CITIZENS' TOOL FOR MONITORING ENVIRONMENTAL PERFORMANCE OF OIL AND GAS COMPANIES.pdf

THE CITIZENS TOOL

FOR

MONITORING THE ENVIRONMENTAL

PERFORMANCE OF OIL AND GAS COMPANIES DEVELOPED BY CIVIL SOCIETY COALITION ON OIL AND GAS (CSCO)

IN COLLABORATION WITHCIVIL SOCIETY ALLIANCE ON OIL AND GAS IN SOUTH AND EASTERN AFRICA (COSEA)

WITH SUPPORT FROM WWF REGIONAL OFFICE FOR AFRICA ENERGY HUB.

ACKNOWLEDGEMENTS: We are very grateful to all those who contributed in various ways to the initiation and development of

this Citizens tool for monitoring environmental performance of oil and gas companies. The team is

grateful to the CSCO Steering Committee (2014); the oil and gas companies in Uganda who cooperated

in pre-testing the tool, the district local governments and local community representatives. The people

involved are too many to mention, but the following deserve special mention. We are grateful to the

following members of the study team; Twebaze Paul and Nathan Makuregye of Pro-Biodiversity

Conservationists in Uganda (PROBICOU); Geofrey Odama and Agnes Ochokoru of Rural Integrated

Community Empowerment West Nile (RICE-WN); Ivan Amanigaruhanga and Robert Ddamulira of the

WWF Regional Office for Africa (WWF ROA) Energy Hub among others.

We also wish to acknowledge and appreciate the support we have received in this process from CSOs

from Mozambique, Tanzania and Kenya.

DISCLAIMER: The views presented in this document dont reflect the official positions of the organizations or

individuals involved. The tool report is supplied in good faith and reflects the knowledge, expertise and

experience of the parties involved. The tool must not be published, quoted or disseminated to any other

party without appropriately referencing CSCO and Civil Society Alliance on Oil and Gas in South and

Eastern Africa (COSEA) as authors of the work. CSCO and COSEA accept no responsibility for any loss

occasioned by any person acting or refraining from action as a result of reliance on the report.

In conducting the analysis in the report the study team has endeavoured to use the best information

available at the date of publication, including information supplied by the various respondents. The

study team approach has been to develop analyses from first principles, on the basis of logic and

available knowledge and evidence from the field. Unless stated otherwise, the study team does not

warrant the accuracy of any results in the use of the tool.

Contents ACKNOWLEDGEMENTS: ................................................................................................................................ 2

DISCLAIMER: ................................................................................................................................................. 2

1.0 INTRODUCTION TO THE TOOL .......................................................................................................... 4

1.1 COVERAGE AND FOCUS OF THE TOOL .......................................................................................... 5

1.2 OBJECTIVES ................................................................................................................................... 5

1.2.1 Overall objective: .................................................................................................................. 5

1.2.2 Specific objectives: ................................................................................................................ 5

2.0 METHODOLOGY OF TOOL DEVELOPMENT ....................................................................................... 5

2.1 EVIDENCE-BASED TOOL: ............................................................................................................... 6

2.2 HOW TO APPLY THE TOOL: ........................................................................................................... 6

3.0 MONITORING ELEMENTS AND REQUIREMENTS: ............................................................................. 7

Table1: Showing monitoring elements, specific requirements and observation checklists..................... 7

ATTACHMENT 1: ENVIRONMENTAL PERFORMANCE MONITORING TOOL SCORE SHEET ................... 19

1.0 INTRODUCTION TO THE TOOL

Oil and gas resources are important for human development. However, the development, transfer and utilization of these fossil-fuel resources presents significant challenges to the long-term conservation of the environment and natural resource especially in areas where oil and gas production takes place in Africa. The Citizens tool for monitoring environmental performance of oil & gas companies (herein referred to as MEPOC) is an instrument which has been developed by WWF Regional Office for Africa (ROA) Energy Hub and CSCO (in collaboration with COSEA) for establishing the extent to which any given oil and gas company is effectively managing and conserving environmental resources, biodiversity and maintaining vital ecosystem services through its direct and indirect activities in a given area over the long-term. The tool covers management actions, policies and guidelines or failure thereof, by companies; their representatives and their contractors or sub-contractors with respect to implementing international and national environmental safeguards during oil and gas development. The tool is based on prevailing national, regional international best practices1 (specifically the

IFC Performance Standards and ISO-14001 Environmental Standards as well as associated

national legal, policy and other legislative frameworks and best practices.

