The company has presented plans to address these impacts to ensure that the proposed project will, upon implementation of the specific agreed measures, comply with all relevant environmental and social requirements, namely the Indian and Bangladesh laws and regulations, and the World Bank/IFC environment and social policies and environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the company is summarized in the paragraphs that follow. Further information is also provided in the attached documentation.
- Group-wide Integrated Health, Safety, Environmental and Social Management System
At the parent company level, Cairn has instituted a group-wide Health, Safety, Environment, and Corporate Social Responsibility Management System (“HSEMS”). This is also integrated with the company’s comprehensive business risk management system which systematically identifies, analyzes, assesses, treats and monitors all of Cairn’s business risks. Furthermore, the HSEMS provides the Company’s HSE manager and staff with procedures to implement the HSE planning and performance target setting process which includes:
- establishing country-level strategic HSE objectives which are made available to the public;
- setting specific annual HSE objectives that support the longer-term objectives;
- establishing annual HSE plans to meet these objectives;
- implementing the HSE plans;
- monitoring the progress of the HSE plans; and
- reviewing the process and providing feedback.
The HSEMS is informed by several key corporate policies, notably:
Cairn’s HSE Policy which declares the company’s commitment to the protection of its employees, stakeholders and the physical and natural environment in all of their activities. Cairn believes strongly in establishing controls for all personnel involved in their activities to protect the human and natural environment. Health and safety awareness and training programs are a key requirement for all employees and contractors.
Cairn’s Corporate Social Responsibility ("CSR") Policy which establishes rigorous standards for all operations. Cairn specifically commits to respect the rule of law, adopt appropriate international standards, implement management systems and strive to operate its businesses honestly and with integrity, respecting the rights and dignity of all employees as well as the different cultures and rights of individuals and indigenous peoples, and contributing to community development.
Not to conduct exploration or production operations in World Heritage Sites (as designated by the United Nations Educational, Scientific and Cultural Organization ("UNESCO") or environmentally sensitive areas (as assessed by Cairn, in collaboration with the relevant host governments).
As a key HSEMS component, Cairn has instituted an environmental management system based on the international standard ISO 14001 and ISO 14001:1996 certification has been obtained on all of the Company’s producing fields in both India and Bangladesh. Cairn publishes annually an Environmental and Social Review ("ESR"), in which it discloses the year’s HSE performance and social activities. This includes specifically air emissions, greenhouse gases ("GHG"), energy consumption, effluent discharge and solid waste as well as initiatives to address project related social issues (e.g. a summary of community development initiatives at each of its areas of operation). In line with best practice, the accuracy of the ESR is independently reviewed by an external consultant, Environmental Resource Management.
Cairn has also established a strategy with regard to climate change which includes setting targets for methane and greenhouse gases (GHG) since the year 2000 and implementing several initiatives to reduce GHG (e.g. installation of high efficiency flares, third stage compression, and a policy on crude oil flaring). Of note, Cairn reports to partners and stakeholders on its emissions of GHG (as well as other climate change emissions) in the ESR. In addition, Cairn has contracted the services of a consulting firm to study the potential impact of climate change on its activities. The study is reviewing the potential opportunities for adding value through doing projects under the Clean Development Mechanism of the Kyoto Protocol.
In furtherance of the above policies and systems, Cairn has prepared a Group Resettlement Action Plan Framework (RAP) to guide mitigation and compensation for any land acquisition, resettlement or economic displacement of households at each of its developments. Cairn has similarly prepared a Group Public Consultation and Disclosure Plan (PCDP) to guide its communications program at each of its areas of operation. The Group PCDP, as complemented by the more detailed site-specific PCDPs, provides for on-going consultation with key stakeholders, and will be reviewed and updated on a regular basis.
- Country-specific Issues in India, Bangladesh and Nepal
In India, Cairn has production operations in Andhra Pradesh (Ravva field) and Gujarat (Lakshmi/Gauri fields), exploration and development activities in Rajasthan (in block RJ-ON-90/1) and exploration opportunities on 8 onshore blocks (RJ-ONN-2003/1 and VN-ONN-2003/1 in Rajasthan, KG-ONN-2003/1 in Andhra Pradesh, CB-ONN-2002/1 and CB-ONN-2001/1 in Gujarat, GV-ONN-2002/1 in Bihar, and GV-ONN-97/1 and GV-ONN-2003/1 in Utter Pradesh) and 2 offshore blocks (KG-DWN-98/2 in Andhra Pradesh and GS-OSN-2003/1 in Gujarat).
