The Company has presented plans to address the identified impacts for the Jubilee Field Phase 1 Development and to implement the IFC Performance Standards, through its corporate EHS management system, in all projects financed by the IFC Loans, i.e., the Applicable Projects. These plans will ensure that the Applicable Projects will, upon the implementation of the specific, agreed measures (which the Company will use its reasonable endeavors to bring into effect by exercising its rights under any petroleum agreement, joint operating agreement or unitization and unit operating agreement (the “Project Agreements”)), comply with the environmental and social requirements: 1) the host country laws and regulations; 2) the IFC environment and social Performance Standards; and 3) the applicable and relevant IFC environmental, health and safety guidelines. The information about how the potential impacts will be addressed by the company is summarized in the paragraphs that follow. Further information is provided in the attached documentation. All references in this document to the company or project taking any action are to be construed as references to Tullow using its reasonable endeavors, to the extent possible by exercising its contractual voting rights under joint operating agreements, to seek to ensure that any Applicable project take such action. Any obligation of the company to ensure compliance with each of the environmental and social issues and mitigation measures set out in this document is an obligation on the company only to use its reasonable endeavors to ensure such compliance by exercising, as far as it is able, its contractual rights under any relevant Project Agreement.
APPLICABLE PROJECTS
PS 1: Social and Environmental Assessment and Management Systems
Corporate Assessment. Tullow’s social and environmental assessment of projects takes place within the framework of its Integrated Management System (IMS), and includes the Company’s Risk Management Guideline and its Environmental Impact Assessment Recommended Practice. At each stage of a new project – new business, exploration, project development, production operations, and divestment/abandonment - Hazard Identification Studies and Environmental Identification Studies are carried out by Tullow staff, and Environmental Impact Assessments conducted by independent consultants where it is required by local regulators or where there are potential high risks identified. These studies and assessments are proportional to the risks and impacts at that stage of development. The studies may also identify specific risks that require additional assessment. Under its existing risk management system, each asset, i.e., each project, must define its own criteria for risk acceptability, which must include local regulatory requirements. Tullow will, however, require that all Applicable Projects apply the IFC’s Performance Standards as explicit criteria for the basic acceptability of social and environmental risk and impacts. Tullow has already carried out reviews of non-operated projects where it has learned of environmental, health, safety, and/or social issues. Tullow will carry this further by conducting a systematic review of existing Applicable Projects to determine whether they conform to the IFC’s Performance Standards and will develop Action Plans where there are gaps. Where Tullow does not control assets in the Applicable Projects, it will use reasonable endeavors to implement the Action Plans for those projects. This requirement will be explicitly stated in revised versions of the Risk Management Guideline and the Environmental Impact Assessment Recommended Practice.
Corporate Management. At present, Company Regional and Line Managers are responsible for ensuring that systems are in place for managing EHS risk, identifying potential hazards, conducting risk assessments for new activities, and putting in place control measures and monitoring them. Tullow also has an EHS auditing system that periodically reviews the various operations it controls with respect to conformance with the ISO 14001 environment management standard. Several units in Tullow’s operations have been ISO 14001 certified and recertified, including its Pakistan and Bangladesh operations. With respect, however, to Applicable Projects, Tullow’s Head of EHS will make sure that all Tullow social and environmental assessments and management systems have been based on the IFC’s Performance Standards, and in particular that new assets controlled by Tullow such as the Project are meeting those Standards.
Corporate Training. Tullow will ensure that all levels of the Company, including line and regional managers, local EHS advisors, and the Head of EHS, have received appropriate training in the IFC’s Performance Standards and the applicable IFC EHS Guidelines.
Corporate Community Engagement. With the adoption of IFC’s Performance Standards for Applicable Projects, Tullow will apply a more uniform approach to community engagement. As some aspects of stakeholder engagement are not tied to operational issues, Tullow may also endeavor to implement better practices in community consultations, even in non-operated projects.
Corporate Monitoring and Reporting. The Integrated Management System framework requires systems for monitoring, auditing, reporting and assessment. In practice, each asset provides monthly EHS reports to the Head of EHS. The Group Management Team receives EHS reports every two months, and the Executive Board receives a report every six months. These reports can highlight incidents at non-operated assets. Tullow produces an annual Corporate Social Responsibility Report that is reviewed by an outside auditor for accuracy. It reports on several aspects of the Company’s environmental, health and safety performance, as well as on its community projects, for its global operations.
