Royal Dutch Shell Plc  .com Rotating Header Image

Preliminary critique of the Shell-IUCN Niger Delta Panel report

Screen Shot 2013-09-06 at 16.45.38Attached is my preliminary critique of the Shell-IUCN Niger Delta Panel report, which was just released this week.  You can see I am very critical of the entire process, as yet anther delay tactic by Shell. 

EMAIL RECEIVED FROM PROFESSOR RICHARD STEINER, ANCHORAGE, ALASKA

Dear John,

I trust you are well.  Attached is my preliminary critique of the Shell-IUCN Niger Delta Panel report, which was just released this week.  You can see I am very critical of the entire process, as yet anther delay tactic by Shell.  I can send you the Shell-IUCN report if you wish as well, just let me know.

Feel free to post this, or circulate however you wish.

Regards,
 
Rick Steiner, Professor
Oasis Earth
Anchorage, Alaska
www.oasis-earth.com

IUCN-­‐Niger Delta Panel final report – Preliminary Comments/Critique

Richard Steiner, Professor Anchorage, Alaska USA Sept. 1, 2013

The IUCN Niger Delta Panel (NDP) final report released last week (dated July 2013):

Sustainable Remediation and Rehabilitation of Biodiversity and Habitats of Oil Spill Sites in the Niger Delta: Main Report including Recommendations for the Future, fails to meet its professed objectives, presents little new information, contains inaccuracies, represents a flawed process, and seriously undermines the credibility of IUCN.

The following are preliminary comments on the just-­‐released Final Report, given that the report’s 11 Annexes are not included in the report and were thus unavailable for review. Upon review of the Annexes, I may have more comments to offer.

Background

The IUCN Secretariat has had a “partnership” with Shell for several years, and in January 2011 Shell apparently approached IUCN proposing the Niger Delta Panel (NDP) process. The internal discussion between Shell and IUCN was concealed at the time from those associated with IUCN with experience in oil spill issues of the Niger Delta. When in September 2011 we became aware of the secret internal discussions between Shell and IUCN regarding the Niger Delta issues, some of us raised concerns about the underlying premise for the NDP process, the Terms of Reference (TORs) for the project, and the secretive internal discussions from which it derived.

In a September 11, 2011 email to IUCN Director General, IUCN President, and the Head of the IUCN Business and Biodiversity Program, I wrote the following:

I was thus dismayed to learn a few days ago that IUCN had entered into an agreement with Shell to convene a panel on oil spill restoration in the Niger Delta, and that there appears to have been a deliberate attempt by the Secretariat, Council, CEESP Chair, et.al, to conceal this project from those of us associated with the Union who had most experience with this issue.

I read through the TORs for the project, and with respect to whomever drafted them, this is simply one of the most uninformed documents I have read on the Delta, and I have read many such things. They reflect a profound misunderstanding of what is actually occurring in the Delta, and a part-­‐and-­‐ parcel of Shell’s fiction about the issue. Further, it is difficult to believe that a company that netted over $100 billion in after tax profits over the past 4 years does not know what it should be doing to behave responsibly in the Niger Delta -­‐-­‐ they do, but they just make too much money not doing so. I am concerned that Shell is simply wanting green validation from IUCN for their irresponsible activities in the Delta, and it most certainly does not deserve such. And, it seems evident that, through projects such as this, Shell is attempting to continue delaying responsible action in the Delta. Shell used the 4-­‐year UNEP Ogoniland study to successfully delay action, and now are looking to use IUCN for another few years delay.

I informed a wider audience of these internal discussions between Shell and IUCN, and was accused by IUCN of committing an “ethical breach” in so doing.

My 9-­‐11-­‐11 email to IUCN Secretariat closed with the following:

I respectfully ask that you contract an independent investigator to look objectively into how this project was conceived and developed, the deliberate attempt to conceal the project from those involved with the Union who are most knowledgeable on these issues, and to recommend ways to prevent a repeat of this sort of episode in the future.

As well, and most importantly, I respectfully urge you to terminate the Shell/IUCN Niger Delta Panel project, and to terminate the Shell/IUCN partnership agreement as it clearly does not, and cannot, lead to constructive conservation action.

However, IUCN elected to proceed with the NDP process. In January 2013, IUCN released an Executive Summary of the Final Report, but oddly not the Final Report. I asked in April 2013 for the Final Report, and was told it would be available in May. The final report, dated July 2013, was finally made available to me last week, at the end of August.

