STOP THE COAL NIGHTMARE!!! A Critique of VRA’s ESIA report on the Coal Handling Terminal in Ghana

Despite the growing global mandate to end fossil fuel investments, the Volta River Authority (VRA) and Shenzhen Energy Group Co., Ltd. (SEC) are still pursuing an agenda to construct a 2x350MW Supercritical Coal-fired Power Plant in Ghana.

The Environmental Protection Agency (EPA) of Ghana has advised that the Environmental & Social Impact Assessment (ESIA) process consider separate reports on the power plant and the port facility to ensure that issues related to port development are given appropriate attention, leading to the ESIA report on the Coal Handling Terminal by VRA published in May 2017. This is in spite of the government’s obligations to the Paris Agreement and other Multilateral Environmental Agreements (MEAs).

Ghana must stop the coal nightmare!

In building a climate resilient future for all Ghanaian citizens, 350 G-ROC offers a critique of VRA’s ESIA report on the Coal Handling Terminal.

  1. No evidence that VRA and Shenzhen Energy Group can comply with international and Chinese requirements

VRA audaciously listed international conventions and Chinese policies to create the impression that it is acting within the borders or remit of international standards and protocols. Such impression is very erroneous. For example, the adverse impact or depletion of flora and fauna to be caused by this proposed project site is INCONSISTENT with Ghana’s obligation to the Convention on Biological Diversity (CBD) as well as the Aichi targets.

Also, Ghana cannot be a signatory to the Paris Climate Agreement of the United Nations Framework Convention on Climate Change (UNFCCC) and at the same time be seen to be permitting the construction of an obsolete coal plant technology. The Paris Agreement comes with very strong but ambitious aim that is, to limit the global temperature rise not just to below 2 degrees, but to strive for 1.5 degree. Ghana must take its international commitments seriously. If Ghana had taken its commitment to Article 7 of the Minamata Convention on Mercury seriously, for instance, we would not be suffering from the conduct of Artisanal and small-scale gold mining activities today.

Furthermore, the Green Credit Guidelines of the China Banking Regulation Commission, which requires compliance with host country law and international norms, is cited in the ESIA. However, merely mentioning it does not necessarily mean proof or ability to comply. In addition,

the Guidelines for Environmental Protection in Foreign Investment and Cooperation, published by China’s Ministry of Commerce and Ministry of Environmental Protection, states clearly in Article 20 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”.

  1. Saying no to fossil fuel dependence

The quantity of coal demanded to operate the power plant in Phase I according to the ESIA report is 2,050,000 tons annually. 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 Ghana’s energy challenges by allowing importation of gas from Nigeria’s oil and gas fields. 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.

Instead, we should promote energy independence by focusing on renewable energies.

  1. VRA misrepresented its consultation process, did not consult stakeholders

To set the record straight, 350 G-ROC (as an interested party) 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.

On the contrary, 350 G-ROC strongly states that it was 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 showed 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 baseline survey.

The best practice in every consultation exercise is to actively engage all groups of persons who shall be affected directly and indirectly by a project. More importantly, the engagement must begin from idea generation to final completion and not in the middle or near end of the project. Thus, although 350 G-ROC has communicated with VRA in the past, these instances cannot be considered as effective consultations for the coal port.

Moreover, Ghana since 2012 has been a party to the Open Government Partnership (OGP), a multilateral initiative that aims to secure concrete commitments from governments to promote transparency, empower citizens, fight corruption, and harness new technologies to strengthen governance. However, VRA refuses to provide details let alone proof of all the various women

groups, youth and civil society it claimed were consulted in the name of promoting transparency. It therefore provokes a question whether VRA complied with the Principles of Free, Prior, and Informed consultation and Consent (FPIC) that Ghana has subscribed to.

Sadly enough, the issues 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 example, VRA has failed to provide detailed information of names and contacts of fishermen group, women and youth groups as well as the NGOs they claim to have engaged. Again, it is important to state that our checks show that the community elders have no knowledge on any compensation package. Indeed, VRA failed to provide information on the characteristics of the coal and fly ash in the report as requested by EPA and 350 G-ROC.

The erroneous claim that VRA consulted 350 G-ROC and other local stakeholders is shameful. This does not only come as a surprise but nonetheless represents a very unfortunate development undermining mutual trust and respect.

Conducting a multi-stakeholder consultation processes for a project such as this must not be compromised.

  1. Environmental Management Plan must be disclosed

Furthermore, the ESIA discusses plans to develop an Environmental Management Plan (EMP) to minimize potential environmental impacts. It gives a sense of the proponent’s commitment to ensure adequate safeguard of the environment as well the population.

It will be interesting to know how EPA has ensured adherence to the Environmental Management Plan (EMP) developed for mining activities to warrant this new venture. Loss of lives and sources of livelihood of vulnerable people are the realities unfortunately.

It’s about time that EMPs are made public if government claims to believe in promoting transparency and accountability.

Our Position:

It is very unfortunate that Ghana is still considering the establishment of a coal-fired plant in this current era. 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 according to a report on Renewable Energy Policy Review, Identification of Gaps and Solutions in Ghana. 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 Ghana would be willing to let China dump coal technologies in Ghana when they are transitioning off coal.

Our analysis shows that the ESIA report is defective. For instance, the ESIA vaguely claims that the coal handler terminal may contribute “marginally” to climate change. This is misleading given that coal is one of the greatest sources of greenhouse gas emissions and climate change. The inevitable impacts of coal on the community’s limited resources and infrastructure will only deepen poverty and inequality levels which are inconsistent with the aim of the Sustainable Development Goals (SDGs). Interestingly, the report even fails to indicate how many temporary or permanent jobs the project will generate for the community.

350 G-ROC’s independent research conducted in the communities in June 2016 to be affected also reveals that VRA did not hold consultations with community people. Perhaps, that explains why it has not been able to show proof of consultations held with all relevant stakeholders in the various communities.

Ultimately, our question is: how can VRA support a project which directly accelerates climate change, when the state herself has committed to cutting carbon emissions?

We call on the VRA and Shenzhen Energy Group to stop the coal nightmare.

About 350 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.


Chibeze Ezekiel



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