In Bangladesh, Cairn operates the offshore Sangu gas field with an onshore processing plant located near Chittagong, and operates exploration activities in Block 16 (offshore), Blocks 5 and 10. Cairn also has a non-operated interest in Block 7 onshore south Bangladesh.
Cairn was also awarded five new operated exploration blocks in Nepal (blocks 1, 2, 4, 6 and 7) in 2004. However, due to the security situation in the country, the Company declared contractual force majeure in August 2005 and is continuing to monitor developments.
- Andhra Pradesh
In Andhra Pradesh, Cairn operates the producing Ravva oil and gas field and also has a 10% interest in the ONGC-operated KG-DWN-98/2 deepwater block, which are both located in the Krishna-Godavari Basin.
The Ravva field comprises 8 offshore platforms and 25 producing wells, with production conveyed through various pipelines (10”-12”) to an onshore processing facility. Crude oil is exported via an offshore loading buoy to tankers for further processing in national refineries. The treated gas enters the local pipeline infrastructure operated by gas transportation company GAIL, where it is used for power generation and fertilizer units located in Kakinda. The nearest village to the Ravva onshore plant is Surasani Yannam (S’Yannam) which is located over 1 km away. The population of around 8,000 people is employed mainly in agriculture and fishing activities and is not directly affected by the project operation.
Cairn’s operation in Ravva achieved ISO 14001 certification (with respect to ISO 14001: 1996 standards) in January 2005. The operations have an integrated HSEMS derived from the parent company HSEMS.
Cairn’s Ravva operations team has instituted a community development plan. Under this, they contribute funds annually to a fund administered by local district administration for improvements to local infrastructure, schools etc. The company also provides financial and direct assistance to various community development projects in S’Yannam, including improvement to school facilities and village water supply systems, the provision of medical care, and adult education and training facilities.
Regular consultation takes place with local communities neighboring the Ravva on-shore facility and a PCDP has been prepared, detailing activities for on-going consultation with key stakeholders (throughout the life of the project).
Cairn has developed onshore and offshore emergency plans for the Ravva operations, including oil spill contingency plans and fire fighting protocols, both of which are validated through regular drills. The operations are evaluated through regular monitoring by Cairn personnel, biannual ISO 14001 audits, annual HSE audits, and external audits by the Government of India Department of Director General of Hydrocarbons ("DGH") and Director General of Mines Safety ("DGMS"). The findings of these audits are evaluated and corrective action plans are established. HSE awareness and training programs are conducted for all employees and contractors.
Cairn has an established waste management plan for all identified liquid, non-hazardous and hazardous waste. The plan identifies methods for handling, treatment, storage and disposal. The plan also outlines methods for segregation of wastes and recycling where possible. Production-related waste at the Ravva plant is segregated and disposed of through Government-approved recyclers and/or disposal sites.
Drilling operations primarily use water-based drilling fluids which conform to the requirements of the Ministry of Environment and Forest ("MOEF"), and the spent drilling fluids and cuttings are disposed of in accordance with the requirements stated in the MOEF Environmental Clearance document. In the event that Cairn decides to use synthetic oil-based mud, it will need the approval of the MOEF and will recycle the mud in line with MOEF guidelines. The drill cuttings are discharged only after proper washing and in accordance with the MOEF offshore discharge guidelines.
Air emissions are generated at the onshore Ravva plant due to combustion of produced gas for power generation and maintaining a small flare for safety reasons. The annual average amount of flaring for 2005 from Ravva operations was 0.26 tonnes/1000 tonnes of hydrocarbon produced. Regular monitoring tests have confirmed that ambient air quality in the area of the offshore platforms and onshore plant are within the applicable limits.
- Gujarat
In Gujarat, Cairn operates the producing Lakshmi and Gauri gas fields located offshore. The fields are located in the Gulf of Khambhat, on the west coast of India. The Lakshmi field consists of two offshore platforms, 11 wells and a 36km pipeline to the onshore terminal at Suvali. The Gauri field has a single platform with four gas wells and one oil well and its production is transported to the one of the Lakshmi field platforms through a 5km 12” subsea pipeline, and from there through a 24” pipeline to the onshore terminal. The Suvali processing facility is located in 82 acres of land, approximately 7km from the industrial belt of Hazira, including the Shell/Total LNG terminal, in the district of Surat. There are no villages within 1km radius of the terminal. The nearest national Park (Velvadar) is located 45km from the fields and is not affected by the project operation. There are no coral reefs and sea grasses in the block.