It is in this regard that the research team seeks to establish;

1) To what extent to which an oil and gas company effectively implements the

requirements of the IFC performance standards for environmental management.

2) The extent to which an oil and gas company is ISO-140001 compliant in its practices.

3) The extent to which an oil and gas company complies with and exceeds the expectations

of a host countrys environmental laws, standards and regulatory requirements.

Environmental conservation (in the petroleum sector) involves practices aimed at resource efficiency, waste minimization, protection of biodiversity (identification and protection/enhancement of important/critical habitats and ecosystems/livelihoods), pollution prevention, among others, as influenced by environmental legislation and ethics in day-to-day conduct of oil and gas companies.

1 Best practices are defined as the exercise of professional skill, diligence, prudence and foresight that would

reasonably be expected from skilled and experienced professionals engaged in the same type of undertaking under the same or similar circumstances globally and regionally (IFC, 2012)

1.1 COVERAGE AND FOCUS OF THE TOOL

The tool covers the elements of the ISO 14001 Standards 1 8, IFC Performance standards 1

and 6 and appropriate environmental laws and regulations of the country in which it is being

administered to measure the level of compliance of international oil companies (IOC). The main

themes that form the core focus of the tool are environmental management, biodiversity

conservation and maintenance of ecosystem services. The breakdown of the standard elements

and their respective requirements is presented in appendix 1.

1.2 OBJECTIVES

1.2.1 Overall objective:

The overall objective of the tool is to design a mechanism for facilitating an objective discussion

between civil society organizations and International Oil and Gas Companies on issues of

environmental concern as a means towards generating consensus for win-win solutions that

benefit people, the industry and the long-term conservation of the environment. The specific

objectives of applying this tool are further discussed below;

1.2.2 Specific objectives:

The tool enables citizens and oil and gas companies to;

i. Periodically discuss and objectively assess how oil and gas development activities are

affecting the environment and natural resources.

ii. Jointly develop and agree upon corrective measures and recommendations on how to

maintain environmental and ecosystem integrity in areas of oil and gas development.

2.0 METHODOLOGY OF TOOL DEVELOPMENT

The initiative is a civil society-led approach to monitoring environmental performance of oil and

gas companies operating in Africa and particularly in areas of high biodiversity conservation

value and which are important to local livelihoods. The idea was jointly developed through a in

a participatory process by COSEA with support from the WWF Regional Office for Africa Energy

Hub. The process involved initial discussions with competent CSO members particularly in

Uganda representing COSEA, for purposes of concretizing the idea, brainstorming on the best

implementation approach and sequencing of activities.

2.1 EVIDENCE-BASED TOOL:

This is an evidence-based tool that draws its conclusions based on the available information

encountered during its application. Literature on environmental requirements of international

standards and local laws should be reviewed to generate a list of what to look out for, also

known as monitoring indicators/elements.

Being an evidence-based approach, this is a critical step as Oil and Gas companies can only be

justifiably held accountable for what they are mandated to do.

2.2 HOW TO APPLY THE TOOL:

A score-sheet showing specific monitoring elements, requirements and sample questions for

each of the requirements is developed and applied on company staff at national offices, field

offices, local government leaders, select affected communities and civil society representing

such communities. The score-sheet also defines scoring criteria upon which deductions can be

made. Analysis of performance and assessment of company compliance to environmental

standards is based on responses/opinions and perspectives of all categories of stakeholders

engaged when applying the tool.