The Final Report does not include the 11 Annexes, to which it repeatedly refers. Thus it is difficult to review the report in total. I have asked for the annexes. And the final report does not include a list the panel members (which are found only on a FAQs link), and even that list does not provide sufficient detail to substantiate the claims of the panel’s oil spill expertise made by the report.

I asked IUCN via email yesterday to disclose how much money Shell has paid IUCN for the NDP process, but IUCN replied that this is confidential and it will not disclose this information.

One of my primary objections regarding the IUCN-­‐NDP process was/is that Shell has been required by Nigerian Law for decades to respond to and restore damage from oil spills (see discussion below). Yet through this IUCN-­‐NDP process, Shell is asserting that it does not know how to comply with the law, and that it has not been in compliance with these Nigerian legal requirements.

The IUCN-­‐NDP process was initiated exactly when the 4-­‐year UNEP study of oil contamination in Ogoniland was completed. This supports the suspicion that Shell is using such studies as a convenient excuse, a cover, to delay taking necessary steps to improve its performance in the Niger Delta. It is a simple delay tactic, and all that this tactic requires is willing collaborators, which Shell has apparently found in UNEP and IUCN. This may be why IUCN concealed this process as long as possible from those who might object.

Then, last month, Shell announced its long-­‐anticipated exit from most of the onshore regions of the Niger Delta. Below is part of the August 2, 2013 news story in Dutch News.nl:

Shell to pull out of Niger Delta

Friday, August 2, 2013

Anglo-­‐Dutch oil giant Shell is to pull out of its oil activities in Niger Delta, its managing director in the country told the NRC in an interview on Friday.

“We are leaving,” Mutiu Sunmonu told the paper. The “recklessness” and size of thefts are forcing Shell to halve its activities in the country.

On Thursday, CEO Peter Voser talked of “divestment” in Nigeria during the presentation of the company’s second quarter results. He gave the “challenges” in Nigeria as one reason why Shell booked disappointing results.

In summary, Shell:

  • has received $ billions in profits from its oil operations in the Niger Delta,
  • has been required to conduct its business there with the highestinternational technical standards,
  • has not re-­‐invested sufficiently in its onshore infrastructure to make it safe,
  • has continued to operate on the Niger Delta knowingly with substandardinfrastructure and operational standards,
  • has commissioned studies by UNEP and IUCN for a few $ million to presentthe appearance of propriety all the while simply delaying for over 6 years the necessary re-­‐investment in the onshore infrastructure to comply with Nigerian law, and
  • has subsequently announced that it is leaving the onshore area.

So for a few million dollars paid to UNEP and IUCN over the past 6 years, Shell has knowingly continued to operate a substandard oil production and transportation system in the Niger Delta, earned $ billions, re-­‐invested little, and is now “leaving.” And that is Shell’s “sustainable business model” in Nigeria.

Nigeria legal requirements regarding oil spills

As discussed in Steiner 2008/2010 Double Standard: Shell practices in Nigeria compared with international standards to prevent and control pipeline oil spills and the Deepwater Horizon oil spill (a report critical of SPDC practices and not cited by the IUCN-­‐NDP report), Nigerian law has for decades required that companies responsible for oil spills immediately cleanup the spill to legal standards; conduct an environmental damage assessment; conduct an environmental restoration program; and fairly compensate those who suffer losses from the spill. In addition, federal law requires that all oil infrastructure -­‐ including wellheads, pipelines, flow stations, manifolds, etc. -­‐ be maintained and operated to highest and safest international standards. It is clear that none of these requirements have been met by SPDC, yet the IUCN-­‐NDP report does not discuss this.

Nigerian law stipulates standards for oil operators in the country requiring companies to incorporate Best Available Technology/global best practice standards into all operations, as prescribed by the American Petroleum Institute (API), the American Association of Mechanical Engineers (ASME), or the Institute of Petroleum Safety Codes (IPSC). For instance, the Nigerian Petroleum Drilling and Production Regulations (implementing the Petroleum Act of 1969) require companies to:

adopt all practicable precautions including the provision of up-­‐to-­‐date equipment (in order to prevent pollution, and if pollution does occur they must take) ‘prompt steps to control and, if possible, end it’

These regulations also require companies operating in Nigeria to prevent:

‘the escape or avoidable waste of petroleum’, (and to cause) ‘as little damage as possible to the surface of the relevant area and to the trees, crops, buildings, structures, and other property thereon.’

