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Re: Financing for Phase 2 construction of Sakhalin II Oil and Gas Development Project |
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APPENDIX 1
OUR CONCERNS AND SEIC'S RESPONSES
Marine resources
We have raised issues concerning the impact on marine resources by
dumping excavation sludge, oil spills, and so on. The responses of
SEIC are still inadequate. For example, there is still a major conflict
between results of analysis by SEIC and NGOs on the cause of the extensive
die-off of herring northeastern of Sakhalin in 1999. SEIC has still
offered no thorough explanation or investigation of this difference,
leaving the true cause still a mystery, a situation that only adds
to the concerns of fishers.
There is a plan to dump dredged sediment to Aniva Bay, during the construction of a crude-oil export terminal in Prigorodnoye in the second phase of construction of the project. Persons involved in the fisheries oppose this dumping, since Aniva Bay is very shallow and serves as a precious spawning sea area for various kinds of salmon, tanner crab and other aquatic life. Although there appears to be an alternative to dump further to the east, there was no mention at the explanatory meetings in Sapporo and Tokyo in September 2003 about the location or method of dumping, leaving concerns about the impacts unanswered. There was also no mention about the project's impact on the marine ecosystem, including microbes such as plankton, which are indispensable for fish. The lack of information makes it impossible to predict the long-term impacts on fisheries. We strongly believe that before starting the second phase of construction, in order to perform suitable monitoring in the future, it is necessary to conduct ongoing investigations (including the collection of baseline data on the current situation), with Japanese fisheries specialists involved.
Oil spill responses
SEIC is now considering and formulating an Oil Spill Response Plan (OSRP) for the second phase of construction. We have heard that the OSRP is to be completed six months before actual operation of the second phase project starts in 2006. We believe that major doubts about this project are justified when one observes the project proceeding with loans from public institutions, despite the absence of a sufficient plan to deal with oil spills. There is at present no guarantee that any plan completed only just before groundbreaking for construction, and organizational arrangements between institutions and countries will be reliable. And in the event any inadequacies are found in the plan, it is doubtful that a scant six months before actual oil and gas production operations under phase 2 would be enough for discussion and revision of the plan.
If the Japanese government is to make a loan, a high priority should be given to building a cooperative system between the Japanese and Russian governments to deal with oil spills. This should include such considerations as the mandatory submission of tanker shipping routes to the Japan Coast Guard, in order to enable rapid response in the event of an accident. Furthermore, any loan approvals should be conditional on the signing of a detailed agreement between Japan and Russia that includes, among other things, plans on how to prevent the spread of oil and transport oil removal equipment and materials at the time of an accident. Without such an agreement, if an accident occurs near a country's territorial boundaries, the absence of clear rules on how to conduct preventive and removal activities is sure create a host of problems. Under the current situation with the imperfect state preparation of even basic international arrangements, it is obvious that too many problems remain unsolved to justify making additional loans to the project. We believe that financing institutions should give special consideration to the matters raised here unless they are willing to be implicated in what could possibly result in irreparable impacts on marine resources and the natural environment in the event of a major oil spill.
Steller's sea eagles and other wildlife
Northeastern Sakhalin boasts a wide variety of wildlife, including birds such as the spotted greenshank and a sub-species of the dunlin (Calidris alpina actites), and fish such as the Sakhalin Taimen, and there is a rising chorus of international concern especially about threats to the Western Pacific gray whale1 and Steller's sea eagles. But it must be said that the credibility of the EIA is very low, despite the fact that it should provide the solid foundations the development project and damage mitigation measures. A large difference of the number of braces of Steller's sea eagles in Chaivo Gulf and Piltun Gulf is found between the Wildlife Preservation Bureau of Hokkaido and Moscow State University joint study2 and the SEIC'S EIA.3 The study by the Wildlife Prevention Bureau and Moscow State University found 15 braces of Steller's sea eagles had bred and inhabited around the Chaivo Gulf this year and it identified many other hatchlings and juveniles, whereas the EIA report indicates only five braces. The figures in the SEIC's EIA underestimated the number of braces by a factor of about 3 in the Chaivo Gulf and about 6 in the Piltun Gulf, compared the four-year joint study. In response, SEIC explained that the EIA showed only the numbers affected by pipeline construction and the number of nests being used among those identified by the baseline assessment. But we find this explanation irrational, since their numbers were part of "basic environment" and "existing environment" sections in the EIA. Under the present situation, SEIC's information fails to correctly describe the actual current conditions and potential impact even about Steller's sea eagles,4 a rare species that attracts global concern.
Meanwhile, SEIC has yet failed to respond to a request the Wildlife Preservation Bureau of Hokkaido made in August 2003 for information about source data and assessment methods used in their EIA. Instead, the SEIC proposed the separate meeting of specialists mentioned above about Steller's sea eagles. The SEIC's actions in setting up such a meeting, without properly replying to requests or questions submitted, only serves to add greater doubts about its behavior. The consideration of impacts of Sakhalin II should not limited to only the Steller's sea eagles, but be broader and more comprehensive, including the natural environment and other wildlife.
Looking forward, below we offer our comments on certain key issues.
At the above-mentioned meetings in September 2003, SEIC proposed another meeting between specialists from SEIC and some Japanese specialists concerning Steller's sea eagles and an oil spill response plan. However, neither the framework of the proposed meeting nor its status have been made clear. We have therefore proposed that the meeting be held in the following manner.
Create a main committee, subcommittees
We recommend that a main committee be created, consisting of experts and representatives of concerned organizations. The main committee would meet regularly to hear and discuss the results from subcommittees created to address specific issues (such as the Steller's sea eagle, oil spill issues and others).
- Rather than just a one-time meeting, we recommend that subcommittees
be created to discuss specific issues, examine and discuss evaluation
of the environmental impact assessment (EIA) and mitigative measures,
etc. Both the main committee meetings and sub-committee meetings should
be held with transparent and accountable processes.
- The subcommittees should be able to request additional investigations
if needed. The project entity should open all relevant documents
and data to the subcommittees.
- Bring the results of the subcommittee meetings to the main committee,
where a broader evaluation should look at the EIA and impact
mitigation measures from various perspectives. Efforts are required
to ensure that matters on which agreement is reached are properly
implemented in the project.
- The subcommittee meetings should discuss not only Steller's sea
eagles and oil spill responses, but also a broader range of issues
such as other species of animals and plants.
- The main committee meetings should be held regularly, on an ongoing
basis. The subcommittee meetings should also be held on an ongoing
basis with the frequency and other details to be decided at the discretion
of the subcommittees.
- Participants in the committees should be determined through agreement
among the stakeholders. They should include not only academic
experts, but also people who have relevant knowledge and experience,
such as persons involved in the fishing industry.
- Each financing institution, the Japanese and Russian governments,
and NGOs should participate in the main committee meetings as
observers, and they should also be open to other observers.
Open consultations and information disclosure in Japan
As mentioned, SEIC held "explanatory meetings" in Sapporo and Tokyo late in September 2003, but the invitees were limited to a small number of governmental, NGO, and civil group representatives. We request SEIC organize larger open meetings in which anyone who is interested can participate. Regarding information disclosure, we suggest that the important sections of documents such as oil spill response plans and wildlife protection measures be translated into Japanese, as they are issues of major concern to Japan.
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