Offshore Cape Three Points (OCTP)

Development
Non-Technical Summary (NTS)

Project Ref: 0272709

April 2015
 Table of contents
Offshore Cape Three Points Development ............................................................................................................. 2
Economic Benefits of the Project ............................................................................................................................ 4
Project Description .................................................................................................................................................. 5
Offshore Construction ............................................................................................................................................. 6
Onshore Construction ............................................................................................................................................. 8
The Environmental Impact Assessment ............................................................................................................... 10
Stakeholder Engagement ..................................................................................................................................... 11
Baseline Highlights ............................................................................................................................................... 12
Impacts Prediction, Evaluation and Mitigation ...................................................................................................... 15
Overall Impact Assessment Results ..................................................................................................................... 17
Summary of Environmental Impacts ..................................................................................................................... 18
Summary of Social and Health Impacts ................................................................................................................ 19
Cumulative and Transboundary Impacts .............................................................................................................. 21
Focus on OCTP and Farming ............................................................................................................................... 22
Focus on OCTP and Fisheries .............................................................................................................................. 24
Focus on Concession Footprint ............................................................................................................................ 27
Action Plan ............................................................................................................................................................ 28
Next Steps in the EIA ............................................................................................................................................ 29

1
 Offshore Cape Three Points Development
Non-Technical Summary Purpose

The main purpose of this Non-Technical Summary (NTS) is to facilitate communication and public involvement, as
public participation is a pillar of modern approaches to impact assessment, in a fully transparent perspective. The NTS
presents, in non-technical language, the findings of a detailed Environmental, Social and Health Impact Assessment
(ESHIA) undertaken in connection with the Offshore Cape Three Points (OCTP) project in Ghana and is a tool that
allows consultation of stakeholders and their participation into the EIA process. Moreover ESHIA disclosure is a
requirement set by Ghanaian Environmental Protection Agency (EPA). The NTS provides an integrated overview of the
two phases of the OCTP Development related to the oil exploitation - Phase 1 and gas exploitation - Phase 2, in order
to make stakeholders aware the of the project activities and their consequences on environment, socio-economic and
health components.

Introduction and Background

The Offshore Cape Three Points (OCTP) Development is a significant oil and gas initiative being operated by eni
Ghana. The development involves three offshore oil and gas fields - Sankofa Main, Sankofa East and Gye Nyame all
located about 60 km offshore the Western Region (see Figure 1). The development is being executed in two phases:

Phase 1: Oil Production Project

Phase 2: Gas Production Project

The OCTP Development is a major achievement for Ghana. Production is expected to reach 45,000 barrels of oil per
day (bopd) and 190 million standard cubic feet per day of gas (MMSCFD). The development has a 20-year life. Gas
from the development will support the Ghana Gas Infrastructure Development Project currently under development in
the Western Region. The development will also provide jobs and other economic benefits to local communities, the
Western Region and to Ghana as a whole.

As required by Ghana laws and regulations Environmental Impact Assessment (EIA) were carried out for each of the
development phases to identify environmental and social impacts and risks. The results of the assessments are reported
in Environmental Impact Statements (EISs) submitted to the Ghana Environmental Protection Agency (EPA) in January
2015 (for Phase 1) and March 2015 (for Phase 2).

Figure 1: Location Area

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Project Developers

OCTP Joint Venture

The Offshore Cape Three Points (OCTP) oil and gas exploration and development license is held by
the joint venture (JV) composed of eni Ghana Exploration and Production Limited (47%), Vitol
Upstream Ghana Limited (38%) and Ghanaian National Gas Company (GNPC) (15%).

eni Ghana is the operator of the license and is leading the development. eni Ghana is a wholly owned
subsidiary of the Italian oil and gas company eni S.p.A., a global integrated energy company active in
85 countries with a staff of 82,000 employees.

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 Economic Benefits of the Project
The development will produce oil for sale to international markets and more importantly gas that will be used
for domestic power generation. At the end of 2012, Ghana generated 12 billion kilowatt-hours (kWh) of
power, of which 67% was from hydropower sources and the remainder from fossil-fuel powered sources.
Despite this, Ghanaians, particularly those in rural areas still rely on biomass sources such as firewood and
waste combustion as energy for cooking and heating. Firewood still accounts for more than 40% of Ghanas
total primary energy consumption.

In terms of natural gas, Ghana imported 22 Billion Cubic Feet (BCF) in 2012 via the West African Gas
Pipeline (WAGP). Gas volumes through the pipeline have been however decreasing since 2011 and remain
unreliable, forcing Ghana to use heavy oil to fuel power plants.

Ghana must expand its installed electricity capacity and distribution system to provide electricity to almost
30% of the population that does not have access to electricity. According to projections by 2017, Ghana will
need more than 800 MMSCFD of natural gas for power generation.