The Nigerian Department of Petroleum Resources (DPR) further expanded these requirements in 1991 when they instituted the Environmental Guidelines and Standards for the Petroleum Industry in Nigeria (EGASPIN), which was revised and updated again in 2002. EGASPIN confirms that oil and gas operations in Nigeria are governed by the Nigerian Petroleum Act and subsequent federal legislation (NG-­‐ EGASPIN 2002).

Regarding oil spill response, EGASPIN states, inter alia:

`Clean-­‐up shall commence within 24 hours of the occurrence of the spill.’

`For inland waters/wetland, the lone option for cleaning spills shall be complete containment and mechanical/manual removal. It shall be required that these clean-­‐up methods be adopted until there shall be no more visible sheen of oil on the water.’

EGASPIN stipulates that oil contamination of soil, sediment and surface water may not exceed a specified level (50 mg/kg TPH target value), and lower BTEX and PAH levels, as is consistent with internationally recognized standards for maximum levels of oil pollution.

Further requirements of EGASPIN (NG-­‐EGASPIN, 2002, as reviewed in Steiner 2008/2010) that are relevant to the conduct of SPDC include the following:

2.1 (i) Requires an Environmental Evaluation Report (EER) for activities that have `been observed to cause significant and adverse environmental effects and impact…spillages of oil or hazardous materials/wastes are under this category.’

2.2 Requires that the EER shall contain a full description of the spill incident, qualitative and quantitative descriptions of the already impacted environment, loss of and significance of impacted environmental resources, restoration plans `to either eliminate or decrease adverse environmental impacts to the greatest extent possible,’ and an environmental management plan post-­‐EER.

1.1.1 `License holders…are required by legislation to take/adapt Practical Precautions and/or all steps Practicable to prevent pollution.’

2.6.1 Requires that `operators respond for immediately containment of oil spill’,

2.6.2 Requires containment to prevent groundwater contamination as a `high priority’,

2.6.3 (i) Requires `complete containment and mechanical/manual removal’ of spills,

6.6 `In an event where groundwater gets contaminated, the operator shall take necessary steps to de-­‐pollute the contaminated soil and groundwater.’

2.11.1 `It shall be the responsibility of a spiller to restore to as much as possible the original state of any impacted environment.’

11.3 (VIII F) requires that (i) `for all waters, there shall be no visible sheen after the first 30 days of the occurrence of the spill, no matter the extent of the spill’, and (ii) `for swamp areas, there shall not be any sign of oil stain within

the first 60 days of occurrence of the incidence’; and (iii) for land/sediment, the quality levels ultimately aimed for (target value) is 50 mg/kg of oil content.’

4.1 `An operator shall be responsible for the containment and recovery of any spill discovered within his operating area, whether or not its source is known.’

6.1 Requires reporting to DPR `within 24 hours’, immediate response, an environmental damage assessment, and `recovery, treatment, monitoring, and rehabilitation programmes.’

7.1 `An operator responsible for a spill shall be required to conduct an Environmental Evaluation (Post Impact) Study of any adversely impacted environment’ (as stipulated in VIII-­‐A.2.0).

1.0 `Licensees/operators shall conduct environmental audits to facilitate the management control of environmental practices and assessing compliance with the management system and regulatory requirements.’

4.6.2 Oil/Chemical/Hazardous materials spillages:
(b) `The spiller (operator or owner of vessel) shall pay adequate compensation

to those affected’, and;
(c) `The spiller shall restore/remediate the polluted environment to an

acceptable level as shall be directed by the Director of Petroleum Resources.’

4.7.1 `any person, body corporate or operator of a vessel or facility, who persistently violates the provisions of these guidelines and standards shall have his lease, license and/or permit revoked.’

It is clear that Nigerian law requires Shell/SPDC to employ the highest international standards in its operations in Nigeria, and it is equally clear that these legally required standards have not been met by Shell/SPDC. In addition, it is apparent that Shell/SPDC either knew, or should have known, that it has been consistently out of compliance with Nigerian federal law. I consider such willful neglect as evidence of gross negligence on the part of SPDC.