Other considerations to make when applying this tool include;

o Conducting adequate literature review to familiarize yourself with what the

company is doing, what is planned and identify any gaps or best practices

applied.

o Think of 3-5 questions per standard element to guide the collection of data from

companies.

o Where possible, company and stakeholder interviews should be with

departments/focus groups and not individuals so as to record positions that are

developed through consensus.

o This is an evidence-based approach, which requires the researcher to collect

evidence before a score is awarded and where evidence cant be obtained such

criteria is better left un-awarded.

o The person administering this tool must have a good understanding of the

standards upon which the assessment is premised; particularly the IFC

performance standards2

o The tool is recommended to be applied by CSOs operating in a team of 3-5

experienced researchers with ability to balance and analyze responses to come

to acceptable conclusions.

o The team must seek and secure feedback first from the oil and gas companies

before cross-referencing such feedback with feedback from other stakeholders.

o Present findings of the tool objectively without making comparison of companies

being assessed.

o The detailed monitoring elements are only meant to assist the researchers in

framing their inquiry appropriately but are not meant to be followed judiciously

through the interview. Instead a summarized interview guide is attached in

Attachment 1.

Note: while the tool is aimed to be as objective as possible based on prevailing evidence; a

degree of subjectivity remains and this can only be eliminated through more cross-referencing

and group discussions rather than individual interviews.

3.0 MONITORING ELEMENTS AND REQUIREMENTS: Table 1 below outlines the various monitoring elements and requirements identified as critical for

facilitating CSOs towards effective monitoring of the environmental performance of oil and gas

companies.

Table1: Showing monitoring elements, specific requirements and

observation checklists

MONITORING

ELEMENT

REQUIREMENT(S) OBSERVATION CHECK LIST

Environmental

Management

System (EMS)

Every oil and gas company must have a

dynamic and continuous system of

identifying, assessing and managing

environmental and social risks that are

directly and indirectly associated with their

activities. This involves engagement

Request to look at a copy if the Environmental Management system is documented.

Cross check on company websites for Environmental Management

2

http://www.ifc.org/wps/wcm/connect/c8f524004a73daeca09afdf998895a12/IFC_Performance_Standards.pdf?MOD=AJPERES

MONITORING

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between the company, its workers, local

communities directly affected and other

stakeholders (IFC, Performance Standard 1:

Para 5. ISO 14001 Clause 1-4).

The ESMS must incorporate the following

elements: (i) policy; (ii) identification of risks

and impacts; (iii) management programs;

(iv) organizational capacity and competency;

(v) emergency preparedness and response;

(vi) stakeholder engagement; and (vii)

monitoring and review. These sub-elements

should be the core focus of your assessment

and are described in detail below;

System/Plans information

Observe different components of the system in practice;-for example the policy statement may be pinned in office.

Take an initiative of ascertaining whether

other members of staff, stakeholders etc

know about the Environmental

Management system and how often

stakeholders may be involved

Request for monitoring reports of the

EMS

1. Environmental

policy

Every oil and gas company should have an

overarching documented policy that clearly

specifies its environmental objectives and

principles to achieve sound environmental

performance in all its operations.

The company environmental policy should

also incorporate applicable national and

internationals laws and regulations in the

host country.

Where the oil and gas company subscribes

to internationally recognized standards (e.g.

ISO14001) these too should be described in

the environmental policy

Top management should define such an

environmental policy and ensure the policy;

a) Is appropriate to the nature, scale

and environmental impacts of its

activities, products and services

b) Includes a commitment to continue

improvement and prevention of

pollution,

c) Includes a commitment to comply

Take a look at the Environmental policy

Crosscheck whether these standards are

described in the policy.

Cross check for its efficiency and

appropriateness with provisions of ISO

14001; 4.2

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with applicable legal requirements

and with other requirements to

which the organization subscribes,

which relate to its environmental

aspects

d) Provides the framework for setting

and reviewing environmental

objectives and targets.

e) Is documented, implemented and

maintained

f) Communicated to all persons

working for and on behalf of the

organizations

The environmental policy should be

available to the public (see IFC, Performance

Standard 1: Para 6, ISO 14001: 4.2)

2. Identification of

direct and indirect

environmental

risks and impacts

from oil and gas

operations

Direct and indirect (third party) impacts on ecosystem services should be identified and assessed; impacts associated with primary supply chains should be identified as well.

The company is required to establish,

implement and maintain a procedure(s) to

identify the environmental aspects of its

activities, products and services within the

defined scope of the EMS that it can control

and determine those aspects that have or

can have significant impacts on the

environment (IFC, ISO 14001); potential

emergency impacts should also be

identified.