Cairn’s Gujarat operations achieved ISO 14001 certification (with respect to ISO 14001:1996 standards) in April 2005. As in the case of Ravva, the Gujarat operations have an integrated HSEMS derived from the parent company HSEMS.
The Gujarat operations have instituted a community development plan, pursuant to which various community development projects have been implemented, including improvement of school facilities and village water supply systems.
Regular consultation takes place with local communities neighboring the Gujarat on-shore facility and a PCDP has been prepared, detailing arrangements for on-going consultation with key stakeholders.
Cairn has developed onshore and offshore emergency plans for the Gujarat operations, including oil spill contingency plans and fire fighting protocols, both of which are validated through regular drills. The operations are evaluated through regular monitoring by Cairn personnel, biannual ISO 14001 audits, annual HSE audits, and external audits by the relevant Government of India departments - DGH and DGMS. The findings of these audits are evaluated and corrective action plans are established. HSE awareness and training programs are conducted for all employees and contractors.
Cairn has an established waste management plan for all identified liquid, non-hazardous and hazardous waste. The plan identifies methods for handling, treatment, storage and disposal. The plan also outlines methods for segregation of wastes and recycling where possible. Production-related waste at the Suvali facility is segregated and disposed of through Government-approved recyclers and/or disposal sites.
Drilling operations primarily use water-based drilling fluids which conform to the requirements of MOEF, and the spent drilling fluids and cuttings are disposed of in accordance with the requirements stated in the MOEF Environmental Clearance document. In the event that Cairn decides to use synthetic oil based mud, it will need the approval of the MOEF and recycles the mud in line with MOEF guidelines. The drill cuttings are discharged only after proper washing and in accordance to the MOEF offshore discharge guidelines
Air emissions are generated at the onshore Suvali facility due to combustion of produced gas for power generation and maintaining a small flare for plant safety reasons. The annual average amount of flaring for 2005 from Suvali operations was 0.66 tonnes/1000 tonnes of hydrocarbon produced. There is no processing involved in the offshore platforms. Regular monitoring tests have confirmed that ambient air quality in and around the onshore plant is within the applicable limits.
- Rajasthan
Cairn also has a 70% interest and operates the RJ-ON-90/1 block in western India. ONGC, India''s largest oil and gas company, holds the remaining 30%. The block is located within the districts of Barmer and Jolore. The total surface area of the block is approximately 4,740 km2. Within the block, the fields of Mangala, Aishwariya, Saraswati, Raageshwari, Bhagyam, Shakti and Guda are currently expected to form the core developments. The block area is arid and semi-arid, with low population density. One of the key aspects of this area is the limited water supply (for potable, agricultural and industrial use).
During exploration, Cairn drilled more than 80 wells with 12 discoveries. Currently, the Company has two drilling rigs and one workover rig in the area. By mid 2006, it is expected that an initial phase of development will come into production, with an initial projected output of about 2,000-3,000 barrels of oil per day ("bpd") - (from the central and southern fields) - which will be transported by truck to a receiving facility at Mehsana in northern Gujarat.
The main focus is the development of the Mangala field in the north of the block, where it is planned to construct fifteen well pads with up to 24 production and 13 water injection wells each and an oil processing facility with a capacity of more than 100,000 bpd. Additionally, the Raageshwari Gas and N-R Water Fields will also be developed for the provision of gas for power generation and saline water for injection into the reservoir to aid oil recovery. The construction will necessitate the transportation by trucks of significant volumes of materials along roads which are in the vicinity of certain nearby communities. Accordingly, Cairn has developed a comprehensive Transportation Management Plan which focuses on ensuring the security and safety of these activities. It is expected that, during the construction of the processing facility, contractors and employees will be housed at camps located within Cairn’s fields, and that all construction activities will be fenced in, so to avoid any accidents involving communities or animals.
