The NCEA reviewed three documents related to oil export from Chad to Cameroon: a draft and final EIA (and other relevant documents) and an oil spill plan.
Significant details
In its advisory review of the Draft EA the Commission concludes that there is much valuable information in the EAs and related documents but that not all relevant issues have sufficiently been addressed. More information is needed on:
- Problem statement and objectives:
- The EAs do not place the project in the present socio-political context. The risk of sabotage to the technical installations and the environmental consequences of this have not been addressed.
- The available information does not rule out the possibility that the pipeline project will serve more objectives than just those stated in the EAs: exploitation of the Doba oil fields.
- The initiative:
- The EAs refer to reports not yet published for information on parts of the initiative. As a result, the environmental consequences cannot fully be judged on the basis of the EAs. The EAs are incomplete.
- Alternatives:
- The basis for disregarding certain alternatives and the way the alternatives were selected cannot be verified from the EAs.
- Impacts:
- Important probable induced developments have not been identified. Their environmental and social impacts have not been assessed:
- development of other oil fields, facilitated by the future availability of (cheap) oil transport capacity;
- development of Kribi as a port.
- A number of impacts have been insufficiently quantified and the effectiveness of proposed mitigating measures has not been adequately demonstrated.
- Monitoring and evaluation:
- The monitoring capacity of local authorities has not been assessed.
- An external independent check on the quality and factual implementation of the environmental management plan in the field has not been described.
- Public information and participation:
- The EAs describe good approaches to public information and participation. Field observations indicate that implementation and compliance with WB requirements is substandard.`
The Commission recommends supplementing the EAs on these points.
Having reviewed the final EA, the Commission concludes that most shortcomings of the Draft persist in the final EA. The Commission is unable to find an analysis of the socio-political risks and concludes that:
- the EA does not make clear which partners in the initiative are committed to execution of the initiative in compliance with the contents of the EA;
- not all objectives of all partners in the initiative have been quoted as project objectives;
- information on oil spill response, on capacity building for implementation, monitoring and enforcement and on monitoring structures is lacking;
- the alternative analysis is incomplete and partly works towards predefined results;
- residual impacts after EMP compliant execution of the initiative have not been assessed.
The Commission concludes that the EA raises expectations by setting high standards and targets but does not balance these by providing guarantees for meeting these standards and targets.