Keeping it clean

SEAs are different from environmental social impact assessments (ESIA) in that SEA studies prescribe long term policy planning for an entire region or sector, whereas ESIA studies guide planning on possible alternatives for specific projects and also propose an environmental management plan (EMP) to include monitoring measures and indicators.

According to the United Nations Environment Program (UNEP), an SEA is an “approach to take account of the environmental effects of policy, plans and programmes.” Often employed to obtain and evaluate environmental information, SEAs are useful in generating policy to guide decisionmaking, containing predictions of how the environment is expected to change if certain alternative actions are implemented with advice on how best to manage environmental changes. In Lebanon’s SEA, RPS Energy writes that the process is intended to strike “a balance between promoting economic development of offshore energy resources and effective environmental and community protection.”

UNEP defines ESIAs as “a procedure that identifies, describes, evaluates and develops means of mitigating potential impacts of a proposed activity” at the project level. RPS Energy prescribes that individual impact assessments be conducted by the exploration and production companies as part of contractual agreements (i.e. exploration and production agreements) between the Lebanese government and oil and gas operators.

Both SEA and ESIA studies are useful for a variety of audiences. These include national and local government staff whose responsibility lies in ensuring effective implementation of the studies’ recommendations and in evaluating and approving development project design. Likewise, the staff of multilateral and bilateral agencies charged with sustainable development projects use the studies to identify, design and implement projects. Private sector actors, particularly those companies with environmental responsibilities (e.g. drilling companies) make use of the studies to ensure proper safety measures are included in project design and implementation. Finally, SEA and ESIA studies are of the utmost importance to civil society, including environmental nongovernmental organizations, which have a vested interest in environmental protection and sustainable societal development.

Volume 1 of Lebanon’s SEA introduces RPS Energy’s study of the country’s exclusive economic zone (EEZ) — its purpose and methodology — outlined through several sections: an overview; a presentation of potential scenarios; risk and impact assessment and evaluation; oil spill scenarios; and assessment, recommendations and conclusion.

The scenarios section outlines seven potential outcomes during the exploratory drilling phase and the options for transporting gas from receiving terminals or LNG plants to power plants.

In Scenario 1, for example, where no commercial reserves are found during exploratory drilling, activities would cease, leaving limited impact on the environment and the economy (e.g. limited job creation).

By contrast, in Scenario 5, where exploratory drilling locates multiple commercially viable oil or gas reservoirs, significant (some positive, some negative) environmental (e.g. air emissions and infrastructure construction), economic (e.g. high generation of revenues), socio-cultural (e.g. price increases) and institutional (capacity deficiencies in authorities) impacts would result.

Mapping possible oil spill incidents — which could occur throughout the drilling and production phases — is also explored in this volume. Because the possible crude oil reserve characteristics are still unknown within Lebanese waters, trajectory models for possible spills of four types of oil — diesel, condensate (from gas wells), light crude and heavy crude — are included, with variables including the quantity and duration of spill release.

1,000m³ instantaneous heavy crude spill from center EEZ position (Trajectory)

Source: Strategic Environmental Assessment

5,000m³ 40 day blowout of heavy crude oil from the southern EEZ position (Trajectory)

Source: Strategic Environmental Assessment

Volume 2 of the SEA outlines the framework for formulating a national contingency plan (NCP) to mitigate marine pollution and coordinate an oil spill response. Among the framework prescriptions is the MoEW’s role as the competent authority to formulate the NCP as the coordinating government agency responsible for oil spill preparedness and response, to request external assistance if needed, to gather oil pollution reports, and to coordinate participation of the petroleum sector in the implementation of the NCP.

To advise the MoEW in formulating and implementing the NCP, a National Contingency Planning Committee (NCPC) would count as its members:

– Minister of Energy and Water (chair)

– Ministry of Environment

– Ministry of Public Works and Transport

– Ministry of Agriculture (Fisheries)

– Representative of each of the Petroleum and Petroleum Products Producing Companies

– Chief of Search and Rescue

– Ministry of Interior and Municipalities: Director General of Civil Defense

– Ministry of Defense 

– Ministry of Public Health

– Harbor Master

– National Center for Scientific Research (Marine Biology Specialist)

The NCPC will coordinate with the following public agencies whose responsibilities, in mitigating and responding to oil spill incidents, include:

Ministry of Public Works and Transportation

Among the ministry’s responsibilities are navigation safety in Lebanese waters, implementing policy to protect marine environment within both public and private ports, and preventing pollution from ships.

Ministry of Defense

Each branch of the military has a role to play. The navy has the responsibility to arrest or escort to the nearest port vessels breaching international or Lebanese law, to conduct routine vessel patrols, and to monitor, sample and report any pollution incidents. The air force will undertake routine air patrol missions to protect Lebanese waters and establish aerial surveillance to identify polluters and oil slick incidents. And the army, when requested, will assist the MoEW in the organization of manpower and equipment during shoreline cleanup following oil spills.

Local government

The four coastal governors will each appoint a representative to the NCPC in the case of a major spill, to coordinate local shoreline cleanup action, and will be responsible for providing temporary storage facilities and final disposal sites for oily wastes during spill cleanup efforts.

Ministry of Finance

Customs authorities will be responsible for approving the temporary import of oil spill combating equipment without payment of duties.

Ministry of Interior and Municipalities

Responsible for immigration, the ministry will approve temporary immigration without delay for oil spill strike teams to assist in spill incident cleanup.

