||Letter to Exxon Neftegas Ltd. and SEIC:"Statement
of Common Demands by Environmental NGOs regarding the Sakhalin-1
and Sakhalin-2 Oil and Gas Projects"
December 12, 2002
Statement of Common Demands by Environmental NGOs
regarding the Sakhalin-1 and Sakhalin-2 Oil and Gas Projects
|| This document is a list of common
demands from Sakhalin, Russian Far Eastern, Russian and international
environmental non-governmental organizations regarding key environmental
issues associated with Sakhalin oil and gas development on Sakhalin
Island and on the island's coastal shelf, as well on the shelf and
coastal areas of Khabarovsk Region that will be affected by development
of the Sakhalin-1 and Sakhalin-2 projects.
Environmental organizations believe that the Sakhalin oil and gas
● Sakhalin - 1 (operator: Exxon Neftegaz Ltd,
a subsidiary of ExxonMobil Corporation, further referred to as Exxon);
● Sakhalin - 2 (operator: Sakhalin Energy Investment Company, Ltd,
a subsidiary of the Royal Dutch/Shell Corporation, Mitsui, and Mitsubishi,
further referred to as Sakhalin Energy-Shell)
should not move forward
until the companies involved adopt the following commitments as the
minimum necessary actions required to protect the environment and
biological resources, and to ensure that oil development on Sakhalin
Island, in Khabarovsk Region, and in the seas that surround and that
are adjacent to these regions takes place in an environmentally and
socially responsible manner.
Environmental organizations believe that
until oil companies fully comply with these minimal criteria, Russian
and Sakhalin authorities, international financial institutions, consumers,
and other interested parties should not allow the Sakhalin projects
to move forward.
1. General Demands
● All companies must use Best
Available Technology (BAT). For example, companies should re-inject
drilling wastes back into the geological formations.
● All companies
must comply with highest global environmental standards, norms, and
rules. For example, companies should comply with the "zero discharge"
standard and oil spill prevention and response preparedness standards
as used in Alaska and the North Sea.
● All companies must comply with
Russian law, especially environmental protection law. For example,
it is unacceptable to violate the laws in the way that Sakhalin Energy
- Shell has done, by discharging drilling wastes into the sea even
though the Russian Federation Water Code and other Russian laws directly
forbid this action.
2. Gray Whale Conservation
● Any anthropogenic
activity that could potentially disturb gray whales, or deleteriously
impact the ecosystems in which they feed or migrate, should fully
protect gray whale habitat and should be mitigated to eliminate disturbance
while feeding and protect this critically endangered species. Oil
companies must use the precautionary principle to prevent any potential
impacts to the species.
● Any proposed drilling platform should be
installed sufficiently distant from shore and gray whale feeding habitat
to mitigate all potential acoustic and other impacts. Specifically,
the new proposed platform for the Piltun-Astokhskoye field for Sakhalin
Energy - Shell's Sakhalin-2 Phase 2 must be moved at least 12 nautical
miles from shore in order to ensure that the platform does not harm
gray whale habitat. Exxon needs to ensure, with the help of preliminary
scientific study that is freely available to the public, that its
onshore drilling pads at Piltun will not have a negative acoustic
impact on the gray whales.
● All underwater pipelines should be constructed
and routed outside of the gray whale feeding habitat to ensure their
safety. In particular, Sakhalin energy - Shell should change the route
of its proposed pipeline from Molikpak to shore further to the South
- at least 12 nautical miles from gray whale feeding habitat - to
fully avoid any disturbance to critical gray whale habitat.
Energy - Shell must immediately stop all discharges of drilling muds
and cuttings, as well as all other types of waste water, from Molikpak
into the sea and must refuse to discharge any wastes from any future
platform to prevent deleterious impacts to benthic communities and
to prevent toxic impacts to the whales themselves.
● Any disruption
of the seabed must be avoided year-round in the feeding area of gray
whales or within 12 miles of gray whale habitat.
● Exxon should not
construct pipelines in or otherwise disturb Piltun Lagoon. Alternatively,
Exxon should construct its pipeline by land around the north end of
● Exxon should eliminate planned construction of a
pier off of Piltun Lagoon into gray whale habitat and any marine offloading
of equipment in gray whale habitat and within 12 miles of habitat.
