For nearly five years since the AFC’s political activist, Dr. Vincent Adams was terminated from the Environmental Protection Agency (EPA), he’s been glorifying his record of accomplishments at the EPA, without any proof.Over the years, he consistently claimed that his EPA permit (s)was/were superior to his successor’s etc. Unfortunately, the evidence is not in his favour. Dr. Adams boasts of a 47-year career at the US Department of Energy (UDOE), yet the EPA Permitunder his hand was embarrassingly inferior when compared to the renewed permit and all the others thereafter under the hand of his successor.
Space precludes a detailed page by page comparative analysis in the form of a matrix, however, for the purpose of demonstrating for the readers’ benefit, hereunder stated are some notable clauses in the EPA permit by his successor, Mr. Kemraj Parsram, that were not contained in Dr. Adam’s EPA permit for the Lisa 2 project.
Liza Phase 1 Project Operation and Production Facilities, Renewed Permit dated October 27, 2022, signed by Kemraj Parsram. The following clauses wereNOT CONTAINEDin Dr. Adam’s permit for the Lisa 2 project dated April 26, 2019:
General
- 3. The Permit Holder shall maintain a Project Community Grievance Mechanism to receive and address complaints from individuals and communities who believe that the project causes environmental harm to their community. The grievance mechanism, which shall be in keeping with the World Bank’s Approach to Grievance Redress in Projects, must be practical, inclusive, and accessible for all project affected stakeholders.
- 3.1. The Permit Holder shall maintain records of environmental grievances and report on the numbers, nature and how these were or will be addressed. This information must be provided in the Monthly Report as required by Condition 13.10.
- 3.2. The Annual Report required by Condition 13.9 of this Permit, must contain a summary of the environmental grievances and management, including actions taken, challenges and /or constraints in addressing same.
Air Quality Management
- 1 The Permit Holder shall implement environmentally-effective and technically feasible best practices, in accordance with the American Petroleum Institute (API) Standards and Recommended Practices, for reducing emissions. (Note: Dr. Adams Permit under this clause failed to specify which international best practice should be adopted, it instead stated vaguely “international best practice”).
- 6 The Permit Holder shall ensure that there is no discharge of ozone-depleting substances (ODS) in accordance with the International Convention for Prevention of Pollution from Ships (MARPOL 73/78) Annex VI.
- 11.1 The Permit Holder shall not exceed 60 cumulative days of flaring during commissioning…
- 11.5 Where flaring during commissioning is expected to exceed 60 cumulative days, the Permit Holder shall seek an approval from the Agency for flaring…
- 11.9 An approval shall not be issued for a period exceeding 60 calendar days. Where flaring exceeds or is expected to exceed the sixty-calendar day period, the Permit Holder shall seek an additional Approval for at least 48 hours before the expiration of the existing approval, which additional approval may be issued subject to further terms and conditions as the Agency deems appropriate.
- 12 The Permit Holder shall pay US$50 per tonne of carbon dioxide equivalents (CO2e) emitted as a result of flaring in excess of the periods of flaring expressly stipulated at 3.11.1 and 3.11.4 above.
- Further, clauses13 to 3.19.8 were not contained in Dr. Adams Permit under the Air Quality Management clause.
Hazardous and Non-Hazardous Waste Management
- 3 The Permit Holder shall implement best practices and best available techniques (BAT) as outlined in the World Bank Group Environmental, Health and Safety (EHS) General Introduction Guidelines (2007) and Environmental Health and Safety Guidelines for Offshore Oil and Gas Development (2015) with respect to the prevention of the spillage of hazardous materials from offshore facilities.
- 4 The Permit Holder shall record any accidental release of waste into the marine environment and corrective actions implemented. The notification as required herein shall be submitted to the Agency within 24 hours of the release.
- 9 The Permit Holder shall manage and dispose of putrescible waste in accordance with Annex V of MARPOL 73/78, Regulations for the Prevention of Pollution by Garbage from Ships.
