Posts Tagged ‘Friends of the Earth’

December 15, 2011

The U.K.’s advertising watchdog has ruled in favor of oil giant Shell over claims it made in a magazine advert that its biofuels reduced CO2 emissions.

Nonprofit ActionAid UK had challenged that the advert, which called the fuels “one of the most effective ways of reducing CO2 from cars and trucks today,” was misleading. ActionAid said that evidence showed that biofuels did not reduce CO2 emissions from vehicles when the full life-cycle of the fuel was taken into account.

But the ASA ruled in favor of Shell yesterday stating that the company had provided data for biofuels manufactured in the U.S. and Brazil for distribution in the U.S. and Europe and that that data had shown that its biofuel did indeed have the capability to reduce CO2 emissions compared to that of petrol over its life-cycle.

Shell has been accused of overplaying its environmental credentials in advertising before. In 2009, Greenpeace took issue with an advert that it claimed suggested that more of Shell’s revenue was derived from renewable sources than was true.

In 2007, Friends of the Earth Europe filed simultaneous complaints to the national advertising standards authorities of Belgium, the Netherlands, and the U.K. about a Shell advertisement depicting the outline of an oil refinery emitting flowers rather than smoke.

SOURCE ARTICLE

RELATED ARTICLES

Shell Criticized for Manipulating Environmental Audit Report

ASA: Shell Environmental Claims Violate Advertising Rules

Shell Accused of Greenwashing, Again

From pages 52, 53, 54 & 55 of “Royal Dutch Shell and its sustainability troubles” – Background report to the Erratum of Shell’s Annual Report 2010

The report was made on behalf of Milieudefensie (Friends of the Earth Netherlands)
Author: Albert ten Kate: May 2011.

A toxic legacy in Curaçao

Curaçao and its oil refinery

Curaçao is an island in the southern Caribbean Sea, off the Venezuelan coast. It is a constituent country of the Kingdom of the Netherlands and has a land area of 444 square kilometres. As of January 2010, its population amounted to around 142,000 people. Prior to 10 October 2010, when the Netherlands Antilles were dissolved, Curaçao was administered as the Island Territory of Curaçao, one of five island territories of the former Netherlands Antilles.

From 1918 until 1985, Shell owned and operated the Isla oil refinery in Curaçao. During this period, the refinery has been one of the most important lifelines of Curaçao. For example, in the early fifties it employed more than 12,000 people out of the total island population of 110,000 people. The refinery generated the foreign exchange necessary to finance the imports the island could not produce itself.  In the beginning of the eighties, Shell-companies provided for 33% of the island’s Gross National Product. Apart from the refinery, Shell had a local sales company, an oil storage/transshipment company, and a shipping company on the island. Shell was very important to Curaçao, and the government of Curaçao treated Shell kindly. In 1980, a former director of Shell declared towards a reporter of the Dutch newspaper NRC: “The Antillean government? We were that government.”

Historically, the Isla refinery formed a link in the Shell-chain of Venezuelan upstream oil production and North American downstream activities. The nationalisation of Shell’s oil production in Venezuela in 1975 and a change in the U.S.-energy policy towards more independence, left the refinery with supply and demand problems. With the exception of 1979 through 1981, the refinery operated at substantial losses during the ten years before 1985. In 1975, the refinery had 2,800 employees. In 1984, there were still only 1,900 employees.

The Isla-refinery, presently still operated, is located along the Schottegat harbour, in the south of Curaçao, near the capital city Willemstad. The refinery and harbour are surrounded by residential areas.

In 1985, Shell sold its refinery and other companies/assets in Curaçao for the symbolic price of four Netherlands Antillean guilders. The buyers were the legal entities Netherlands Antilles and island territory Curaçao. Subsequently, Curaçao leased the refinery and terminals to the Venezuelan state-owned petroleum company PDVSA. Since 1985 and ongoing, PDVSA operates the refinery.

Yes, Shell created a mess

The agreement in 1985 between Shell and the Netherlands Antilles and Curaçao stated that the buyers had to abstain irrevocably and unconditionally from existing and future claims for pollution or other environmental effects exerted by Shell’s companies in the Netherlands Antilles. During 67 years of operation, Shell created a toxic legacy in Curaçao. The refining business has caused massive pollution to air, soil and water.