PS 2: Labor and Working Conditions
Corporate Human Resources Policy and Organization. Tullow has a human resource (HR) organizational structure that includes HR management at corporate level and country level. HR managers and advisors are generally deployed in-country where the Company operates its assets. The Company has approximately 500 staff employees and 140 consultants. Tullow’s IMS provides the framework for occupational health and safety (OHS) management and performance. Specific standards are devoted to crisis and emergency management; incident investigation; EHS performance measurement; monitoring and reporting; audits; and reviews. Tullow has adopted occupational health and safety (OHS) metrics, according to recognized international standards. The Company’s performance in terms of lost time incidents and total recordable incidents is recorded and publicly reported their CSR annual report. An Accident and Incident Investigation and Reporting System has been developed, which allows identification and more focus on the potential severity of the incidents rather than on their actual severity. EHS reviews are performed during contractor selection, and the Tullow management system requires pre-contract award and post-award audits of contractor EHS practices. The Company has implemented Malaria Management Programs in the countries where it operates to reduce the incidence of cases in the workforce and to work with the local communities in combating malaria. A corporate Driving Policy was issued in 2006 to prevent and reduce risks associated with vehicles and road journeys. Tullow has dedicated crisis management facilities and team.
The corporate HR manager will be responsible for ensuring that all Applicable Project assets meet the requirements of PS 2. This will include a systematic review of all these assets and the development of Action Plans where there are gaps between PS 2 standards and individual asset HR policies and practices.
PROJECT – GHANA JUBILEE PHASE I
The following section reviews the measures that Tullow will use its reasonable endeavors to put in place with respect to the Project.
PS 1: Social and Environmental Assessment and Management Systems
Assessment. Tullow is preparing the Environmental and Social Impact Assessment (“the ESIA”) for the Jubilee field for the Ghana Environmental Protection Agency (the “EPA”). The ESIA will include an environmental baseline study (“EBS”). The EBS data gathering phase has been completed. The EBS results will be included in the ESIA that will be reviewed by the EPA. An Environmental Permit for the project will be issued by the EPA following a successful review of the ESIA, including a process for public comment on the ESIA. The timeline for the developing the ESIA is a scoping phase that was completed in February 2009, a stakeholder engagement process to take place from the beginning of January to late May 2009, a target for the draft final ESIA to be submitted to Ghana EPA in early June 2009, and approval expected in late August, 2009.
Management Program. The Jubilee Joint Venture has an Environment, Health and Safety Management Framework (EHSMF) that has a management of change standard ensuring that all changes in design, operations, risk management, project organization and personnel, legislation are taken into consideration. Tullow will periodically review the Project – at least once a year but more often during early stages – to determine whether changes in the EHS management need to be undertaken. The Project will also develop policies and procedures that reasonably foresee issues in future phases, such as land acquisition.
Organization and Training. The Project is developing a staffing and training plan, with appropriate job descriptions, to ensure the ongoing management of the project according to EHSMF and the Environmental Management Plan that will result from the ESIA. The Project will ensure that all staff understands the basic environmental and social policies, procedures and actions of the Project.
Stakeholder Engagement. As part of the procedure for permitting by the Ghana EPA, the Project will need to participate in two sets of public meetings: one set for the scoping phase and another for the draft ESIA. The development of the ESIA will involve approximately 100 days for stakeholder engagement, including over 20 days of formal stakeholder consultations on the ESIA and 60 days of open stakeholder engagement. Tullow will make a copy of the ESIA available to the local communities for a period of 30 days, once it has been approved by the Ghana EPA. As the Project is off-shore, the potential impacts from its operations will be from (i) the establishment of exclusion zones around the drilling vessels and FPSO where any fishing will be prevented and (ii) the risk, although minimal, of oil spills reaching the shore. Given the Project’s distance from the shore, impacts on local fisheries are likely to be limited. However, the Project is working with local fishing communities who may operate in the area of the off-shore operations to explain the need for the exclusion zones and the methods by which they will be maintained. The latter are explained further below, under PS 4. The Project will have an Oil Spill Contingency Plan that will be developed in consultation with local authorities and communities. Tullow will report at least bi-annually to the local communities on those aspects of the Environmental Management Plan that address community concerns.