The OCTP Development will bring Ghana sourced natural gas to the market for the benefit of industry and
the people of Ghana. The Project will have positive impacts in terms of jobs and the economy through
increased government revenue, employment opportunities and skills enhancement, local procurement and
hospitality and tourism.

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 Project Description
The development comprises two phases.

Phase 1: Oil Development Project. This phase will consist of 14 subsea wells (8 oil producers, 3 water injectors and
3 associated gas injectors), subsea facilities, and a Floating Production, Storage and Offloading (FPSO) unit that
would be located ca. 60 km offshore south of Sanzule.
Phase 2: Gas Development Project. This phase will consist of 5 subsea wells, subsea facilities, gas treating
facilities on the FPSO unit, a 63 km subsea gas pipeline, an Onshore Receiving Facility (ORF), and tie-in with the
GNPC sales gas pipeline.

Figure 2: OTCP Development

Implementation of the development will include the following steps:

Onshore Site Preparation: equipment mobilization, material transport, site clearance and infilling for the ORF
(Onshore Receiving Facility) and construction of internal roads.
Offshore Construction: well drilling and completion, subsea system installation, FPSO mooring and hook up,
gas export pipeline laying, pre-commissioning and commissioning activities (well testing, FPSO commissioning,
pipeline hydrotesting, subsea system testing).
Onshore Construction (mainly related to gas production): gas export pipeline installation (underground), ORF
(Onshore Receiving Facility) construction, permanent accommodation camp and helipad construction; temporary
facilities construction, installation of pipeline from ORF to GNGC (underground), pre-commissioning and
commissioning activities (ORF commissioning, pipeline hydrotesting).
Operation: oil and gas extraction, reinjection of excess gas and produced water, oil stabilization and gas
treatment on the FPSO, oil transportation via shuttle tankers, gas transportation via subsea pipeline, gas
metering and compression at the ORF.
Decommissioning: facilities will be decommissioned and abandoned in accordance with Ghana laws and
regulations and international guidelines for abandonment of oil and gas facilities. A detailed program of
abandonment and decommissioning will be prepared.

Well drilling is planned to start in July 2015 and the ORF construction to start approximately on Q1 2016 until Feb. 2018.
Oil production is expected to start in 2017 and gas production in 2018.

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 Offshore Construction
Well drilling

Well drilling will be performed by the drilling ship Maersk Voyager (Figure 3). This drilling ship can operate in water
depths up to 3,300 m. It is an advanced drilling ship designed to minimize emissions and discharges to the
environment.

Well drilling requires the use of drilling fluids which are injected in the borehole to serve various purposes: move debris
from the bottom of the well and carry it up to the surface, cool and lubricate the drilling bit, contain the fluids present in
the rock formations, consolidate the walls of the borehole and reduce infiltration into the formation. The drilling fluids
can be water or oil based depending on the drilling conditions. Both drilling fluids will used in this case: water based
drilling mud for the shallow drilling section and non-aqueous drilling fluid system for the deep drilling section. There will
be no discharges of exhaust drilling muds in the environment. Appropriately treated drilling cuttings will be discharged to
the seabed near the drilling point. Collected liquids will be offloaded periodically to the supply vessel tanks and then
carried to land for treatment and disposal.

Figure 3: Maersk Voyager Drilling Rig

Figure 4: Schematic of a FPSO (Floating Production, Storage
and Offloading)

FPSO Operation
The FPSO unit (Figure 4) will be constructed in Singapore and will then be towed to Ghana for installation.

The FPSO units processing systems will perform the following:

separate, process to export specification, store and offload crude oil;
separate, dehydrate, compress and re-inject associated gas;
treat non associated gas to separate condensates and dry the gas;
separate, treat and re-inject produced water; and
lift and treat sea water.

The design, positioning and configuration of the FPSO consider the worst metoceanic conditions. The hull is designed to
withstand 20 years of operation. In order to mitigate tank corrosion, a corrosion protection coating will be applied to ballast
tanks and upper and bottom cargo tanks surfaces. The FPSO will provide accommodation for a total of 136 persons.

Offshore Pipeline

A 63 km long rigid pipeline will be laid on the seabed. The main subsea pipeline will be laid down by two lay barges using
the S laying mode for shallow water section and J laying mode, for the deepest water (Figure 5).

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 Offshore Construction
Figure 5: S-lay and J-lay methods

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 Onshore Construction
Onshore Facilities

Onshore, there will be both temporary construction facilities and permanent operations facilities (
Figure 6):

Permanent facilities:
ORF
permanent worker accommodation camp
helipad
roads and pipelines.

Temporary construction facilities

temporary construction site
temporary accommodation camp
construction camp.

The initial step in the onshore construction process will involve site preparation by clearing vegetation and levelling the
ground. The site road network will be constructed at this stage to assist the movement of heavy equipment.

