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 The tool must not be published, quoted or disseminated to any other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
1.1
1.2
OBJECTIVES ................................................................................................................................... 5
1.2.1
1.2.2
2.0
2.1
2.2
3.0
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.
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
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.
ii.
Periodically discuss and objectively assess how oil and gas development activities are
affecting the environment and natural resources.
Jointly develop and agree upon corrective measures and recommendations on how to
maintain environmental and ecosystem integrity in areas of oil and gas development.
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
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.
REQUIREMENT(S)
Environmental
Management
System (EMS)
Every oil and gas company must have a Request to look at a copy if the
dynamic and continuous system of Environmental Management system is
identifying, assessing and managing documented.
environmental and social risks that are Cross check on company websites for
directly and indirectly associated with their Environmental Management
activities. This involves engagement
http://www.ifc.org/wps/wcm/connect/c8f524004a73daeca09afdf998895a12/IFC_Performance_Standards.pdf?M
OD=AJPERES
MONITORING
ELEMENT
REQUIREMENT(S)
MONITORING
ELEMENT
REQUIREMENT(S)
MONITORING
ELEMENT
REQUIREMENT(S)
MONITORING
ELEMENT
REQUIREMENT(S)
3. Company capacity
and competence
to address
associated
environmental
risks and impacts
MONITORING
ELEMENT
REQUIREMENT(S)
MONITORING
ELEMENT
REQUIREMENT(S)
MONITORING
ELEMENT
REQUIREMENT(S)
MONITORING
ELEMENT
REQUIREMENT(S)
6. Monitoring,
review of
company EMS
MONITORING
ELEMENT
REQUIREMENT(S)
7. Compliance with
environmental
principles and
safeguards
prescribed by
your national
environmental
law.
8. Pollution
management of
waste arising
from oil and gas
development
activity
9. Protection of the
environment,
conservation of
biodiversity and
maintenance of
ecosystem
services
IEC materials
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
Waste bins
Waste management plans
Budgets for waste management
Existence of human resource
An independent contractor in
place
MONITORING
ELEMENT
REQUIREMENT(S)
are no alternatives there should be no-netloss3 of biodiversity and preferably a netgain to biodiversity
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
ELEMENT
REQUIREMENT(S)
MONITORING
ELEMENT
Environmental
Management
System (EMS)
Very Poor
Poor
Good
Very good
Exemplary
1. Company
Score
(1-5)
MONITORING
ELEMENT
environmental
policy
2. Identification of
direct and indirect
environmental
risks and impacts
from oil and gas
operations
Score
(1-5)
MONITORING
ELEMENT
3. Environmental
risk and impact
management
Score
(1-5)
MONITORING
ELEMENT
4. Company capacity
and competence
to address
associated
environmental
risks and impacts
Score
(1-5)
MONITORING
ELEMENT
management staff?
5. Company
disclosure,
consultation and
participation
engagement of
stakeholders in
environmental
management
Score
(1-5)
MONITORING
ELEMENT
Score
(1-5)
MONITORING
ELEMENT
6. Monitoring,
review of
company EMS
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
Score
(1-5)
MONITORING
ELEMENT
7. Compliance with
environmental
principles and
safeguards
prescribed by
your national
environmental
law.
Score
(1-5)
8. Pollution
management of
waste arising
from oil and gas
development
activity
Waste bins
Waste management
plans
Budgets for waste
MONITORING
ELEMENT
management
Existence of human
resource
An independent
contractor in place
Describe how you are applying
the mitigation hierarchy?
9. Protection of the
environment,
conservation of
biodiversity and
maintenance of
ecosystem
services
Biodiversity plans
Budgets for biodiversity
conservation
Biodiversity study reports
Restored sites
Systematic review reports
Score
(1-5)
MONITORING
ELEMENT
Score
(1-5)
Reports of stakeholder
involvement.
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.