Alternatively, Exxon should transport equipment to site by road;
All oil companies should avoid any seismic exploration within 30 km
of gray whale feeding habitat and migration corridors during periods
that whales are present in these areas; O All companies should avoid
any construction activities in gray whale feeding habitat and in a
30 km zone around that habitat as well in migration lanes during those
portions of the year when gray whales are found in these areas.
All companies should reject any development of underwater quarries
or dredging of the seabed (as was done to provide seabed for the Molikpak
platform), and should limit impact to the seabed within the specific
● All companies should review the issue of cumulative
impacts to gray whales and to their habitat from all oil production
projects on the Sakhalin shelf over the entire period of development.
● All companies should guarantee financing for independent, peer-reviewed
scientific research with complete transparency of information from
all research projects.
● Environmental organizations
demand that offshore-to-onshore pipelines not cross either gray whale
feeding habitat or Piltun Lagoon. These pipelines must be constructed
in a manner that eliminates any noise impact in gray whale habitat.
● Although there are problems even with the Trans-Alaska Pipeline,
environmental organizations demand that the safety level of Sakhalin
pipelines be no lower than that used for construction of the Trans-Alaska
● All pipelines for the Sakhalin-1 and Sakhalin-2 projects
must be built with all necessary safety measures to protect from seismic
activity and to guarantee accident free operation without ruptures
in the event of a 9.0 Richter scale earthquake. To ensure this, pipelines
must be built above ground on special vertical support systems to
guarantee adequate flexibility without ruptures during earth movements.
● Pipeline crossings across all spawning rivers and streams on Sakhalin
Island and on the coast of Khabarovsk Region must be made with a bridge
over the river, on specially designed suspension systems, to avoid
damage to the streambed and water channels. Environmental organizations
categorically oppose trench crossings of salmon streams and rivers.
● Environmental organizations demand that the construction of new
pipeline infrastructure be limited to a minimum in order to maximally
protect spawning rivers, fisheries resources and forests. Therefore,
environmental organizations demand that oil companies involved in
the Sakhalin-1 and Sakhalin-2 projects use a common infrastructure
for transport of oil (processing, pipelines, and off-loading terminals).
First and foremost, this should involve improving the current Rosneft
- Sakhalinmorneftegaz pipeline to the mainland and using this pipeline
to transport all oil from both shelf projects to a single off-loading
terminal facility on the mainland.
● Exxon must reject its plans to
construct a subsea gas pipeline from the Sakhalin-1 fields to Japan
due to the large threat of extremely negative impacts to marine biological
resources and fisheries, especially to salmon migration routes.
Oil Spill Dangers
● Environmental organizations believe that Sakhalin
Energy - Shell and Exxon must adopt much more aggressive and effective
measures in order to prevent oil spills and to be prepared for their
clean up. The first priorities for such measures should be the primary
recommendations from the report "Sakhalin's Oil: Doing It Right,"
(Yuzhno-Sakhalinsk, 1999) including the establishment of mandatory,
safe tanker routes along all coastlines, mandatory inspections of
each tanker by independent inspectors, introduction of tugboat escort
of tankers in critical navigation areas, installation of a real-time,
continuous tanker traffic monitoring system for the entire route in
coastal waters and continuous communications between tankers and shore
side dispatchers, a significant increase of the volume of oil spill
response equipment stockpiled on Sakhalin Island and its placement
at special bases along tanker routes and in those locations most vulnerable
to oil spills (for example, at the entrances to the bays in northeastern
Sakhalin) or that are considered dangerous from the point of view
of potential accidents (for example, La Perouse Strait) (cf: "Sakhalin's
Oil: Doing It Right," (Yuzhno-Sakhalinsk, 1999).
● Sakhalin Energy
- Shell and Exxon must carry out response trainings in the open sea
and in coastal waters in various weather conditions, and that provide
for both product cleanup and also for wildlife and environmental response.
● Sakhalin Energy - Shell and Exxon must categorically reject the
use of dispersants as an oil spill response technique in or near gray
whale habitat and within a 30 km zone around this habitat, and in
or near key fisheries areas. Dispersants should in no instance be
used in waters less than 40 meters deep.
● Environmental organizations
categorically oppose any winter transport of oil in ice conditions
with the use of icebreakers, as currently proposed by Exxon from the
port of De-Kastri, and demand that Exxon develop an alternative that
does not involve transport of oil through ice-clogged seas. Any current
oil transport operations in the vicinity of Molikpak must also occur
only in ice-free conditions.
