On Tuesday, September 30, a public hearing on the implementation and content of the strategic environmental impact study on the Environment and the Exploration and Exploitation of hydrocarbons in the Adriatic Sea (OPP) was completed.
Association Sunce, together with the Green Forum, participated in a public hearing. We prepared comments on the OPP itself as well as on the proposed method of implementation and content of the strategic environmental impact study. Since this is an extensive document, you can download the full attachment HERE.
Strategic study is a law envisaged procedure that should establish the cumulative effects of the proposed plan, inter-sectoral impacts, large-scale effects, long-term and indirect effects. Following this strategic assessment, the door to the hydrocarbon exploration permit in the Adriatic opens.
Given that OPP hydrocarbon exploration and exploitation in the Adriatic has significant and long-lasting, real and potential negative impacts on the environment and organisms, and thus on the two important economic activities of which the Adriatic is a basic resource – tourism and fisheries, it is crucial to make serious strategic study as a prerequisite for determining possible damage, but also for finding possibilities and ways of reducing it through the implementation of numerous protection measures, but also with the exclusion of some areas from the exploitation process.
Therefore, it is to be expected that the Strategic Study, as well as the OPP itself, schould be a serious and professional document that will predict all possible, direct and indirect, damages and offer solutions to their removal, or setting the degradation level to environmentally acceptable. It is therefore surprising that the OPP’s work on hydrocarbon exploration and exploitation on the Adriatic that are presented to the public and represents the basis for the strategic environmental impact assessment has only three pages.
We believe that the General Plan and the program of hydrocarbon exploration and exploitation in the Adriatic is inadmissibly deficient and as such can not serve as a basis for discussion and the procedure of strategic environmental impact assessment. Here is why:
1. INABILITY TO PROPOSE STRATEGIC ALTERNATIVES FOR THE REALIZATION OF THE OPP
Not enough attention is devoted to the development of alternative (variance) solutions, that is, to the various / most favorable options / variants that can be used to achieve the objectives of the Plan and Program, which must be an integral part of each strategic environmental impact assessment.
However, the goals of the Plan and Program are not known and therefore, it is not clear what strategic alternatives will be identified. Without strategic alternatives, the whole process will be reduced to a simple environmental impact assessment with one solution (from the Framework Program of Hydrocarbon Exploration and Exploitation in the Adriatic) – which provides 29 exploration fields of the total area of 38,822 km2 in the Adriatic. Since the total area of the Croatian part of the Adriatic sea is 40,984 km2, exploration and exploitation is foreseen on 90% of the surface of our side of the Adriatic.
Some of the possible alternatives that we propose are OPPs with a smaller scope of activities that do not stem for unreasonable assumption that the exploration is conducted on 90% of the total Croatian Adriatic area. A more reasonable and balanced OPP would limit the number of simultaneous research and exploitation activities which is not the case now. With that, we gain more possible alternatives in regards to the number and intensity of allowed simultaneous research and exploitation activities, as well as more time to train institutions in the country to manage this demanding and risky business.
2. CUMULATIVE POLLUTION INFLUENCES ARE NOT CONSIDER
Pollution in exploration and exploitation of oil and gas is not potentially harmful. It is real and inevitable and therefore it is crucial to take into account the cumulative impact of these activities.
As Dr. Sc. Draško Holcer from the Institute of the Blue World told us “technical water“, which is produced and used in exploration and exploitation (but also other water and liquids that can be found on platforms) contain a large amount of toxic substances including crude oils and various additives. Additionally, a number of polyaromatic hydrocarbons, phenols, cadmium, chromium, arsenic, mercury, lead, barium, zinc, and copper, radioactive elements, endocrine disruptors (compounds acting in the body as hormones), nitrogen compounds (which acting as nutrients) etc, can be found in tehnical waters.
Some of these compounds cause acute poisoning while others accumulate in the body and cause various chronic illnesses. Polluted technical water released into the environment has a direct negative impact on all the organisms in its vicinity. Given the long-term nature of the activities themselves, there is a large potential for a wider, prolonged and significant influence on the accumulation and concentration in the environment and in certain organisms (bioaccumulation, biomagnification). Apart from damaging organisms in the sea, this impact is also directly linked to human health through the consumption of marine organisms in which the concentration of toxicants is increased. It should not be forgotten that the Adriatic Sea is a small, shallow and closed sea where such cumulative effects can only have faster and more difficult consequences.
In the light of all of the above, it is unbelievable that the Environmental Impact Assessment Decision does not state the obligation to estimate the cumulative impact of planned phases and areas (exploration and exploitation) and the cumulative impact of existing exploration activities for hydrocarbon exploitation in the Adriatic Sea (Croatian and Italian Adriatic).