Ministry of Public Health

Responsible for preparing contingency plans and arranging for expertise to cover potential health hazards resulting from oil spill accidents.

The third volume of the SEA outlines a Stakeholder Engagement Plan (SEP) used to demonstrate a comprehensive stakeholder engagement process from program conception through project development, and engaging stakeholders (a registry of whom can be found in Volume 6: Registers) across communities and interests affected by the development of an oil and gas industry.

Including stakeholders in the preparation of the SEA allows the recording of concerns by industry experts, government officials and civil society. Some of the main issues raised by key stakeholders were:

Ministry of Agriculture

“Concerns of negative impacts on the fishery cooperatives and community” though “new fisheries legislation is pending.”

Ministry of Environment

“The MoE is under-resourced” but the ministry’s Environmental Impact Assessment decree has been ratified.

Ministry of Interior and Municipalities

“Search and rescue is under resourced and could not cope with oil spills.” Lebanon has begun to address this concern by restructuring the country’s civil defense, granting volunteers full employment status and improving the force’s ability to respond to disasters.

United Nations Population Fund

“Fears that money or profit will be taken by corrupt officials [thus] preventing regeneration.”

CNRS

“Adverse impact on marine life from oil and gas activities.”

Multiple sources

“Fear that there is no accountability or communication either between or within the ministries” and “lack of awareness of what an SEA/ESIA and offshore exploration entails.”

The RPS consultation team highlights the range of concerns and comments in the Concerns Registry.

One of the main points made by RPS in this section regarding stakeholder concerns is that “it does not matter whether the concerns are founded or unfounded; there is an obligation from the MoEW or the industry to respond.”

This volume presents an overview of the available environmental and socio-economic data and information on Lebanon at the time the study was conducted. Its purpose is to emphasize the weaknesses in this data so that Lebanese authorities can address the deficiencies in preparation for commencement of oil and gas development activities.

Regarding the data available for use in this report, the authors wrote that there is a “serious data deficiency, and this is alarming in the context of a developing oil and gas industry.” It provides an overview of the petroleum industry and the primary concerns including its impact on a number of factors from oil and gas itself to closely related fisheries and water to tourism, cultural heritage and anthopogenic effects.

Oil and gas: A full review of the upstream, midstream and downstream, including techniques and equipment used.

Onshore ecology: Summarizes the available data for coastal and lowland habitats; vegetation; birds; mammals; reptiles and amphibians; terrestrial invertebrates; fish; and other sensitive areas.

Fisheries: A thorough review of the legal and regulatory framework for fisheries in Lebanese waters.

Air: A summary of air quality and air pollution concerning public health and assessment of data available for air quality management.

Social: An assessment of the social impacts, a thorough review of the available data on demographic trends, wealth distribution, employment and workforce, poverty, ethnic context, cultural makeup, political structures, gender, life expectancy, literacy, land ownership and usage, crime, infrastructure and energy use.

Tourism: A thorough assessment of the temporary and sustained impacts felt by coastal and marine tourism.

Anthropogenic [influence of human activity] effects: Focus on the data available considering non-routine impacts such as oil or chemical spills, fire and unexploded ordnance as well as anthropogenic impacts not considered in the other sections.

Environmental law overview: A thorough review of the environmental legislation in the context of the oil and gas exploration lifecycle and also air, water, soil, biodiversity, land use, agriculture, energy, industry, construction, transportation, noise, solid waste management and tourism.

Offshore ecology: A summary of the available data for benthic and planktonic species, demersal and pelagic fish, marine mammals and reptiles

Water: An extensive overview of the available data on water management and usage, regulatory framework and planned strategy

Waste: An analysis of available data on municipal solid waste management, waste generation, waste streams and waste infrastructure

Health: An analysis of the impacts on public health including regulatory framework and review of existing available data

Cultural heritage: An assessment of the baseline and potential impacts on archaeological remains, historical buildings, and historic landscapes in both offshore and coastal onshore zones

This volume comprises a description of the available GIS (geospatial) datasets acquired by the RPS consulting team, including the methodology in organizing the metadata for use in informing decisionmaking by the relevant authorities (e.g. the MoEW). The primary recommendation of the RPS team to the MoEW is to set up a geoportal to increase dialogue between the MoEW/LPA and stakeholders to share the GIS information, avoid inconsistencies and facilitate data exchange.   Aggregating datasets from various sources including the MoEW, the army, NGOs, various state organizations and private companies will better assist decisionmaking.

This volume includes the law, consultation notes, identification of stakeholders engaged and a list of data acquired from specified stakeholders. It is intended to be continually updated.

The legal register contains the code and number of legal articles consulted, with a description of the legal requirements for various issues as well as the limitations of a specified piece of legislation.

The stakeholder register lists the names and contact information of all stakeholders engaged throughout the data acquisition and study life cycle.

The consultation register is a record of the details and outcomes of meetings, conversations and verbal agreements between the RPS consultation team and stakeholders.

The data acquisition register lists all data or documents received from stakeholders.

The concerns register records all concerns raised to and by the RPS consultation team based on consultation with stakeholders and RPS interpretation of in-country observations and secondary research.

This volume shows, through pictures, the proposed route of an onshore pipeline stretching from Tripoli in the north of Lebanon — bypassing the Greater Beirut area offshore — to Tyre in the south of the country.

  Proposed onshore pipeline route

Source: Strategic Environmental Assessment

The final volume of the SEA provides a description of surveying and sample techniques as an instruction guide for conducting further offshore, biological and social surveys as well as a starting manual to carry out future ESIA baseline surveying.