso Sea (east of the southern US and northeast of the Caribbean Sea). The reason for the migration of Sargassum to West Africa in recent years is still under study, but is thought to be potentially related to climate change, changes in Atlantic current patterns and changes in the productivity of marine habitat on a regional scale. A study by Armah, Allotey and Foli supports the opinion that the source of Sargassum blooms in Ghana are part of a more regional pattern. Source: Google Earth, accessed 19 September 2014 The photographs at right, taken from the referenced 2012 study, show similar blooms on beaches in Ghana in 2012 and in the Caribbean in While oil and gas is actively being produced offshore Ghana and in the Gulf of Mexico (adjacent to the Caribbean Sea), it is not offshore Sierra Leone or neighboring countries. Despite being a nuisance to fishermen, Sargassum blooms provide important ecological benefits to the marine environment. Naturallyoccurring Sargassum patches floating on the ocean s surface can span up to several acres across, providing habitat for over 145 different invertebrate species and more than 80 fish species (including commercially-important tuna), as well as migration routes for over 25 endangered pelagic species (including humpback and sperm whales) (Roe, 2011). However, the biomass of pelagic Sargassum has been drastically reduced in recent decades (a 94% reduction since 1933), due largely to commercial harvest of pelagic Sargassum removing as many as 180 tons per year (a practice banned in US waters since 2004) and also to increased marine pollution (Defenders of Wildlife, 2010). Another common algae that raises concern to fishermen in the region is Ulva clathrata (formerly Enteromorpha flexuosa), known locally as green green. Aby Lagoon, along the coastline of Ivory Coast, is thought to be one regional source of the periodic green green blooms in nearshore marine waters. This algae has been present in Aby Lagoon since the 1980s, entering the lagoon through a tidal inlet and able to survive as long as the lagoon s salinity remains above 20 parts per thousand. The algae growth first became problematic in 1991, when mats over 1.5 meters thick Some researchers suggest an increase in coastal nutrient concentrations, resulting in increased algal growth. Another suggestion says that the 2010 oil spill in the Gulf of Mexico may play a role by contributing more nutrients, and since after the spill there was a temporary change in the current pattern, six months after which the Sargassum began to increase. (Armah, Allotey & Foli, 2012) Figure 2-4: Sargassum in Ghana, 2012 (a), and Sargassum in Caribbean, 2011 (b) (a) (b) Source: Armah, Allotey & Foli,

17 developed in the lagoon, killing large numbers of fish. Each year green green grows inside Aby Lagoon during the dry season (January-March) and persists until the rainy season swells the Tano and Bia rivers, which flush the lagoon and transfers the algae into the longshore eastward current toward Ghana s shorelines to the east (Granger et al., 2012). Since 2011, Sargassum seaweed has been a nuisance in Ghanaian waters and shores part of a regional and global trend. The prevailing longshore marine current conveys both the green green from the Aby Lagoon and the Sargassum from the Sargasso Sea and other points to the west, in an easterly flow until driven onto the beaches of Cote d Ivoire and Ghana by the on-shore winds. Reports of Sargassum washing up on the beach begin in August and September around New Town then spread to other locations. Reports about the end of the bloom were generally associated with the end of the rainy season; however, along the coast between Figure 2-5: Typical Tar Balls Assini-France, New Town, and Half-Assini the bloom can linger into March (EPA, 1995) Tar Balls The presence of coagulated oil tar ( tar balls, see photo) on the beaches of Ghana has been observed since the 1960s, with senior members of communities noting that during the 1960s and 1970s one could not walk along the beach without soiling feet with a thick layer of tar. During these periods, community members were unable to fish, but the tar balls would last for two to three weeks before dissipating. It is suspected that many of these events were caused from oil of passing oil tankers (Modern Ghana, 2011; Study Interviews, 2014). Source: NOAA Research into tar balls indicates that they may be generated by both anthropogenic and natural activities. According to Woods Hole Oceanographic Institute, as much as one half of the oil that enters the coastal environment comes from natural seeps of oil and natural gas. These geologic features are known to occur in clusters around the world, but are still relatively unstudied. This research shows natural oil seeps occurring worldwide, including offshore Ghana (NPA, 2013). A study by the geophysical survey company CGG identified specific seep locations a summary map of CGG s global database is shown in Figure 2-6. Seeps are often found in places where oil and gas extraction activities are also located. As a result, surface slicks and tar balls caused by seeps are often attributed to releases from Figure 2-6: Location of Oil Seeps Worldwide Source: 12

18 oil and gas platforms. There is an important difference in the nature of and rates of input of natural oil seeps as compared to oil input from human activities: namely, that seeps are generally very old and flow at a very low rate, and organisms living nearby are adapted to the conditions in and around seeps. A study was performed in late 2014 to analyze eight tar ball samples collected from Western Region beaches as a means of evaluating whether they might be related to oil produced from oil and gas industry activities offshore Ghana (Reed, 2015). Figure 2-7 indicates where the samples were collected in relation to the Jubilee Field. The study used a common chemical fingerprinting methodology Figure 2-7: Tar Ball Samples Collected at Busua to evaluate the source characteristics of the tar ball material and found that it definitively did not match the properties of the Jubilee Field oil. Further study would be needed to attempt the actual source of material forming the tar balls Coastal Environment The coastal zone of the Western Region includes a number of lagoons that support rich and ecologically sensitive biological habitat and proposals for national protection. A July 2011 assessment by the University of Rhode Island Coastal Research Center identified the wider Cape Three Points areas and the Amansuri Estuary as potential biodiversity hotspot that need urgent strategic management attention. (CRC, Assessment of Critical Coastal Habitats of the Western Region, Ghana, 2011) Over 90 coastal lagoons exist along the Ghanaian coastline, forming important ecosystems for a wide variety of fish, shrimps, crabs, mollusks and polychaete species. These serve as migratory water bird habitats as well as nursery areas for juvenile marine fish and shrimp. Threatened or Source: Google Earth endangered species residing in the coastal zone include the West Africa Manatee and five species of marine turtles. The coastal economy is largely divided into three sectors fishing, salt production and subsistence farming. The coastal zone accounts for about 80 percent of Ghana s annual fish production, which totals roughly 450,000 metric tons per year (see Table 2-1). Table 2-1: Summary of Ghana Fish Production Category 2013 (Metric tons) 2014 (Metric tons) Annual Fish Production 456, , Annual Marine Fish Production 333, , Annual Inland Fisheries Production 95, , Aquaculture Production 27, , Source: MFRD 13

19 Six onshore sites have been designated as Ramsar Wetlands of International Importance, including the Sakumo Lagoon, Songor Lagoon, and the Densu Delta, all in Greater Accra. The Anlo-Keta lagoon complex is located in the east of the country near the Togo border, the Muni Lagoon in the Central Region, and the Owabi wetlands in the Ashanti Region. Parties interviewed for this project felt that these could be ideal areas for extending protection into the marine zone to create a coastal protected zone. Mangroves play an important role in the reproduction and recruitment of fish and other important marine organisms. In Ghana, these trees are mainly located along the lower reaches of the Volta River and around lagoons on the Western Region, where they are most common between Cote d Ivoire and Cape Three Points. Due to high development rates along the coast, most mangrove fringes are relatively small in area and distribution and rarely develop beyond a thicket stage. Mangroves are used extensively for fuel wood to smoke fish and for construction purposes. Local residents interviewed report using the bark of one mangrove species for tanning fishing nets. Losses of mangrove areas have also been caused by tourism development, sand winning, solid waste disposal, reclamation of lands for agriculture, urbanization and salt ponds (FAO, 2005; Mensah, 2013). Many of the lagoons in the country experience high rates of bacteriological pollution, particularly from human waste (Ampofo, 1997). The lagoons are also choked by solid waste such as plastics, as discussed below. These stresses reduce the productivity of the lagoons as habitat for fish to spawn, hatch and grow prior to heading out to sea and reduce overall recruitment of new fish to the fishery Fisheries Fishing in the waters offshore Ghana has been an important source of economic and cultural activity since the 18 th century. Ghana was a West African fishing power in the 1950s and 1960s (Mills, et.al, 2004). Despite overexploitation and other stresses on the resource, the fishery remains a critical part of life in coastal Ghana. One of the main factors defining the Ghanaian marine ecosystem and the fishery is upwelling 4, in particular the major annual upwelling event from July-September and the minor event from December to February. The EIA for the Jubilee field noted the importance of the upwelling to the increase in primary productivity in the area, as shown in Figure 2-8. The upwelling is known to have considerable influence on both the local and sub-regional fisheries. The position and dynamics of the upwelling are variable, but it is clear the upwelling influences the migratory patterns of pelagic fishes and is linked with the marine fish catch in Ghana (Armah and Amlalo, 1998). Figure 2-8: Primary production off West Africa during major upwelling (a) and non-upwelling (b) seasons Source: Jubilee EIA Tullow Ghana Limited, Upwelling is a natural oceanographic process by which currents drive cooler water that is typically nutrient rich from lower depths toward the ocean surface. 14

20 2.2 Fishing Industry Overview Fishing Activities The fishing industry in Ghana is of great importance to the country, both economically, and as an important element of the national culture. The fisheries sector generates over US$1 billion 5 in revenue annually, and accounts for approximately 2 percent of Ghana s GDP. Approximately ten percent of Ghanaians are employed either directly or indirectly in the sector (Republic of Ghana National Plan of Action on IUU Fishing, 2014). Within Ghana s fishing industry, fish capture, processing, marketing and associated services also provide significant sources of livelihood, with estimates suggesting that one fishing job creates seven additional livelihoods (unpublished reports by USAID and SFLP). In all, as many as 2.2 million Ghanaians depend on the fisheries sector, of which approximately 135,000 are fishers (Republic of Ghana Fisheries and Aquaculture Development Plan ). In addition to its economic importance, fishing is a critical food source in Ghana. Fish accounts for approximately 60 percent of the animal protein in the Ghanaian diet. The annual per capita consumption of fish is kg. The marine fishing industry is characterized by three main fishing units: Artisanal unit made up of approximately 13,000 canoes, often motorized, and using purse seines, set nets, draft gill nets and hook and line. Some of the larger canoes can go to sea for several days and have ice chests to preserve the fish until they return to shore. This sector contributes percent of total marine fish output (Fisheries Scientific Survey Division, 2013) and employs 80 percent of Ghanaian fishers. Semi-industrial/inshore fleet locally built wooden vessels between 8 and 37 metres long which use purse seine gear during the major and minor upwelling periods, and practice trawling in the shallow coastal waters during the offseason. Industrial Fleet large, steel-hulled vessels including trawlers, shrimpers, tuna pole and line, and purse seiners (FAO, 2004). Fishing is a critical part of the Ghanaian coastal economy and culture and the primary source of protein in the Ghanaian diet. Targeted fish include small pelagic species (i.e. sardinella, chub mackerel, anchovy), large pelagic species (i.e. tuna) and demersal species (i.e. Sparidae, Lutjamidae, Mullidae, Pomadasydae, Serranidae, Polynidae and Penaeidae). Sardines in particular have been the mainstay of the marine fishing industry in Ghana. In the country s six Western Region districts, the main fish species caught are primarily round and flat sardines (Sardinella aurita and Sardinella maderensis): Shama Sardinella aurita, Sardinella maderensis, Frigate Mackerel (Auxis thazard), and Long- Finned Herring (Ilisha africana) Sekondi Takoradi Metropolitan Sardinella aurita, Sardinella maderensis, Frigate Mackerel (Auxis thazard), and Long-Finned Herring (Ilisha africana) Ahanta West Sardinella aurita, Sardinella maderensis 5 This figure includes production from both the fishing industry and related economic activities such as processing and subsequent sale of seafood products. In 1998, the fishing industry contributed $380M (USD) to the Ghanaian economy, while in 2011, this figure fell to $254.4M (MoFA, 2012, and The decline of a regional fishing nation, 2004). 15

21 Nzema East Municipal Sardinella aurita, Sardinella maderensis Ellembelle Sardinella aurita, Sardinella maderensis Jomoro Sardinella aurita, Sardinella maderensis, and Atlantic Little Tuna (Euthynnus alleteratus) For over a decade various experts and observers have been indicating that the fishing industry is in decline and has the potential to collapse (Modern Ghana, 2000; Joy Online, 2013; Republic of Ghana National Plan of Action in IUU Fishing, 2014). A 2009 study of Ghanaian fisheries by the United Nations and Nippon Foundation stressed that there is currently a serious scarcity of fisheries resources, disputes over jurisdiction, inadequate conservation and management measures and a high influx of foreign fishing vessels in Ghanaian fishery waters, impacting heavily on the country s ability to meet domestic demand, threatening fish food security and the livelihood of many Ghanaians, as well as the country s economy. (Kwadjosse, 2009). International organizations such as the FAO, USAID, DFID and the World Bank have been working along with Ghana s Ministry of Food and Agriculture, Fisheries Commission and NGOs such as Friends of the Nation to improve fishery management at both the community and national levels. The Government of Ghana and the FAO identify the main causes of the fisheries production decline to be an inadequate fisheries governance framework, excessive fishing pressure, overcapacity in the fisheries, use of illegal fishing gear, and weak compliance with fisheries controls (Republic of Ghana, 2014) Fishery Resource Exploitation Fish catch statistics reported by the FAO show that the industry has experienced a general decline in fish catch since approximately the year During that same timeframe the size of the active fleet increased substantially. United Nations Food and Agriculture Organization (FAO) and the Marine Fisheries Research Division (MFRD) of Ghana s Ministry of Fisheries records indicate that the number of artisanal canoes, semi-industrial and industrial vessels all increased during this period. The decline in Ghana s fishery follows a significant increase in the harvesting of fish during the 1980s and 1990s well before the discovery of the Jubilee field. Figure 2-9 shows the overall fish landing data for Ghana from 1950 through 2013 and, where available, data on the number of fishing vessels active in Ghanaian waters. Figure 2-10 focuses on trends since 1980, showing a steep increase in the number of fishing vessels through the late 1990s, followed by a precipitous decline in catch. This decline started well in advance of the oil and gas exploration and appraisal drilling (2010) and later production activities in and around the Jubilee field. As for the increase in fish catch from , the experts interviewed believe this could be primarily related to strong upwelling that occurred during that time period. 16