5. Discharge of Drilling Wastes
Energy - Shell must provide for zero discharge, i.e. 100% reinjection
of all drilling wastes (including oil-based, synthetic-based, and
water-based drilling muds, drilling cuttings, produced waters, and
sewage) back into the formations. "Zero discharge" standards must
be applied at Molikpak and at any other platform. Environmental organizations
fully support the decision of Exxon to introduce the "zero discharge"
standard that calls for 100% reinjection of all drilling wastes at
all future drilling platforms and drilling sites.
● Existing discharge
at Molikpak must be immediately halted.
● Sakhalin Energy
- Shell and Exxon, prior to the start of operations, must fully estimate
damage to commercial and non-commercial fisheries resources, to spawning
grounds, to migratory fish populations (salmonids), to terrestrial
flora and fauna that is caused during construction and operations.
All damages must be compensated to stakeholders (government, fishermen,
indigenous peoples, hunters, municipal administrations, etc.).
routes and safety corridors must be set up for all tankers transporting
oil along the eastern shore of Sakhalin Island and through the Tatar
Strait, as well as in the Sea of Japan. All other types of vessels
should be denied entry into these areas. Losses caused to fisheries
as a result of annexation of fishing zones for tanker corridors should
be paid by the oil companies to the fishing community.
● All technical
plans and decisions whose implementation will have a negative impact
on fisheries must be coordinated with all fishing companies and organizations,
and personally with the heads of the ten largest fishing companies
in the region whose interests will be affected by such plans.
to Information and Public Participation
● Sakhalin Energy - Shell
and Exxon must provide complete access to all information on the status
and protection of the environment, and in particular, all data on
environmental monitoring. The public must be provided information,
in print and electronic forms, promptly upon a first inquiry. Environmental
organizations believe that the responsibility associated with the
current extreme difficulties in receiving environmental information
about the Sakhalin projects are first and foremost the responsibility
of Sakhalin Energy - Shell and Exxon.
● Oil companies must coordinate
their activities, projects, and activities with all interested parties,
and in particular with all indigenous peoples upon whose traditional
lands the projects are developing, which has not yet fully occurred.
It is necessary also to fully research all potential impacts to all
interested parties together with their representatives.
● All scientists
carrying out research as part of the Sakhalin projects must be allowed
to freely use and disseminate all information obtained. Oil companies
must exclude from contracts all conditions requiring the confidentiality
of scientific research and scientists should retain all rights to
publish such research. The right of final review of all scientific
research must rest only with the authors of this research, and not
with international consulting firms hired by oil companies or with
the oil companies themselves, as is now the general practice.
Energy - Shell and Exxon must adopt and guarantee much more proactive
measures to ensure effective and appropriate public participation
than is currently provided. For example, Shell's public participation
measures both for public consultations on phase 2 of its project and
for public discussions of its Western Gray Whale Protection Plan were
extremely lacking and did not provide the public with the opportunity
to make substantive recommendations for improving this work. Exxon's
public participation measures for public consultations on phase 1
of its project were also extremely lacking.
8. Socio-Economic Issues
and Financial Responsibility
● It is extremely concerning that research
by the Russian Federation Audit Chamber (2000-2001) shows that the
people of Sakhalin will not receive their fair share of project revenues.
Sakhalin Energy - Shell and Exxon must agree to immediately restore
all Sakhalin regional and local tax payments from the Sakhalin-1 and
Sakhalin-2 project and from all project contracts and subcontracts.
● Environmental organizations believe that oil companies, in order
to solve a very serious energy crisis on Sakhalin, must sell extracted
natural gas on the local market for heat and electricity at domestic
Russian prices and not at world prices as is now planned by Sakhalin
Energy - Shell.
● Production sharing agreements for both projects
should be available to the public (except for information that by
Russian law is secret). The project budgets for all development phases
must also be transparent to avoid financial dealings of the "Enron"
type and to avoid unjustified project cost overruns and infringement
upon the interests of Sakhalin and Russian contractors.
Energy - Shell and Exxon must fully pay for normative and excessive
emissions and discharges to the environment, as required in the Russian
Federation "Law on Protection of the Environment." Exxon currently
refuses to comply, which is unacceptable.
● Sakhalin Energy - Shell
and Exxon must incur full financial responsibility for any oil spill,
without exception, that results from their operations, including tanker
accidents, oil loading, and other causes. This responsibility must
include an obligation to pay for all clean up costs of polluted areas,
damage and compensation payments to oil spill victims (local residents,
indigenous peoples, fishing companies, tourist companies, local governments,
etc.) as well as all non-economic (environmental) damages.