Grievance Mechanism. A partner in the Project, Kosmos, has developed a Social Reconciliation Plan (“SRP”), which includes a grievance mechanism that has been reviewed and found acceptable by IFC. Tullow will vote in favor of a substantially similar plan to be implemented by the Project, pursuant to its voting rights under the joint operating agreement.
Monitoring and Reporting. The monitoring program will be available as part of the ESIA to be submitted to the Ghana EPA. Senior management of Tullow, as one participant in Jubilee Joint Venture, will receive periodic (but not less than one year) reports on the monitoring measures and will seek to ensure that the project maintains and improves its environmental and social performance.
PS 2: Labor and Working Conditions
Working Conditions. At this early stage, Tullow has approximately 30 employees in Ghana, out of which 20 are Ghanaian nationals. Tullow will finalize a human resources policy by April 30, 2009 that will recognize the rights of workers under Ghanaian law, including hours of work, overtime arrangements and compensation, policies on leave, principles of equal opportunities and non-discrimination, and rights to work organization and collective bargaining. The human resources policy will also spell out a worker grievance mechanism that will be accessible, transparent and prompt.
Worker Health and Safety. The Project has developed health and safety policies and procedures. Four specific plans are of primary relevance to occupational safety: the Mobile Offshore Drilling Unit (MODU) Operation EHS Bridging Document, the Emergency Response Plan (ERP), the Permit to Work System, and the Chemical Handling (COSHH) Procedure. The MODU Operation EHS Bridging Document synthesizes responsibilities and accountabilities of Tullow and its contractor, communication procedures, management of change, work programs and procedures, emergency response procedures, equipment procedures, personnel selection, competency and training, monitoring, auditing, and review. The resulting Bridging Document provides a uniform framework for operations to which all must adhere. The drilling ERP, among other objectives, protects the lives of personnel. It presents the emergency response arrangements and organization both for the MODU and for the coastal facilities. Training, audits and drills are planned. It includes a Medical Evacuation Plan in case of serious injury on the off-shore facilities. The Company will update this document for the other phases of the Project, including an Operations Phase ERP. The Permit to Work System is a drilling contractor document that applies to contactor activities on the MODU. Similar documents will be developed for or required of other contractors, for the FPSO operations, and for shuttle transport. The Permit to Work System authorizes a type of work in a specific location - e.g., confined space - following a hazards assessment and identification of protective measures. The Chemical Handling (COSHH) Procedure addresses handling, storage, use and transportation of all hazardous-to-health chemicals and substances, whether offshore, onshore, or in transit to or from Company installations. It includes reviewing new chemicals in the work place, maintaining an inventory list and material safety data sheets for hazardous chemicals, and providing information to workers and managers on those chemicals in a multiple-employer worksite. Thus, the health and safety policies and procedures are designed to ensure that Tullow will include appropriate use of personal protective equipment for different areas of operation, identification of hazards and measures to reduce potential injuries to workers, labeling of different materials according to their hazards, training of workers, documentation and analysis of incidents and accidents, and implementation of an emergency response plan to protect workers, as required by PS 2.
PS 3: Pollution Prevention and Abatement
Atmospheric Emissions and Noise: Phase 1 activities during development and operations will emit varying amounts of air pollutants, including carbon monoxide (CO), oxides of nitrogen (NOx) and sulfur (SOx), volatile organic compounds (VOCs), and particulate matter. Dilution and dispersion of air pollutant emissions from the mobile offshore drilling units (MODUs) and the FPSO are expected to be rapid and the potential effects on ambient air quality to be limited to a short distance from the emission sources. No detectable effects on ambient air quality onshore in Ghana and Côte d’Ivoire are expected considering the relatively limited amount of air pollutants emitted and the distance from shore. The Project will ensure that offshore facilities and support vessels will comply with the requirements of MARPOL Annex VI (relevant to sulfur oxide and nitrogen oxide emissions from ship exhausts and diesel engines, prohibition of deliberate emissions of ozone-depleting substances, and prohibition of the incineration of certain products on board) and relevant IFC guidelines for small combustion sources, minimization of venting and flaring (consistent with the Global Gas Flaring and Venting Reduction Voluntary Standard) and minimization of fugitive emissions.
