A Critique of VRA’s ESIA Report on the Coal Handling Terminal in Ghana


In the light of current global calls to end fossil fuel investments and rather focus on interventions that are climate friendly, the Volta River Authority (VRA) and its counterpart Shenzhen Energy Group Co., Ltd. (SEC) are still pursuing an agenda to construct a 2x350MW Supercritical Coal-fired Power Plant in Ghana.

In October, 2016, the former Minister of Environment, Science, Technology and Innovation (MESTI), Hon. Mahama Ayariga at a Press Conference firmly stated that: “I don’t think we are setting up a coal plant. Somebody has put in an application to set up a coal power plant, he hasn’t been given permission to set up a coal power plant. I am not sure that there will be a permit issued to anyone to set up a coal power plant in Ghana,” he said, adding that “having gone to deposit our instrument of ratification of the Paris Agreement, we will not come back home and be permitting coal plants. Be rest assured that nobody has permission to build a coal power plant.” https://goo.gl/xPLos5.

Inspite of this, the Environmental Protection Agency (EPA) of Ghana went ahead advise that the Environmental & Social Impact Assessment (ESIA) process should consider separate reports on the power plant and the port facility to ensure that issues related to port development are given appropriate attention. An ESIA report on the Coal Handling Terminal has subsequently been published by VRA. This inconsistency even within government institutions leaves much to be desired.

This must be an evidence of poor coordination and inconsistencies among state institutions perhaps giving credence to the fact that key policy makers are not knowledgeable on climate change according to Ghana’s 2nd Communication Report to the United Nations Framework Convention on Climate Change (UNFCCC). In a recent development, there was confusion over granting of mining license or permit to Exton Cubic, a mining company. Responsible state institutions showed how poorly they conducted their work.

The conduct of EPA in this regard is very unfortunate given the fact that it has arguably failed to meet its own obligations in ensuring environmental sustainability. For example, random checks show that noise and air pollutions are very rampant with virtually little response or reaction. Ghana became a signatory to the Minamata Convention on Mercury in September, 2014 with Article 7 focusing on Artisanal and small-scale gold mining. Again, EPA inspite of its Environmental Management Plan has failed to deliver on this hence the current galamsey (illegal mining) crises bedeviling the nation.

Indeed, 350 G-ROC submitted letters to the EPA since April 2016 requesting for a meeting over this subject matter but the institution has failed to honour the request. On the basis of ethics and morality, EPA from its conduct cannot be “trusted” to uphold good environmental governance in Ghana.

This paper is an abridged version of the ESIA report analysis for the attention of the project proponents and other relevant stakeholders as requested. A full version shall subsequently be published

Our observations and comments on the various components of the ESIA report structure:

1.     Policy, Legal & Administrative Framework:

We acknowledge that all the local laws, international protocols, conventions, legal requirements, corporate standards etc listed in the report are relevant. However, just reproducing existing national regulations or laws of the various state entities does not guarantee adherence or compliance. Infact, non-enforcement of laws and poor coordination among state institutions have been consistently cited as major ban to Ghana’s development agenda.

Again, some relevant international conventions were listed in the report to create an impression of the project proponents acting within the borders of international standards or protocol. Unfortunately, we have discovered that this project is INCONSISTENT with commitments binding on Ghana.

Furthermore, the report merely mentioning the requirements of the Green Credit Guidelines of the China Banking Regulation Commission does not necessarily mean proof or ability to comply. Infact, there is the Guidelines for Environmental Protection in Foreign Investment and Cooperation, published by China’s Ministry of Commerce and Ministry of Environmental Protection. Article 20 states that Chinese enterprises “take the initiative to strengthen their contacts and communications with their communities and relevant social groups, and take opinions and suggestions with respect to environmental impacts of their construction projects and operation activities through forums and hearings”. There is no evidence to show that SEC has complied in this regard.

2.     Description of the Undertaking:

The justifications advanced for this coal project brings to mind the nearly identical arguments that were marshalled to support the West African Gas Pipeline (WAGP), a project that turned out to be a nightmare. We were told that the WAGP would solve our energy challenges by allowing us to import gas from Nigeria’s oil and gas fields. In spite of these rosy promises, Ghanaians still suffer from erratic power supply. Obviously, it was unwise to rely on the WAGP as a reliable source of power, and that lesson should be applied here: there is a price to pay when we seek to rely on seemingly cheap and easy, external sources for our energy needs. We cannot discount our vulnerability and potential exposure to supply failures by relying on South Africa for the importation of coal. How sustainable is this?

Also, the ESIA report claims that the process involved consultations with various stakeholders, both the affected and interested groups, on the development of the proposed 2X350MW

Supercritical Coal-fired Power Plant and the affiliated Coal Handling Terminal and Material Off- loading Facility.

To set the records straight, 350 G-ROC has NEVER been consulted on the affiliated Coal Handling Terminal and Material Off-loading Facility including the revised work schedule for the construction of the coal plant and terminal handler as the ESIA report seeks to communicate. This does not only come as a surprise but a very unfortunate development undermining the spirit of transparency. We therefore challenge VRA to show evidence of such consultations involving 350 G-ROC.