22 Figure 2-9: Ghana Fish Landings and Number of Fishing Vessels Source: various Professor Patrick Ofori-Danson, a leading fisheries scientist at the University of Ghana, stated in an interview for this study that Ghana s estimated maximum sustainable yield for fisheries is approximately 400,000 tons/year. Records obtained from Ghana s Marine Fisheries Research Division indicate that this level was surpassed in the mid-1990 s, followed within five years by a significant and sustained decline in annual catch (see Figure 2-10). Biomass surveys estimate that the small pelagic fishery could sustain a maximum catch of 180,000 tons per year. Maximum sustainable yield (MSY) estimates for the large pelagic fishery are 60,000 tons per year, <50,000 tons per year for demersal fish, and 350 tons per year for shrimp (excluding artisanal catch). Annual demersal take, however, between 1980 and 1990 exceeded 50,000 tons per year, indicating that Ghanaian fisheries were under stress (FAO, 2004). 17

23 Figure 2-10: Ghana Fish Landings and Fishing Vessels, Source: Acorn International, based on data from Ghana Marine Fisheries Research Division Globally, fish catch has been increasing since the 1950s. However, much of this increase has been the result of aquaculture production, particularly since the mid-1990s (Figure 2-11). While capture production overall has remained fairly steady since the 1990s, the contribution of marine capture fisheries has decreased slightly since the late 1990s (Figure 2-12), although the global declines have not been as drastic as those witnessed in Ghana. In areas of the world s oceans where decreasing fish catch has been halted or reversed, global experience shows that strong, and sometimes extreme management measures (i.e. seasonal closures) were required to allow fish populations to recover. 18

24 Figure 2-11: World Capture Fisheries and Aquaculture Production Source: FAO World Review of Fisheries and Aquaculture 2012 Figure 2-12: Global production from marine capture fisheries Source: FAO World Review of Fisheries and Aquaculture 2012 Figure 2-13 shows fish catch trends in Ghana in relation to those of other West African countries for which comparable FAO data are available. Unlike the trends for global and Ghanaian production, most neighboring countries have experienced either stasis or modest increases in fish catch since This includes Angola and the Republic of Congo, both of which have active offshore oil and gas industry activities. Results for Nigeria, which has extensive offshore exploration and production, show a prominent increase in fish catch. 6 This independent study has not attempted to verify nor explain the results from FAO. Note that while the FAO data differ somewhat from the Ghana MRFD results shown in Figure 2-10, the same general trend is shown by both sets of records. 19

25 Figure 2-13: Fishery Production in Selected West African Countries Source: FAO Illegal Fishing Illegal, unreported and unregulated (IUU) fishing, is a significant concern in both Ghana and worldwide as it contributes disproportionately to depleting fish stocks. Residents of the Western Region interviewed for this study expressed concerns that fishermen continue to use illegal means to capture fish (including lights, explosives and dynamite) and that there is inadequate government monitoring to stop these unsustainable practices. One fishmonger said, for example, When we complain, they (the fishermen) tell us to mind our own business. But the problem of using illegal means to increase fish catch is not particular to Ghana. The World Ocean Commission s 2014 Summary Report identifies IUU fishing as a principle threat to the health of global marine ecosystems. As fish catches have dwindled, the competition for available fish has increased and the use of illegal methods have become more commonplace. Techniques employed to catch fish illegally include the use of chemicals, dynamite or other explosives, lights to attract fish, and small net mesh sizes to capture juvenile fish. Pair trawling is another illegal method that has been reported offshore Ghana. The international community has identified Illegal, unregulated and unreported fishing as one of the most severe problems affecting global fisheries. Given that fish stocks are shared across maritime boundaries and inadequate fisheries monitoring and management systems exist in most West African countries, it is difficult to remove the economic incentives that promote illegal fishing. Fishmongers interviewed for this study indicated that when fish were landed they were able to tell whether chemicals had been used to catch the fish. The use of chemicals can be felt on their hands when they purchase fish, and the catch has a decreased quality of skin and meat, especially after being smoked. Despite the efforts of various organizations to reduce illegal fishing methods, those interviewed for this study indicated use of chemicals and other banned methods was on the rise. Both the fishermen s associations and fish mongers noted that although 20

26 inappropriate methods were being used, it was an economic imperative to do so to ensure boats did not return empty, which could result in a devastating loss of cash for the businesses and dependent families. Illegal fishing and over-exploitation have caused a significant decline in the productivity of Ghana s fishery. Globally, the FAO estimates that illegal fishing can account for up to one-third of the catch in some important fisheries, although there are no estimates for how much illegal fishing has affected the Ghanaian fish stocks. However, in May 2014 the Government of Ghana, with support of the FAO, released its National Plan of Action to Prevent, Deter and Eliminate Illegal, Unreported, and Unregulated Fishing. The Plan consists of a 20-point action plan to address a range of issues from regional fisheries management and the use of market mechanisms, to the use of port and flag state controls to ensure compliance of the industry. 2.3 Existing and Planned Legislative and Management Actions Ghana is part of the UN Law of the Sea Convention and the FAO Compliance Agreement from The country is not a party to the UN Fish Stocks Agreement of Fisheries are regulated through Fisheries Act 625 of Through the Act, a Fisheries Commission (FC) has been established and mandated to manage the fisheries of Ghana. The objective of the Fisheries Commission is to regulate and manage the utilization of the fishery resources of Ghana and coordinate related policies. The Minister of Fisheries has ministerial responsibility over the FC (FAO, 2007). However, the Fisheries Commission has limited resources for executing its responsibilities, and as a result certain requirements of its legislative framework are not well enforced. One important example is the requirement for Fisheries Impact Assessments (FIAs). The Fisheries Act makes provision for preparation of FIAs. Specifically, the Act requires any proponent planning to conduct any activity other than fishing, which is likely to have a substantial impact on the fishery resources or other aquatic resources of Ghana, shall inform the Commission with a view to the conservation and protection of the resources. The Commission may require reports regarding the likely impact of the activity and the development of means of preventing or minimizing any adverse impacts. Several stakeholders advocated for compliance with the FIA provision in the Fisheries Act by the oil companies, as a separate requirement, in addition to the ESIA submitted to EPA for environmental permit. While the FC is exploring the means to give effect to that provision in their Act, the EPA tends to hold the view that a separate FIA may not be necessary or rather could be problematic (especially if the FC attempts to administer the process by itself). Ghana and the European Commission (EC) have been engaged in a dialogue process with regard to a range of corrective actions required to be taken by Ghana to meet obligations as a trading partner of EC. These corrective actions include enhancing the fisheries legislature framework, adopting a National Plan of Action against IUU fishing, adopting a system of dissuasive sanctions, adopting a fishery management plan, and strengthening the monitoring, control and surveillance system. 2.4 Threats to the Quality of the Marine Environment The 2008 Biodiversity Threats Assessment for the Western Region, Ghana (Coastal Resources Center, 2008) identified the following as key threats to marine biodiversity in the Region: 21

27 Overexploitation of marine fisheries resources due to illegal fishing methods Pollution from domestic and industrial solid waste By-catch of endangered species like seabirds, sea turtles, sharks, dolphins and manatees Weak governance, legislation and institutional framework due to the fragmented nature of environmental legislation and lack of political will to enforce legislation Development of oil and gas resources, causing conflicts with the fishing industry over the use of marine space, and potential negative impacts on coastal and marine habitats Climate change and sea level rise Climate change is a global phenomenon that is affecting each area of the world differently. Although any particular change in the environment is difficult to associate specifically with global climate change, observations may, in some cases, give rise to a likely correlation. The solution to reducing the current stress on Ghana s fisheries will need to take into account the range of factors environmental and cultural contributing to the decline. The Marine Fisheries Research Division of the Fisheries Commission has been observing beach temperatures and salinity as a means to measure the strength of upwelling off the coast since the year Although the driving force of the upwelling mechanism is not fully known, temperature and salinity play key roles in determining its strength. The upwelling index calculated by the Fisheries Commission shows that since 2000 there has been a general decrease in the strength of the upwelling (Figure 2-14), which results in lower levels of nutrients, primary productivity and ultimately the food source for various fish species. Upwelling is therefore an important factor in sustaining the fish population in the region. A decrease in the strength of the upwelling could exacerbate existing problems of reproduction and recruitment in fish populations. Figure 2-14: Annual Mean Variation in Upwelling Index, Source: Yaqub, H. B. et al,

28 As referenced previously, the World Ocean Commission s Summary Report 2014 highlighted overfishing as a key threat to the health of the marine environment on a global scale. Other threats identified include climate change and offshore oil and gas exploration, specifically: Threats to fish and marine mammals from seismic surveys CO2 and methane disturbance from gas flaring and venting Increased pollution Oil spills in deep and remote waters None of the stressors to the marine environment operate in isolation. In some cases, such as the decline in the fishery, multiple factors combine to have a much greater effect than any of the individual effects would have on its own. For instance, the fisheries sector is negatively impacted by overfishing of adult fish, capture of juvenile and sub-adult fish, loss of recruitment areas through the destruction of mangroves, destruction of coastal shelf habitat as a result of bottom-trawling, a decrease in nutrients and food supply related to a weakened upwelling, and attraction of existing fish stocks to the lighting on offshore oil and gas facilities. The result of the accumulation of effects is that there is no single management action that could be taken on its own to sufficiently reduce stress to the fisheries. Rather, a combination of actions is required to sufficiently reduce the multiple environmental and human-induced stresses, including those arising from the offshore oil and gas industry. Achieving a better understanding of the extent to which the development of oil and gas resources poses a threat to the marine environment is important for focusing attention on the management practices and policies needed to address actual risks versus unsubstantiated concerns. The next chapter provides a basis for this understanding. 23

29 3 Offshore Oil and Gas Industry Activities This chapter describes the oil and gas industry activities offshore Ghana, noting typical sources of impacts and management practices and summarizing the results of environmental performance monitoring. It is intended to serve as a basis for understanding the concerns raised regarding impacts to Ghana s marine and coastal environment. 3.1 General Description of Activities Oil exploration in Ghana dates back to From that time until the late 1990s about one hundred exploration wells were drilled, all onshore, with no significant discoveries except for the offshore Saltpond oil find in 1970 (Ghanaweb.com). Oil and gas exploration drilling began in earnest offshore Ghana in 2007, when the Jubilee field was discovered in a subsea basin about 60 kilometers offshore. Production in the field began in December of 2010 (see Figure 3-1). Figure 3 1: Timeline of Oil and Gas Exploration Activities Offshore Ghana Source: Anadarko, Jubilee Field Overview, December Accessed at Media%20Center/Jubilee%20Presentation.pdf At present an estimated 104,000 barrels of oil per day equivalent (bopd) are produced offshore Ghana from the Jubilee Field, through a network of 9 producing wells and a single floating production, storage and offloading (FPSO) facility (see Figure 3-2). Operations are supported largely from Takoradi, in the form of transfer of material and crews to offshore platforms by supply vessels, transfer of crews by helicopter, and management of oil field wastes 24

30 by onshore facilities. The FPSO separates produced oil from formation waters and gas prior to transferring the oil to tankers for export. Gas is presently flared at the FPSOs, although a pipeline and onshore gas plant are under construction to generate power from that gas. Produced water is discharged back to the ocean after treatment. Figure 3 2: Jubilee Field Production Facilities Source: Anadarko, Jubilee Field Overview, December 2010 Other activities have included exploratory and appraisal drilling in the West Cape Three Points Block and the Deepwater Tano Block. Development is planned in the Deepwater Tano Block, in the Tweneboa, Enyenra and Ntomme (TEN) fields. Contracts for the FPSO and subsea infrastructure have been awarded and plans are underway for a FPSO for this project with initial capability of producing 80,000 bopd. First oil from these fields is anticipated in (kosmosenergy.com) Given the success of these developments, additional exploration and appraisal and development activities are likely to occur offshore Ghana s Western Region. 3.2 Primary Sources of Potential Impacts The potential environmental impacts of offshore oil and gas operations can vary based on the nature of the activities and the sensitivities within the receiving environment. In general, however, the primary sources of potential impacts include: Emissions to the atmosphere Discharges to water Generation of waste Noise emissions Potential spills of oil or other materials Maintenance of safety exclusion zones and transportation Figure 3-3 provides an overview of the sources of impacts associated with one aspect of the exploration and production (E&P) activities - an offshore drilling operation, as an example. 25