Evaluating the sale, ten years after

In 1996, a documentary on the environmental legacy from Shell’s operations in Curaçao was shown on Dutch television. Interviewed were: Ms. Maria Liberia Peters (prime minister of the Netherlands Antilles during the deal in 1985), Mr. Errol Cova (member for Curaçao in the negotiation team during 1985), Mr. Bart de Beer (director general affairs Shell Netherlands during 1996), Mr. R. Gonesh (a former technical supervisor for Shell Curaçao) and Mr. Edgar Leito (a former environmental chief at Shell Curaçao).

The interviewees provide some insight in why the environmental legacy had been included to the deal between Shell, The Netherlands Antilles and Curaçao:

− Mr. Cova stated that, during the negotiations, Shell had brought forward that the asphalt lake would be beneficial to Curaçao. This was confirmed by others. The discussions during the deal were never about cleaning up pollution, it was about exploitation of the lake. Later on, it turned out that the lake was too polluted, and that it was not economically justified to process it.

− Ms. Peters stated that, during the negotiations, it was thought that cheap fuel could be processed from the lake, while at that time the island used expensive fuel for water production. She also claimed that in 1985 Curaçao didn’t really have a choice to make. It could have decided to take legal action against Shell. Then it would have to close down the refinery and defy all social and economic consequences. The other choice was to keep the business going, so that the island could diversify its economy, but obviously with the risk that it might later end up with certain environmental consequences. She also stated that, in order to submit a claim against Shell, the island would have needed millions to hire expensive consultants to quantify the damage. Certainly with the perspective of refinery closure, the country could not afford such expensive consultants.

− According to Mr. Gonesh, the people on the Curaçao side of the negotiation table had not kept any records. Shell had however kept records, as a well-documented and bright company. Shell knew what it had put in the ground. It knew about the asphalt lake and the groundwater problems due to oil leaks. Mr. Gonesh took the view that Shell had handled in a criminal way, by transferring the pollution to simpletons which did not have the resources and know-how for a clean-up.

− Mr. De Beer stated that he could hardly imagine that people from Curaçao would feel cheated by the deal. In fact, Curaçao acquired the main economic engine of the island for free. Curaçao was very happy with the results of the agreement, according to De Beer. The Dutch government, which advised Curaçao, was also very happy with it. Mr. de Beer could not explain why the acid tar lake, which he thought to be originating from about the fifties, was not cleaned up earlier by Shell. According to him, it was envisaged that an incinerator would be built, after processing the asphalt lake. This incinerator could be used to burn the remains of the asphalt lake (the tar sandy mix at the bottom of the lake) and the acid tar.

Shell to be held liable?

The government of Curaçao is currently reconsidering the future of the Isla refinery. As of April 2011, the refinery is still causing severe air pollution. In December 2009, the Dutch parliament adopted a resolution, ordering an investigation on the possibilities to recover the costs associated with the remediation of the damage from, among other, Shell. In the same month, the parliament of the Netherlands Antilles adopted a similar resolution, stating that Shell should be held liable for “the serious damage caused to the earth and sea bed, groundwater, seawater and inland waters of Curaçao.” In a civil case, Shell could still be held liable for negligence at the cost of the environment and the health of people.

THE COMPLETE 73 PAGE REPORT (with reference sources)

From pages 42 & 43 of “Royal Dutch Shell and its sustainability troubles” – Background report to the Erratum of Shell’s Annual Report 2010

The report was made on behalf of Milieudefensie (Friends of the Earth Netherlands)
Author: Albert ten Kate: May 2011.

In May 2005, Shell signed an agreement to start a joint venture with the Libyan National Oil Corporation. The joint venture would revamp and expand the existing liquified natural gas (LNG) Plant at Marsa el-Brega on the Libyan coast. It would also explore for gas and subsequently develop five areas totalling 20,000 square kilometres located in the heart of Libya’s Sirte Basin. Shell was committed to invest USD 637 million in the first phase of the joint venture.

Already in March 2004, Malcolm Brinded, head of exploration and production at Shell, stated: “We were in Libya in the Fifties and we were in Libya in the Eighties for an exploration programme, but for this one we came back in 2001 and so this is the culmination of discussions over that.” International sanctions on Libya were lifted in 2003 and 2004. Thus, Shell had been fishing for contracts from Gaddafi a long time before international sanctions were lifted.