Risks and impact identification should be based on recent environmental and social baseline data at appropriate level of detail. The process of identification of risks and impacts should be adequate, accurate and

Request to look at copies of a recent

Environmental Impact Assessment

reports.

Ask about the procedures in place to

identify the environmental aspects of

company activities, products and services

within the defined scope of the EMS and

as an ongoing process.

Look out for:

Evidence of pollution of air, water and soils

Change in quality of air, water and soils

Waste management

Restoration and decommissioning of drilled sites

Camouflage of industry infrastructure

Changes in landscape and aesthetics

Land degradation, loss of vegetation

Animal movement and behavior and disappearance of species

Wetland degradation or disappearance

MONITORING

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objectively done by competent professionals. The identification process will identify relevant threats to biodiversity and ecosystem services focusing on habitat loss, degradation and fragmentation invasive species, overexploitation, hydrological changes, nutrient loading, and pollution, emission of greenhouse gases; potential trans-boundary effects e.g. air pollution and pollution of international waterways. Where the project involves specifically identified physical elements, aspects, and facilities that are likely to generate impacts, environmental and social risks and impacts will be identified in the context of the projects area of influence. This area of influence encompasses, as appropriate: The area likely to be affected by: (i) the project and the clients activities and facilities that are directly owned, operated or managed (including by contractors) and that are a component of the project; (ii) impacts from unplanned but predictable developments caused by the project that may occur later or at a different location; or (iii) indirect project impacts on biodiversity or on ecosystem services upon which Affected Communities livelihoods are dependent (IFC PS 1:Para 6-8). Associated facilities, which are facilities that are not funded as part of the project and that would not have been constructed or expanded if the project did not exist and without which the project would not be viable. The company is required to establish,

implement and maintain a procedure(s) to

monitor and measure, on a regular basis,

and shrinking or receding lake, river, swamps and streams.

Testimonies from community members about impact (s)

MONITORING

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the key characteristics of its operations that

can have a significant environmental impact

(ISO 14001).

Cumulative impacts that result from the incremental impact, on areas or resources used or directly impacted by the project, from other existing, planned or reasonably defined developments at the time the risks and impacts identification process is conducted (ISO14001: 4.3.1) Cross-reference this requirement by referring to relevant national and regional laws, guidelines and standards (e.g. Environmental Impact requirements).

3. Company capacity

and competence

to address

associated

environmental

risks and impacts

The organization should have an established

and fully maintained organizational

structure that defines clear roles,

responsibilities and authority to implement

its Environment Management System.

Key environmental management

responsibilities should be defined and

communicated to relevant personnel and

the rest of the organization.

Sufficient human and financial resources

should be provided on an ongoing basis to

achieve effective environmental

performance.

ISO14001 requires every certified company

to ensure the availability of resources

essential to establish, implement, maintain

and improve the EMS

See: IFC PS 1:6 Para 17-19 and ISO14001

4.4.1-4.4.2

Cross-reference this requirement by

referring to relevant national and regional

Kindly describe the organizational

structure responsible for implementing

your environmental management system?

Who has overall and subsidiary

responsibility for the effective

implementation of your environmental

management system?

How many people (permanent and

temporary) are available to implement

your environmental management system.

How much is your annual budget for the

implementation of the environmental

management system?

MONITORING

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laws, guidelines and standards.

4. Company

management of

environmental

risks and impacts

Every oil and gas company must establish

programmes and performance improvement

measures that effectively address the

identified environmental and social risks of

their operational activities.

These plans shall consist of documented

operational procedures, practices, plans and

related supporting documents (e.g. waste

management plan; oil spill contingence

plans etc).

Such environmental risk and impact

management plans should abide by the

mitigation hierarchy which will favor

avoidance of impacts over minimization and

where residual impacts remain,

compensation/offset where technically and

financially viable.

The mitigation measures chosen should take

into account the outcomes of the

engagement process with affected

communities.

The outcome of environmental risk and

impact management should be Action Plans

which should clearly define desired

outcomes and actions to address the issues

raised in the identification process.