The construction of the ORF is a conventional civil project and does not require unusual heavy equipment or
construction techniques. The main machinery needed are bulldozers, heavy excavators, soil removal trucks, large
heavy-lift cranes, generators, excavators, and rock breakers.

The temporary accommodation camp will be constructed to house personnel during the three year construction phase
estimated at 400 to 600 workers. The permanent accommodation camp will be about 27000 m2 and will be located near
the ORF. The camp will house about 45 workers involved in the operation of the onshore facilities.

Figure 6: Onshore facilities layout

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 Onshore Construction

Onshore Pipeline

There will be two sections of gas pipeline onshore:

Pipeline connecting the offshore section to the ORF (about 1500 m); and
Pipeline connecting the ORF to the existing GNGC gas pipeline (about 800 m).

The onshore pipelines will be installed underground. This will involve clearing a strip about 34m wide and digging a
trench. On one side of the trench, excavated topsoil and other material will be separately stockpiled. On the other side
of the trench the pipeline assembly and vehicles movements will occur. A typical cross section of the construction
working strip is shown in Figure 7.

Figure 7: Pipeline laying activity

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 The Environmental Impact Assessment
The EIA Procedure

The EIA for the development was undertaken in accordance with the Ghana Environmental Assessment Regulations.
The Ghana Environmental Assessment Regulations (Legal Instrument 1652 issued in 1999) define the EIA procedure.
The EIA also considered the requirements of international financial institution environmental and social standards (e.g.
World Bank Group). The EIA study included also baseline definition and impacts evaluation for the Social and Health
components in the Project area.

The EIA for the Phase 1 Project was registered with Ghana EPA in September 2013. The scoping report was approved
by EPA in 2014 and the EIS was submitted to EPA in January 2015. The EIA for the Phase 2 Project was registered in
December 2014. The scoping report was approved by EPA in January 2015 and the EIS submitted in March 2015.

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 Stakeholder Engagement
Stakeholder Engagement
Stakeholders are persons or groups who are directly or indirectly affected by the development as well as those who
may have interests in a project and/or the ability to influence it. Stakeholder engagement is the process of dialog
between the development and stakeholders.

Stakeholder engagement required as part of the Ghana EPA EIA regulations. It is also required by international lenders
and by enis internal policies. Stakeholder engagement in the context of the EIA process included the following:

Phase 1 EIA (March 2012 and November 2013):

25 meetings with national, regional and district authorities, traditional leadership, NGOs and fishermen;
4 meetings with communities.

Phase 2 EIA (December 2014):

30 meetings with national, regional, district and local authorities, NGOs, international organizations and fishery
association;
10 meetings with communities.

A Stakeholder Engagement Plan will be developed as part of this project: it has the main purpose build and maintain
positive relationships between the Project and relevant stakeholders. It facilitates constructive engagement and
continuous dialogue with affected communities throughout the entire project life.

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 Baseline Highlights
Baseline Studies

eni Ghana began collecting information about the environmental, social and health setting starting in 2011. This
included a number of field surveys for data gathering.

Environmental surveys included:

Offshore physical and biological surveys on seabed sediments, geophysical studies, seawater quality, plankton,
benthic communities, fish catch studies and coastal erosion data.
Onshore physical and biological surveys on air quality, background noise, surface and groundwater quality,
geology and soils, habitats, flora, fauna, ecosystems and protected areas.

Social and health surveys included:

Socio-economic surveys including meetings with community groups and members, interviews with experts on
specific matters and communitys or institutions representatives.
Fisheries studies and a Fisheries Impact Assessment.
Community health survey through interviews with communities and direct observations.

Onshore Environment
The onshore Project area is a flat area of low altitude (0-10 m) with very few headlands or rocky outcrops, located along
the Western Ghanaian Coast. The coast in this area is characterized by low sandy beaches. In the vicinity of the Project
area, the coastal low lying areas extend inland for several kilometres. The habitat within the concession area consists
largely of modified habitats with a large proportion of the area covered by degraded coconut palm plantations, degraded
vegetation and wet evergreen forest with palms. The coastal areas are dominated by regenerating vegetation
comprising of palm trees and thorny shrubs. To the east of the concession is a natural habitat that is classified as
Swamp and Mangrove Forest. Sensitive habitat occurs along the coastal beaches where turtles nest.
The Ankasa Conservation Area and the Cape Three Points Forest Reserve are the most significant protected areas in
the general area of the Project (located 25 and 42 km respectively from the project area).
The onshore components of the Project area lie within the greater Amansuri wetland area, and close to the estuary of
the Amansuri river. This is not an officially designated protected natural area; however it is classified as Important Bird
Area (IBA) as it offers a habitat for bird species.