31 Figure 3-3: Sources of Potential Impacts from Offshore Oil and Gas Drilling Operation Source: OSPAR Commission, 2009 Impacts to fishing may occur as a result of one or more environmental impact sources noted above. For example, excessive and inadequately managed discharges or spills could impact the quality of marine habitat and impact fish populations. Additionally, the presence, use and movement of vessels, equipment and installations may disrupt fishing activity in specific locations. Drilling rigs, seismic survey vessels and permanent installations establish exclusion zones for public safety within which fishing may not occur; thus creating some limitations on areas available for fishing. A general overview of environmental impacts related to the offshore oil and gas industry is presented below Air Emissions The main source of air emissions from offshore E&P activities is from combustion sources such as power generation and the use of compressors, pumps, and engines on vessels (including drill rigs, seismic vessels and support vessels) and offshore facilities. The main pollutants from these sources include nitrogen oxides (NOx), sulfur oxides (SOx), carbon monoxide (CO) and particulate matter. To a lesser degree, other pollutants such as hydrogen sulfide (H2S), volatile organic compounds (VOCs, including benzene, toluene, ethylbenzene and xylene, collectively referred to as BTEX). Methane and ethane, glycols and polycyclic aromatic hydrocarbons (PAHs) are also given off by flaring and other combustion activities or from venting or fugitive emissions of gas. Flaring is the controlled burning of natural gas released from the reservoir during production, testing and some 26

32 drilling activities. Much of the produced gas from the operations offshore Ghana is re-injected into the reservoir, although some is flared to stabilize operations. However, the recent completion of the Atuabo Gas Plant isallowing the Jubilee produced gas to be sent to the Plant for processing and benefitial use. The operators report that efforts to maximize gas exports and its subsequent processing for end users are ongoing. An interview with Tullow indicated that the company undertook air quality monitoring for sulfur dioxide (SO2), nitrogen dioxide (NO2), and ozone (O3) on the FPSO Kwame Nkrumah, and at its shore base offices in Takoradi. The results of this sampling indicated that the level of all three pollutants were well below World Health Organization and Ghana Environmental Protection Agency (EPA) guidelines. Tullow reports that this was supported by an air dispersion modelling study for potential additional Jubilee flaring emissions which showed that the concentrations of NO2 and CO from flaring at the Jubilee FPSO were very low (ERM, 2014). Air quality sampling was not conducted in or near the coastal communities as modeling predicted that emissions concentration were all attenuated to ambient conditions within 5-10 km radius of the FPSO source (60 km offshore) Discharges Discharges from offshore oil and gas activities may flow from a number of sources, including: Industrial Process Sources (associated with exploration or production activities): Produced water water associated with reservoir fluids, brought to the surface and separated from oil and gas. Produced water is treated and discharged to the sea, or captured for disposal. Produced water contains hydrocarbons and may also contain chemical additives used in production. Discharge of produced water is subject to EPA and international standards. Drill cuttings a mix of drilling muds, rock and fluids that are generated during drilling as the drill bit advances through the seafloor to the target drilling depth. Initially, drill cuttings may be discharged directly to the seafloor, but once a casing is installed around the drill stem, the cuttings are returned to the drill rig for treatment. Treated cuttings may be discharged to the sea or captured for disposal. Discharge of drill cuttings is also subject to EPA and international standards. Hydrostatic testing water water used to test the integrity of pipelines and vessels. The wastewater resulting from hydrostatic testing may include traces of hydrocarbons or chemical additives from the lines and vessels tested. This water may be discharged to the sea or captured for disposal. Discharge of this water is subject to the provisions of the International Convention for the Prevention of Pollution from ships (MARPOL) requirements, which sets standards for vessel discharges to minimize pollution of marine waters. Cooling water water used to cool equipment and after use may contain traces of hydrocarbons or chemicals. Discharge of this water is subject to MARPOL requirements. Key discharges from the offshore oil and gas activities include controlled and monitored releases of drill cuttings and produced water after treatment to meet Ghanaian standards. Vessel discharges (associated with vessel operations): Ballast water water used to maintain stability of vessels. Discharge of this water is subject to MARPOL requirements. Bilge water water that collects in the lowest part of a vessel and may be a mix of various water sources and may contain pollutants. Discharge of this water is subject to MARPOL requirements. 27

33 Deck drainage rainwater or water used for washing vessel decks (including drill rig decks). For larger vessels, deck drainage is collected and treated through an oil/water separator to remove any residual oil collected from equipment. Discharge of this water is subject to MARPOL requirements. Domestic discharges (associated with living quarters/crew) Grey and black water these wastewaters are generated from showers, washing activities (grey water) and toilets (black water) onboard vessels or installations. Discharge of this water is subject to MARPOL requirements. Food waste food waste is macerated (chopped up into fine particles). Discharge of the macerated food is subject to MARPOL requirements. Of the discharges listed above, produced water, drill cuttings and ballast water are of most relevance for the industry offshore Ghana. Accordingly, these are discussed further below. Consistent with other producing offshore oil and gas fields worldwide, by far the greatest volume of discharge is produced water Produced Water Oil in Water (OIW) measurements are used to evaluate the content of hydrocarbons in produced water and can be used to evaluate the effectiveness of treatment of produced water prior to discharge to ensure that pollution is minimized. In Ghana the allowed OIW limit set by the EPA is 29 mg/l. Tullow has set a target limit of 20 mg/l for produced water discharged from the Jubilee FPSO 7 ; if OIW levels exceed these levels, the water is held for further treatment prior to discharge. Interviews with Tullow indicate that monitoring results from 2013 showed that the OIW in produced water discharged from the Jubilee FPSO varied between 20 mg/l and 29 mg/l Drill Cuttings Exploration, appraisal and development wells have been drilled in and around the Jubilee Field over the last several years to find, evaluate and produce oil and gas from hydrocarbon-bearing reservoirs beneath the sea floor. In each case, the drilling activity removes a column of soil and rock that is brought to the surface as cuttings. For the portion of the well that used water-based fluids (WBF), cuttings were discharged to the sea. Where a non-aqueous drilling fluid (NADF) was used, cuttings were stored on the drilling units and then transported to shore for disposal (Jubilee EIA). NADFs may include chemicals that are harmful to the environment; therefore these cuttings are not discharged to the sea 8. Equipment is used to treat cuttings to reduce the Oil on Cuttings (OOC) content, a measurement used globally to evaluate the residual hydrocarbons that adhere to the cuttings. In Ghana, cuttings with an average OOC over 10 percent cannot be discharged, while the discharge of cuttings with an average OOC over 2 percent is subject to a surcharge by EPA. Cuttings generated during drilling are returned to the surface and vibrated in a shale shaker that removes large solid particles. The cuttings can then be dried and sent through a centrifuge that further removes excess mud. Cuttings are discharged at approximately 15m below the sea surface. Modeling can be performed to evaluate the potential distribution of cuttings on the seafloor. 7 This is the only source of produced water offshore Ghana at present with the exception of small amounts produced for a few weeks at a time during occasional well testing operations. 8 Tullow and Kosmos report using low toxicity drilling fluids when drilling conditions make the use of water based fluids ineffective. 28

34 Concerns for environmental impact from the discharge of drill cuttings may include: Toxicity to marine life due to the presence of residual oil or other materials such as metals that may have been present in drilling fluids. Smothering of benthic marine life or disturbance to benthic habitat or sensitive seafloor features from the physical impact of the material settling onto the sea floor. A study conducted in 2009 (Nyarko et al, 2011) noted that concentrations of various heavy metals (Cu, Cr, Hg, and Zn) were within the expected background concentration range in deep-sea sediments of the Jubilee oil field. In other words, the study results suggest that these metals were not necessarily attributable to oil industry operations but may be present from natural sources or other historic anthropogenic (human caused) sources. Barium, however, exceeded the expected background levels (> 0.6 µg/g) at all sampling stations and particularly in the area of the Jubilee field (Nyarko et al, 2011). Barium, as barium sulfate or barite, is a common ingredient used in drilling fluids. Reported barium concentrations in the Nyarko study ranged between 1.5 and 171 µg/g, while the baseline information for the Jubilee Field found much lower concentrations between 5-6 ppb, or to µg/g. The Nyarko study concluded that elevated barium levels observed around the Jubilee field may have been the result of the release of drill cuttings into the environment during initial offshore exploratory drilling. When discharged, cuttings disperse through the water column with the ocean currents, but still generally settle on the seabed in a fairly localized area. Most suspended solids tend to settle out within m from the discharge point, but thin accumulations can be found 1 km or more depending on the water depth and current speeds. 9 Cuttings dispersion modeling and monitoring studies performed for drilling programs worldwide indicate that within the area closest to the well (generally less than 50m radius), cuttings can accumulate in layers sufficiently deep (up to roughly 0.25 cm) to partially smother or impair benthic organisms and corals, if present (see Section 2.1.3). Once settled, barium concentrations in cuttings tend to stay stable or reduce slightly over time (CNSOPB, 2009). When disturbed by activities such as trawling, barium tends to adhere to the cuttings particles and, because it is not soluble in seawater, does not further disperse into the water column (OSPAR 2007a in OSPAR 2009). A 2012 study was performed to evaluate the impacts of drill cutting discharge approximately 60 km offshore Ghana and in waters 1100 to 1700 m deep (Balcom, et. al, 2012). The subject drilling activity utilized non-aqueous drilling fluid (NADF) (Escaid 20) and cuttings were treated to approximately 5% oil on cuttings prior to discharge. It was expected that localized impacts may be seen including patchy zones of anoxic conditions and disturbed benthic communities, altered grain size, and total organic carbon (TOC) concentrations, as well as potentially detectable changes in metals and hydrocarbon concentrations. The study included the collection of 46 samples at stations in the near-field, mid-field and far-field strata from a wellsite. The results of the study found that the accumulation of drill cuttings around wells was very localized, consistent with the findings of prior studies in the area and with general industry findings. Specifically, Balcom, et al., observed the potential accumulation of drill cuttings in most, if not all sediments in near-field (less than 100m) and some mid-field ( m) zones around platforms. The sampling showed that impacts were found to be limited to an approximately 500m radius from the wellsite, with decreasing impacts observed with increasing distance from the wellsite. Reduced numbers of benthic species, and increases in hydrocarbon and metal concentrations were observed in the higher accumulation zone closer to the well site, though none of these were considered to be significant. 9 Neff, J Composition, Environmental Fates, and Biological Effect of Water Based Drilling Muds and Cuttings Discharged to the Marine Environment: A Synthesis and Annotated Bibliography. Prepared for Petroleum Environmental Research Forum (PERF) and American Petroleum Institute (API). Retrieved from the PERF website: 29

35 An interview with Tullow revealed that a marine environmental monitoring survey will be conducted within the Jubilee Field to assess the overall impacts of all operational discharges (drill cuttings, water based drilling fluid discharges, produced water, completion fluids, etc) on water column and sediments quality status Ballast Water Ballast water is taken on and discharged from ships ballast tanks to help maintain proper buoyancy and safe operation. Figure 3-4 shows how ballast water is managed. Figure 3 4: Ballast Water Cycle Source: globallast.imo.org, 2014 The primary environmental concern with ballast water discharge is the potential for non-native species to be introduced to an environment when the water (which may originate from another country or region) is discharged. The vast majority of marine species carried in ballast water do not survive the journey, due to the disturbance caused by the ballasting and de-ballasting cycle, and due to the environment inside ballast tanks which can be inadequate for organism survival. For those that do survive a voyage and are discharged, the chances of survival in new environmental conditions are further reduced due to predation by and/or competition from native species or changes in temperature, among other factors. However, when all factors are favorable, an introduced species may survive to establish a reproductive invasive population in the host environment, out-competing native species and multiplying into pest proportions. In 2004, the International Maritime Organization (IMO) established the International Convention for the Control and Management of Ships Ballast Water and Sediments (BWM Convention). 10 The Convention requires all ships 30

36 to implement a Ballast Water and Sediments Management Plan, to carry a Ballast Water Record Book, and carry out ballast water management procedures to certain standards. BWM requires ballast water exchange to occur at least 200 nautical miles from the nearest land and in water at least 200 m in depth. In cases where the ship is unable to conduct ballast water exchange, it must be done as far from land as possible and at least 50 nautical miles from the nearest land and waters at least 200 m in depth. (IMO, 2014) Solid Waste Management Solid waste generated by offshore oil and gas activities is categorized and separated on the offshore installations. Some of these wastes may be reused or recycled where possible; otherwise they are sent to shore for disposal in waste management facilities. An example of the types of wastes produced by Kosmos Energy in its operations offshore Ghana is presented in Table 3-1. Management of wastes generated from offshore operations is subject to MARPOL regulations. Table 3 1: Kosmos Waste Streams in Ghana Color Waste Classifications Code Waste Streams Blue General Waste General Solid Waste & Food Green Non-hazardous & segregated wastes for recycling Wood, General Plastic, Paper & Kitchen Grease/Oil Black Scrap Metal Metals Red Hazardous Wastes Batteries Electronic Flammable Liquids Waste Oil Oily Solids Oily Sediments Tank Slops Chemicals Containers Yellow Special Hazardous Fluorescent Lights Medical Waste (first-aid sources) Wastes Radioactive Waste (NORMS) Noise Generation Noise arising from activities related to the offshore oil and gas industry includes elements such as construction work, drilling, ship traffic, and seismic surveys (OSPAR, 2009). Seismic operations, and installation of structures, in particular pile driving, can adversely affect marine mammals and fish (BOEM, 2014). Noise from seismic surveys has received special attention in the oil and gas industry due to the potential effects on marine mammals and sea turtles. Effects to fish have also been studied. 31