Energy - Shell must immediately cease flaring gas at Molikpak since
it is not prescribed in the project and was not approved through the
government environmental impact review ("ekspertiza") or by Russian
officials and so therefore is illegal. Such irresponsible corporate
behavior with valuable resources leads to thoughtless environmental
pollution and losses to the Russian side, which could use this gas
|The following public environmental non-governmental organizations agree with and sign on to these demands:
Regional Public Organization "Sakhalin Environment Watch"
Dmitry Vasilievich Lisitsyn, Chair of the Board
Catriona Glazebrook, Executive Director
David Gordon, Associate Director
Doug Norlen, Policy Director
Worldwide Fund for Nature (WWF)
Igor Yevgenievich Chestin, Director of the Russian Office
Center for Russian Environmental Policy
Aleksei Vladimirovich Yablokov, President
Центр экологической политики России,
Президент Алексей Владимирович Яблоков,
Vera Leonidovna Mischenko, President
Legal Center "Rodnik"
Olga Alekseevna Yakovleva, Executive Chair
Friends of the Earth Japan
Tokiharu Okazaki, director of Programs
The "Living Seas" Coalition of Public Environmental Conservation Organizations, including:
Fund for Wild Nature of Sakhalin
Sergey Stepanovich Makeev, Chair
SROO "TKK 'Piligrim'"
Sergei Mikhailovich Pervukhin, Head
Bureau for Regional Outreach Campaigns
Anatoly Viktorovich Lebedev, Chair
MOBO Far Eastern Resource Center ISAR
Valentina Innokentievna Dmitrieva, Director
Center for Defense of Wild Nature "Zov Taigi"
Vasily Anatolievich Solkin, Director
Public Ecological Children's-Youth Organization "Rostok"
Liubov' Pavlovna Samchinskaya, President
Galina Mikhailovna Stetskaya, Chair of the Public Council
Magadan Center for the Environment
Timofei Ilyich Savchenko, Executive Director
MROO "SoDeistvie - Team Work"
Olga Yaroslavna Moskvina, Chair of the Board
Chukotka Ecological Union "Kaira Club"
Gennady Pavlovich Smirnov, Chair
MROO "Taiga Rangers"
Liudmila Valerievna Churikova, Chair of the Board
Kamchatka League of Independent Experts
Olga Andreevna Chernyagina, President
EE Information Center "Lach"
Nina Nikitichna Zaporotskaya, Director
Kamchatka Regional Association of Public Associations of Native Small-Numbered
Peoples of the North
Valery Anatolievich Sankovich, President
Kamchatka Itelmen Council "Tkhsanom"
Oleg Nikitovich Zaporotsky, President
Union of Public Organizations (Communities) of Native Small-Numbered
People of the North of Kamchatka Region "YaYaR"
Liudmila Grigorievna Ignatenko, Head
ANO Resource Center "PILOT"
Dmitry Viktorovich Panov, Director
Public Environmental Nature Guard "Voron"
Ekaterina Vladimirovna Bort, Head
IA "Svobodnoe Slovo (Free Word)"
Oleg Vitalievich Baishev, Head
Center for Public Initiatives "Trioniks"
Irina Belova, Director
Public Environmental Nature Guard "Nizhne-Amurskaya Ecological Inspection"
Anton Safonov, Director
Buryat Regional Union for Baikal
Sergey Gerasimovich Shapkhaev
BTC Monitoring Project
Alexander Nikolayevich Sutyagin, Head
Alexei Yurievich Knizhnikov, Coordinator of the Caspian Program
Interregional Public Ecological Fund "ISAR-Siberia"
Yuri Romanovich Shirokov, President
Public Institute "Siberian Scientists for Global Responsibility"
Sergei Eduardovich Paschenko
International Socio-Ecological Union
Sviatoslav Igorevich Zabelin, Co-chair of the Board
ROO "Baikal Environmental Wave"
Marina Petrovna Rikhvanova, Co-chair
Union "For Chemical Safety"
Lev Aleksandrovich Fedorov
TROO "Roza Vetrov"
Vladislav Evgenievich Urbanovskii, Chair of the Board
Oleg Aleksandrovich Kotikov, Chair of the Board
Non-Commercial Partnership "Ecological Committee"
Sergei Vladimirovich Kostarev, Chair of the Board