In April 2010, documents obtained by the UK newspaper The Times revealed that the former UK prime minister Tony Blair lobbied Colonel Muammar Gaddafi on behalf of Shell. Shell had written a letter in draft form for Mr Blair to write to Colonel Gaddafi. In May 2005, shortly after Mr Blair’s official letter was written, Shell secured the deal.

Both letters were released after a lengthy Freedom of Information process. The Cabinet Office of the UK government would release only a part of Mr Blair’s official letter. In its draft-letter, Shell tells the Prime Minister to congratulate the Libyan leader on Revolution Day and to comment on the “remarkable year of progress for Libya”. In relation to its deal, the draft letter from Shell said: “Understand that all the terms of the agreement have now been negotiated and approved now waiting for [Libyan] Cabinet approval.” The section on Shell in Mr Blair’s official letter sounded very similar to the draft: “I understand that the necessary technical discussions with the relevant authorities in Libya have been completed satisfactorily. All that is needed now are final decisions by the [Libyan] General People’s Committee to go ahead.” Shell declined to comment to The Times. The journalist of The Times, David Robertson, later characterised Shell’s draft- letter “unusually informal or unusually forward in the way that Shell thought it would be able to dictate British foreign policy.”

In September 2009, The Times requested all communication between the UK Department for Business and the following companies: BP, BG group and Shell (all oil and gas companies), and defence company BAE Systems. A limited number were released in December 2009. One was an email from Shell to UK Trade & Investment dated September 2004 complaining of slow progress with its Libyan deal. Just months earlier Mr Blair and Colonel Gaddafi had met in a tent outside Tripoli to end Libya’s diplomatic isolation.

EXTRACT ENDS

RELATED ARTICLES

Shell wrote letter Tony Blair used in £325m Libyan oil deal (Daily Mail)

THE COMPLETE 73 PAGE REPORT (with reference sources)

Royal Dutch Shell Executive Director Malcolm Brinded and Gaddafi.

From pages 48 & 49 of “Royal Dutch Shell and its sustainability troubles” – Background report to the Erratum of Shell’s Annual Report 2010

The report is made on behalf of Milieudefensie (Friends of the Earth Netherlands)
Author: Albert ten Kate: May 2011.

The Sakhalin-2 project

According to its developers, the Sakhalin-2 project is the world’s largest integrated oil and gas project. The capital expenditure for this project amounted to USD 21.3 billion from 2001 through 2009, while total costs exceeded USD 24 billion.

The project is about extracting gas and oil offshore Sakhalin Island, in the Russian Far East. The fields are called Lunskoye (mostly gas) and Piltun-Astokhskoye (mostly oil). The company Sakhalin Energy Investment Company Ltd. (Sakhalin Energy) is the operator of the project. Royal Dutch Shell is a partner and lead technical adviser to the operator. Under the shareholding structure of Sakhalin Energy, Gazprom holds 50% (plus one share), Shell 27.5% (minus one share), Mitsui 12.5% and Mitsubishi 10%.

The field development of the Sakhalin-2 project involved:

− two offshore platforms (Lunskoye-A and Piltun-Astokhskoye-B);

− an 800 kilometres onshore pipeline system to the south of the island; − offshore pipelines systems;

− an onshore processing facility;

− a liquefied natural gas (LNG) plant;

− offloading terminals for crude oil and LNG.

At the end of 2010 the liquefied natural gas (LNG) plant of Sakhalin Energy reached its full production capacity of 9.6 million tonnes a year. Sakhalin Energy now has a 5% share in the world’s LNG market. The entire output is contracted under long-term arrangements (for 20 and more years). Around 65% of the Sakhalin LNG will be supplied to customers in Japan. The rest is intended for consumers in South Korea and North America. In 2009, Sakhalin Energy produced and offloaded over 5.5 million tonnes of oil and condensate. Oil produced from the Molikpaq and the PA-B is blended with gas condensate from the Lunskoye field. The blend of crude is used to produce petrol, kerosene, diesel fuel, and source materials for the petrochemicals industry. Molikpaq (Piltun-Astokhskoye-A) was the first offshore oil platform, installed in 1998 during phase 1 of the Sakhalin 2 project.

