The following missive, as captioned above, was addressed to the Hon. Johnny Briceno, Prime Minister of Belize and President of the CARICOM Heads of Government Conference.
Dear Prime Minister, further to our letter to Prime Minister Mia Mottley, dated March 27, 2022 (Annex 1), we are writing to you regarding some current and potential negative impacts on the coasts of Caribbean island nations caused by the expanding reckless oil production from deep-sea deposits off Guyana. The oil fields were licensed by the Government of Guyana (GoG) to a consortium of EEPGL/Hess/CNOOC and operated by EEPGL under a Production Sharing Agreement (PSA) for the Stabroek Tract, dated Accessed June 27, 2016. ExxonMobil (XOM) is the parent company of EEPGL and is headquartered in Irving, Texas. We write to you as citizens of Guyana and residents of CARICOM. At the outset, we express how inspired we are by the example of Belizeans and the successful campaign led by the Belizean NGO Oceana which resulted in the unanimous passage of the Petroleum Operations (Moratorium on the Area) Bill offshore), 2017, which imposed an indefinite moratorium on offshore oil exploration. or production in the Exclusive Economic Zone (EEZ) of Belize. We have two interrelated requests for information: First, we kindly request that you obtain information on the composition, procedures and progress of the “Cross-Border Working Group”, which Esso Exploration and Production Guyana Limited (EEPGL) has is committed to creating in 2017 (Environmental Resources Management 2017). We provide the relevant information below, in Appendix 2 to this letter. So far, Environmental Resources Management (ERM) has been EEPGL’s sole compiler of Environmental Impact Assessments (EIAs) for the Stabroek Tract oilfields, with the texts written as commitments made by client EEPGL.
Second, we are also seeking information on CARICOM’s internal processes for addressing member state actions that impact transboundary harm. We give three examples below – (1) risk of a massive, uncontrolled oil spill from deep high-pressure wells similar to the Macondo well in the Gulf of Mexico in 2010; (2) the dumping of large quantities of “produced” water and heated and contaminated cooling water, and (3) the flaring of associated gas in these offshore oil fields. We would appreciate receiving any public statement issued by CARICOM on these issues. Or, please let us know if CARICOM maintains an online repository. We noted that Guyana’s combined annual oil revenue generated from the sale of its 12.5% share of the oil produced and the 2% royalty received from ExxonMobil is half a billion dollars, and is expected to reach well over $1 billion a year within a few years. years. CARICOM should compare this sum to the value of beach tourism in the Caribbean islands potentially threatened by oil spills in Guyana’s EEZ. Jamaican tourism alone is worth around $1.3 billion. Neither Guyana nor XOM are insured against the consequences of massive oil spills.
Our first request for information relates to our concern over the lack of public information on cross-border commitments regarding our common Caribbean Sea and the complete lack of transparency shown by the GoG and XOM in sharing information, despite numerous demands and protests from the international community, civic organizations and the public, for this information. EEPGL’s rampant drilling of exploration and production wells is currently concentrated inside the northern edge of Guyana’s Exclusive Economic Zone (EEZ). This places the potential for transboundary damage closer to several CARICOM member states than to the Guyanese coastline. We request specific information on the measures taken to honor our countries’ distinct commitments to the protection of the global environment: namely the principles of precaution 2, prevention 3 and of common interest for humanity. ERM maps of oil spill models are included in the EIA volumes for each of the first four oilfields under development in the Stabroek Tract, confirming EEPGL’s confidence in these simulations. These four fields are Liza-1 and Liza-2, both currently in production; Payara under development; and Yellowtail under exploration and planning, and recently received a contested environmental permit (March 30, 2022). The oil spill response plan was criticized as weak by international specialist Robert Bea, given the problems in US oil fields.