Offshore Environment
Seawater quality in the offshore environment is good with low or very low levels of pollutants. In terms of sensitive
animals, the offshore environment may also host up to 18 different cetacean species. The Gulf of Guinea is also an
important migration route, feeding ground, and nesting area for sea turtles with nesting activity highest between October
and January.

Fisheries
The key small pelagic fish species found in the Ghanaian waters are sardinella, anchovy and chub mackerel. These
species are commercially important and represent approximately 80% of the total catch landed in the country.

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 Baseline Highlights

The large pelagic fish species include tuna, billfish and sharks. These species are highly migratory and occupy the
surface waters of the entire tropical and sub-tropical Atlantic Ocean. There is a long tradition of both artisanal and distant-
water fishing fleets.
Fishing, fish processing and fish trade are among the most important sources of livelihood not only in coastal
communities of the Western Region but also in communities inland.

The fisheries sector contributes 4-5% to agricultural Gross Domestic Product (GDP) and offers employment to about 10%
of the population and their dependents.

Socioeconomic Environment
The onshore portion of the development will be located in the Ellemebelle District of the Western Region. The
communities in the Direct Area of Influence (see Figure 8) include the communities of Anwonakrom, Sanzule, Bakanta,
Krisan and Eikwe. Atuabo, which is located outside the Direct Area of Influence (DAoI) is however likely to be effected by
project activities as it is a larger and better serviced community in the proximity to the project area.
The land that will be acquired (long term lease) for the onshore facilities is made up of cultivated palm groves, croplands
or the remains of natural vegetation and water bodies. No settlements are located within the borders of the area and the
closest community is Anwonakrom located on the south-eastern border.
The largest income-generating livelihood activity in the communities is fishing. Fish mongering is also an important
livelihood activity. In addition almost every household in the towns participates in small-scale and subsistence agricultural
activities.
Tourism in Ghana has become a major socio-economic activity and an important and fast growing sector of the
Ghanaian economy. The tourism potential in the Western Region is related to the number and extent of tropical beaches
as well as wildlife parks, forests and game reserves, inland lakes, and rivers. Currently none are being exploited for
tourism in the Direct Area of Influence.

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 Baseline Highlights
Figure 8: Communities within and around the Direct Area of Influence of the Project

Health
The most common diseases in the direct area of influence are malaria, respiratory infections, anaemia and diarrhoea.
HIV prevalence rate in the Western Region in 2013 was 2.4%.

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 Impacts Prediction, Evaluation and Mitigation
Predicting Impacts and Risks

The EIA considers potential positive and negative impacts of the project on:
environment (internal and sea water, air, soil and groundwater, noise, flora and fauna, etc.),
socio-economics (communities, land use and land tenure, fishery and other economic activities, cultural
heritage, utilities and public infrastructures),
health (health infrastructures, transmission of diseases, road traffic, security).

enis impact assessment approach is based on the following three steps:

1. Impacts prediction: impacts and risks are identified by analysing disturbance factors and interactions of the
project with the natural and social environment.
2. Impacts evaluation: according to eni standards requirements the significance of each impact is to be ranked
according to the evaluation criteria of Table 1.
3. Impacts mitigation design: mitigation measures are developed to avoid or reduce negative impacts and
enhance positive benefits.

Table 1: Ranking and Evaluation Criteria

Evaluation criteria
Ranking Importance / Resilience of Significance
Duration Extent No. of elements Involved
Receptor/ Resource
Local scale: the Low value/ sensitivity of
Affecting small no. of individuals,
Low Less than 1 year / proposed operating receptors or resources, able to
households, individual enterprises
1 Temporary site and its immediate recover or adapt to the change
and/or small no. of species
environs without interventions
Regional scale: as
Moderate value/sensitivity of Affecting small number of
determined by
Medium Between 1 and 5 receptors or resources, able to individuals, communities or
countrys
2 years adapt with some difficulty and administrative and/or higher no. of
administrative
which may require interventions species and habitats
boundaries (ranging from
High value/ sensitivity of Affecting great no. of individuals, 4 to 16)
High Between 5 and 10 National scale: Entire receptors or resources, poorly households and /or medium/large
3 years country able to adapt to changes with enterprises and/or habitats and
strong interventions ecosystems
Affecting huge no. of individuals,
Extreme value/ sensitivity of
Critical Over 10 years / International scale: households and /or large
receptors or resources, resulting
4 Irreversible trans-boundary enterprises and/or habitats structure
in permanent changes
and ecosystems functions
Score (1; 2; 3; 4) (1; 2; 3; 4) (1; 2; 3; 4) (1; 2; 3; 4)

Impacts significance is assessed both before and after mitigations definition and implementation in order to reduce the
significance of each residual impact, to an acceptable level. For this reason, all proposed mitigation measures listed in the
ESHIA become a commitment for the Project and will be implemented. To assure the proper and timely implementation of
the identified mitigation measures management plans are developed, as presented in the Action Plan section.

