1. Background In January 2016, the Volta River Authority (VRA) in Ghana published a Scoping Notice to announce government’s intention to collaborate with the Shenzhen Energy Group Co., Ltd. of China (SEC) to develop a 2×350MW supercritical coal-fired generating units (including affiliated coal handling terminal), at Ekumfi within the coastal areas of the Ekumfi District in the Central Region of Ghana. The scoping notice indicated that the project dubbed as the “2 x 350MW Supercritical Coal Fired Power Plant” represents the first phase of the development which is to be further expanded either by a 4×350MW (or 2×600MW) supercritical coal-fired generating units. The plant is estimated to cost about US$1.5 billion dollars to be financed by the Chinese- Africa Development (CAD) Fund. The notice was to inform the general public as part of the procedures for the conduct of EIA in accordance with Regulation 15(1) of LI. 1652. As part of meeting its obligations, the Volta River Authority (VRA) published a Scoping report in December 2015. The intended plan to begin the construction of the coal plant has been postponed from August 2016 to April 2017. II. Scoping Report Analysis: An analysis of the scoping report was conducted and these are key issues identified and collated to the VRA for their response or feedback. 1. In the regulatory framework section, Chinese overseas policies (which the Chinese developer, SEC, is obligated to comply with) are not listed. Is there a reason for this? 2. There were no non-coal/fossil fuel based project alternatives specified in the report. Is there any reason why this was omitted? 3. The report mentioned that consultations were held with Land owners, Chiefs and Opinion Leaders of the fishermen group, the farmers group, the women’s group and the youth. It indicated that a comprehensive list of stakeholders consulted to date was provided in Annex 4. It was observed that Annex 4 primarily provides a list of government institutions or agencies engaged. Therefore detailed information of names and contacts of fishermen group, women and youth groups as well as the NGOs engaged is been requested.
4. At the biological environment section, the report states that an unpublished report from the Winneba Wildlife Office indicates that fauna such as Duikers, Bushbuck, Ground Squirrels, Gambian rats, African civet as well as Grasscutter can be found in the area. Species of birds found in the propose area include plantain eater, hornbill, Senegal coucal, Barn swallow, Nightjar, Black kite, Pied crow, and Laughing dove. Species of snakes, lizards, frogs, ants, butterfly, bats etc can also be found in the project area. It was observed that the scoping report merely over simplifies the potential impact of the construction on animals noting that the animals around the site would be frightened by the activities of construction and move further away into nearby bushes. We posit that this assertion can’t be wholly accurate as some animals or species require a certain space size or noise level to survive. Information on accurate and up-to-date biodiversity data on the animals and species in that zone will be appreciated. 5. The scoping report also indicates that history of consultation notes of the consultation meetings, attendance registers, written comments and correspondence received have been collected and organized. Part of the consultation records were provided in Annex 6. It was again observed that available records show only consultations with government agencies and Shenzhen Energy without any data on other stakeholders consulted as communicated in the report. Therefore copies of all the consultations held in the name of transparency have been requested. 6. EPA according to the scoping report did suggest to VRA/SEC to look into different coal-fired power plant technology in generating electricity. Also, VRA/SEC was tasked to provide EPA with the characteristics of the coal to be used and the fly ash. The status or feedback from EPA’s request is required as there are different types of coal-fired plants such as the Subcritical, Supercritical, Ultra-Supercritical, Advanced Ultra-Supercritical and Integrated Gasification Combined Cycle (IGCC). Similarly, there four types of coal namely Peat, Lignite, Black coal and Anthracite. 7. The report acknowledges that majority of the employed population (52.3%) of the Ekrumfi District work within the skilled agriculture, fishery and forestry industry. So to say that as part of mitigating socio-economic impact, the project would create direct or indirect employment generation with employment opportunities for both skilled and unskilled labour, enhance skills development and good localization opportunities is vague. A request for the specific kind of job opportunities to be created was made. Again, some of the concerns raised by the Chief and Elders were not addressed such as compensation for lands acquired. 8. Also, the report states that the Phase I of the project is planned to be commenced in August 2016 and the 2×350MW units will be completed and put into commercial operation from 2019. A request for specific timelines and methodology to conduct the ESIA as well as public fora to be held was made. 9. The project according to the report is estimated to cost 1.5 billion US Dollars to be fully funded by CAD Fund. A request to VRA was whether the estimated cost include health issues and environmental damage (as well if applicable agricultural land loss). Detailed breakdown of these costs shall be appreciated. These concerns or questions have not been officially responded to by VRA. An official of VRA indicated that these shall be addressed in the ESIA which is currently on-going. This means a comprehensive analysis shall again be conducted when the ESIA is completed and distributed. III. Community Entry Exercise: 350 G-ROC1 embarked on a community entry exercise from 24th – 27th June 2016 to engage the chiefs, elders and youth leaders of Ekrumfi community. The purpose of the exercise was to mobilize and raise awareness or sensitize community people on the dangers of Coal-fired Plant on their health and its negative impacts on environment leading to stronger resistance plans of establishing the coal plant. 7 communities were visited namely IMMUNA, KOKODO, SARFA MPOANO, KOTENKORE, OTUAM, ABOANO & ETUBEDU. Summary of findings: Community members were curious about the project as they had some reservations about the project. A queenmother at Etubedu mentioned a case of the negative impact of Takoradi stonemills on the life of the people so they are not fully sure what this coal plant has in store for them. 350 G-ROC is an informal network of youth-leaders formed with the aim of partnering with key stakeholders to champion the need for carbon emissions reduction while actively promoting renewable energy systems as a key effort in combating climate change