The FPSO, MODUs and vessel operations will generate noise into the marine environment with potential impacts on biota. The low-frequency noise levels from offshore drilling and production activities are relatively weak in intensity, but they can be detected and produce some behavioral responses (e.g., avoidance) in marine mammals, particularly baleen whales. However, these levels are much lower than those known to cause hearing loss, discomfort, or injury. Marine mammals do often congregate around offshore platforms and become accustomed to predictable noise, as in the case of ships following a shipping route and stationary sources. Tullow will ensure that routine inspection and maintenance of engines, generators, and other equipment, noise and air emissions monitoring and use of low-sulfur diesel fuel will be defined as part of the Project’s environmental monitoring program.
Greenhouse Gas Emissions: Under Phase 1 Development all associated gas (after fuel use on the FPSO) will be re-injected into the formation for future recovery and use. The FPSO will have the capacity to handle and re-inject 100% of associated gas volumes - 160 millions of standard cubic feet per day (MMscfd) - to the field through three gas injection wells. Greenhouse gas emissions (GHG) will be generated from engines, burner fuel consumption, and fugitive emissions of associated gas. The estimated total GHG emission during the construction phase, including drilling, completion, installation of the subsea facilities and FPSO, will be approximately 1.3 millions tons of CO2 equivalent. The annual GHG emission during production and operations is estimated at approximately 160,000 tons CO2 equivalent per year. As required by PS 3 for projects with GHG emissions greater than 100,000 tons CO2 equivalent per year, the Project will maintain a monitoring program for GHG emission, and will establish programs to minimize the emissions, based on the monitoring data.
Drilling Fluids and Cuttings Management: The use of both water-based fluids (WBFs) and low-toxicity, enhanced mineral oil based fluids (EMOBFs) is planned during drilling production and injection wells. WBFs will be used in the upper sections of the well bore, down to approximately 500 m below the mudline. EMOBFs will be used to drill the mid- and lower well sections to the bottom of each hole (approximately 2,500 m). The Project will ensure that recovered EMOBFs will not be discharged and they will be returned to the vendor for recycling.
The Project evaluated feasible alternatives for the disposal of spent drilling WBFs and all drilled cuttings, including disposal through (i) injection, (ii) containment and transfer to shore for treatment and disposal, and (iii) discharge to sea. The ESER prepared by Kosmos for the Project identified the continuous discharge of drilled cuttings, containing residual WBFs and EMOBFs within acceptable limits, as the best alternative for disposal. Water depth precludes injection of muds and cuttings, and environmental impacts associated with barging cuttings to shore are estimated to be greater than discharging offshore because (i) onshore facilities for treatment and disposal are not currently available to receive the oily cuttings; (ii) energy consumption and air emissions for discharge overboard are lower than to ship-to-shore transfer; and (iii) handling of cuttings and muds for shipping to shore increases personnel safety risks. It is estimated that cuttings discharged will account for approximately 3,000 bbl, or about 470 cubic meters per well, of which approximately one half (1,500 bbl or 235 m3) will be cuttings drilled with EMOBFs. Drilling discharges for each well will also include approximately 1,000 bbl (about 155 m3) of WBFs. Discharge to the ocean will be at a rate of 0.2 to 2.0 m3/h. The ESER reviewed the potential effects of the drilling discharges on water quality, plankton, fish, sediment quality, and benthic communities. Low toxicity and rapid dispersion of drilling discharges due to significant water depth and strong currents will cause limited or no measurable impact to the biological environment. Water clarity will be affected within a few hundred meters to about 2 km of drilling rigs during drilling fluid discharges, and dispersion will allow a return to background levels in a relatively short time. Dispersion also minimize benthic impacts. Impacts on benthic communities of soft bottom areas will only be measurable within a few hundred meters of each drill site, and that re-colonization of these areas should happen within a few years. As a main mitigation measure, each drilling unit will have a cuttings dryer that will be used to minimize oil retention on cuttings drilled with EMOBFs. The maximum oil retention allowed for discharge will be 8%. However, the drying systems installed should be able to attain 5% or less oil retention, which should limit the tendency to clump, allow sufficient dispersion, and limit the production of cuttings piles. These levels are above the IFC guideline of 1% on oil content of cuttings disposed to the sea. The IFC guideline is not achievable through available technology and was intended to discourage ocean disposal. Exceptions to the IFC Guideline are acceptable where a project’s environmental documents provide a justification for ocean disposal. Because the alternatives are not feasible or may cause greater environmental harm, the ESER has provided a justification for a higher oil retention range. The Offshore Drilling Waste Management Plan will specify the requirements adopted for no free oil on discharged drilling fluids or cuttings (implementing visual sheen tests) and limitations on cadmium and mercury concentrations in stock barite as per IFC guidelines. Methods and procedures, adopted by the Project for the management of drilled cuttings and fluid disposal, will be included in the Waste Management Plan. The methods and procedures will take into account cuttings and fluid dispersion, chemical used, environmental risk, and necessary monitoring. WBFs and residual EMOBFs on drilled cuttings will be subject to tests for toxicity, barite contamination, and oil content, as per IFC guidelines. The Project will develop a cuttings deposition model (which will be included in the final Jubilee ESIA report) to quantify the average sea bottom coverage of cuttings, maximum horizontal extent from the drilling unit location, and the estimated total sea bottom area impacted by the drilled cutting. The model results will support the management and mitigation measures included in the Drilled Cuttings and Fluid Disposal section of the Waste Management Plan.