Well Blowout Prevention (BOP)
- 12 Within 60 calendar days of the issuance of this Permit, the Permit Holder shall submit for the Agency’s approval, relevant safety case information, including risk assessment and management plan for the well drilling operations. (Note:in the Vincent Adams Permit, Permit Holders were given one (1) year to comply with this clause as opposed to sixty days or 3 months by his successor).
- 13. The Permit Holder shall maintain access to at least one (1) subscription service in a location outside of Guyana to allow mobilization of a Capping Stack to the Liza Phase 1 Project location within nine (9) calendar days or less of an uncontrolled event.
Oil Spills Emergency Plan
- 1 The Permit Holder, in the event of a discharge or spill of any contaminant into water or on land must comply with the polluter pays principle and is therefore responsible for eliminating or controlling the discharge/spill, cleaning up to the extent practicable, and remediating any resulting damage, and monitoring of the impact and taking appropriate measures to prevent, reduce and mitigate impacts, consistent with the National Oil Spill Contingency Plan, the OSRP, and the Environmental Protection Act.
- 19 The Permit Holder shall conduct a Net Environmental Benefit Analysis (NEBA) and a Spill Impact Mitigation Assessment (SIMA), in accordance with international petroleum industry standards, and include the findings therefor, in an application for approval under Condition 10.20. The Permit Holder shall ensure that findings detail whether in-situ burning and the use of chemical dispersant (s) is necessary in the circumstances.
- 20 In-situ burning and the use of chemical dispersant (s) shall not be used, unless approved by the Agency prior to application. An approval granted in accordance with this condition shall be subject to such terms and conditions as may be required by the Agency…
Employees and Personal Safety
- This section in the renewed Permit under the PPP/C government contains a total of twenty-two (22) (11.5 – 11.26) clauses that were NOT CONTAINED in the Vincent Adams signed Permit.
New Sections Included in the Renewed Permit and All other Permits there onwards that were not contained in the Vincent Adams signed Permit:
- “Chemical Handling and Management”, clauses 6.1 – 6.12,
- “MARINE ECOSYSTEMS AND MANAGEMENT”, clauses 8.1 – 8.7,
- “Production Operations and Safety”, clauses 12.1 – 12.2,
- “Emergency Shutdown System”, clauses 12.3 – 12.6,
- “Gas-detection System”, clauses 12.7 – 12.10,
- “Fire-detection System”, clauses 12.11 – 12.14,
- “Firewater System”, clauses 12.15 – 12.17.
The Section on “Financial Assurance and Liability for Pollution Damage”, under the Vincent Adams signed Permit contained thirteen (13) clauses, whereas his successor’s contained nineteen (19) clauses. And finally, the section on “Institutional Authority”, under the Vincent Adams signed Permit contained ten (10) clauses, whereas his successor’s under the PPP/C Government contained thirteen (13) clauses.
As evidently demonstrated herein, the EPA Permit issued under the hand of the AFC’s so-called oil and gas expert and former Executive Director of the EPA, Dr. Vincent Adams was invariably inferior in contrast to the renewed Permit and all the new Permits thereafter under the hand of his successor, Mr. Kemraj Parsram. It therefore means that, disappointingly, for nearly five long years Dr. Vincent Adams was being outrageously disingenuous about his track record at the EPA under his tenure. The new Permits have been vastly improved and far superior in substance, in terms of safeguarding Guyana from the environmental risks in the petroleum industry.
In a forthcoming missive, we will examine is financial and operational performance of the EPA under his tenure.
For ease of reference, here’s the link to Dr. Adam’s EPA Permit for your readers’ independent verification https://epaguyana.org/download/final-liza-phase-ii-permit-signed/, and here’s the link to the new Permits signed by the current Executive Director, https://epaguyana.org/download/yellowtail-signed-permit-pdf/.