Produced Water Spill – In addition to an oil spill, very hot produced water contaminated with petroleum and many toxic and radioactive elements is discharged into our Caribbean Sea after partial treatment, as repeatedly reported in the EIA: e.g. Section 126.96.36.199 Products Water Treatment – “The Produced Water Treatment System will be designed to collect produced water from the FPSO treatment facilities and treat the water so that ‘discharged overboard in accordance with standard industry practice’ (EIA for Liza Phase 1, Volume I, nominal page 34, actual page 86/498, 2017). For the Liza-1 field alone, the volume of water produced is 100,000 barrels per day, for 20 years. The revised Environmental Operating Permit for Liza-1, issued on January 17, 2022, still allows a monthly average of 29 parts per million (ppm) of oil and grease in produced water discharged from the floating production vessel, storage and offloading (FPSO) Liza Destiny, and a daily maximum of 42 ppm; section 4.7. While 29 to 42 barrels of pure oil will be spilled in every million barrels of water spilled, a myriad of radioactive and toxic elements remain untreated. Based on EIA projected reject rates of ≤300,000 barrels per day (BPD) each, and XOM’s publicly announced plan to have 10 FPSOs in service by 2027, it is conservatively estimated that hundreds thousands of barrels of pure oil would be spilled into the ocean over the lifetime of oil operations estimated at at least 20 years; and this does not take into account the many other operators who are expected to start production in the near future4. Coupled with a possible oil spill, this spill will heighten concerns in the Caribbean region about the resulting devastating effects on our ecological systems and our fishing and tourism industries.
The permit also allows the discharged water to heat the surrounding ocean up to 3 degrees Celsius above ambient water temperature 100 meters from the FPSO and 55oC at the FPSO discharge point – at least two times the ambient ocean water temperature; section 4.12. Yet, with the increase in ocean surface temperature shown recently for the western Atlantic (Cheng et al. 2022) (Figure 4), seawater was already very close to the upper limit tolerance for certain commercial fish, as recognized in the MRE’s EIA for the Yellowtail Oilfield. These discards are not consistent with the application of the United Nations precautionary principle when Caribbean fish stocks are already facing critical temperature problems. Flaring of produced gas – Permits clearly dictate that “routine flaring or venting is prohibited”, but flaring has been allowed to continue since operations began in December 2019, resulting in a cumulative amount flared of over of 15 billion standard cubic feet. Instead of reducing production by a miniscule amount of around 3% to stop flaring, GoG in May 2021 amended permits to: (1) redefine “routine flaring”, to legalize flaring of quantities unlimited amounts of gas, as long as the operator pays a paltry fee, while earning additional revenue of more than 60 times that fee by not reducing production by that tiny amount to stop flaring; and (2) give XOM 60 days of free flaring after startup, reversing the decision of a GoG team of Canadian expert consultants and GoG agencies, including the Environmental Protection Agency, requiring only 2 days of flaring after start-up and no flaring thereafter, per US regulations.
Prime Minister, we want to assure you that we fully support oil production in Guyana, but this must be done in a way that protects the environment, safety, health and economic well-being of the region. To this end, we urge CARICOM to engage the GoG to ensure that oil operations off Guyana are conducted in a safe and environmentally responsible manner. Failure to do so could devastate the region’s economy and environment. Specifically, we demand that: (1) CARICOM demand that the GoG take immediate action to enforce the legal requirements of EIAs and environmental permits; (2) CARICOM demands that GoG prevent EEPGL from discharging hot, toxic and radioactively contaminated produced water into the Caribbean Sea; (3) CARICOM demands that the GoG reverse its decision to allow unlimited flaring with a small fine and revert to the original regulations where “routine flaring or venting is prohibited”; and (4) CARICOM commits the GoG to ensure that its oil extraction laws and regulations are consistent with the 2016 Paris Agreement.
Please note that our intention is to make this letter public as the issues we describe affect all CARICOM citizens. We celebrate our distinct and shared identity that has withstood external and internal stresses and strains. Lloyd Searwar’s insight still holds: “CARICOM’s identity comes from its particular history, which differentiates it from that of Latin America (independence movements in CARICOM states were led by descendants of slaves and indentured labourers). This identity has provided the region with resilience in the face of severe divisions and is seen as an ultimate security resource” (Searwar 1995, p.19). We are encouraged by the protections and guarantees given to CARICOM citizens, including environmental rights, set out in the CARICOM Civil Society Charter (1997). We acknowledge CARICOM’s strong expressions of support for the territorial integrity of Guyana, in the face of longstanding Venezuelan aggression, most recently in 2018 (Stabroek News 2018). Mr. Chairman, we hope to receive your acknowledgment of receipt and respond to our requests. We are ready to dialogue with you on these issues.