Fundamental in this is that if a company cannot conduct its business safely (e.g. protect against the illegal activities repeatedly cited by the company and the IUCN-­‐ NDP report), then it should not operate in the region unless and until it can.

_______________________

Preliminary Comments on IUCN-­‐NDP Final Report

  • The NDP report mentions “biodiversity and habitat remediation” countless times, but surprisingly does not actually provide any detail regarding the biodiversity of the region. There is no description of the Niger Delta biodiversity at risk, baseline studies, and biodiversity losses as a result of oil spills. To meet its goal of assisting in biodiversity restoration, the NDP report must provide such detail. This must include detailed description of the communities of vertebrates impacted -­‐ birds, fish, reptiles, mammals, amphibians; species of special concern; the invertebrate fauna impacted (e.g., crab, shrimp, cockles, periwinkles, oysters, etc.) and plankton communities (freshwater and marine); subtidal and intertidal communities, and various plant communities. There is no discussion at all of the marine communities, other than a very superficial discussion of produced waters from offshore production facilities. And there is no discussion of predator-­‐prey relationships impacted by oil spills, or how to restore such impacts.
  • The IUCN-­‐NDP should have had access to SPDC’s 2004 Niger Delta Environmental Survey (NDES), and cites this in its bibliography. The NDES (which I understand is still not publicly released) should contain comprehensive information on the biodiversity of the region as it pertains to the goals of the NDP. As well, there are countless Environmental Impact Statements, Environmental Evaluation Reports, and other documents that should have been available to the NDP. None of this is discussed.
  • In particular, the NDP final report does not provide a detailed discussion of impacts to the mangrove ecosystems of the Niger Delta, and on restoration techniques for such. It is possible the Annex may have more detail on this.
  • The NDP report focuses almost exclusively on terrestrial spill sites, with little discussion of aquatic systems at all, freshwater or marine, which is clearly where most damage has occurred.
  • There is little new information in the NDP report. Most of the recommendations are general, simplistic, and superficial -­‐ e.g., the need to “speed up response to oil spills,” provide better monitoring and community engagement, provide for enhanced consideration of biodiversity, etc. Most of the recommendations have been well known to Shell/SPDC for many years.
  • The report does provide a general discussion of various terrestrial oil spill remediation techniques, including use of oxygen, plants, fungi, algae, microbes, and biosurfactants. However, the information provided is so general that it is of limited operational utility.
  • The NDP report states: the Panel’s work in the field has been severely hampered by security issues in the Niger Delta. This is a convenient Shell/SPDC excuse for negligent operation in the Delta.
  • Literature reviewed in the NDP report excludes publications that are critical of Shell/SPDC practice in the Niger Delta. For instance, the original environmental damage assessment work conducted in the region in 2006 by an IUCN Commission in concert with the Nigerian federal government and NGOs, was not cited at all. However, the NDP report presents many of the same conclusions as the 2006 study, but without attribution. This is scientifically and intellectually dishonest. There are many other reports the NDP should have drawn upon, but didn’t.
  • Qualifications and experience of panel members are not provided. The report states panel’s seven members are: technical experts in the science of oil spill management and oiled site remediation and rehabilitation. But the report itself does not list the panel members, and the list is found only in a FAQs link. And the list in FAQs does not provide sufficient detail with which to substantiate the claimed expertise of the panel.
  • The NDP report mentions many times the problem of illegal artisanal crude oil refining, sabotage, and oil theft, but seldom mentions the well-­‐known negligent operations of Shell/SPDC. For instance, the report states: The Panel also recognizes that repeated spills from anthropogenic activities— especially crude oil theft and illegal refining—are at critical levels, causing significant economic and environmental impacts (emphasis added). The report states that operational spills result from occasional infrastructure failures. This is the same overt bias found in the UNEP 2011 report, and is the inaccurate position held by the client and sponsor of both reports, Shell. This is the precise bias to which local communities consistently object.
  • The report claims that: SPDC has implemented its remediation measures to meet the EGASPIN standards. This is simply untrue, as it is obvious most of SPDC activities fall far short of EGASPIN requirements (see Steiner, 2008/2010).
  • The process for selecting study sites by the panel is not sufficiently discussed, and is questionable. There is no detailed description of spills at the sites, volume, causes, response, and so forth.
  • It is evident that the NDP did not examine some of the more heavily contaminated sites (e.g. Bodo). In Oguta, the panel reported a significant amount of surface oil present, but did not conduct their assessment, asserting the difficulties from earlier flooding.
  • The Report claims that there exists in local residents a: ‘quick money syndrome’, which is fuelled by over-­‐expectations for compensation from the oil industry. But the report fails to discuss the contrary, equally valid perspective held by the communities that Shell/SPDC has provided inadequate compensation for the extreme environmental, social, and economic damage caused by Shell operations in the region. In fact, the most pernicious quick money syndrome in the Niger Delta is that in Shell, the other oil companies, and the government.
  • The report inaccurately states that: “the vast majority (about 97%) of PAHs in produced water are of BTEX (benzene, toluene, ethylbenzene and xylene).” But these are not PAHs, and this error exposes a poor grasp of petroleum chemistry.
  • Section 3.6 is a general discussion of produced water from offshore rigs, apparently at the initiation of SPDC, but there is essentially no other discussion of the marine environment.
  • Recommendation 4.2.1 “Speed up response to oil spills” states that: a target response time of 48 hours for Tier III spills is “not feasible for SPDC.” This contradicts federal legal requirements. And it states that: “safe bioagents (enzymes and biosurfactants) could be sprayed directly at the well head.” This proposal deserves considerably more detail.
  • Recommendation 4.3.2: “Include biodiversity rehabilitation along with remediation activity using trials on the major habitat types,” only discusses phytoremediation (use of plants), and simply does not discuss biodiversity restoration. Again, biodiversity impacts and restoration is not discussed sufficiently. This should include all ecological effects of large-­‐scale oil pollution in the region.
  • Recommendation 4.3.2 proposes: “rapidly implement a strategy to replace lost fishery resources where applicable,” but does not provide any more discussion of this proposal. This is of course central to the panel’s professed goals.