The environmental impact action plan

should be complete with performance

indicators and targets that can be tracked

over defined time periods with estimates for

resources and clearly assigned

responsibilities.

The management plan should also outline

Can I have access to copies of the

environmental risk/impact management

action plans?

How are the responsibilities of the

environmental action plans assigned

within the company?

What impacts have been identified that

can be directly attributable to third-party

(e.g. contractors) stakeholders?

How is the environmental management

action plan adaptable to unforeseen

environmental risks and impacts?

MONITORING

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relevant actions and events controlled by

third-parties.

The Action Plan should be dynamic and be

responsive to changes in circumstances,

unforeseen events and results of monitoring

and review.

IFC: PS 1: Para 13-16

ISO14001. 4.4.6; 4.4.7

Cross-reference this requirement by

referring to relevant national and regional

laws, guidelines and standards.

5. Company

disclosure,

consultation and

participation

engagement of

stakeholders in

environmental

management

Oil and gas companies should have a clear

and ongoing process for stakeholder

engagement including stakeholder analysis,

planning, disclosure and dissemination of

information, consultation, participation,

grievance mechanism and ongoing reporting

to affected communities.

The company should demonstrate that the

aim of its stakeholder (particularly CSOs and

affected communities) engagement process

is to build strong, constructive and

responsive relationships that are essential

for management of environmental risk and

impacts.

Where the stakeholder engagement process

depends substantially on community

representatives, the company should make

every reasonable effort to verify that such

persons do in fact represent the views of the

affected communities.

Disclosure: The oil and gas companies

should disclose relevant information to

affected communities on i) purpose, nature,

Outline the process through which you

identify affected communities to your

operations?

Kindly describe your affected communities

and CSO engagement plans and activities?

Can you please provide a copy of your

stakeholder engagement plan?

How do you ensure that community

representatives in fact represent affected

communities?

Describe your grievance handling

mechanism?

How have you ensured that that your

grievance handling mechanism is well

understood by affected communities,

CSOs and other stakeholders?

Describe to your stakeholder consultation

process?

In what ways do you ensure that such a

process is continuous and is a basis for

MONITORING

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scale of the project ii) duration of proposed

activities iii) any risks to and potential

impacts on communities and relevant

mitigation measures iv) envisaged

stakeholder engagement process and v)

grievance mechanisms

Consultation: companies must undertake

effective and early consultation as a two-

way process that i) begins early during

identification of impacts and risks and

continue as an ongoing basis for further risk

and impact identification ii) is based on prior

disclosure and dissemination of relevant,

transparent, objective, meaningful and

accessible information to affected

communities and CSOs that represent them

iii) is inclusive (women, youth, children,

elderly vulnerable and disadvantaged

groups) iv) be free of external manipulation,

interference, coercion or intimidation v)

enables meaningful participation vi) is

documented.

Informed consultation and participation:

for projects with potentially adverse impacts

on affected communities companies must

undertake this kind of consultation. This

involves in-depth exchange of views and

information in an iterative process and

companies should incorporate the views of

affected communities on matters that affect

them directly e.g. sharing of benefits and

opportunities, mitigation of impacts and

sequencing of implementation.

Where government capacity is weak, the oil

and gas companies play an active and

supplementary role to ensure stakeholder

engagement planning, implementation and

ongoing impact identification and

mitigation?

How do you ensure that you capture the

views of women, youth, elderly, minorities

and other disadvantaged groups?

Can you kindly provide some

documentation of your most recent

stakeholder consultation/participation

activities?

How do you ensure and community back

to communities on the extent to which

their views and ideas on impact

management have been incorporated into

your environmental management action

plans?

In what ways have you complimented

government efforts to ensure effective

stakeholder engagement planning,

implementation, review and monitoring?

Kindly describe your current grievance

management mechanism through which

you receive and resolve concerns on your

environmental performance?

Describe how you have ensured that your

grievance mechanism resolve

environmental and social concerns

promptly in an understandable and

transparent consultative process that is

culturally appropriate and readily

accessible?

MONITORING

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monitoring are effective and adequate.

Grievance mechanisms: oil and gas

companies should establish and clearly

communicate an effective grievance

handling mechanism to receive, facilitate

resolution of concerns and grievances about

the clients environmental performance.