3.     Consideration of Alternatives:

The construction of a coal terminal handler is undoubtedly necessary for the functioning of a coal plant. However, the adverse environmental impact cannot be ruled out. The report claims that principally, in a no development situation, the communities of Ekumfi would not experience the considerable infrastructural development and economic transformation the project is likely to bring in. There is no evidence to such likelihood. On the contrary, it will likely increase poverty and social vices especially when the jobs promised the community people are merely temporary

4.     Baseline Information:

350 G-ROC strongly states that we were not consulted in this baseline exercise. Checks with the leadership of the Fisheries Alliance in Ghana (a network of over 60 Civil Society Groups, individual researchers and security agencies) also show that they were not consulted. We therefore challenge VRA to provide details of all CSOs and citizens consulted as well as the tools employed in this survey.

5.     Consultations:

We strongly reiterate that we were not consulted IN ALL THE PROJECT PHASES as the report claims and we challenge VRA to prove that. Infact, we are still waiting for the issues the group raised in Scoping Report since June 2016. Also, our engagement with the Minister of Energy on this issue seems to cast serious doubts on VRA’s consultation approach.

Furthermore, the issues of concern 350 G-ROC raised are conspicuously missing in the ESIA report where the concerns of all parties are purported to have been captured and addressed.  For the avoidance of doubt, we still stand by our position that we are strongly against the establishment of coal-plant and disassociate ourselves from that “unfair and inaccurate” reportage.

6.     Identification, Analysis and Evaluation of Impacts:

The report acknowledges that the potential public health risks and insecurity resulting from the construction works and activities would relate to increased community population and the resulting demand on community health and educational facilities, demographic changes and

cultural and moral implications. This means that such inevitable impacts on the community’s limited resources and infrastructure shall further deepen poverty and inequality levels which are inconsistent with the aim of the Sustainable Development Goals (SDGs). Interestingly, the report vividly captures the various job or employment types currently in the community but woefully fails to indicate how many jobs the project will generate for the community people – be it temporary and/or permanently.

7.     Mitigation Measures:

According to the report, the socio-economic impact is largely positive and the effort would seek to enhance and optimize the impact. Local inhabitants would be organized and supported to improve their competences in vocational skills and entrepreneurship, thereby enhancing the opportunity for decent jobs for the local inhabitants with better income opportunities. It is however, unclear who will be responsible for developing the vocational skills and entrepreneurship of the people. VRA must provide clarity on this.

Also, the increased population will put pressure on the social facilities which calls for the provision of more facilities or infrastructure else it will conversely lead to increase in poverty thus perpetuating inequalities.

8.     Monitoring Plan:

As stated earlier, 350 G-ROC cannot trust the state’s ability to ensure that the correct measures are practiced from past experiences. Certainly, entertaining coal in Ghana is dangerous to the citizenry and environment.

9.     Environmental Management Plan:

Can EPA demonstrate how it is ensuring adherence to the Environmental Management Plan (EMP) developed for mining activities to warrant such venture?

10.  Decommissioning:

350 G-ROC argues that this project is inconsistent and should not be commissioned in the first place.

11.  Conclusions & Recommendations:

We disagree that the EPA guidelines, IFC Environmental Health and Safety Guideline and in line with Equator Principles and China Banking Regulation shall be adhered to given the history of Ghana’s conduct. EPA has failed to demonstrate that it is open for discussions contrary to laid down principles and rules in good governance and partnerships.

Relying on raw materials (coal) from South Africa shows that the state has not learnt its lesson from a similarly failed project, that is, the West African Gas Pipeline.

Documentations of the consultations conducted with relevant NON-STATE stakeholders have NOT been disclosed contrary to the principles of transparency, accountability and good governance. This project is likely to increase poverty and inequality levels of the people in the affected community.

Our Position:

It is very unfortunate that Ghana is still considering the establishment of a coal-fired plant. Interestingly, the Chinese government set a target to raise non-fossil fuel energy consumption to 15% of the energy mix by 2020 and to 20% by 2030 in an effort to ease the country’s dependence on coal. In addition, China is currently increasing its use of natural gas to replace some coal and oil as a cleaner burning fossil fuel and plans to use natural gas for 10% of its energy consumption by 2020. Therefore it beats logically reasoning why VRA should be entertaining such a venture.

Our analysis has shown that the ESIA report is defective and fails to meet the required  standards. Not only is non-adherence and abuse of our local laws common but also relevant international conventions or protocols do not support such projects. 350 G-ROC’s independent research conducted in the communities to be affected shows that VRA has not demonstrated proper consultations with community people. No wonder, it has not been able to show all relevant documentation of such consultations with community people.

The report further claims that coal handler terminal is unlikely to have significant adverse effect on the environmental resource, however may contribute marginally to climate change. As vague as “marginally” may sound, VRA has admitted that the project will further contribute to climate change when the state has committed herself to significantly cuts or reduction in carbon emissions.

President Nana Akufo-Addo of Ghana is a Co-chair of the SDGs Advocates thus establishment a coal plant will only make mockery of him and dent Ghana’s image as derailing from the Paris Agreement. In any case, New Patriotic Party (NPP) government pledged to pursue Renewable Energy Development in its manifesto and should be seen to be pursuing that to demonstrate consistency with our international commitments or obligations.

About 350 Ghana Reducing our Carbon (G-ROC):

350 G-ROC is an informal network of youth groups and individuals formed with the aim of mobilizing and empowering young people to actively champion the need to reduce our carbon emissions and promote renewable energy system as a key effort in combating climate change.


Portia Adu-Mensah 0243-785618

Benaiah Nii Addo 0260-704666

Chibeze Ezekiel 0244-967931

Solomon Yamoah 0245-144118

Email: 350groc@gmail.com

Website: https://world.350.org/ghana/


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