37 The possible impacts to marine fauna associated with seismic survey noise include: Damage to individual fish, fish eggs, and larvae in the vicinity of air gun use Disruption to marine fauna habitat by introducing noise from air guns that could interfere with echolocation, grazing, and other behaviors of these sensitive animals Studies have shown varied results for marine fauna thresholds for physical and behavioral harm from marine noise. The discussions below addresses relevant studies to support evaluation of the potential impacts of noise from air guns to fish, marine mammals and sea turtles. Noise from seismic surveys can cause fish to alter movements or avoid certain areas and can cause temporary hearing loss and physiological effects depending on the proximity of the sound source to the fish and the sensitivity of the species. Spawning aggregations of fish could potentially be temporarily disturbed. Mortality of fish, however, is not likely. Studies indicate that fish typically exhibit a startle response to seismic airgun sound (generally at levels exceeding db re 1 mpa) followed by tolerance and after some time, resumption of normal behavior. The temporary avoidance of fish due to seismic survey noise could potentially cause short-term localized reduction in fish catch. (BOEM, 2014) Seismic surveys can impact marine life in the direct vicinity of the air gun releases, but more mobile species temporarily scatter to avoid such impact. Studies on the impact of underwater noise emitted by air guns on marine mammals leave significant uncertainty, and agree that further study is needed. A study by the National Environmental Research Institute, Denmark (2009) found that injuries to individual marine animals caused by air gun firing during seismic surveys has little impact, unless the individual animal belongs to a vulnerable species, at a population level. The study states that the significant risk comes from behavioral reactions to sound that can impact at a population level: As animals in most cases react to sounds at much lower levels than those needed to inflict damage, these reactions can occur at much larger distances from the source and thus have the potential to affect a very large number of animals (National Environmental Research Institute, 2009, p.16). The difficulty of quantifying and mitigating these impacts to marine mammal populations from seismic surveys was also noted. An overview of the impacts of underwater sound in the marine environment performed by the OSPAR Commission in 2009 states that there is no conclusive link between performing seismic surveys and mortality in marine mammals (OSPAR Commission, 2009). An environmental assessment for L-DEO s Northeast Pacific Seismic Surveys (2012) similarly noted the lack of specific documentation of temporary or permanent hearing impairment/ damage in marine mammals exposed to sequences of air gun pulses (LGL Ltd., 2012, p.156). However, there is evidence to suggest that different species of marine mammals have varied physical and behavioral responses to seismic surveys. An important study with regard to seismic survey noise impacts to marine mammals was performed by Southall, Bowles, Ellison, Finneran, Gentry et al, Their study indicated that the lowest levels of seismic noise that might elicit slight auditory injury to marine mammals range from 186 db re 1 mpa to 198 db re 1 mpa depending on the species. The US National Marine Fisheries Service (NMFS) sets criteria for considering marine mammal species to be harassed to the point of injury at 180 db db re 1 mpa, and to experience behavioral harassment at 160 db re 1 mpa. (BOEM, 2014). 32

38 A modelling study by O Brien et al indicates that noise levels generated by air guns are approximately 254 db at the source, generally dissipating to 214 db within 100 meters and 190 db within 1,500 meters from the source (O Brien, et al, 2002). This comparison suggests that marine mammals within distances up to 1,500 m or more from the source of one air gun could receive slight auditory injury. Depending on the type of marine mammal, individuals could receive more severe injury at closer distances and could detect and possibly be disoriented by noise at a much greater distance from the source. The study of underwater noise impacts to marine mammals is complex. Different species are sensitive to noise at different frequency ranges, and marine mammals do not hear equally well at all frequencies. Researchers (Southall, 2007, NMFS) have categorized different species into functional hearing groups and utilize different weighting criteria for evaluation of each group to identify where a species sensitivity is high or low. Whales are considered to be in either low or moderate frequency groups while many dolphins are in the moderate frequency group. Though severe physical injury and mortality of marine mammals has not been directly linked to seismic survey noise, studies have shown evidence of reactions including alertness, minor response (such as vocal modifications), cessation of feeding or interaction, temporary avoidance, modification of group structure or habitat abandonment. (Southall, 2014). A number of studies have been performed for different species and tools are available for assessing the potential impacts to marine mammals from a specific survey depending on the details of a given seismic survey. On-going studies sponsored by the joint industry-academic group E&P Sound and Marine Life Program 11 are being conducted to better understand the impact of sound on marine mammals and other marine life. Submarine noise from seismic surveys can harm marine mammals within 2 km of the source, and can potentially interfere with echolocation at greater distances. The limited monitoring results available for this study are not sufficient to indicate whether seismic activities or other oil and gas industry activities that generate underwater noise have in fact impacted fish or marine mammal habitat offshore Ghana. Marine mammal observations performed by offshore operators interviewed indicate the presence of 34 primary species (including turtles) in the vicinity of exploration activities throughout the course of those activities, but do not measure any difference between pre and post activity prevalence or behavior Spills Spills from offshore oil and gas facilities can occur due to equipment failure, accidents or human error. Very large spills can be catastrophic to the marine environment and coastal livelihoods, but these are rare events. Such spills may result from the complete loss of well control (known as a blow out ), such as occurred with the Macondo well. The rate of blowouts in the US Outer Continental Shelf between 1996 and 2009 was percent. Since the subsequent Macondo spill, important advances in well control, process safety management and spill containment and response practices have been adopted and applied by operators, regulators and financiers/insurers worldwide. These advanced practices and technologies further reduce the likelihood of spills from offshore oil and gas activities, including blow outs. 11 See 33

39 Kosmos, for example, adopted new Well Integrity Management guidance in early 2013, based in part on industry lessons learned from the Macondo spill investigation. Tullow has provided materials and some training to coastal communities regarding what actions to take in the event of a major oil spill. Community members indicated their satisfaction with this as a first step, but expressed a desire for further practical training to ensure they are prepared for any event. Ghana developed a national oil spill contingency plan which is currently administered by the EPA, and each of the operators is required to have its own plan in place. Currently, Ghana has a contract in place with Oil Spill Response Limited for a Tier III (major) spill. For Tier I and II incidents, offshore operators, and the government of Ghana have equipment in place and conduct drills to ensure they are prepared. A significant spill could affect fishing in several ways: Oiling of fishing gear and equipment Adverse effect from oil to fish decreasing fishing populations Restriction of access to fishing areas for cleanup activities The effects to fish and other marine life on which fish may use for food are discussed below. Fish Fish can be adversely impacted by contact with and ingestion of toxins from a release. US EPA declares that fish: may come into direct contact and contaminate their gills; the water column may contain toxic and volatile components of oil that may be absorbed by their eggs, larvae, and juvenile stages; and they may eat contaminated food. Fish which are exposed to oil may suffer from changes in heart and respiratory rate, enlarged livers, reduced growth, fin erosion, a variety of biochemical and cellular changes, and reproductive and behavioral responses. Chronic exposure to some chemicals found in oil may cause genetic abnormalities or cancer in sensitive species. If chemicals such as dispersants are used to respond to a spill, there may be an increased potential for tainting of fish and shellfish by increasing the concentration of oil in the water column. 12 Plankton Larval fish and certain species of plankton are at risk of harm from an accidental spill because they have little or no mobility. USEPA notes that fish eggs or larvae could die or become deformed by contact with oil from a release. Population-level impacts could occur if plankton are significantly impacted; e.g., if a release occurred during spawning, reproduction could be hindered. Additionally, if oil becomes trapped in sediment and leaches out over time then longterm exposure could occur. 13 Plankton play an important role in the food chain and severe impact to plankton could adversely affect the marine ecosystem. Benthos Benthic organisms can be affected when oil spilled to the marine environment coagulates and settles to the sea floor. Oiled sediment and organic matter falling from the water column could deposit in a localized area near a release and accumulate, impairing the quality of the benthic environment over several years or more. The severity of impact would depend on the nature of the release and dynamics of the environment. 14 Ghana lacks sufficient data to determine the economic impacts of the damage from a potential major spill event. For instance, in the artisanal fishery, no specific catch statistics are kept which would identify the amount of 12 United States Environmental Protection Agency (US EPA), Office of Emergency and Remedial Response, Oil Program Center Understanding Oil Spills and Oil Spill Response. Retrieved from the US EPA website: 13 US Department of the Interior, Bureau of Ocean Energy Management. July Outer Continental Shelf Oil and Gas Leasing Program: , Final Programmatic Environmental Impact Statement. 14 US Department of the Interior, Bureau of Ocean Energy Management. July Outer Continental Shelf Oil and Gas Leasing Program: , Final Programmatic Environmental Impact Statement. 34

40 compensation fishers should be paid for loss of their livelihood. The lack of data could result in either too much or too little compensation being awarded in comparison to the actual impacts. Fisheries Commission has taken steps to remedy this by requiring all canoes to be registered, although specific catch statistics per vessel are not currently captured. In addition, the Government does not administer any fund, or require companies to post a bond, for possible compensation to be paid for liabilities arising from a large spill. A large oil spill could generate significant impact to Ghana s marine and coastal environment though unlikely to occur, this potential impact warrants critical attention. No large oil spills have occurred as a result of oil and gas activities offshore Ghana, and as noted such a spill is unlikely to occur. Of higher likelihood are smaller spills, which may or may not have a cumulative effect on the marine environment. For instance, in December 2009 Kosmos Energy spilled approximately 600 barrels of lowtoxicity mud into the sea, followed by two smaller spills in March 2010 and July 2010 (Ghana Web News, 2010; My Joy News, 2010). Each of these spills was identified and reported publicly by Kosmos. No reliable information was found during this study to indicate what if any effect these spills may have had on the marine environment over time. In the experience of the study team, the effects of such spills on the health of the marine environment would likely be minor and not persistent, but more extensive impacts could result from more frequent or larger spills Safety Exclusion Zones Safety exclusion zones are established around offshore oil and gas facilities to prevent fishing and marine vessels from colliding or becoming entangled with these facilities. The exclusion zones, typically defined by a 500 1,000 meter radius around a facility or activity, are established and enforced as a means to keep all parties safe. While exclusion zones for drilling and seismic exploration activities are typically only maintained for periods of up to two to four months, those established around FPSOs and other production facilities are maintained throughout the life of the facilities (generally a few decades). Establishment of safety zones in a state s exclusive economic zone (EEZ) to protect the safety of offshore installations is addressed in the United Nations Convention on Laws of the Sea (1982) 15. IMO has also adopted resolutions relating to the safety of offshore oil and gas installations and safety of navigation to address unsafe consequences of collisions with offshore facilities. An IMO Sub-Committee on Safety of Navigation has more recently (2010) considered extending safety zones to more than 500m, though IMO has not formalized such a change. Countries are able to specify greater exclusion zones if desired. Fish are attracted towards the offshore facilities due primarily to the use of lighting at night, concentrating the fish in areas where they are unavailable for catch. As the number of operations in the oil and gas industry increases in Ghana, so do the number of areas in which the fishers are excluded over short or longer term periods. Although relatively small in comparison to the surface area available for fishing, the facilities act to both attract fish and then exclude fishing boats from these areas. Stakeholders interviewed for this study have raised the concern that the presence of as few as ten facilities could 15 Ghana is a signatory to this Convention. ( ) 35

41 drastically reduce the available fishing area for some gear (see further discussion in Section 4.1.2). This is a particular concern in relation to drift gill nets, which can be extremely large and difficult to keep out of the exclusion zones. The concern may continue to gain importance as further offshore oil and gas activities, and their added exclusion zones, are introduced offshore Ghana. Exclusion zones are required by international safety standards, but they frustrate fishermen who are drawn to the high density of fish around offshore facilities. Offshore operators provide advance notice to fishermen and dedicate vessels to patrol the exclusion zone in an effort to prevent incursion within the zone by fishermen. Nonetheless, in the study team s experience, incursions are common, with up to several incursions occurring around some facilities each day. In addition to the introduction of exclusion zones around stationary offshore facilities, the development of the Jubilee field has increased the number of vessels operating in Ghana s waters and the Western Region in particular. Support vessels shuttle materials and personnel to the offshore facilities from Takoradi. These vessels are often very large in comparison to the canoes that are used for fishing and have limited mobility. During the exploration and early production phases of Jubilee there were a number of collisions and close calls between fishing and support vessels. In some cases, fishing gear was damaged or destroyed during the trips to and from the offshore facilities. Fishermen have expressed their frustration with the increased vessel traffic, but indicated they were becoming more aware of how to interact with the larger vessels and the importance of moving out of the way. This is attributed in part due to outreach and education programs run by the Jubilee Partners. Other steps have been taken to try to reduce conflicts between the different maritime users, such as the addition of radar reflectors to the masts of fishing boats. This effort met with mixed success, as fishermen reported the reflectors were not durable and tended to fall off while at sea. Several organizations are keeping statistics on conflicts between vessels, including the Fisheries Commission, Tullow, and the non-governmental organization Friends of the Nation. Each of these organizations reported an improving trend of fewer incidents such as collisions, damage to fishing gear, and near misses between fishing vessels and supply vessels for the oil and gas industry Cumulative Effects Examples of specific sources of potential impacts from Ghana s offshore oil and gas activities have been provided above to illustrate the type and scale of potential impacts related to groups of activities. These need to be understood in the context of cumulative impacts that may be associated with all of the discharges, wastes, exclusion zones and other sources of impact from the sum of all industry activities offshore Ghana over time. The effects of impact sources from all offshore oil and gas activities over multiple years will, of course, have a greater magnitude of overall impact on the marine environment than individual sources operating at a given time. Further, none of the impact sources from oil and gas activities nor other sources of impact on the marine environment is operating in isolation. Multiple stressors may have an additive effect on a certain component of the environment. For instance, the fisheries sector is influenced by: Mangrove destruction/reproduction area loss 36