The grievance mechanism should resolve

concerns promptly in an understandable and

transparent consultative process that is

culturally appropriate and readily accessible.

The mechanism should not impede access to

judicial or administrative remedies and

should be effectively communicated to

affected communities.

See: IFC PS: 1 Para 25-36 and ISO14001

6. Monitoring,

review of

company EMS

Oil and gas companies should involve

representative of affected communities in

monitoring environmental impact

management activities.

Company should maintain external experts

to verify its monitoring information.

The company should use dynamic

mechanisms such as internal inspections and

audits to verify compliance and progress

towards desired environmental outcomes.

Oil and gas companies must collaborate with

government to establish an effective

environmental risk and impact monitoring

system.

Companies should document results form

impact/risk monitoring activities and

How have you involved representatives of affected communities in providing external feedback to your environmental management activities? Describe how you are verifying your environmental monitoring and impact management system through external expert feedback processes? How are you applying internal inspections and audits to verify compliances and progress towards desired environmental outcomes? How are the results of environmental impact monitoring processes communicated to top management? What are some of the actions top management takes in relation to these environmental monitoring results?

MONITORING

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identify and reflect necessary corrective and

preventative actions in the updated

management programmes and plans.

Top management is required to review the

companys EMS at planned intervals to

ensure its continuing suitability, adequacy

and effectiveness ISO 14001, 4.4.3), IFC

Standard 1, Para 22- 24

Other things to look out for;

Evidence of meetings with a variety of stakeholders

Meeting minutes about EMS

Reports of workshop on EMS

Community voices

Biodiversity study reports

Films and videos of monitoring exercises

7. Compliance with

environmental

principles and

safeguards

prescribed by

your national

environmental

law.

CSOs applying this tool should check and

summarize here the requirements of the

relevant national environmental laws and

guidance with respect to environmental

management, restoration, forest

conservation laws, protection of wetlands,

species management plans, Environment

Impact Assessment (EIA) guidelines etc.

IEC materials




Community voices



8. Pollution

management of

waste arising

from oil and gas

development

activity

CSOs applying this tool should check and

summarize here the requirements of the

relevant national, regional and international

laws, guidelines and standards on pollution

management of relevance to the oil and gas

sector. These should be summarized here as

guidance notes.

Waste bins

Waste management plans

Budgets for waste management

Existence of human resource

An independent contractor in place

9. Protection of the

environment,

conservation of

biodiversity and

maintenance of

ecosystem

services

Companies should apply the impact

mitigation hierarchy which should seek to

avoid all impacts, where this fails should

minimize impacts where this fails should,

rehabilitate and restore biodiversity and

ecosystem services.

Companies must ensure there is no

conversion of natural habitats unless there

Describe how you are applying the mitigation hierarchy? Describe how you are safeguarding critical habitats and species through a long-term biodiversity conservation programme? Describe how you are promoting and enhancing the long-term conservation aims and effective protected area management for protected areas in or

MONITORING

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are no alternatives there should be no-net-

loss3 of biodiversity and preferably a net-

gain to biodiversity

Protection of biodiversity and ecosystem

services for modified habitats, natural

habitats and critical habitats (e.g. Ramsar

sites) requires a long-term biodiversity

monitoring and evaluation programme.

In legally protected areas the oil and gas

companies must demonstrate that their

activities are legally permitted; consistent

with government management plans for

such protected areas, consult protected area

managers, affected communities and other

stakeholders; and are undertaking

programmes to promote and enhance long-

term conservation aims and effective area

management

IFC: Performance Standard 6 (Para 9-23)

Ecosystem services: Where a project is likely

to adversely impact ecosystem services as

determined by the risks and impact

identification process, the Company will

conduct a systematic review to identify

priority ecosystem services

Priority ecosystem services include i) those

services which if affected will result in

adverse impacts on local communities; ii)

those services which company operations

depend upon.