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 Impacts Prediction, Evaluation and Mitigation
Mitigating Impacts:

eni will implement a series of mitigation measures to reduce the negative disturbance and enhance the benefits of the
project realization and operation on the environment. The mitigation hierarchy for planned events is outlined in Table 1.

Table 1: Mitigation Hierarchy for Planned Project Activities

AVOID AT SOURCE; REDUCE AT SOURCE

Avoiding or reducing at source is essentially designing the project.
Often called minimization e.g. re-routing a pipeline, relocating facilities, etc.

REDUCTION ON SITE
This involves adding design control system to the basic design to abate the effect - pollution controls fall within this category.
Often called end-of-pipe e.g. wastewater treatment, NOx reduction technology

REDUCE OFF SITE

Example soundproof equipment at a nearby residences, visual screening by planting of hedges)

RESTORE
In case of unavoidable damages to a resource, e.g. vegetation disturbance.
Repair essentially involves restoration and reinstatement type measures.

OFFSET
Where other mitigation approaches are not possible or fully effective, then compensation, in some measure, for loss, damage a nd general
intrusion might be appropriate. Example in a like-for-like biological offset attaining ecological no net loss.

NET POSITIVE OUTCOMES

Make, if possible, a positive contribution to Biodiversity conservation and/or improvement of Ecosystem Services and communities
development.

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 Overall Impact Assessment Results
The main conclusions of the EIA are the following:

The development has the potential for creating positive impacts through increased government revenue,
increased procurement, employment and skills development.
The significance of negative impacts could be reduced through design, use of control technology and operational
management controls.
There were no impacts or risks identified that could not be mitigated to an acceptable level.
The area where there is a residual impact after mitigation is the economic effect of displacement of farming and
further mitigation measures will be put in place.

A summary of the significance of impacts during construction and operation is provided in the following sections.

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 Summary of Environmental Impacts
ONSHORE

As construction activities have a limited duration and the sensitivity of the onshore environment is low/medium,
environmental impacts during construction were ranked of medium to low significance.

Medium significance impacts during the operation phase are likely to occur on the following components:
air quality: due to the airborne emissions from ORF and vehicles
ambient noise due to noise emissions from ORF and vehicles
soil and groundwater connected reduction of groundwater resources, possible accidental fuels or chemicals
spills, and soil compaction
fauna as a result of the negative effects of pollution, traffic and hunting
landscape due to the presence of the onshore infrastructure and offshore activities, including lighting.

Impacts during operation on surface water and on flora and fauna are expected to be of low significance.

Onshore Impacts Mitigations:

Dust reduction measures
Low emission vehicles, machinery and ORF equipment
Zero flaring philosophy
Selection of equipment with low noise emissions and good operational management
Prevention of oil and chemicals spillages and proper waste management
Proper groundwater wells management
Avoid habitat reduction, fragmentation and isolation
Minimizing disturbance and displacement of fauna
Vegetation and restoration to screen the ORF

OFFSHORE
The project works on the seabed such as pipeline laying, deposition of drill cuttings and especially seabed intervention
works and well drilling, will lead to impacts in terms of increase of seawater turbidity and potential release of. The impact
of the cuttings on the seabed will be limited to the vicinity of the well and any potential toxicity introduced is likely to
remain deposited there. The impact on the seabed has been evaluated as medium significance.
Low significance impacts are expected during the construction phase on other offshore components (air quality,
benthic communities, underwater noise, and erosion).

Medium significance impacts during the operation phase are likely to occur on the following components (the
significance of the impact is mainly due to their duration all along the project operation, not to their qualitative/quantitative
importance):
seawater quality
seabed potential contamination by hazardous and non-hazardous accidental spills and sediment accumulation
and/or erosion
air quality: due to the airborne emissions from FPSO, vessels and helicopters
underwater noise continuous disturbance of non-relevant intensity
marine fauna and flora the noise disturbance going to be continuous but its limited intensity is likely to induce
only behavioural changes and avoidance patterns of a few individuals of marine mammals and turtles.

Low significance impacts are expected on coastal processes that would cause erosion or accretion given the temporary
interruption of existing sediment transport dynamics and the range of mitigation measures considered.
Offshore Impacts Mitigations
Minimising turbidity and release of contaminants and nutrients
Proper mud and drilling cuttings management
Low emission vessels and FPSO equipment;
Zero flaring philosophy
Minimizing noise emissions and disturbance to fauna
Minimizing erosion and scouring during near shore pipeline laying

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 Summary of Social and Health Impacts

SOCIO-ECONOMICS
High significance positive impacts for the national and/or local communities are expected from:
increased government revenue, this impact is considered high during construction and enhanced to (positively)
critical during operation;
procurement opportunities during construction;
employment opportunities during operation;
skills enhancement during operation.