Waste: Waste streams associated with Phase 1 activities will include hydrotest water, produced water, cooling water, gray water and sewage, bilge water, deck drainage, ballast water, cooling water, and solid waste. Hydrostatic testing of offshore equipment and lines will involve pressure testing typically with filtered seawater to verify equipment and pipeline integrity. A Hydrotest Water Disposal Plan will be prepared that considers points of discharge, rate of discharge, chemical use and dispersion, environmental risk, and monitoring.
Produced water will include formation water, injection water, and process water. Produced water is likely to be the largest effluent discharge during production. It is anticipated that quantities will be low during initial production, but may increase during the later stage of the life of the Jubilee field. The design throughput capacity of the FPSO is for handling up to 160,000 barrels of total fluid (i.e., oil and produced water), out of which a maximum of 80,000 barrels of produced water per day can be processed. Produced water will be treated through oil water separation to meet IFC guidelines (oil and grease not to exceed 42 mg/L daily maximum or 29 mg/L monthly average) before being discharged overboard. A produced water discharge sampling point will be installed in the FPSO and relevant procedures developed to monitor compliance with the IFC guidelines.
Only limited non-contact cooling water will be discharged into the marine environment. Tanker vetting procedures will be required to ensure that all shuttle tankers have segregated ballast water tanks to limit the risk of oil-contaminated discharges. Vetting procedures will also include requirements for ballast water exchange, consistent with Annex II of MARPOL 73/78, to avoid the introduction of invasive species. Ballast water management measures will be detailed and included in the environmental management system for operations. Sewage will be treated using marine sanitation devices that will produce an effluent with a minimum residual chlorine concentration of 1.0 mg/L and no visible floating solids or oil and grease. Treatment sludge will be transported to shore for disposal at an approved facility. Food waste will be ground prior to discharge, in accordance with MARPOL requirements. The MODUs and FPSO include design features that will contain runoff and prevent oily drainage from being discharged, diverting potentially contaminated deck drainage collected by an open drain system to oil water separation systems. The Project’s operations are designed to only allow for discharge of water meeting the criteria of 42 mg/L and 29 mg/L oil, daily maximum and monthly averages respectively, and will not allow discharge of free oil in deck drainage that would cause a film, sheen, or discoloration of the surface of the water, or a sludge or emulsion to be deposited beneath the surface of the water. The drain system on the processing deck will also include a closed drain system, collecting oily fluids, which will be sent to a cargo tank.
All solid waste generated during drilling will either be incinerated aboard the MODUs or FPSO, or transported to shore by service vessels for disposal at approved facilities. Disposal of trash and debris in the ocean will be prohibited consistent with MARPOL requirements.
The Project has adopted and implemented (and will require its contractors to adopt and implement) a Waste Management Plan that contains a clear waste tracking mechanism to track waste consignments from the originating location offshore to the final waste treatment and disposal location. Efforts will be made to eliminate, reduce, or recycle wastes at all times. The Project will ensure that all waste materials will be segregated offshore, at a minimum, into non-hazardous and hazardous wastes and shipped to shore for re-use, recycling, or disposal, as needed. The existing Drilling Waste Management Plan will be updated to include other planned activities during facility installation, as needed. An Operations Phase Waste Management Plan will then be developed and audits of the waste management facilities regularly conducted. The Chemical Handling (COSHH) Procedure will be implemented to handle all hazardous chemicals that are produced, used, or stored aboard Project vessels or facilities, ensuring consistency with IFC guidelines. Transportation of hazardous material will comply with United Nations regulations and specific training will be provided to all personnel.