For services (e.g. climate moderation) upon

which local communities depend; the

near your operation areas? What priority ecosystem services have your identified will required special attention for management during your operations? Describe measures you plan to undertake to safeguard such ecosystem services? How do you ensure that affected communities are involved in identifying priority ecosystem services? Check also:

Biodiversity plans

Budgets for biodiversity conservation


Restored sites

Systematic review reports

Reports of stakeholder involvement

3 No net-loss is defined as the point at which project related impacts on biodiversity are balanced by measures

taken to avoid and minimise the projects impacts, to undertake onsite restoration and finally offset significant residual impacts if any on an appropriate geographic scale.

MONITORING

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companies must make effort to avoid

adverse impacts. Communities should also

be involved in determining priority

ecosystem services as part of the

stakeholder engagement process.

For services upon which operations depend;

companies should avoid and minimize

impacts as well as ensure resource efficiency

* CSOs applying this tool should enrich this

section by cross-reference with their

national wildlife protection laws and

regulations.

ATTACHMENT 1: ENVIRONMENTAL PERFORMANCE MONITORING TOOL

SCORE SHEET

Aim: This score-card aims to establish to what extent any given oil and gas company is committed and

taking actions that are aimed at protecting, conserving, maintaining biodiversity and vital ecosystems

and sustainably managing living natural resources during its oil and gas development activities within its

area of operation. Such actions are either directly by the company itself or through its contractors.

Score guide:

1 Very Poor

2 Poor

3 Good

4 Very good

5 Exemplary

MONITORING

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OBSERVATION CHECK LIST Score

(1-5)

Evidence/justification for the score

Environmental

Management

System (EMS)

Request to look at a copy if the Environmental Management system is documented.

Cross check on company websites for Environmental Management System/Plans information

Observe different components of the system in practice;-for example the policy statement may be pinned in office.

Take an initiative of ascertaining

whether other members of staff,

stakeholders etc know about the

Environmental Management

system and how often

stakeholders may be involved

Request for monitoring reports

of the EMS

1. Company Request to take a look at the

MONITORING

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(1-5)


environmental

policy

company environmental policy

Does the policy integrate national

and International environmental

best practices and standards

Is the company committed to

continuous improvement and

prevention of pollution

Does the company communicate

the policy to all persons working

for and on behalf of the company

Does the company conduct policy

reviews on environmental

objectives and targets?

2. Identification of

direct and indirect

environmental

risks and impacts

from oil and gas

operations

Request to look at copies of a

recent Environmental Impact

Assessment reports.

Are Environment Impact

Assessments available and

accessible to the public?

Does the company have

competent staff and

professionals to continuously

identify environmental risks and

impacts?

Ask about the procedures in

place to identify the

environmental aspects of

company activities, products

and services within the defined

scope of the EMS and as an

ongoing process.

Look out for:

MONITORING

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(1-5)


Evidence of pollution of air, water and soils

Change in quality of air, water and soils

Waste management

Restoration and decommissioning of drilled sites

Camouflage of industry infrastructure

Changes in landscape and aesthetics

Land degradation, loss of vegetation

Animal movement and behavior and disappearance of species

Wetland degradation or disappearance and shrinking or receding lake, river, swamps and streams.

Testimonies from community members about impact (s)

3. Environmental

risk and impact

management

Does the company have

procedure(s) to monitor and

measure, on a regular basis, the

key characteristics of its

operations that can have a

significant environmental

impacts?

Can I have access to copies of

the environmental risk/impact

management action plans?

How are the responsibilities of

the environmental action plans

assigned within the company?

What impacts have been

identified that can be directly

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(1-5)


attributable to third-party (e.g.

contractors) stakeholders?

How is the environmental

management action plan

adaptable to unforeseen

(emergency) environmental

risks and impacts?

4. Company capacity

and competence

to address

associated

environmental

risks and impacts

Kindly describe the

organizational structure

responsible for implementing

your environmental

management system?

Who has overall and subsidiary

responsibility for the effective

implementation of your

environmental management

system?

How many people (permanent

and temporary) are available to

implement your environmental

management system?

How much is your annual

budget for the implementation

of the environmental

management system?

Does the company have the

requisite infrastructure and

equipment for managing

environmental risks and

impacts?

What plans are in place to

ensure ongoing capacity

development of environmental

MONITORING

ELEMENT


(1-5)


management staff?