Regarding employment opportunities, at this stage of the project, it is estimated that approximately 200-300 persons
could be potentially engaged during construction and 70 persons during operations, depending on the skill set required
for the specific activities to be performed.

High significance negative impacts are associated to the economic displacement (loss of livelihoods) due to loss of
access to farmland during construction and operation.

A Medium significance was assigned to impacts on:

employment opportunities during construction;
skills enhancement of workforce during construction;
price inflation due to increased expenditure in the DAoI and economic vulnerability as low income households
will be particularly vulnerable due to little/no savings availability;
workforce demobilization (at the end of the construction phase);
disruption of onshore and near-shore fishing activities;
damage to fishing gear;
changes to cultural and social norms, increased anti-social behaviour, tension and conflict between
villages due to the influx of Project workers and jobseekers;
cultural heritage resources (during operation) and sense of place due to the duration of the impact not to the
quality/quantity of the impact;
social, road, health infrastructure and marine traffic and infrastructure associated to the increase in
population through introduction of a migrant workforce but also through other economic in-migrants settling in the
area with the intention of securing employment with the Project or seeking other economic opportunities;
enhanced hospitality and tourism potential during operation.

The following impacts are rated as of low significance:

access to offshore fishing grounds
cultural heritage resources during construction
infrastructure lighting
Enhanced hospitality and tourism business potential during construction.

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 Summary of Social and Health Impacts
HEALTH, SAFETY AND SECURITY
A Medium significance was assigned to impacts on:
increased transmission of STIs (Sexually Transmitted Infections) including HIV/AIDS, communicable
diseases due to the influx of workers and in-migrants
road traffic accidents
increased pressure on health care resources due to the influx of workers and in-migrants

Low significance impacts on

workers health, safety and rights given that a number of mitigation and management measures will ensure the
minimization of this impact.

Social and Health Impacts Mitigations:

Influx management
Development of local people skills
Support to develop alternative economic activities
Community Development Plan and Livelihood Restoration Plan
Land replacement
Cash compensation
Stakeholder consultations and grievance mechanism
Workforce code of conduct
Social and Environmental Investment Plan

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 Cumulative and Transboundary Impacts
A cumulative impact of major significance was identified on livelihoods and ecosystem services, in particular fishing and
farming based livelihoods.
Moreover, the following impacts assessed as of medium significance have been identified:

Surface water pollution related to the additive effects of changes to the surface water flow and unplanned spills
which could affect the Amansuri River system;
Increased pressure in social infrastructure and service delivery;
Increased price inflation.
Increased potential for habitat degradation / land use change.
Physical and social sense of place.
Economic and psychological cumulative impact resulting from post-decommissioning.
Health community and safety.

During all the Project life, eni will collaborate with the Government of Ghana, other operators and affected stakeholders
in order to identify mechanisms to monitor and manage potential cumulative effects.

No significant trans-boundary impacts are expected to occur as a result of normal operations. However, modelling
simulations of a large oil spill into the marine environment (blow out worst case scenario) show that oil could be
transported throughout the Gulf of Guinea. Due to the high sensitivity of resources, the probability of a crude oil spill due
to a blow out and receptors and the prevention measures defined the impact is assessed as being of Medium
significance during operations. However, a number of mitigation measures aiming to decrease the probability of such
events have been included in the project. Moreover, in order to reduce the consequences of the residual risk, eni Ghana
has developed an Oil Spill Contingency Plan.

The Government of Ghana is currently working closely with the other contracting parties of the Abidjan Convention to
seek and finalize formal arrangements for dealing with trans-boundary oil spill incidents.

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 Focus on OCTP and Farming
Farming in OCTP area
Subsistence and commercial farming takes place in the DAoI, however land suitable for farming in the coastal zone is
scarce.

A range of crops are grown in the land acquisition area, from cash crops to food crops (perennial and annual): the most
common crops grown are cassava, pineapple, coconut and oil palm (Figure 9).
The size of plots reportedly depends on the strength of the individual or family to work an area. Average farm size per
household is reported to be 2.5 acres even though some individuals have much bigger farms. Farmers rely on the rain
for agricultural production, as there are no irrigation systems

The acquisition of this land will lead to the economic displacement (loss of income) of those currently using it for growing
and harvesting crops.