Preliminary Conclusion

In a normal client/contractor relationship, a client would likely conclude that the final report of the contractor – IUCN-­‐NDP -­‐ was not fit-­‐for-­‐purpose, and either request substantial amendment with more detail, or request its money back.

However, as discussed in the Background section above, this is not a normal client/contractor process. Shell received precisely what it wanted from this process – a few more years to make $ billions from oil in the Niger Delta, not have to upgrade its oil infrastructure to international standards and not have to correct its irresponsible business practices, and now will be leaving the area.

This was my concern before the project was initiated, and remains my unfortunate conclusion now. That IUCN participated willingly in this corporate deception, allowing environmental harm to continue unabated in a biodiversity hot spot, calls into serious question the credibility of IUCN.

RELATED SEPT 2011 EMAIL

September 11, 2011

Email: FR:    Richard Steiner: [email protected]

TO:    Julia Marton LeFevre, DG IUCN

         Ashok Khosla, President IUCN

         Juan Marco Alvarez, IUCN Business and Biodiversity Prg.

         CEESP-SEAPRISE

RE:    IUCN-Shell Niger Delta Panel issue

Dear Ashok –

I trust you are well, and continuing our collective struggle to conserve the natural systems of Earth.

I wanted to very briefly contact you directly re: the Shell/IUCN panel on Niger Delta oil spill restoration, and respectfully ask that the agreement be terminated.  I would greatly appreciate you copying this along to all Council members as well.

As you may know, I have worked on the issues of oil spill prevention, response, damage assessment, restoration, litigation, policy, etc. for decades around the world, including in the Niger Delta, where I now serve as an expert witness for local communities in legal cases against Shell. I drafted the UNEP manual on oil spill damage assessment and restoration, and collaborated with IUCN in Pakistan in 2003/2004, where I served as the Chief Technical Advisor to the Government of Pakistan.  I have worked on these issues across the U.S., Russia, Canada, China, Europe, the Arctic, central Asia, southeast Asia, Africa, etc., particularly with local and Indigenous People in support of their efforts to responsibly manage extractive industry.  As well, I served on the first such IUCN/Shell panel, looking at the interaction between offshore oil drilling off Sakhalin Island and the critically endangered western gray whale population.  As you and I discussed in New Zealand earlier this year, I helped to craft and pass 3 resolutions at the World Conservation Congress in Barcelona that deal with extractive industry responsibility and active engagement with civil society (I continue to believe that implementation of these Resolutions would alleviate many of the problems we continually encounter with extractive industry).  Together with Clive Wicks and Prof.Obot, I’ve participated with several SEAPRISE activities in the Niger Delta as well, and serve as an advisor to government in the Delta on these issues.