Emergency Preparedness and Response: The Project will install downhole safety devices - surface-controlled subsurface safety valves (SCSSVs) - at each well, which will be controlled by subsea and FPSO safety control systems. These systems will shut the valve in the event of an emergency or operational upset in the well or process. All subsea flowlines and risers will be tested during the installation and hookup process. The FPSO processing equipment will be protected by safety systems that monitor critical information and activate process controls to reduce the risks of accidents and injuries. Specific requirements, providing for controls for all vessels activities and based on international guidance, including the International Safety Guide for Oil Tankers and Terminals, will be developed to govern all crude oil transfers from the FPSO to shuttle tankers. All wells will be equipped with a blowout preventer during drilling, and Well Control Plans will be prepared to address drilling, completion and production operations for each well. These plans will contain strategies to respond to specific situations, including well kicks and blowouts. A Drilling Emergency Response Plan (ERP) is available, including procedures for medical evacuation, search and rescue. The ERP will include response procedures to emergencies potentially associated to all construction activities planned, including fire prevention and protection, environmental emergencies, and other incident responses. The Company will also develop and implement an Operations Phase ERP. Tullow’s Ghana Oil Spill Contingency Plan (OSCP), which considers potential spill scenarios for the drilling and installation phases, has been prepared and is structured consistent with the IFC guidelines. Spill scenarios for the production operations phase will be developed to develop the operations phase OSCP. Quantitative modeling, based on the potential surface and subsurface oil spill release scenarios, will be conducted, and an assessment of potential oil-spill related impacts to offshore and coastal environmental resources, including turtle nesting beaches, will be conducted. The final OSCP, developed in consultation with local authorities and communities, will define specific measures for protecting turtle habitat and other protected and sensitive coastal habitats. Jubilee Joint Venture is a member of Oil Spill Response (OSR, formerly Oil Spill Response Limited) and will have access to OSR’s Tier III and Tier II spill response equipment. As part of the oil and gas operators in Ghana, the Project participates in the establishment of a mutual aid agreement among operators to access spill response equipment, currently planned to be based in Takoradi.
Although the presence of hydrogen sulfide (H2S) is not expected, a H2S Program will be developed and adopted by the Project and its contractors, as needed. Hydrogen sulfide detection equipment will be installed in all Project facilities.
PS 4: Community Health, Safety and Security
Safety and Security. The Project will have 500 m exclusion zones around its drilling ships (MODUs) and 1000 m zones around the FPSO. These zones will protect other vessels from collision with the project vessels and fouling the anchor lines. Because the Project is in deep water and distant from the shore, its construction and operations will not affect most artisanal fisheries, but commercial fishing ventures may utilize the Project area. However, the possible fouling of flow lines by nets and other fishing gear is considered unlikely. The MODU and FPSO can act inadvertently as fish attracting devices to which fishing communities may, in turn, be attracted. Maintenance of these safety zones will come through a combination of educating fishing communities onshore and intervention at sea in the Jubilee field, including management of boat traffic to the offshore facilities. The Government of Ghana is establishing a regulatory basis for the exclusion zones to ensure that intervention in the field can be maintained without legal challenge. Rules of engagement will be developed to ensure proportionality in the enforcement of the zones. The at-sea intervention will, in the first instance, be carried out by the Project’s own vessels in a non-threatening way. Direct intervention by Ghanaian law enforcement may be necessary where a vessel persists in encroaching into a safety zone and approaching a Project vessel. The use of national law enforcement authorities will follow the US-UK Principles on Security and Human Rights.
PS 6: Biodiversity Conservation and Sustainable Natural Resource Management
The ESER, developed by Kosmos, presents a literature review of baseline information on fish species, benthic communities, marine mammals, sea turtles, and marine and coastal birds, and identifies risks and impacts on the biological components and the vulnerability of the biodiversity and natural resources present in the Project area.
There are no marine protected areas at or near the Jubilee Field. Marine waters offshore Ghana are within the Central West African upwelling zone, with a major upwelling season from July through September and a minor upwelling season from December through March. Upwelling of cool, nutrient-rich water results in enhanced primary production, and therefore a situation conducive to high productivity for fish resources. Approximately 480 fish species are reported to be native to the coastal areas of Ghana, out of which approximately 180 are associated with deepwater habitats. Over 300 different species of commercially important fishes are also reported for Ghana. The upwelling zone at its peak approximately coincides with the Ghana Exclusive Economic Zone (EEZ), of which the area directly affected by Jubilee Field Phase 1 Development (approximately 64 km2) represents 0.03%. Although the Project’s direct footprint can be seen as negligible with respect to the extent of upwelling and its impact on fish resources, potential impacts on fisheries are to be managed as discussed under PS 1 and PS 4.
Soft bottom benthic communities are expected to be consistently present in the Project affected area. Although extensive hard bottom areas occur offshore of Ghana, a geohazards study conducted by the Project indicated there are no hard bottom features in the Project area. The same geohazard study did not identify any seabed features (e.g., mounds, faults, craters, wipeout zones) that are known to be associated with high-density chemosynthetic sites. Therefore, the presence of chemosynthetic communities is not expected, although they have been reported in the region offshore of Ghana. The results of the Environmental Baseline Survey will complement and provide assurance on these findings.
The regional waters are known to support a diverse marine mammal fauna, including baleen whales, toothed whales and dolphins. The Project identified the potential presence offshore Ghana of three whale species - blue, sei, and fin whales - that are classified as Endangered by the IUCN Red List, and one species classified as Vulnerable (sperm whales). Humpback whales, for which the classification was recently changed to Least Concern from the previous classification of Vulnerable, are also reported to be present offshore of Ghana and other West Africa areas, where they have their breeding and nursery grounds. Sperm whales and Bryde’s whales, a Data Deficient species, may occur year-round offshore West Africa, while the presence of baleen whales is likely limited from May through October (austral winter). The Project reviewed the available literature on life history, biology and behavior, distribution range, population size, regional presence, preferred habitat, seascape features critical to the survival of these species, and the migratory routes for the marine mammal species reported in the region. This review indicates that the Project area is a natural habitat that includes primary or secondary range for blue whales, and secondary range for fin whales. Based on current knowledge, the Project-affected area does not meet the criteria for the designation as critical habitat because the area is not critical for the survival of any of these species. However, the Project recognizes that there is a lack of specific information on actual species occurrence, and particularly on aggregation areas for blue whales that, theoretically, could be associated with the area of upwelling. The EBS has provided important information, which will be included in the ESIA, on oceanographic or benthic features in the vicinity of the Jubilee Field. The Project will develop and implement a program for training vessel’s and helicopter’s operators in marine mammal observation and monitoring at, and in the vicinity of, the proposed Jubilee Field development. The program will be included in the final Jubilee ESIA and developed in consultation with the Ghana EPA. The Project will also develop and enforce a specific policy and procedures to ensure that traffic and operations of drilling vessels, support vessels and helicopters will minimize disturbance to marine mammals.
Five species of sea turtles have been recorded in the Gulf of Guinea, including along the 70% of the Ghanaian coastline that is suitable for turtle nesting, with 80 km that are densely nested. Two species, hawksbill and leatherback turtles, are classified as Critically Endangered by the IUCN Red List, and three species, green, loggerhead, and olive ridley turtles - the latter being the most common in Ghana - are Endangered. The nesting season is from August through March, with a peak from September through January. Thirty-six sites, including five along the coast, have been designated as Important Bird Areas (IBAs) in Ghana. The closest IBA to the Project area is the Amansuri wetland, which is located west of Takoradi. It includes the freshwater Amansuri lagoon, flood plains of the Amansuri river, coastal Amansuri lagoon and estuary, and Esiama beach, and supports the largest stand of intact swamp forest in Ghana. The wetland is not situated along the direct line of flight for helicopters supporting Project’s operations. Project activities will not directly affect nesting sites and other sensitive coastal areas, including the IBAs, and the risk of accidental oil spill impacts to these sites will be minimized and mitigated through prevention and response measures developed in the Oil Spill Contingency Plan, as discussed under PS 3. The Project will also ensure that support helicopters will routinely avoid flying over the Amansuri wetland and that, if avoidance is not feasible due to weather conditions, a minimum altitude will be specified, according to international good practice, when flying over this area to minimize disturbance to wildlife.