Under the terms of the production sharing contract ("PSC") for Cairn’s Rajasthan block, the Contractor (Cairn/ONGC) is to sell 100% of the production at the Delivery Point located at the Mangala Central Tank Farm to a Government nominee, subsequently confirmed as ONGC subsidiary Mangalore Refineries and Petrochemical Limited - ("MRPL"). ONGC has prepared a pre-feasibility study for an export pipeline as an initial delivery option, the results of which were presented to Cairn and MRPL in early December 2005. The study proposes that the export of the Mangala field crude will be to the port of Mundra in Gujarat, a distance of 471 km. The proposed pipeline will follow a route through the RJ-ON-90/1 Development Area linking to the national highway 15 to Saltapur, where it will pick up the existing and approved Mundra-Delhi pipeline corridor. ONGC will be responsible for establishing the Right-of-Way (ROW) of usage along the entire export pipeline route. ONGC has indicated that their route selection has been designed to minimize impacts to highly populated areas and environmentally sensitive areas. Accordingly, only a small portion of the pipeline (approximately 10 km) will cross the low-lying flood plain of the Rann of Kutch. Although the Company is not responsible for transportation beyond the delivery point, it is committed to continuing to work closely with ONGC to ensure that the crossing of this environmentally sensitive area is revisited to analyze alternatives, and to mitigate in an appropriate manner.
Given the scarcity of fresh water in the Rajasthan area, Cairn commissioned a water resources feasibility study, to assess the expected water requirements during drilling, construction and commissioning at the Mangala field and identify the optimal way of addressing these with the least impact on the environment. The study estimated that approximately 25,000 m3/day of saline water will be required for the Mangala development. It further reviewed several options for water abstraction and/or transportation from other areas. Ultimately, however, these were discarded in favor of the proposal to use the Thumbli saline water aquifer, as the study confirmed that the abstraction will have a negligible impact in the existing fresh water resources. As part of a broader analysis of the fresh water situation in the area, Cairn is providing technical support to the Groundwater department who are carrying out a study to improve the freshwater resource management in the Barmer Area. It is important to note, however, that Cairn recognizes and has made clear to the authorities that responsibility for managing and supplying the fresh water resources to the local communities rests with the Government.
Cairn’s activities in Rajasthan are also managed under an HSEMS and the ISO 14001 certification is planned for soon after first oil production from Mangala, in 2008.
A comprehensive RAP Framework is being prepared to address and mitigate all temporary and permanent land acquisition and resettlement related impacts in Rajasthan, associated with seismic investigations, well drilling and completion, construction camps, production and processing facilities, pipelines and access roads. Provision has also been made for the preparation of more detailed site-specific RAPs, as required, for any future land acquisition that may involve significant economic or physical displacement. Land acquisition is currently planned to take place in two phases which will span the periods up to August 2006. Every reasonable effort has been made to avoid any resettlement of homesteads by rerouting of the pipeline and access roads and by altering the siting of well pads and making use of directional drilling techniques. The existing land acquisition and compensation process is undertaken in accordance with the Land Acquisition Act ("LAA") which governs land acquisition in India. It is a comprehensive legislation which addresses in detail all the facets of the land acquisition process and provides a credible mechanism to determine the quantum of compensation. Currently, Cairn is in discussions with the District Administration on the completion of the LAA process and has committed that during this period no physical relocation will take place.
Cairn has established a substantial Corporate Social Responsibility ("CSR") program in Barmer district, employing several dedicated staff and implementing community projects through local NGOs, with the purpose of contributing to the development of sustainable livelihoods in the project area. In the course of construction in Rajasthan, there will be an increased number of employment opportunities for local labor, but this will decrease substantially once production commences, as ongoing field operations will not be labor intensive. With the support of IFC’s Corporate Citizen Facility ("CCF") and the Small, Medium, Enterprise ("SME") linkage group, Cairn has implemented a number of initiatives and is now developing a multi-stakeholder community development plan, which is based on a comprehensive social baseline study and process of stakeholder engagement. Projects implemented to date include rainwater harvesting systems, upgrading of school facilities and projects focused on vulnerable groups. A District Co-ordination Committee has been established under the Chairmanship of the District Collector/Chairman District and attended by Additional District Magistrate, the Sub-Divisional Magistrate of the concerned blocks, and representatives from the Public Health Engineering Department, Health Department, Forest Department, community representatives and concerned special invitees, and the Company, to facilitate implementation of future community projects. The community development plan will lead to a formalized and coordinated integrated plan for community and local economic development, bringing together local communities, local government, NGOs and Cairn.