5. Company

disclosure,

consultation and

participation

engagement of

stakeholders in

environmental

management

Outline the process through

which you identify affected

communities to your

operations?

Kindly describe your affected

communities and CSO

engagement plans and

activities?

Can you please provide a copy

of your stakeholder engagement

plan?

How do you ensure that

community representatives in

fact represent affected

communities?

Describe your grievance

handling mechanism?

How have you ensured that that

your grievance handling

mechanism is well understood

by affected communities, CSOs

and other stakeholders?

Describe to your stakeholder

consultation process?

In what ways do you ensure that

such a process is continuous and

is a basis for ongoing impact

identification and mitigation?

How do you ensure that you

capture the views of women,

youth, elderly, minorities and

MONITORING

ELEMENT


(1-5)


other disadvantaged groups?

Can you kindly provide some

documentation of your most

recent stakeholder

consultation/participation

activities?

How do you ensure and

community back to communities

on the extent to which their

views and ideas on impact

management have been

incorporated into your

environmental management

action plans?

In what ways have you

complimented government

efforts to ensure effective

stakeholder engagement

planning, implementation,

review and monitoring?

Kindly describe your current

grievance management

mechanism through which you

receive and resolve concerns on

your environmental

performance?

Describe how you have ensured

that your grievance mechanism

resolve environmental and

social concerns promptly in an

understandable and transparent

consultative process that is

culturally appropriate and

readily accessible?

MONITORING

ELEMENT


(1-5)


6. Monitoring,

review of

company EMS

How have you involved representatives of affected communities in providing external feedback to your environmental management activities? Describe how you are verifying your environmental monitoring and impact management system through external expert feedback processes? How are you applying internal inspections and audits to verify compliances and progress towards desired environmental outcomes? How are the results of environmental impact monitoring processes communicated to top management? What are some of the actions top management takes in relation to these environmental monitoring results? Other things to look out for;




Community voices



MONITORING

ELEMENT


(1-5)


7. Compliance with

environmental

principles and

safeguards

prescribed by

your national

environmental

law.

CSOs applying this tool should check and summarize here the requirements of the relevant national environmental laws and guidance with respect to environmental management, restoration, forest conservation laws, protection of wetlands, species management plans, Environment Impact Assessment (EIA) guidelines etc. Other things to consider:

IEC materials




Community voices



8. Pollution

management of

waste arising

from oil and gas

development

activity

CSOs applying this tool should check and summarize here the requirements of the relevant national, regional and international laws, guidelines and standards on pollution management of relevance to the oil and gas sector. These should be summarized here as guidance notes.

Waste bins

Waste management plans

Budgets for waste

MONITORING

ELEMENT


(1-5)


management

Existence of human resource

An independent contractor in place

9. Protection of the

environment,

conservation of

biodiversity and

maintenance of

ecosystem

services

Describe how you are applying the mitigation hierarchy? Describe how you are safeguarding critical habitats and species through a long-term biodiversity conservation programme? Describe how you are promoting and enhancing the long-term conservation aims and effective protected area management for protected areas in or near your operation areas? What priority ecosystem services have your identified will required special attention for management during your operations? Describe measures you plan to undertake to safeguard such ecosystem services? How do you ensure that affected communities are involved in identifying priority ecosystem services? Check also:

Biodiversity plans

Budgets for biodiversity conservation


Restored sites

Systematic review reports

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ELEMENT


(1-5)


Reports of stakeholder involvement.

* CSOs applying this tool should enrich this section by cross-reference with their national wildlife protection laws and regulations.

REFERENCES:

1. IFC, 2012. Performance Standards on Environmental and Social Sustainability, IFC

Washington DC.

2. ISO 14001, 2004. Environmental Management systems requirements with guidance

for use, Geneva, Switzerland.

3. UNEP, 1997. Environmental management in oil and gas exploration and production.

UNEP and the Oil Industry International Exploration and Production Forum. Nairobi,

Kenya.

CITIZENS' TOOL FOR MONITORING ENVIRONMENTAL PERFORMANCE OF OIL AND GAS COMPANIES.pdf

Documents

tool report

gas csco

citizens tool

gas companies

study team approach

eastern africa cosea

study team twebaze paul

africa energy hub