The queen mother at Kokodo community, Oheemah Nana Fosuaa shared her experience from a different community (Obuasi) how rainwater which the community people formerly harvested for drinking and bathing are no longer safe. People have been affected with strange skin diseases believed to be as a result of dangerous emissions affecting rain water. Such rainwater is only best for scrubbing the floor. The community leaders generally acknowledged that the welfare of the youth and unborn generations must be taken into consideration when making decisions, in this case something that bothers on the environment. The elders in Aboano in particular raised deep concerns about the possible effect on rainwater which they depend on for drinking, bathing, washing etc. For them such concerns have not been adequately addressed for their understanding. Chief and Elders of Ekumfi Aboano, Opinion Leaders of the fishermen group, the farmers group, the women’s group and the youth were not adequately properly consulted as the Scoping report claims which against the rules of engagement with respect to community consultations in any project that will directly or indirectly them. The youth at Kotenture (primarily a fishing community) initially refused to give the team audience thinking we were government officials. The youth are in high anticipation of the jobs promised but have not idea of the kind or type of jobs to be offered them and even whether those jobs will be temporary or permanent. All the community leaders engaged granted the team the needed permission and approval to go ahead with our forum and pledged their readiness to participate. Below are responses to interviews conducted with some key and influential persons in the communities: Donpehene Ekumfi Etubedu Community [Chief Nana Koji Mensa II] “From the engagement we had with the VRA, the organization made it clear that the project will not disturb the communities in anyway. We understood that the olden day coal technology allowed emissions to be emitted far and near, which causes harm to people and environment. The technology for this one allows for the emission to be kept underneath. The machines to be used are capable to minimizing the negative effects of coal. People have been criticizing coal but the machine will help to reduce emission into the atmosphere. Rain harvesting is done by people who cannot afford pipe borne water, but having gone on tours organized by the VRA, we have been told that the machines can help to address any damage to water harvested through the rain. We embraced it, the project will come to help the poor get jobs to do and the machines will not bring any diseases to people. I am not sure the project will contaminate the atmosphere”.
Queen mother-Nana Fosuaa of Kokodo Community “Prior to the beginning of mining in Obuasi, people in the area used to harvest rain and use it for domestic purposes without any side effects. But once mining began, any harvested rain for drinking purposes ends with skin rashes for people. Doctors say the situation can results in deaths, which has actually led to many people to die. As a result we do not harvest rain for domestic purposes. In this area, once it begins to rain, people harvest rain for domestic purpose in this community and can lead to deaths as well due to carbon emissions”. Dennis Aidoo – Spiritual leader of Aboano Community “The chief has refused to sit down with the eldest and even the entire community to deliberate on the benefits and setbacks of the project. He always says the project is yet to begin so we should exercise patience. We are happy 300 Ghana Reducing Our campaign to sensitize the community on the coal project to learn to broaden our knowledge. VRA has already held meetings with us on the project. We told them that we do not have any expertise on the project, for instance emissions and the possibility of contaminating rain water and health implications for the people. We were told by the VRA that they have some technology that can address that, but once they have no started work we have not seen it. No compensation has been discussed yet”. Some of the findings from the community exercise were inconsistent with the scoping report. For example, the youth leaders were not fully aware of the coal plant establishment other than the fact that it will create jobs. Again, our checks show that no compensation has been discussed with the community people. This raises doubt whether VRA did a proper community consultation effort as it claims. The link to the full community entry report can be found here (https://goo.gl/fHJ9VQ). IV. Conclusion: This first report seeks to query and/or challenge the scoping report of the coal plant establishment in Ghana. A more detailed analysis shall be conducted when the ESIA is finalized and presented as required by law. It is important to indicate that Ghana was among about 175 country parties that appended their signature to the Paris Climate Agreement on April 22nd , 2016. In August 2016, the Parliament of Ghana ratified the Paris Agreement thus making it binding on the nation since it has become part of the laws. The aim of the Paris Agreement is to achieve the long-term 2-degree temperature goal by 2030.
For this reason, Part 2 of this paper shall not only critique the ESIA but will also seek to prove that Ghana’s coal intention is most likely to derail the aim of the Paris Agreement.
About Author Chibeze Ezekiel is a young Climate Change Analyst in Ghana certified as a Master Youth Trainer on Climate Change by the World Bank Institute (WBI). He has considerable other environmental work related interventions such as Biological Diversity (Biodiversity) and Forestry. His publications can be found on his blog – www.chibeze.blogspot.com