Stakeholder engagement in the process of developing the community development plan has strengthened the existing comprehensive public consultation process. Successful workshops were recently held with local communities, civil society and authorities on human rights issues (i.e. rights, roles and responsibilities of each stakeholder). A Public Consultation and Disclosure Plan (PCDP) is being prepared, detailing arrangements for on-going consultation with key stakeholders.
- Bangladesh
Cairn’s assets in Bangladesh include the country office and a guest house in Dhaka; the Sangu onshore processing facility in Chillimpur; a small, unmanned offshore platform located 45 km southwest of Chillimpur; and a pipeline to transfer produced gas and liquids from the platform to the Sangu facility. The Sangu facility is operated by KBR on behalf of Cairn.
There are no routine discharges from the offshore platform; all produced gas and liquids are transported by pipeline back to the onshore facility. Current production is around 165 million cubit feet of gas with approximately 450 bpd of liquids, of which 20% is condensate. The remaining fraction (± 360 bpd) is conveyed to a discharge pond, where it is treated (by settling and aeration) and diluted to conform to the Bangladesh Department of Environment (DoE) discharge limit, and discharged 500m offshore via a discharge pipeline. Recent changes in operations at Sangu have led to the higher concentrations of contaminants in produced water. These include additional perforation of production wells in 2003, which resulted in increased salinity (chloride and Total Dissolved Solids) and the addition of new production wells in 2004, which has resulted in increased levels of Chemical Oxygen Demand, Oil in Water, and Volatile Organic Compounds ("VOCs"). Ambient VOC concentrations in the plant have further increased as a result of the aeration program.
Cairn is aware that dilution is not an acceptable long term strategy, and has undertaken several studies to consider other options, including:
- internal and external studies of possible process changes to lower the levels of contaminants in produced water;
- an analysis of employee exposure to VOCs;
- a Produced Water Environmental Risk Assessment; and
- a feasibility study of produced water reinjection as a disposal option at the onshore Chillimpur facility.
The process studies led to optimizations of the existing process which have resulted in a 33% reduction in the levels of COD in the produced water and a consequent commensurate reduction in the dilution factor needed (from 6 to 4). The analysis of employee exposure included both air sampling and analysis of VOC concentrations and analysis of blood samples drawn from Sangu employees. Based on the data obtained, Cairn has installed a permanent cover on the discharge pond, and controlled access to the area around the pond, and continuous atmospheric monitoring for VOC concentrations. Cairn expects to have completed its feasibility study of additional water treatment options versus development of a reinjection well by June 2006. This work will produce the scope of work for both options plus costs, enabling a decision to be made by June 2006, with implementation shortly afterwards. Cairn has prepared a detailed Corrective Action Plan and will report quarterly on progress until full resolution of the current produced water situation.
The Bangladesh operations source their power requirement from two gas-fired generators, with a third (diesel) generator used as a standby. Emissions from the generators are negligible. Diesel fuel is stored in a single 1000-liter aboveground tank, enclosed by a cement bund. Transfer of diesel from tanker trucks to the storage tank is done by Sangu staff, and not the truck drivers, to minimize the risk of spillage. Small amounts of low pressure gas are flared. One of the process changes undertaken to address ambient high VOC levels in produced water in the plant due to the aeration process was to capture and flare them.
Cairn is also planning to install a short (2.5 km) onshore “bypass” pipeline to take gas from the plant directly to the Chittagong low pressure supply ring main. This new line will be laid adjacent to the existing transmission pipeline; necessitating the existing pipeline ROW will need to be widened by approximately 3 meters to accommodate the new line. Cairn has establishes a local RAP which accords with the Group RAP and a project specific RAP will be developed to address the requirements of the “bypass” pipeline.
As in India, Cairn has an established waste-management plan for all identified liquid, non-hazardous and hazardous waste. The plan identifies methods for handling, treatment, storage and disposal and outlines methods for segregation of wastes and recycling where possible. Cairn has in place onshore and offshore emergency plans for the Sangu operations, including an oil spill contingency plan and fire fighting protocols, which are tested through regular drills. Operations are further evaluated via regular monitoring by Cairn personnel, ISO 14001 audits twice a year, and an annual programme of HSE audits. HSE awareness and training programs are conducted for all employees and contractors.