42 Catch of juvenile and sub-adult individuals Over-catch of adults Attraction of current stocks to offshore facility lights Destruction of habitat through trawling, global and regional marine pollution and potential oil spills Decreased upwelling of nutrients/food supply Careful evaluation of the potential impacts and management practices for oil and gas activities offshore Ghana needs to consider these cumulative factors. Chapters 5 and 6 take cumulative effects into account in addressing the findings and recommendations of this study, respectively. Chapter 4 describes the primary concerns that have been raised by stakeholders regarding potential impacts of offshore oil and gas activities in Ghana. 37

43 4 Issues and Concerns Raised Regarding Changes to Marine Environment The study team reviewed nearly 200 relevant documents, articles and records and engaged more than 100 stakeholders in order to understand the range of concerns that have been raised regarding marine/coastal environmental conditions and trends in Ghana. Those that have been most commonly cited as concerns linked with oil and gas industry activities include the following: Fishery, including Decreased Fish Catch Safety/Exclusion Zones Vessel Conflicts and Collisions Whale Mortality Algal Bloom/Sargassum Tar Balls General Marine Environmental Conditions Discharges Routine Discharges Accidental (Oil Spill) Coastal Socio-cultural Conditions The concerns raised regarding each of these are described in the sections that follow. 4.1 Fishery Three specific issues have been raised in relation to the perceived impact of oil and gas activities on Ghana s marine fishery and fishing activities a decline in fish catch, disruption by exclusion zones, and conflicts with oil and gas industry support vessels Decreased Fish Catch Concerns regarding the declining fish catch have been raised in Ghana for over a decade (Modern Ghana, 2000; MyJoy News, 2013, Republic of Ghana National Plan of Action in IUU Fishing, 2014). However, since the commencement of commercial oil production in 2010, many claims have been directed towards the oil and gas industry as being a major contributor to the decline. Many fishermen in the Western Region report that they believe the fish catches have declined as a result of oil and gas activity. Of particular concern is a potentially disproportionate negative economic impact on women due to decreased catch levels (Boohene & Peprah, 2011). A key concern from the communities is the reduction in bumper catches during the upwelling season. Historically, fishermen and fishmongers reported that a bumper catch could result in 20 baskets of fish (per canoe) after one day of fishing. But currently, two to three days of effort during the upwelling season may catch only four baskets of fish. This decline is perceived by the fishers to have started approximately when oil was discovered in Interviewed fishermen association members recognized that oil and gas may not be the main cause of the decline, but suspect the industry is contributing to declines (Interviews with Western Region House of Chiefs, fishmongers). 38

44 Likewise, one of the Ghanaian NGOs stated that they don t believe oil and gas industry is responsible for the fishery decline, but they are concerned that an oil spill or poor environmental management practices could significantly harm the fishery further Exclusion Zones Operators of fishing vessels also reported being frustrated with the implementation of 500m safety exclusion zones around the offshore facilities, due to the aforementioned higher concentrations of fish than in the open ocean. The fishermen interviewed noted that if fish were abundant in other areas the exclusion zones would not be a concern, it was only because of the low catch rates and clear evidence of greater numbers of fish near the facilities that they were frustrated. Several fishermen suggested that they would be less concerned if there were a means to deter the fish from congregating in the exclusion zones. Oil company representatives and government officials participating in the stakeholder workshops stated that the exclusion zones are an international standard applied for the purpose of preventing accidents that pose safety and environmental risks. This concern was raised by many of those interviewed and has been covered extensively by NGOs as well as the Ghanaian press. What Are People Saying? We don t believe there is a direct relationship between oil and decline of fishery but we do see oil as challenge to fishing industry in the future (due to potential spills) NGO EIA trivializes fishing impacts - involve fisheries sector in this analysis. Mitigation measures identified in the EIA were not fulfilled, including the need for FLOs (Fishing Liaison Officers) at sea. Fishers Association Need for fishery impact assessments is ignored - NGO The attraction of fish by the FPSO is a real frustration... Fishermen would welcome attempts by the company to find a method to repel fish from the area Fishers Association The catch is less diverse than it once was. Since 2009 the use of lights on boats has been reducing the available fish even further. Fisher Organizations / Fishmongers Illegal fishing practices and overfishing are the key threat to fisheries International expert Vessel Conflicts and Collisions Vessel traffic is possibly the most frequent complaint of fishermen. Fishermen cited two main impacts from conflicts with supply vessels for the offshore industry: Collisions at sea due to the increased number of boats that are active in a relatively concentrated area Destruction of nets or other fishing gear by the supply vessels 39

45 There have been several instances reported where the fishermen had a minor collision or close call with a supply ship, but were unable to provide a name or number of the ship to issue a formal complaint. Fishermen acknowledged that communication and outreach programs by the offshore operators have been helpful in reducing the number of incidents. The study team received documentation of one interaction between a canoe and the seismic vessel BGP Pioneer. Although the documentation indicates that 5 bundles of nets were lost, the community members who shared the information alleged that the canoe was sunk by the seismic ship in 2010 and that no follow-up occurred nor was compensation provided. Damaged nets continue to be a concern, particularly when drift gill nets are used. Attempts have been made to ensure nets are marked, but still operators of supply vessels report difficulty in determining whether what they are seeing is one or multiple net markings. At the same time, fishermen who are out for several days and working in the vicinity of oil and gas industry activities indicate that they may not always be aware of an approaching supply ship and thus not able to remove gear in time to avoid damage to nets and lines. Some fishermen in Ghana s Central Region use floating lights to mark the boundaries of drift nets so that they can more easily find and retrieve the nets at night. Use of these lights (see Figure 4-1) would also make the nets easier to see and be avoided by support vessels. Figure 4-1 Lights Used by Fishermen in Central Region to Mark Drift Nets Source: Photo provided by CRC (University of Rhode Island Coastal Resources Center), October 2014 A subsequent frustration reported in the communities was that there is not a clear mechanism for complaints to be made. This concern is addressed in Section Whale Mortality The stranding of whales on Ghana s beaches has been observed and recorded from as far back as 1975 (Ghana EPA, 2014a). For instance, in October of 1988 two whales were beached at Bortianor (near Kasoa), and Chorkor in Accra (People s Daily Graphic, 1988). However, recently there has been an increase in the number of dead 40

46 whales washing up on Ghana s beaches, particularly in the Western Region. Between 2009 and 2014 there were 24 reported dead cetaceans along Ghana s coast, with 20 of these occurring in the Western Region (Ghana EPA, 2014a). Some have raised concerns in the media speculating that the increased frequency of dead whales on the Western Region shore may be the result of offshore oil and gas industry activities (see reference in What Are People Saying? box below). This concern prompted Ghana EPA to carry out a study into the cause of the increase in dead whales beaching. The study investigated the causes of death to the extent possible, considering that some of the whale carcasses were in such an advanced stage of decomposition so as to prevent necroscopic examination. The causes of death suggested by the study varied from vessel strikes, to ingestion of debris to harm by fishing activities to natural causes. The report did not reference oil and gas activities per se as a potential cause, although the increase in marine vessel traffic to support the oil industry could increase the likelihood of vessel strikes. What Are People Saying? Though the death of whales is not an uncommon phenomenon, the frequency within the last four years is worrying, - NGOs (per BBC, suggesting connection with offshore E&P activities) There was some speculation that the oil and gas industry caused this, but we don t have any evidence to determine causes. - Wildlife Division Whales are common offshore Cape Three Points URI/CRC researcher studying the Western Region EPA whale study: Many of the carcasses are so degraded that they were likely floating for several days or more A variety of causes including vessel strikes, fishing by-catch and ingestion of debris Ghana marine expert conclusion: Current patterns (west to east) indicate that most of these whales died well west of Ghana s marine zone and drifted in currents to Western Region beaches. Although the investigations of the EPA indicate there are multiple reasons for the death of the whales, news reports and editorial letters often claim these deaths are related to the oil and gas industry. One NGO reported to the international press (in relation to concerns about oil and gas activity impacts) that Though the death of whales is not an uncommon phenomenon, the frequency within the last four years is worrying (BBC, 2013; Ghana Web, 2010b; Joy Online, 2013). Particular concerns have been raised in relation to the use of acoustic surveys during the exploration stage (Daily Graphic, 2013), and collisions with oil supply vessels. 4.3 Algal Blooms Fishermen, tourism industry representatives and other stakeholders have raised concerns over increasing amounts of floating algae (seaweed) fouling nets and beaches in Ghana in recent years. It is reported that Sargassum seaweed was present in the 1980s and 1990s along the shores of Cote d Ivoire, but it had not reached Ghanaian waters in significant quantities at that time (Interviews with fishermen and URI/CRC, 2014). In 2011, large amounts of Sargassum reached the shore of Ghana. Exacerbating this condition is the periodic blooms of Ulva clathrata 41

47 found in Ghana s marine waters, reportedly from seasonal flushing of Abby Lagoon and other coastal lagoons. Ulva, another floating algae, is referred to globally as sea lettuce and known in Ghana as green green. At times during 2014, fishermen in the Western Region noted that they simply parked their boats and waited to fish on days when the volume of seaweed was relatively low. What Are People Saying? Fishers Associations: Sargassum was coming in the 80s and 1990s in Cote d Ivoire, but when it started coming on shore in Ghana (2011), given the amount, people began assuming it was coming from the Ghanaian oil activities. In the absence of information, people are assuming changes to the marine environment that they observe are due to the oil and gas activities. Poses problems to fishermen having a full net of the seaweed which takes 3 days to properly clean. Coastal Resources Center Study: Eutrophication of lagoon in Cote d Ivoire is periodically flushed, and this feeds the Ulva blooms offshore Ghana. According to interviews and press reports, many assumed that the increase in algal bloom is related to the offshore oil and gas industry activities. Others interviewed for this study indicated that although the source of the seaweed might not be from the oil and gas industry, they would appreciate having clarity provided by industry as to whether or not it was contributing to the severity of the incidents. The EPA issued a public statement on the matter in May 2014, but community members submitted that this information had not been sufficiently disseminated within the coastal communities to help them understand the known or suspected causes of the algal blooms. The Chief Fishermen interviewed expressed their desire that the EPA should take a more active role to inform and educate communities on the issue. 4.4 Tar Balls As noted in Chapter 2, tar balls have been observed along Ghana s shorelines for decades. In fact the presence of tar balls on beaches is a global issue, and the literature reviewed points to a number of causes, both anthropogenic and natural. Stakeholders reported seeing an increase in the amount of tar balls appearing on beaches in Ghana (including but not concentrated in the Western Region) in 2011, prompting concerns that these have been generated by the offshore oil and gas industry activities. The Ghana Petroleum Commission (PC) reported that it has received complaints from local residents that their economic opportunities are being destroyed by the presence of tar balls and other oil and gas impacts (Interview with PC, July 2014). But the PC noted that it advised those raising the concerns that tar balls were present before oil production started offshore Ghana. 42

48 What Are People Saying? Tar balls have been seen along the coast since the 1960s, and would appear for up to 2 or 3 weeks at a time. -Fishers Association Main sources of tar balls appear to be passing international tankers and seeps, but it is easy enough to trace the source from sample analysis. International marine experts As much as one half of the oil that enters the coastal environment comes from natural seeps of oil and natural gas. These geologic features are often found in places where oil and gas extraction activities are also located. As a result, many surface slicks and tar balls caused by seeps are often attributed to releases from oil and gas platforms. - Woods Hole Oceanographic Institute 4.5 General Marine Environmental Conditions The broad range of stakeholders interviewed for this study shared concern over the need to ensure that the quality of marine environmental resources while responsibly producing oil and gas from subsea basins. In a foreword to Ghana EPA s 2014 Strategic Impact Assessment of the Oil and Gas Sector, the Ministers of Energy and Environment, Science, Technology and Innovation cautioned that there is a need to consider serious policy choices and environmental concerns that need to be addressed to ensure that oil and gas development contributes to sustainable broad-based development (EPA, 2014). Specific concerns raised include potential impacts to the marine environment due to: Routine discharge of drill cuttings, produced water and other operational discharges, Submarine noise that could disrupt whales Accidental spills that can harm the marine and coastal environment What Are People Saying? Ghana s (natural resources) are being depleted at an alarming rate: Fish, timber, and non-timber forest product stocks are decreasing rapidly. - World Bank The problem we have is that we have no baseline of marine environmental conditions to use as a basis of comparison. Petroleum Commission We have baseline data for the entire offshore region it will be updated in 2015 and subsequently every 3 years. - EPA The people need to be able to see and understand results of on-going monitoring to reduce doubts and we need the oil companies to help provide this information because we cannot get it from EPA. NGO To be most credible, we should involve people from scratch so they can be part of team and present results at the level of those who they work/live with. And we should include them in monitoring. Oil company representative 43