I was thus dismayed to learn a few days ago that IUCN had entered into an agreement with Shell to convene a panel on oil spill restoration in the Niger Delta, and that there appears to have been a deliberate attempt by the Secretariat, Council, CEESP Chair, et.al. to conceal this project from those of us associated with the Union who had most experience with this issue.

I read through the TORs for the project, and with respect to whomever drafted them, this is simply one of the most uninformed documents I have read on the Delta, and I have read many such things.   They reflect a profound misunderstanding of what is actually occurring in the Delta, and a part-and-parcel of Shell’s fiction about the issue.   Further, it is difficult to believe that a company that netted over $100 billion in after tax profits over the past 4 years does not know what it should be doing to behave responsibly in the Niger Delta — they do, but they just make too much money not doing so.  I am concerned that Shell is simply wanting green validation from IUCN for their irresponsible activities in the Delta, and it most certainly does not deserve such.  And, it seems evident that, through projects such as this, Shell is attempting to continue delaying responsible action in the Delta.  Shell used the 4-year UNEP Ogoniland study to successfully delay action, and now are looking to use IUCN for another few years delay.  I can talk to you personally at some point about Shell’s astonishingly dishonest, criminally negligent activities there, if you wish.

On the issue of concealing the project from many of us, Section 8 of the Shell/IUCN partnership agreement states the following:

Shell and IUCN agree that the nature of this relationship is based upon openness and will encourage greater transparency. Neither Party shall unreasonably hold information confidential.

Clearly this must apply within both entities as well as between them. Secrecy in governance is not good policy, wherever it occurs.

In this spirit, when I first became aware of this project a week ago, I felt obliged to inform a broader audience, and did so.  This was not an “ethical breach,” as some have characterized it.  The only ethical breach in all of this is in the attempt by some to maintain secrecy for the project, and not solicit input from some of the only people associated with the Union who have experience with the issue — SEAPRISE.

The TORs state that project had been in discussion since January, and others said that the project now was “a done deal.”  It had already moved to the stage of soliciting nominations for prospective members, etc.  And yet, most of us knew nothing whatsoever of it.  This does not seem in keeping with Section 8 of the agreement, nor with IUCN transparency policies.

And yes, my input would have been / is in objection to the project going forward at all, but even at that, constructive input could have helped revise the project to be more effective and legitimate.  Fear of dissenting opinion has lead to many horrible mistakes in civil society, and it certainly restricts creative resolution of problems.  Even many corporations have come to understand this simple truth.  Projects such as this one deserve inclusive, thorough deliberation, solicitation of different perspectives, particularly from those most knowledgeable on the issues at hand, and this one obviously has not had such.  This deliberation must also include those people living in the region that is to be discussed, and again, this has not occurred.  You attended the wonderful “Sharing Power” conference organized by Aroha Mead in NZ earlier this year — clearly, sharing power starts with full transparency, honesty, and inclusion.

And please note:  I would have not wished to serve on this Shell/IUCN panel even if the TORs had allowed such (I am precluded due to my serving as expert witness for communities in the Delta) as the manner in which this project was developed and concealed, appears to validate Shell’s criminal and horribly irresponsible activities in the Delta.

You may recall that many members voted to terminate the Shell/IUCN partnership at the last WCC in 2008.  This incident is indicative and symptomatic of the many problems with this partnership.

Given the above, I respectfully ask that you contract an independent investigator to look objectively into how this project was conceived and developed, the deliberate attempt to conceal the project from those involved with the Union who are most knowledgeable on these issues, and to recommend ways to prevent a repeat of this sort of episode in the future.

As well, and most importantly, I respectfully urge you to terminate the Shell/IUCN Niger Delta panel project, and to terminate the Shell/IUCN partnership agreement as it clearly does not, and cannot, lead to constructive conservation action.

Respectfully,

Rick Steiner, Professor

Oasis Earth

Anchorage, Alaska 

www.oasis-earth.com

RELATED

PROFESSORS LETTER TO SHELL CEO PETER VOSER & SHELL ALASKA VP PETER SLAIBY

Comments are closed.

%d bloggers like this: