Dear Editor,
We reflect on the risks involved as ExxonMobil drills through ~2,000 metres of water (>1 mile) and ~3,700 metres (> 2 miles) of rock to get to the petroleum and associated gas located under the weight of such pressure in Guyana’s offshore territory.
We note that the increase in daily production to 155,000 barrels per day (bpd) for Liza-1 compared with EIA-reported design levels of 100,000/120,000 (bpd) has occurred and is continuing without formal EPA approval or any indication that the equipment was ever designed to operate safely at such an increased level.
We do not see in the public domain any safety certificates or any explicit mention of such safety certificates by EEPGL, the builder/operator SBM Offshore, or the EPA. Guyana’s National Bureau of Standards has also been silent, likewise the Ministry of Labour which is responsible for checking industrial Health and Safety.
Given the risks that the Operator (ExxonMobil) is taking in accelerating production, we all know that a loss of wellhead control would lead to a massive oil spill and potential major environmental and economic damage to Guyana’s and Caribbean Islands’ economies.
The EEPGL oil spill response plan (OSRP) is vague on what international standards were used to design the OSRP, how the OSRP is actually used, training, on-ocean practices of spill control and clean-up.
Public reporting on practice on-ocean sessions has been nil. The published reports on one or two shore-side practices with a 60-foot or 60-metre inflatable boom show an almost insulting lack of preparedness or understanding of the major risk.
Moreover, the EPA appears to have been entirely delinquent against its own mandate in not requiring more attention to risk assessment, mitigation and restoration. The fact of the historical occurrence of major spills, including in oil fields operated by or for ExxonMobil, show that our concerns are not just theoretical.
Editor, as Justice Kissoon has ruled (and many commentators have pointed out) a parent company guarantee that assumes responsibility for all costs in the event of a spill is simply an official legally-valid letter signed by the CEO of ExxonMobil. As Dr Vincent Adams (former Head of the EPA) has said repeatedly, a parent company guarantee costs nothing. So what is the problem? If ExxonMobil, as it says, is so careful that there are no spills, then that guarantee will simply never be activated or drawn upon.
Editor, the most recent version of the EPA environmental (operating) permit for the Liza-1 oil field was signed on 27 October 2022. EEPGL has had seven months to draft and sign the one-sentence letter of unlimited liability coverage (See section 14.10, page 37).
Editor, seven months are more than enough to meet the ‘as soon as reasonably practicable’ time allowance. And so thought Judge Sandil Kissoon.
To Mr Routledge and our Guyana government: we demand a parent company guarantee – simply an official legally-valid letter – signed by the CEO of ExxonMobil.
Yours faithfully,
Janette Bulkan
Danuta Radzik
Vanda Radzik
Alfred Bhulai
Elizabeth Deane-Hughes
Alma O’Connell
Mosa Telford
Christine Samwaroo
Karen de Souza
Wintress White
Joy Marcus
Susan Collymore
Vanessa Ross
Halima Khan
Red Thread
Salima Bacchus-Hinds
Immaculata Casimero
Colin Klautky
Nicole Cole
Joan Cambridge-Mayfield
Troy Thomas