49 While many of the stakeholders participating in the October 2014 validation workshops believed that the oil and gas companies operating offshore are applying good international industry practices to prevent and manage potential impacts, others stressed the need to apply the precautionary principal when governing these activities. Specifically, an NGO leader and a representative of the Fisheries Commission wished to highlight that absence of notable impact to the marine environment to date does not mean that this could not happen in the future. Significant concerns were also raised about the apparent absence of environmental and social baseline or monitoring data needed to evaluate the potential effects of E&P activities offshore the Western Region over time. A number of stakeholders, ranging from NGOs to fishermen to government agencies, raised concern that they are not aware of any baseline or monitoring data other than what has been recently collected and reported by oil companies for individual exploration activities in specific locations. EPA representatives stated that they began collecting baseline data for the entire Ghanaian marine zone with the support of the Norwegian Government in 2009, adding that they have recently obtained baseline data even for the Deepwater Tano and Cape Three Points offshore area and intend to perform updates every three years. The environmental baseline data is in the custody of the EPA. While accessing this data has proven difficult, EPA asserts that it is available for public review. 4.6 General Socio-cultural Conditions Fishermen and those working in jobs that rely on the fishing industry have raised repeated concerns about the impact of offshore oil and gas activities on their livelihoods and socioeconomic well-being in communities of the Western Region. These concerns have been amplified by NGOs, development specialists and district/local government officials interested in helping to ensure the development of oil and gas resources actually has a positive effect on peoples lives 16. The primary concerns raised by stakeholders interviewed relative to socioeconomic conditions are: Reduced fish catch Exclusion zones complicating fishing activities, and irritating fishermen Increased marine traffic causing damage to fishing equipment Increased cost of common goods and services Limitations on the apparent effect of community investments and economic benefits Lack of clarity on how to raise questions and concerns and have them addressed Concerns related to fish catch, exclusion zones and marine traffic/collisions have been addressed in Section 4.1 from the perspective of the fishery and fishing activities. Ultimately each of these concerns ties back to the economic well-being of the fishermen and their families, and indirectly to their customers, supply chain and other members of the economic activity network within the Western Region communities. Thus the perception by some that oil and gas is restricting the economic well-being of fishermen raises concerns over community and region-wide economic impact. These concerns are exacerbated by the increased cost of some goods and services within the region. Some of the local stakeholders interviewed believe the presence of the oil and gas industry is responsible for the increased 16 NGOs addressing this issue include Friends of the Nation, Oil Watch and Hen Mpoano. The primary development specialists studying and documenting these concerns is a team from the University of Rhode Island Coastal Resources Center which is performing a multi-year USAID-sponsored study, planning and development effort in the Western Region communities. 44

50 costs of consumer goods as foreigners and Ghanaians with high paying jobs are able to absorb higher prices for food, housing and other items. For example, fishermen in Dixcove reported that the cost of a 40 horsepower motor has increased from approximately 2000 cedis in 2010 to 10,000 in And as the cost of inputs increase and number of fish available decrease, fishmongers report that the one pound of fish they bought for 2 cedis in 2012 now costs them 5.60 cedis (Interviews with fishermen and fishmongers in Western Region, July 2014). Coincident with concerns over the perceived impact of oil and gas on fishermen s well-being, many stakeholders (including fishermen) interviewed felt that fishing is not an economic activity that will deliver sustainable development of their communities. As a result, most of the fishermen and fishmongers interviewed on the subject expressed an interest in efforts to promote the development of alternative livelihoods for themselves and their children. What Are People Saying? Education is needed on improved record keeping and verification. (Fishers would welcome this move) Fisher association We need to educate our children to take up other vocations as the fish resources dwindle Fishmonger Investments and other development opportunities brought about by the oil and gas activities are situated mainly in Takoradi, without any coming to the Nzema area. Oil-related investments in the Nzema areas will go a long way to benefit the people in the Nzema area, such as creating job opportunities, etc. Fisherman (note, same comment from fishermen in other remote areas of the Western Region) We want to believe that oil companies want to behave responsibly. If true, we need to open channels of communications between the people and the companies. NGO A subsequent frustration reported in the communities was that there is no clear mechanism for complaints to be made or questions to be asked about the oil and gas activities. The Fisheries Commission, Tullow, Kosmos and the other companies, as well as some NGOs such as Friends of the Nation all indicate that they offer reporting (or grievance ) mechanisms to fishermen in the event of a conflict with a supply ship. This has become confusing for fishermen who often have a minimal amount of shore time but want to make a formal complaint. And although each of these organizations keeps records of complaints or feedback received, the decentralization of the feedback mechanism could prevent accurate statistics from being kept to determine the severity of the concerns and to provide clear assurance that the concerns are being addressed. 45

51 5 Findings The preceding sections of this report have addressed what is known and perceived about marine and coastal resource conditions in Ghana and the impact of oil and gas activities on these resources. Chapter 2 provided an overview of baseline conditions and Chapter 3 described the oil and gas activities offshore Ghana. Chapter 4 summarized the principle concerns that have been raised by Ghanaian stakeholders regarding perceived impacts of oil and gas activities on the marine and coastal environment. This chapter presents the findings of the study team s independent analysis of the extent to which literature review, stakeholder interviews and professional experience along with stakeholder vetting indicate that the concerns identified are attributable to oil and gas activities. Table 5-1 summarizes where the study team found or did not find credible evidence to suggest the concerns may be directly or indirectly related to oil and gas activities. The basis for these distinctions is provided in subsections below. At a more general level, the study revealed two over-arching observations that are important context for the specific findings presented below and the related recommendations in Chapter 6: Many of the concerns raised and underlying issues driving these concerns are regional or even global in nature. This is true to varying extents for fisheries, whales, algae and tar balls. It is appropriate for Ghanaian authorities, operators and other stakeholders to address these issues within the context of Ghana. At the same time, it is critical for these parties and their international affiliate / parent organizations to focus on global solutions for global trends affecting Ghana as well as activities and concerns that are within Ghanaian jurisdiction. Most of the concerns raised relate to existing offshore oil and gas activities and outcomes or perceived outcomes those related to planned, on-going operations and management activities for production of oil and gas offshore. Without losing emphasis on these concerns, the study team notes that the effects of a large oil spill in Ghana s marine zone, though a remote possibility 17, would likely dwarf the urgency of the other concerns raised. For this reason, priority attention should be paid to the findings and recommendations related to accidental oil spills. 17 See discussion in Sections 2 and 5.5 regarding the good international industry practices already being applied for oil spill prevention and response in Ghana. 46

52 Table 5-1 Summary of Findings 5.1 Fishery The findings of this study 18 indicate that despite some perceptions to the contrary, the offshore oil and gas activities are not responsible for a general decline in fisheries offshore Ghana. While information collected and reviewed 18 The findings noted are based on the review of published sources and records and the stakeholder interviews performed for the study, as well as on the experience of the study team in Ghana and worldwide. See Appendix B for study team credentials. 47

53 clearly indicates a decline in catch, the records show a correlation between the declining catch and increasing fishing activity over the years, whereas oil and gas activities began offshore Ghana after fish catches began to decline. While the findings indicate no credible evidence that oil and gas activities have impacted the overall fishery, two particular aspects of oil and gas activities do have some measurable impact on fishing activities, and these are outlined in Section 5.6. These are: maintenance of an exclusion zone an increase in marine traffic by support vessels The exclusion zone prevents fishermen from capturing fish within 500 meters of drill rigs and the FPSO. This is particularly annoying to fishermen because the drilling and production facilities generate light and macerated food waste that attract fish in higher concentrations than outside the exclusion zones. The increased number of vessels operating in waters off the Western Region to support oil and gas activities raises the possibility of further conflicts with / damage to fishing nets and canoes that are also operating in these waters. A major oil spill could potentially cause further reduction in fish stocks or impede the ability of the fishery to recover from other stresses this consideration is addressed in Section 5.5. Finding: No credible evidence of direct relationship with declining fishery, but exclusion zone and support vessels present localized restrictions to fishing (see Section 5.5 for discussion of potential oil spill impact) 5.2 Whales Records review and interviews conducted reveal that oil and gas activities offshore Ghana do not appear to have had any direct responsibility for the increase in dead whales observed along Ghanaian beaches in recent years. One factor influencing this observation is the predominant west to east current and the fact that many of the beached whale carcasses appeared to have been floating for days or longer, according to EPA s whale study. Thus, the cluster of dead whales beached on Western Region shores since 2009 would have very likely died in marine waters well to the west of the Ghanaian marine zone. Further, the evidence obtained in this study suggests that the increased number of whale deaths observed 19 are attributable to a variety of habitat-wide causes. These include ingestion of trash at sea and physical damage from vessel strikes in addition to natural causes and other background conditions. The first two causes can indirectly be attributed to an increase in oil and gas activity to the extent that the activities have the potential to introduce more solid waste and debris and to elevate the potential for strike damage due to increased vessel traffic. The potential impact of submarine noise from offshore oil and gas activities, primarily seismic surveys, on marine mammals is being studied extensively. While it is known that marine mammals can detect and potentially have echo-location functions disrupted by noise from air guns used in seismic surveys, the evidence reviewed for this study does not indicate that seismic noise is responsible for the mortality or beaching of whales in the Western Region (see further discussion in Chapter 3 and Section 5.5). Marine mammal observations recorded during seismic surveys conducted offshore Ghana in 2014 do not show a decline in marine mammals in the area during the course of the surveys. 19 Based on the number of whale carcasses found on Ghanaian beaches since

54 Finding: No credible evidence of direct relationship with whale mortality (but evidence of a potential indirect, cumulative risk of harm from oil and gas activities [direct vessel strikes] as well as potential disruption from seismic noise). 5.3 Algal Blooms The information obtained and evaluated is inconclusive about the likely source of increased algae along Ghanaian beaches since While some of those interviewed for this study or other studies reviewed believe it is attributable to oil and gas activities offshore Ghana, a review of literature and background information by Armah, et al. points out that the increase in the amount of Sargassum present is consistent with a global trend (see Section 3.3.5), not activities or conditions that are specific to Ghana or neighboring countries. Similar increases in the algae Ulva appear to be connected with periodic flushing of coastal lagoons, not with oil and gas activities. What is clear is that the abundance of the Sargassum in Ghanaian waters and beaches is a nuisance for fishermen, tourists and others who depend on the marine and coastal zone. Properly managing the effects of these blooms will depend first on understanding the true source and causes. Finding: No credible evidence of direct relationship with increased algae. 5.4 Tar Balls Information reviewed suggests that tar balls found on Ghana s beaches to date are likely from sources other than oil production offshore Ghana. Tar balls are found worldwide, and have been noted in Ghana since the 1960s (well before oil and gas activities began in marine waters off the Western Region.) Experts interviewed for this study speculate that the tar balls present on Ghana s beaches may be generated by oily discharges from passing tankers or natural seeps. This speculation is strongly supported by January 2015 chemical fingerprinting analysis of tar ball samples from beaches in the Western Region, which show that the sampled tar balls are not from Jubilee Field oil. Finding: No credible evidence of direct relationship with tar balls. 5.5 General Marine Environmental Conditions The findings reveal on-going or potential impacts to the marine environment that are attributable to three specific aspects of oil and gas activities offshore Ghana. First, the planned discharges of produced water, drill cuttings, and air emissions introduce traces of hydrocarbons to the water column (in the case of produced water), sediments (in the case of settled cuttings during drilling operations) and the ocean surface (in the case of settled particles in flared emissions during well tests or production operations). The offshore operators and EPA officials interviewed indicate that in each case these discharges are routinely controlled by operators and are in accordance with both Ghanaian standards and good international industry practice. Based on these observations, the practices applied and modeling studies carried out for the industry activities offshore Ghana, as well as the results of monitoring performed for offshore exploration and production programs in other countries, it is reasonable to believe that these discharges are unlikely to cause measurable changes to the marine environment outside of localized areas 20 around the discharge points. 20 Typically changes to ambient water and sediment quality conditions are not detectable beyond meters from the sources of produced water, drill cutting or flare emissions discharges. 49