In the Environmental Impact Assessment ("EIA") carried out when Sangu was under development, no sensitive natural habitats were identified in close proximity to either the onshore facility site or the location of the offshore platform. Cairn has stated that it will undertake a full, independent EIA for its proposed satellite development in Block 16 (known as “South Sangu”), once the elements of the development have been finalized and the project has been approved by Cairn’s Board. The EIA will be developed in accordance with Cairn’s policy, IFC guidelines and DoE requirements. Cairn will submit the draft Terms of Reference for the EIA, as well as the EIA report, to both IFC and DoE for review and comment. As part of the EIA, any sensitive natural habitats and species that might be affected by the development will be identified, and appropriate mitigation measures proposed. The EIA studies are expected to be conducted in mid-2007.
Cairn contributes to a number of community development programs in the villages near Sangu and parts of blocks 16 and 5. The largest of these is the Chillimpur community-based adolescence project in partnership with Mamata, a national NGO, to provide skills training for unemployed youths and others at locations throughout Bangladesh. Cairn funded the establishment of a Mamata program in Chillimpur and reoriented the training programs to include skills that it most often requires from local contractors; for example, electrical services and computer literacy. The Mamata center in Chillimpur also provides free health services, including testing for sexually transmitted diseases and HIV, maternal and child health programs, and general medical services. The program especially targets adolescent women and mothers, and provides satellite counseling and clinical facilities in order to serve women who do not leave their villages for religious/cultural reasons. In addition, similar programs are in place, also in partnerships with NGOs, in the field of conservation and community development. Cairn is consolidating its plans for future community work in a Community Development Plan, which will guide its future corporate social responsibility activities. As part of its environmental outreach efforts, Cairn sponsors a sea turtle conservation program in Cox’s Point, some 15km south of the Sangu facility.
There is significant fishing activity in the area around Sangu. For security and safety reasons, Cairn has established a 500m exclusion zone around the offshore platform. Enforcement of the zone boundaries is carried out by Cairn’s offshore support vessel, which is kept on station close to the platform, except when it is needed to transport people or equipment to or from the platform (e.g., for maintenance). Cairn indicated that it has instructed the master of the vessel to enforce the 500m limit only when needed to protect the platform.
The company has also prepared a stakeholder engagement plan to address any impacts to fishing activities associated with its future development activities in Bangladesh. The impact of fishing activities around Sangu is a significant safety risk to the offshore support vessel, her crew and the platform from fouling fishing nets in the vessel’s propeller. Cairn will include a review and analysis of regional artisanal fishing activities in the EIA to be prepared for the proposed South Sangu development.
As part of Cairn’s integrated management system, Cairn has in place Group Security Policy and Guidelines, which commit the organization to protect the safety and security of everyone involved in its activities. The Group Security Guidelines draw upon the Voluntary Principles on Security and Human Rights, the United Nations ("UN") Basic Principles on the Use of Force and Firearms by Law Enforcement Officials, and the UN Code of Conduct of Law Enforcement Officials.
Cairn’s Bangladesh operations utilize the services of armed ANSAR guards. The guards are drawn from across Bangladesh and are posted in any given location for one year, then rotated out. Those working at Sangu are accommodated in a camp located in Chittagong. Cairn also employs unarmed guards from a private security firm, who work in teams with the ANSAR guards. The guard force has a total of 62 security personnel, including supervisors, operating in 3 x 8-hour shifts. Each shift includes 5 ANSAR guards, who patrol jointly with unarmed private security personnel. The Cairn head of security operations communicates daily with the supervisors of both forces, and the two groups are understood to work well together. Cairn has indicated there have been no problems with either the ANSAR guards or the private security force during their tenure at Sangu.
As discussed above, Cairn has also prepared a detailed PCDP to guide its communications and information disclosure activities with communities in the area around the Sangu facility.
Under the terms of a PSC with the government of Bangladesh, Cairn is also the operator for exploration and development activities in Block 5. The Sundarbans Reserve Forest ("SRF"), a World Heritage Site declared by UNESCO in 1997, is located in the south portion of this block. The SRF, which occupies almost half of the block, has abundant natural resources and is also rich in biodiversity. A 10 Km wide buffer area around the SRF has also been declared as an “Ecologically Critical Area (ECA)” by the Government of Bangladesh. In line with its policy, Cairn has stated that it will not carry out any exploration activities in the SRF or ECA.