OCTP Project and Land Acquisition

According to IFC Performance Standard 5, all parties affected by loss of land and livelihoods are entitled to alternative
land or restoration of livelihoods lost including those without formal title or use rights to the land. All individuals using
land or natural resources for their livelihoods within the Project land acquisition area should therefore be identified, and
considered eligible for compensation and restoration of livelihoods as part of the Project impact mitigation and
management programme. Mitigation for economic displacement of land-based livelihoods will be detailed in a Livelihood
Restoration Plan (LRP) and supporting measures described in the Project Community Development Plan (CDP). These
documents will:
Fully characterize the loss of use rights to land and associated livelihoods incurred by all affected households,
and identify suitable compensation at replacement cost to guarantee improved or at least restored livelihoods;
Identify additional support to affected households to diversify their livelihood strategies to develop alternative
economic (non-farming) activities to supplement marine fishing and farming incomes and subsistence (e.g. small
scale trade, transport, service industry); and
In conjunction with measures in the Project Community Development Plan CDP, explore further investment
opportunities to support and enable farmers to improve their farming income: e.g. through establishing producer
groups to increase efficiencies and reduce/share the burden of transport of produce, and support with marketing
to enable them to better manage supply and market their products.

eni Ghana will employ dedicated staff to manage the implementation of the Livelihood Restoration Plan (LRP).
The LRP will include a stakeholder engagement plan and standalone grievance procedure, which will explain how to
express possible complaints in order to obtain response from eni.

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 Focus on OCTP and Farming
Figure 9: Example of a typical Cassava Field Surrounded by Palms at Bakanta (outside the land acquisition area)

23
 Focus on OCTP and Fisheries
Fisheries in the Local Communities

The largest income-generating livelihood activity in all of the DAoI communities fishing and therefore the primary
livelihood activity with both men and women involved, although they are divided by gender in their roles.

The fishing industry in Ghana consists of three main sectors namely (i) small scale (or artisanal) marine and onshore
fishing, (ii) semi-industrial (or inshore) and (iii) industrial fisheries. Targeted fish species within the marine sector include
pelagic, demersal and shellfish resources (Figure 10).

There are two fishing seasons, towards the end of June and peaking during August and September and towards the end
of November, peaking between late January and March. April to May is a rest period for mending nets, boat repair and
fishermen engage in onshore artisanal work to supplement their income.

Fish mongering is also an important livelihood activity for women who process fish by salting and drying or smoking. The
women buy fish locally and transport for sale at Aiyinasie. Large catches are also sold to hotels in Axim. Income from fish
mongering is reduced due to lack of cold storage such that fish prices are lowered by the high levels of supply during
fishing seasons.

Fishermen reported locally declining catches over the past number of years, attributed to increased human populations
and consumption, increase in fishing activities, increase in fishing canoes working the area and illegal fishing. Many
community members in the Study Area believe that the offshore oil production activities have contributed to the decline in
fisheries.

Figure 10 : Typical large artisanal fishing canoes

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 Focus on OCTP and Fisheries
OCTP Project and Fishery

The project is not expected to have any significant impact on the abundance of fish, crustaceans and cephalopods (all
evaluated impacts on marine fauna are rated of Low significance).

However the following impacts have a potential to affect to some extent fisheries activities and fisheries based livelihoods:
Restricted access to offshore fishing: A legally enforceable safety exclusion zone around drilling vessels will
be maintained throughout construction and operation to reduce the risk of collisions at sea and to ensure
personnel safety. Fishing vessels will not be able to fish within the exclusion zones for safety reasons. This
restriction will result in a very small reduction in the available fishing grounds and will affect only those fishermen
who fish around 60 km off shore in the project area.
Disruption of Onshore and Near Shore Fishing Activities during construction: There will be an exclusion zone
of approximately 100 m either side of the gas export pipeline preventing fishers from using the beach in front of
the ORF land acquisition area for landing catches and boats and gathering for fish-mongering/trading activities.
This area is small however, relative to the extent of the beach, and the exclusion zone will only be enforced
during the installation of the pipeline (
Figure 6).
Damage to fishing gear: There is the potential for this gear, which is left floating in the open ocean, to enter the
exclusion zone and become entangled in Project vessels and be lost to the fishermen. The exclusion zones
around Project vessels are intended to reduce the likelihood of this impact occurring as far as possible.
Infrastructure lighting: at night time fish may be attracted by the artificial lights on the Project vessels, where no
fishing is allowed due to the exclusion zone. This could have the effect of reducing the fish catch.

There is concern amongst fishers in the Direct Area of Influence (DAoI) and Extended AoI that the Project will have a
negative effect on fish catch due to exclusion zones. However, considering the mitigation measures put in place by eni,
no high impact is expected on fishery. The disruption of onshore and near-shore fishing activities, and damage to fishing
gear have been assigned a significance of medium, while restricted access to offshore fishing grounds due to exclusion
zones and the impact of infrastructure lighting are anticipated are anticipated to have a low significance.