55 Seismic exploration activities generate submarine noise at frequencies that are detectable by whales and dolphins. Global studies 21 are inconclusive on the extent to which seismic survey noise may adversely impact marine mammal habitat, but as a precaution contractors performing these surveys now typically follow international standards 22 designed to minimize potential impacts. Accidental releases of oil, untreated produced water, drilling fluids or other materials associated with exploration and production offshore Ghana could cause a measurable adverse impact to the marine and coastal environment. A large scale spill that continues uncontrolled for a week or more (such as the 2010 Macondo spill) could cause long term impacts to fishing grounds and coastal communities. Smaller releases would have a higher likelihood of occurring but a more limited effect. Interviews and records reviewed indicate that operators in the Jubilee and Cape West Three Points fields are applying good international industry practice (improved practices that were not in place during 2010) to reduce the risk and effects of a potential oil spill. Finding: Evidence of direct relationship with certain changes or potential changes to marine environmental conditions. Specifically: minor on-going impacts to marine environment from routine discharge of drill cuttings, produced water and other operational discharges potential for harm to marine mammals due to submarine noise generated during exploration activities potential for harm to marine and coastal environment from accidental oil spill 5.6 General Socioeconomic Conditions The findings reveal some very limited adverse effects on offshore fishing activity as well as both adverse and positive effects to socioeconomic conditions in Western Region coastal communities that are attributable to offshore oil and gas activities. Maintenance of an exclusion zone around offshore facilities does cause a localized disruption to fishing activities. There is clear evidence that fish tend to congregate close to these facilities (and thus within the exclusion zones), understandably a frustration to fishermen who need to optimize the efficiency of their efforts to earn a cost-effective catch. But there is no evidence that maintaining exclusion zones has an adverse effect on the overall productivity of this or any fishery. On the contrary, the long term exclusion zone around the FPSO may (on a very limited scale) provide some of the same benefits to replenishment of the fishery that restricted fishing zones are intended to provide in other parts of the world. Damage to drift nets, long lines and even canoes by passing vessels have been well documented offshore Ghana, and some of the damaging events are documented to have been caused by oil and gas industry support vessels. The industry has taken some steps to reduce these incidents, and some of the fishermen interviewed credit these steps as helpful. Nonetheless, the issue remains a concern to fishermen who feel their traditional way of life is being challenged and complicated by an overpowering oil and gas industry 23. Oil and gas companies operating offshore Ghana have made substantial investments in programs designed to benefit the coastal communities of the Western Region and have programs in place to maximize and increase the 21 See, for example, 22 See JNCC Guidelines, 2010 at 23 See, for example, opinion published on Joy Online by Richter Armarfio on August 24, 2014 at php 50

56 amount of labor, goods and services it can procure from local suppliers 24. Even so, most of the residents interviewed felt frustrated that the oil and gas industry activities did not provide more jobs and economic activities. The economic benefits that have accrued to these communities have been accompanied by some associated adverse economic impacts due to the increased costs of some goods and services noted in Section Finding: Evidence of direct relationship to disruption of fishing activities and some economic benefits to coastal communities due to oil and gas activities. 24 Independently verified Annual Monitoring Reports by Tullow and Kosmos reveal that over US$8million was invested in projects during 2013 and over US$2.5million was invested in These included programs focused on supporting small and medium business development, job training, safe drinking water and public health improvements. Kosmos records showed that 82 percent of its total 2013 procurement spend was from national providers, with 8 percent from providers within the Western Region. 51

57 6 Recommendations and Next Steps The research, consultation and analysis presented in Chapters 2-5 are intended to provide a better understanding of the background and source of environmental and social issues that have led to the concerns about oil and gas industry activities offshore Ghana. The analysis also aimed to distinguish where there is credible evidence that the industry activities are responsible for these issues versus other possible causes. This distinction is important not only to promoting better alignment and more positive dialogue between stakeholders on the concerns raised, but also to providing a reasonable foundation on which to determine how to effectively address the issues causing these concerns. The focus of this chapter is to highlight the recommendations and next steps needed to address the identified issues and concerns. In most cases, the recommendations focused on additional study or improved/sustained management practices by the industry. Others are targeted at managing issues whose causes do not appear to be directly related to oil and gas, but are nonetheless important to the well-being of those living and working in the Western Region. Preliminary findings and recommendations were vetted with stakeholders at a series of four workshops during October , and adjustments were made as appropriate based on feedback received in the workshops. Table 6-1 highlights the vetted recommendations in relation to the associated concerns, and the subsections below provide summaries of the recommendations Exclusion Zone Management Plan While maintaining exclusion zones around oil and gas facilities is a necessity 26, further measures may help to mitigate the impact of exclusion zones on fishermen and to reduce conflicts through communication and alignment of expectations. Some of those interviewed in the Western Region acknowledged that some offshore operators have done a good job of communicating and raising awareness with fishermen about the importance of avoiding exclusion zones and support vessel routes, but that more can be done. There was some discussion in the October 2014 stakeholder workshops about possibly applying measures to deter or reduce the congregation of fish from around drill rigs or the FPSO, through acoustic deterrent signals or by using lighting that is less attractive to fish, for example. The feasibility of using acoustic deterrents for fish is still being studied and not yet determined. While green or blue lighting have been used on offshore rigs to reduce the attraction of birds, the study team found no reliable evidence that it has been successfully used to minimize the attraction of fish. Further study of these and other technology applications is warranted. 25 Three in various locations of the Western Region and one in Accra 26 Maintaining exclusion zones around stationary marine installations is required under United Nations IMO convention to which Ghana is a signatory for the preventing accidents that could harm humans or the environment. 52

58 Table 6-1 Recommendations 53

59 The recommendation is for one or more of the oil and gas companies operating offshore Ghana to lead a multistakeholder effort to develop and implement an exclusion zone management plan. The plan should address: Mutually agreed measures to communicate and raise awareness about the importance of respecting the exclusion zone Practices to be followed to support effective engagement by the support vessel personnel, rig/ FPSO captain, marine police and fishermen, consistent with the Voluntary Principles for Security and Human Rights (VPs) Consideration of the use of VP-trained fishing liaison officers on support vessels 27 to promote better on-site communication with fishermen Consideration of further research and possible application of measures to deter or reduce the congregation of fish near the rigs and FPSO Formalizing mutual adoption of the plan through a global memorandum of understanding 28 by all interested stakeholders may help ensure the plan is followed by all Strengthened Capacity for Governance of Fishing Activities The primary causes of Ghana s fish catch decline appear to be independent of oil and gas industry activities, but rather related to unsustainable fishing practices. Specifically, overfishing and illegal, unregulated and unreported (IUU) fishing are key issues that need to be better managed to protect Ghana s marine fishery. Ghana s Ministry of Fisheries and Aquaculture Development issued a National Plan of Action to Prevent, Deter and Eliminate IUU Fishing 29 in May of Implementation of this plan will be critical to promote a sustainable fishery. Promoting and ensuring the application of more sustainable fishing practices will require a fundamental change in how some fishermen think about and behave toward the fishery, and in how government regulators refine, apply and enforce good governance of the resource. The recommendation is for the Ministry of Fisheries and Aquaculture Development to implement the 20 core actions outlined in its National Plan of Action. These actions include, for example: Strengthening the regulatory framework for operational fisheries management in Ghana Effectively controlling activities associated with IUU fishing Improving management of all marine fisheries sectors, consistent with FAO Code of Conduct on Sustainable Fisheries; eliminating overfishing; minimizing risk of irreversible damage to ecosystems Enhancing systems for fisheries monitoring, data collection (catch, effort, socio-economic data, ecosystem impacts), digitization and analysis; collaborating within ICCAT for assessment of shared stocks, and with other agencies, universities and development partners for related research 27 This practice is being applied offshore Cote d Ivoire at present with some positive results. (Acorn International, direct experience) 28 Global MOUs have been used in Nigeria to help promote sustainable action plans among oil companies and other stakeholders with different perspectives but common interests. 29 Related actions, including those pertaining to Fishery Impact Assessments and alternative livelihoods for fishermen, are presented in subsequent recommendations of this study. 54

60 In line with these recommendations, special attention should be given to consistent application of the Fisheries Impact Assessment (FIA) requirement in the Fisheries Act relative to offshore oil and gas activities (see recommendation 10 in Section ). Implementing the recommendations outlined in the National Plan of Action as well as implementing and consistently applying sector guidelines for FIA will require broad stakeholder support. In particular, fishermen will need to be involved in meaningful dialogue toward building solutions that are in their interests to apply consistently. Further, the Ministry should carry out an objective evaluation of its capacity to implement the recommended actions and then develop and execute a plan for building the capacity (legislative clarity, cooperation from others, training, equipment, etc.) needed to do so Additional Measures to Minimize Harm to Whales The EPA s 2014 subcommittee study on whale mortality identifies vessel strikes, incidental harm or by-catch by fishermen and marine debris as suspected primary causes of the increased number of dead whales washing up on Ghana s shores. The report provides a set of well-developed recommendations for managing these causes, including both further study and direct actions by government and industry alike. Because the oil and gas activities offshore are responsible for an increase in vessel traffic, some of the responsibility for implementing practices to minimize vessel strikes on whales must fall to the operating oil companies. The recommendation is for the subcommittee to prioritize implementation of the recommendations in its 2014 report regarding advanced controls for Marine Vessel Traffic Management and by-catch management. Specific actions include, for example: Tracking studies (such as development of a computer-based system to plot the sighting and distribution of whales) Raising the awareness of fishermen and alerting them to the magnitude of stranding as a problem Setting up a marine mammal stranding network dedicated to the promotion of best practice in stranding response and management all along Ghana s coast Creating a marine mammal stranding task force to serve as a rapid response team to the site of any future reported stranding cases The subcommittee will need to direct and ensure implementation, but in doing so it will need to clearly define the responsibilities of particular members, or other parties, to implement and own the actions Marine Noise Study and Management Practices Seismic surveys conducted as part of offshore oil and gas exploration activities generate submarine noise at a frequency that is detectable by whales. The extent to which this noise impacts whales on a habitat level is not clear. The industry is conducting research and applying new techniques 30 in attempts to understand, avoid and minimize any such impacts. The Oil and Gas Producers Forum s Sound and Marine Life Joint Industry Programme (soundandmarinelife.org/) and the United Kingdom s Joint Nature Conservation Committee s (jncc.defra.gov. uk/) guidance on managing the effects of seismic exploration on marine mammals are examples of industry and government led programs that are promoting research and development on this subject. 30 See for information on this programme and the research and technology developments being undertaken. 55

61 Continued study and advanced development and application of practices / technologies to avoid or minimize any seismic impacts on whales, other marine mammals and marine turtles is a critical element of managing the risks of oil and gas industry activities on the marine environment worldwide. The recommendation is for operators in Ghana to continue to support such research and development and proactively apply emerging good international industry practices to seismic surveys being conducted offshore Ghana. At the same time, Ghana s EPA, Fisheries Commission and other interested stakeholders should maintain familiarity with the on-going research and development to help encourage the application of appropriate emerging technologies and to ensure debates and decisions have a foundation in sound science Algae Study and Management Plan This study finds that the source of algae blooms offshore Ghana are not related to the offshore oil and gas activities but rather conditions in the western Atlantic (in the case of Sargassum) or natural flushing of coastal lagoons (in the case of Ulva clathrata). Regardless, the large quantities of this seaweed are a nuisance for Ghana s fishing and tourism industries. Further study into the why there are increased amounts of the seaweed offshore Ghana could help identify solutions to reducing the nuisance. In addition, promoting the application of business practices to harvest and use seaweed from Ghana s waters and beaches as a source of biodiesel can help reduce this nuisance and simultaneously provide a limited number of jobs for local residents (Joy Online, 2015). The recommendation is for the Ghanaian Government to study causes and potential practices to reduce the effects of the algae blooms, promote seaweed harvesting businesses, develop a management plan and take steps to apply any management practices that are deemed warranted from that plan. Cooperation with governments in other countries fronting the Atlantic to the east (from Cote d Ivoire to Sierra Leone) or regional environmental and development interests should be considered as the algae blooms are a regional phenomenon Tar Ball Fingerprinting Analysis and Management Plan As with the algae, the source of tar balls on Ghana s beaches does not appear to be offshore exploration and production activities. However, because accidental oil spills could generate tar balls among other impacts in the future, the oil and gas industry may want to consider developing a simple study and plan to manage the concern over tar balls. The recommendation is for the oil and gas operators in Ghana to consider conducting a simple tar ball study and management plan. A simple management plan should be developed and adopted in cooperation with Ghana EPA, representatives of the fishing and tourism industry and other interested stakeholders to focus attention, debate and solutions on controlling the actual sources. The plan should include consideration of preventing and responding to accidental oil spills as a potential future contributor to the problem Continuous Improvement in Waste Management Oil and gas industry activities offshore Ghana involve the controlled discharge of drill cuttings, produced water and domestic wastewater, the emission of exhausts and flared gas and the generation of solid and oily wastes. Each of these waste streams are managed and monitored to ensure they meet Ghanaian standards prior to being discharged or sent to shore for disposal. The management practices employed appear to be meeting good international industry practice (GIIP) and thus limiting the impact of these wastes on the environment to localized areas and low levels of intensity. Nonetheless, improved management technologies and practices are continually emerging that will help further reduce waste-related impacts, and the industry should be encouraged and enabled to develop and apply these improvements. 56

