– says NGL facility was covered by Gas-to-Energy EIA

THE Environmental Protection Agency (EPA) has defended its environmental authorisation process for the Wales Gas-to-Energy project, rejecting claims that the Natural Gas Liquids (NGL) facility was excluded from environmental assessment and that its decision to exempt the gas-fired power plant from a separate Environmental Impact Assessment (EIA) was never published.
In a statement issued on Wednesday, October 14, the EPA said the environmental assessment record showed that the NGL facility was covered under the wider Gas-to-Energy EIA, while the proposed 300-megawatt (MW) power plant was screened separately under the Environmental Protection Act.
The statement was issued in response to comments attributed to environmental specialist Dr Vincent Adams in the Kaieteur News on October 11, which the agency described as materially inaccurate.
According to the EPA, the Gas-to-Energy project was placed on public notice in June 2021 after the agency determined that a full EIA was required. Members of the public were given 28 days to submit questions they wanted the assessment to address.
The agency subsequently prepared terms and scope for the assessment, which included the offshore and onshore pipelines, the NGL facility, a temporary materials offloading facility and associated infrastructure.
The EPA said the assessment expressly covered the NGL plant’s construction, commissioning, start-up, operation, maintenance and decommissioning.
The power plant was excluded from the direct scope of that EIA because it was to be constructed and operated by a separate entity, but its potential contribution to cumulative environmental impacts was considered.
The cumulative impact assessment modelled air emissions from the NGL facility alongside those projected from the planned power plant and other existing, permitted or proposed activities associated with Esso Exploration and Production Guyana Limited (EEPGL), the agency stated.

POWER PLANT SCREENED SEPARATELY
Addressing the power plant’s environmental authorisation, the EPA said its decision that a separate EIA was not required was published in the Guyana Chronicle on January 6, 2023.
The agency determined that the proposed 300MW facility would not significantly affect the environment and therefore qualified for an exemption from a separate EIA under Section 11(2) of the Environmental Protection Act.
The published notice outlined six reasons for the decision, including the cumulative impact assessment undertaken for the wider Gas-to-Energy project, predicted air quality in relation to World Health Organization limits, emissions associated with natural gas combustion, and projected carbon emissions compared with heavy fuel oil.
Other considerations included wastewater treatment before discharge and the project site’s location within a highly modified landscape, together with the proposed environmental controls and mitigation measures.
The notice also advised persons who might be affected by the decision of their right to appeal to the Environmental Assessment Board within 30 days.
The EPA further cited a Kaieteur News report published on January 9, 2023, in which Adams reportedly challenged the decision and referred to the six reasons provided by the agency.
According to the EPA, Adams disputed aspects of the justification, including the treatment of particulate matter and the reliance on the cumulative impact assessment.
The agency argued that his earlier criticism of the decision contradicted the claim now attributed to him that no decision had been published.

ENVIRONMENTAL BOARD UPHELD DECISION
The EPA said two appeals, dated February 3 and 5, 2023, were subsequently lodged with the Environmental Assessment Board within the prescribed period.
The Board advertised a public hearing on March 5 and heard submissions from the appellants, the developer and the EPA on March 22, 2023.
On May 10, 2023, the Board upheld the agency’s decision, subject to permit conditions addressing the concerns raised during the appeal process.
The EPA said Section 11(2) of the Environmental Protection Act assigns the agency responsibility for determining whether a proposed project requires an EIA, adding that this statutory role had also been recognised by the High Court in Radzik et al v the EPA.
The agency maintained that the power plant’s exemption from a separate EIA was therefore subject to a formal review process, including public participation and consideration by the Environmental Assessment Board.

PERMIT INCLUDES ENVIRONMENTAL SAFEGUARDS

The EPA also pointed to the environmental safeguards contained in the power plant’s permit, reference number 20220201-GPLPG, issued to Guyana Power and Gas Inc. and valid from May 2023 to April 2028.
Among the requirements are an Environmental and Social Management Plan incorporating an Emergency Response Plan, as well as monitoring arrangements for effluent, ambient air quality, stack emissions, fence-line conditions and noise.
The permit also requires a gas leak detection and repair programme, prohibits routine flaring and venting, and establishes limits for ambient air quality, stack emissions and effluent discharges.
Additional provisions cover hazardous waste and chemical management, the reporting of non-compliance or environmental emergencies to the agency within 24 hours, and the EPA’s right to inspect construction and operational activities.
The agency, however, distinguished between the existence of these permit conditions and evidence of their implementation, stating that compliance remained subject to its monitoring and oversight.

FURTHER TECHNICAL ASSESSMENTS

The EPA said technical assessments continued after the initial screening decision.
It cited an Air Quality Modelling Update prepared by ERM in May 2024, which examined both the NGL facility and the power plant and assessed predicted pollutant concentrations against International Finance Corporation guidelines.
The agency also referred to publicly available project documents through the United States Export-Import Bank, including the Gas-to-Energy EIA, a water quality modelling update and a transmission line assessment.
While defending the assessment process, the EPA acknowledged that modelling results represent predictions based on assumptions and do not eliminate the need for ongoing environmental monitoring, verification and enforcement.
It also stated that any proposed expansion of the project would be considered according to its scope and the applicable authorisation and screening requirements under the law.
The agency said it welcomed evidence-based scrutiny of environmental decisions but rejected accounts that, in its view, misrepresented the scope of completed studies and the history of the authorisation process.
The dispute centres on the distinction between requiring a full EIA for the wider Gas-to-Energy project, assessing the NGL facility within that study, and determining whether the separately developed power plant required its own assessment. The EPA maintains that each step was undertaken through the statutory process and that the power plant decision was subsequently reviewed and upheld by the Environmental Assessment Board.