There is also a question of number of boreholes that can be activated at the same time. Considering that one exploration site has between 1020 and 1635 km2, and the exploration permit can be allocated in theory for all 29 planned exploration fields, several wells can occur in each exploratory field. How can cumulative impact be assessed if the number of wells is unknown or is not limited?
Officially conducted studies have shown a very high level of living fish caught near petroleum platforms as well as in the surrounding seabed (1996, Mexican Gulf, US Department of Interior’s Mineral Management Service). The study, conducted by the GESAMP consortium of experts in marine life sciences, founded by UNESCO, the FAO, the United Nations and the World Health Organization – estimates that one typical exploration well will drop into the sea between 30 and 120 tonnes of toxic substances for their working duration, by chance or deliberately.
3. DOES NOT ASSUME NOISE POLLUTION IMPACT ON THE ENVIRONMENT AS A BYPRODUCT OF EXPLORATION ADN EXPLOITATION
Since environmental impact assessment has not been carried out during the study of hydrocarbon reserves in the Adriatic, which has a significant negative impact on marine organisms (physical injury and death as well as behavioral changes), a strategic impact study should be used to assess their influence and evaluate whether they should be implemented in the Adriatic or not.
4. DOES NOT PREDICT RISK LEVEL OF OIL SPILLS
In the proposed content within the strategic SUO, an estimate of the risk or potential impacts of the damage from hydrocarbon spills is completely ignored. It is unacceptable for the exploration areas to be planned only 6 km away from the island and 10 km from the coast guaranteeing visibility from the coast (ie from the terrace and the beach). There is no need to mention what this means in case of oil spills.
5. DOES NOT ESTABLISH THE IMPACT ASSESSMENT BEYOND THE BOUNDARIES OF EXTRASION AND EXPLOITATION FIELDS
The study does not envisage an assessment of the impact on areas outside the boundaries of exploration and exploitation fields. In other words, it ignores the influence of wind, waves and sea currents (let’s not forget the fields are 6 km away from the island and 10 km from the coast).
Therefore, apart from examining possible impact on the ecological network of special conservation areas in accordance with the Habitats Directive, it is necessary to look at possible impacts on areas of special protection under the Birds Directive as well as on protected areas (national parks and nature parks) that are completely ignored in the draft, and are very close to exploration and exploitation fields.
It is important to mention that the exploration fields cover the area of the Jabuka Kotlina, one of the most important breeding and growing areas of numerous commercial fish and invertebrates from which other parts of the Adriatic are inhabited. Destruction of this area may have incalculable consequences on the overall biodiversity of the Adriatic and on the entire fishery.
6. THE PRESUMED TIME DURATION FOR STUDY COMPLETION IS TOO SHORT
Although the first eight points clearly point to the inadequacy of the OPP and the Decision on Implementation of the Strategic Assessment Process, we bring to light few more comments from our colleagues from the Blue World Institute (whose full statements can be read HERE) which testify to the “seriousness” of these documents:
The content of the Decision on the Implementation of a Strategic Assessment is unclear and uses different names for the same things, as well as names without meaning, indicating a certain level of unprofessionalism in compiling a basic document, therefor making the document unclear.
The entire Decision and in particular the review of the strategic assessment is short and unstated An example of meaningless name in Chapter 5 of the Decision that addresses the content of strategic assessment:
“… possible development of the environment without the implementation of the Framework Plan and Program …” – what is “possible development of the environment”?
“… sea-bottom disorder … water column disturbance and helicopter flight disturbance …” – disorder of what?
“… Natura 2000 Program habitats” – Natura2000 is not a program.
Example from Table 1 of the Decision:
“… the impact of air strikes” – only a few sections above that the name was “the influence of aerial waves”. What are the air strikes at sea? The text speaks of “tortoises”, but since turtles live on land, in freshwater and in the sea it is necessary to determine which group the study refers to and call them full name “sea turtles” …
We would also like to refer to the term “commercial fishing” used in the text of the Document (item 2, review of existing data) with the comment that such term in Croatian legislation does not exist. It is probably related to economic fishing, but in this case it is unclear why other forms of fishing in Croatia are excluded (small coastal, recreational and sporting).
In the existing liability regime, oil company can not always be identified as fully responsible, and part of the cost of sanitation often remains uncovered.
Given all the above, we just have to conclude that the Framework Plan and the Program of Hydrocarbon Exploration and Exploitation is nothing else than gambling. Everything of value in the Adriatic, tourism, fisheries, coasts, islands, traditions, biodiversity, protected areas, the government seems ready to put on black and play roulette. The roulette that could easily be shown to be Russian tomorrow…