Eni has foreseen the following mitigation measures in order to minimize and if needed compensate any disturbance to
fishery:
eni will develop and implement a detailed Fisheries Management Plan (FMP). The FMP (and if appropriate,
supporting measures in the CDP) will focus on fully characterising the losses incurred by fishermen, and establishing
suitable compensation and livelihood restoration measures for any temporary or permanent loss of fisheries
livelihoods, or damage to fishing gear due to Project activities. Eni will consult local fishermen on the possibility of
implementing a participatory monitoring plan.
The Project will limit exclusion zones around Project infrastructure as far as possible, without compromising safety
measures.
eni will employ a Fisheries Liaison Officer (FLO) to liaise with fishermen and to provide information to fishing
communities, regarding enis activities during construction.
Interaction with fishermen and other users will be monitored through the CLO/FLO and the Projects grievance
procedure.
A vessel transit route will be agreed with the Ghana Maritime Authority and communicated to fishermen and other
marine users through the CLO/FLO.
The exclusion zone will be monitored with the assistance of the agencies of the Government of Ghana, for the safety
of the facility and other users of the area (e.g. fishermen) when potentially close to Project infrastructure or vessels.
Measures will be implemented to ensure that those engaged in maintaining the exclusion zones have received
adequate training on the correct code of conduct and rules of engagement which will be based on the UN Voluntary
Principles of Security and Human Rights.

25
 Focus on OCTP and Fisheries
Figure 11: Beach Seine Fishing

26
 Focus on Concession Footprint

Onshore Concession Footprint

Known tangible resources in the Project area include places of formal religious worship (churches, mosques) as well as
places and locations associated with traditional religious practices (sacred forest groves, lagoons, the sea). Also identified
in the Project area are places of burial and worship. This includes the Branvien Shrine and cemeteries at the coastline at
Sanzule and one to the east of the community, designated for burial of relations of the traditional royal family.

The initial concession area included the area of the Royal Cemetery near Sanzule (see Figure 12) as well as part of the
Anwonakrom settlement (blue dots on the Figure). eni then re-aligned the land acquisition area to avoid the inclusion of
the settlement and the cemetery.

In addition, for Cultural heritage protection, eni will:

eni will adopt a participatory approach with communities directly impacted by Project activities to agree how
archaeological and cultural heritage sites will be identified and protected.
eni will fence off the Royal cemetery (if required) during construction activities to prevent accidental damage to
the cemetery. Local people will be allowed to access the cemetery. The fencing, if present, can be removed
during operations.
eni will develop a Chance Finds Procedure to define the processes aligned with relevant national laws and
regulations, local customs and traditional norms that must be followed to ensure appropriate treatment of a
chance find, and to minimise disruption to construction activities.

Figure 12: Concession footprint modifications to avoid cemetery and village inclusion

27
 Action Plan
In order to ensure that all mitigation measures and commitments are implemented, eni Ghana will prepare and put in
place a number of management plans. These will define the requirements and monitoring for protection of
environmental, social and health resources.

A number of management plans are already provided in the EIS:

Health, Safety and Environment (HSE) Plan
Emergency Response Plan
Waste Management Plan
Oil Spill Contingency Plan
Medical Emergency Response Plan

Further plans which will be developed for construction and operations:

Workers Management Plan
Influx Management Plan
Community Health Management Plan
Security Management Plan
Project Procurement Plan
Local Content Development Plan
Project Recruitment, Employment and Training Plan
Livelihood Restoration Plan
Stakeholder Engagement Plan
Fisheries Management Plan
Pollution Prevention and Control Plan
Biodiversity Management Plan
Water and Wastewater Management Plan
Social and Environmental Investment Plan
Traffic Management Plan
Marine Traffic Management Plan
Decommissioning Plan
Well Control Plans

A number of environmental, social and health indicators will be monitored to make sure that protective measures are
effective. These include:

Offshore
Ecological Monitoring Program (marine mammals and sea turtles);
Participatory Fisheries Monitoring Program (fish catch surveys, water quality measurements, plankton
measurements and stakeholder engagement);
Environmental Monitoring Plan (sea water quality, marine fauna, FPSO air emissions, seabed monitoring,
routine effluent and discharge monitoring).
Onshore
Environmental Monitoring Plan (emissions and ambient noise, ORF air emissions and ambient air quality,
fauna, vegetation and alien species, biodiversity and ecosystem services, water quality/quantity).

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 Next Steps in the EIA
Further studies are being conducted to support the development of social management plans
supplementary baseline livelihoods survey work:
assessment of the proportional scale of livelihoods losses;
assessment of the availability of alternative agricultural land in the direct area of influence;
development of a livelihood restoration plan;
development of a fishermen management plan;
resettlement planning process.

Fisheries baseline is being further studied to confirm the data on fish catch, to inform the fisheries management plan and to
develop the participatory fisheries monitoring program.

A noise and air quality computer model is being created to verify that emissions are within acceptable limits, which are
protective of ambient noise and air quality. The discharge of treated drill cuttings offshore is being further studied using
computer modelling to support the assessment that impacts on water quality and seabed sediments are localized and of
minor significance.

A Biodiversity Management Plan is being developed to ensure protection of wildlife and habitats.

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