62 The recommendation is for oil and gas industry operators in Ghana to develop a mechanism that helps ensure they continue to pursue and apply emerging GIIP for waste management with the objective of reducing impacts to the marine environment to levels that are as low as reasonably practicable 31. The mechanism may involve forming a committee 32, developing a memorandum of understanding or putting in place another structured initiative to help drive, monitoring and ensure continuous improvement in waste management GIIP. Ghana EPA and the Petroleum Commission should be engaged in this initiative, along with other interested stakeholders to support awareness of industry progress and to promote good governance of the issue by managing concerns and aligning expectations among stakeholders Continuous Improvement in Oil Spill Prevention & Response As with waste management, oil and gas industry operators are presently applying good international industry practice for preventing and responding to potential oil spills. And as with waste management, continuous improvement in these practices must be a priority interest for both operators and regulators. There is a particularly strong need for continuous improvement in this area because an accidental oil spill could represent the single most damaging impact to Ghana s marine and coastal environment from oil and gas operations. From the perspective of this study, focusing attention and energy on oil spill prevention would be an appropriate priority for all interested stakeholders. For example: Oil companies might focus on advancing technology and management practices as well as developing a solid understanding and documentation of environmental and social baseline conditions (see Recommendation 9, Section below). Government agencies might focus on continuous improvement in contingency planning and systems to efficiently manage potential spill response and clean up. Fishermen might focus on building and taking advantage of opportunities for building awareness of and communication with the oil and gas industry about oil spill contingency planning, providing the EPA an accurate census of fishermen and developing alternative livelihoods as an option for local residents Civil society and non-government organizations might focus on building awareness of contingency planning, supporting effective communications and participating in monitoring if needed. The recommendation is that operators should develop a mechanism to ensure they continue to pursue and apply emerging GIIP for oil spill prevention and response (OSPR). Over time, this formalized initiative should be linked with the mechanism developed and applied for waste management, including ensuring cooperation with relevant stakeholders. Those depending on or responsible for the health of the marine and coastal environment should prioritize working with operators to ensure continuous improvement and diligence in applying GIIP for preventing and responding to a potential oil spill in Ghana Integrated, Participatory and Transparent Baseline A number of stakeholders, both civil society members and government agencies, have commented that there is no integrated base of data regarding baseline environmental and social conditions within the marine and coastal zone. The concern is that there is not a reliable basis against which to evaluate potential impacts of the oil and gas 31 For reference, see a definition of ALARP from the UK Health and Safety Executive at 32 Or working through the existing E&P Forum of Ghana s operators 57

63 industry activities. Ghana EPA has custody of environmental baseline for the marine zone, but few appear to have access to this data. In addition to restricting the benefit of this information for cooperative dialogue and planning about marine environmental concerns, the limited availability of the baseline information foments criticism and distrust between stakeholders, EPA and oil companies. The recommendation is for Ghana EPA to develop and consistently maintain a mechanism to share the baseline information openly for public review, query and understanding. It should work with a broad range of interested stakeholders to regularly (e.g., at least annually) communicate the results, discuss implications for sources of potential impact (including the oil and gas industry) and plan the scope of future baseline sampling and monitoring programs. These efforts should be coordinated with the oil and gas operators and with the Independent Oil & Gas Information Resource Center 33, which was established and is funded by the World Bank to support transparency and improved awareness about the oil and gas industry in Ghana. The baseline information collected and maintained should include socioeconomic as well as environmental baseline data related to the marine zone. In particular, a census of livelihoods of people living in coastal communities will be critical to have in advance in the possible event of an accidental oil spill for which people with affected livelihoods might need to be compensated. Because the oil and gas industry has an interest and has already been involved in some efforts to define existing environmental and socioeconomic conditions in the marine and coastal zone of the Western Region, operators should continue to cooperate with EPA in producing the baseline data. Ghana EPA will likely need external resources to help it create and maintain this transparency. It should hold discussions with the World Bank, Norwegian Institute, other international finance and development institutions and the Petroleum Commission to transparently solicit and manage funds and capacity as needed. EPA might also consider charging a fee for users to access the database. To ensure full transparency, it may help to establish a multi-stakeholder steering committee of government and industry to oversee development and management of the database. Participation by oil and gas companies operating offshore Ghana will be critical in maintaining and updating the database. While EPA plans to update its baseline data every three years, supplementary data from project-specific baseline and monitoring surveys will provide an important supplement to the limited EPA data. The collective effort for such comprehensive data assembly would help to assure credibility (eliminating potential accusations), and would also be beneficial and cost-effective for industry. Industry would not need to duplicate effort by having to conduct/generate such baseline and monitoring data for the general coastal and marine environment in the Western Region, for instance. Relevant protocols for access to the database for commercial, academic and other purposes could be determined by the EPA or steering committee in association with the operators involved Additional Measures to Minimize Impact to Fishing Activities Periodic damage to fishing vessels and nets by oil and gas industry support vessels, among other vessels, temporarily impacts the ability of affected fishermen to earn a living and can strain relations between users of the marine zone. Further, as noted in relation to exclusion zones (see Sections and 5.1), the location and maintenance of oil and gas facilities and the execution of oil exploration activities temporarily impacts fishing activities. 33 See 58

64 Fishermen report financial hardships from these conflicts and feel offended that oil and gas activities are given priority over the fishing that has occurred in these waters for generations. Vessel operators report trouble in seeing canoes and nets in time to avoid collision or disruption. The Fisheries Act of 2002 includes mechanisms intended to minimize conflicts regarding fishing, including requiring the preparation and review of Fishing Impact Assessments for applicable activities. To a large extent the Ministry and its Fisheries Commission (FC) have not been able to implement these mechanisms effectively. Likewise, the Ghana Maritime Authority has a Vessel Tracking Information Management System (VTIMS) that is intended to prevent marine vessel collisions, but the system is not fully implemented. It is recommended that the Ministry of Fisheries and Aquaculture Development conduct further capacity building both within the FC and with fishermen and other stakeholders to apply existing and potential future practices to minimize impacts to fishing. The mechanisms needed will include, at a minimum: Expansion of awareness building, in cooperation with offshore oil and gas operators, Ghana EPA, Ghana Maritime Authority (GMA) and the Petroleum Commission, to make fishermen aware of support vessel routes/schedules and the need to avoid these areas as well as exclusion zones (see Recommendation 1) Either consistently requiring oil and gas companies to prepare Fishing Impact Assessments or developing a memorandum of understanding with Ghana EPA to develop a fit-for-purpose scope of baseline and impact considerations related to fishing in the terms of reference (TOR) for each EIA required for regulated offshore activities (see further discussion below). Coordinating with GMA to promote the application of the VTIMS is applied to fishing vessels (for example, that beacons/detectors are installed in fishing vessels) and raising fishermen s awareness to promote the use of such devices. Building the capacity of Western Region fishermen to use lights to make their canoes and the boundaries of their drift nets more visible to other passing vessels. Promote mariculture development initiatives as an alternative livelihood for fishermen and a supplementary protein source for Ghanaians. The FC should look to its cooperating agencies (above) and international aid/development organizations for the resources to build this capacity. Fishermen might propose that assistance in obtaining beacons, lights and training in avoiding marine conflicts be supported through the social investment programs to which oil and gas operators have committed. The requirement for FIA should be seen as one of the sector-specific areas of Impact Assessment (IA) under Ghana s EIA system. Once the Screening outcome for a project requires EIA, the Scoping process should identify the key issues of concern (with guidance from the sector-specific guidelines developed by FC), in preparing the ToR for the EIA. In exceptional cases, where the issues of concern are significantly and predominantly fishery-sector biased, the project impact assessment could be titled by the sector name, e.g. Fisheries Impact Assessment (FIA). The more common practice, however, is to focus the assessment on the key issues identified scope and terms of reference, but provide separate, stand-alone mitigation and management plans such as: oil spill contingency plans or contingency compensation plan for fisheries impacts. The name attributed to an impact assessment is not as important as the existence of guidelines that ensure comprehensive coverage of the relevant sector issues, and the availability of professional capacity to review the IA report competently. 59

65 To enhance further development and improvement in the EA system, it may be helpful to develop sector-specific IA guidelines for key development sectors, including FIA. FIA guidelines for offshore oil and gas activities would help clarify agency responsibility for the FIA requirement, including responsibility for compliance monitoring, supervision of implementation of mitigation measures, and management oversight role during project implementation. They would also help avoid duplication of effort with EIAs required by EPA. The FC should prepare sector guidelines for FIA with the collaboration of the EPA and other relevant parties. FC should also build the required capacity of its staff in IA to meet a number of objectives: Advise competently on adequacy of FIA ToR (in Scoping Reports) Review fisheries components of IAs submitted Oversee implementation of fisheries mitigation measures Conduct compliance monitoring of FIA components during project implementation Apply the FIA in its licensing decisions on such projects Improved Land Use Planning/Governance for On-shore Projects This study has focused on impacts to the marine and coastal zone that are either a result of or have been alleged to be the result of offshore oil and gas activities. While the study has not addressed potential effects of on-shore oil and gas activities (e.g., construction of a gas plant, pipeline and port) in the Western Region, concerns related to these on-shore activities were raised frequently during stakeholder engagement sessions. Most of the concerns focused on land use, environmental, local content/hiring and socioeconomic impacts. Some stakeholders report that the Town and Country Planning Department has conducted spatial land use plans and the EPA has overseen rigorous review of environmental impact assessments related to these activities. However, others have stated that the level of review and planning is far too little to reasonably limit negative impacts and promote the local and regional benefits that should accrue from such developments. The recommendation is that the EPA and Town and Country Planning Department conduct a review of their activities to manage the on-shore developments so that it can evaluate if further measures may be needed. At the heart of this review should be a meeting or meetings with a broad range of interested stakeholders to hear opinions and recommendations regarding concerns that may need further consideration and additional measures that may need to be taken. In addition, or as an alternative, EPA may wish to extend the scope of this independent study to address on-shore activities Coordinated Consultation and Capacity Building Oil and gas operators conduct targeted community consultation activities throughout the Western Region as a condition of their permits from EPA and consistent with company policies / good international industry practice. These programs include maintaining community liaison officers and applying systematic grievance mechanisms to facilitate and provide assurance over community concerns, complaints and questions. Some of the programs included in the operators community investment budgets are targeted at building community members capacity to understand the offshore activities and their potential impacts. Other stakeholders interviewed for this study, including two NGOs, have similar activities on-going in the Western Region. Fishermen and other community members reported confusion about who they should go to in order to raise 60

66 concerns and gain better awareness. And multiple layers of efforts to raise awareness and build capacity about potential impacts and management practices present the possibility for misinformation, confusion and mistrust within affected communities. At the same time, some community members indicated there is still a low level of awareness about the offshore activities, impacts and avenues available to raise concerns making the interest of NGOs and others in helping meet these needs understandable. The recommendation is for oil and gas operators to take initiative to work with NGOs and community leaders to develop and deliver a more cooperative, integrated community liaison and capacity building program. This strengthened program should include local NGOs and community leaders not only in delivering key messages but also in determining and planning what key information should be shared and how. Those working with the oil and gas operators should provide input to and promote the grievance mechanisms that the operators have in place but not maintain alternative mechanisms that could disrupt the open exchange of concerns and responses Continuous Improvement to Promote Local Content Development Most of the concerns raised regarding socioeconomic conditions were related to employment and economic opportunities for residents of the Western Region s coastal communities. Tullow, Kosmos and other operators have invested several million dollars in community development programs, most of which focus on education, local enterprise development and skills training to prepare local residents to meet the local content objectives for employment, contracting and procurement of goods and services. These companies, along with the Petroleum Commission, also have internal requirements and objectives to prioritize and increase local content hiring and procurement. The companies report that it can be difficult to find the specific skills and materials needed from within the Western Region, thus their investment in local skills and local enterprise development. The feedback received through interviews range from praise for these programs, to appreciation but belief that they need to be significantly expanded, to lack of awareness and associated resentment that some are benefiting while others are not. The recommendation is for oil and gas industry operators in Ghana to develop a mechanism that helps ensure they continue to pursue and apply emerging GIIP for local content capacity building. The mechanism may involve forming a committee 34, developing a memorandum of understanding or putting in place another structured initiative to help drive, monitor and ensure continuous improvement in the development of local capabilities to provide the labor, services and goods needed. The Petroleum Commission should be engaged in this initiative, along with the Western Region District Assemblies and other interested stakeholders to support awareness of industry efforts and to promote further progress on this subject. Additionally, operators should conduct broader outreach to raise awareness with more residents throughout the Western Region about the programs in place, access to these programs, and progress being made to promote local hiring and procurement. 6.2 Recommendations Prioritization and Action Plan The study team believes well-coordinated responses to each of the findings are needed to create a broad platform for cooperation in addressing concerns about actual or perceived impacts of the offshore oil and gas industry in Ghana. But making meaningful progress on all recommendations simultaneously is not realistic given the complexities of varied stakeholder interests, resource limitations and capacity constraints of the government and 34 Or working through the existing E&P Forum of Ghana s operators, as with the recommendations in relation to waste management and oil spill prevention. 61

67 civil society groups involved. For this reason the study team has prioritized those recommendations that it believes warrant immediate or early attention and presents specific actions to be taken to advance each of these focus areas. Table 6-2 highlights the prioritized recommendations (numbers 8, 9, 10 and 12) and provides justification for why these should be prioritized over the other important recommendations. Table 6-2 Recommendation Priorities and Justification for Selection Stakeholders engaged for this study stressed that understanding what is to be done to address the concerns raised is only a start, and that what is needed is specific plans, commitments and measures to ensure and monitor effective implementation of the recommendations. Developing an effective management and implementation plan will require further stakeholder input, particularly from those who will need to agree to and make a commitment to taking responsibility for the actions. This is a critical next step, beyond the scope of this study. 62