Case: the Western gray whale is on the brink of disappearing forever

The offshore gas and oil extraction by Sakhalin Energy interferes with the feeding grounds of the Western gray whale. Western gray whales feast throughout the summer and autumn in the waters off Sakhalin Island. The estimated population size in 2009 was about 130 whales, including only around 30 mature females. The population, which is listed as critically endangered on the IUCN Red List of Threatened SpeciesTM, could be driven to extinction by the mortality of just a small number of reproductive females.

In 2006 the International Union for Conservation of Nature (IUCN) created a panel of independent scientists – the Western Gray Whale Advisory Panel (WGWAP) – which provides scientific advice and recommendations on the operational plans and mitigation measures by Sakhalin Energy. On the first day of the 9th meeting of the WGWAP (4-6 December 2010, Geneva, Switzerland) Sakhalin Energy announced a plan to construct another offshore oil and gas platform.

The NGOs World Wildlife Fund (WWF), Pacific Environment, International Fund for Animal Welfare (IFAW) and Sakhalin Environment Watch strongly oppose the construction of a new platform and associated subsea pipeline. Subsequently, they also oppose the seismic survey in preparation for this platform, which is announced by Sakhalin Energy to take place during the summer of 2011.

The NGOs have urged the WGWAP to strongly recommend that Sakhalin Energy will not develop the extra platform. To underpin their statement, the NGOs have put forward several arguments:

− The acoustic pollution due to all platform-related activities near an area of high whale density might scare the whales away from their feeding grounds.

− There are increasing risks that a vessel might strike a whale.

− The risk of a Sakhalin-2 platform-related oil spill and/or additional subsea pipeline accident risk increases by 50%.

− The marine ecosystem may get polluted through drilling.

− The Western gray whales are likely already stressed from major seismic surveys which took place in 2010. Assessment of the full range of impacts (including impacts to feeding and reproduction) of the 2010 seismic surveys will not be possible until late 2011.

− It is essential to, at first, evaluate the cumulative impacts on the Western gray whales from the variety of different off shore oil and gas activities off Sakhalin Island.

− There is no good reason why the seismic survey needs to happen in 2011, as Sakhalin Energy has reiterated that a decision whether or not to go ahead with building the new platform would not be taken for several years.

− Sakhalin Energy has already put out a tender for the seismic survey and ruled out some design alternatives. The proposed route of the associated subsea pipeline(s) have not been disclosed even in the most cursory form. All this contradicts the repeated call for information on company activities to be presented to the WGWAP and observer organizations in a timely manner.

− The construction of a new platform fundamentally changes the full Sakhalin II project scope. Prior WGWAP recommendations (which are required by lenders) were based on an assumption that a total of two platforms would be built. The same is true of prior lender decisions, and Russian environmental regulatory decisions. Thus, Sakhalin Energy’s revelation brings into question whether the WGWAP should review the adequacy of prior recommendations.

THE COMPLETE 73 PAGE REPORT (with reference sources)

RELATED ARTICLE: 6 Oil Wells On Sakhalin Go Offline Moscow Times 14 October 2011

A spill that occurs right before fall freeze-up (October or November) might not allow enough time to drill a relief well before sea ice conditions make it unsafe to continue drilling. Under such a scenario, the well could continue to blow out through the winter ice season until well control could be attempted after the spring thaw in May or June.

From pages 45, 46, & 47 of “Royal Dutch Shell and its sustainability troubles” – Background report to the Erratum of Shell’s Annual Report 2010

The report is made on behalf of Milieudefensie (Friends of the Earth Netherlands)
Author: Albert ten Kate: May 2011.

The Beaufort and Chukchi Seas on Alaska’s Arctic coast

The marine environments of America’s portion of the Arctic Ocean – the Chukchi and Beaufort Seas – are among the least understood in the world. This wide swath of ice-covered ocean waters – circulating between Canada and Russia – is home to one-fifth of the world’s polar bears, as well as seals, migratory birds, bowhead whales, several other types of whales, Pacific walrus and much more. The Inupiat people who live on Alaska’s North Slope call the Arctic Ocean “their garden.” The bowhead whale is the foundation for the Inupiat people’s subsistence culture.

Threatened and endangered species

In November 2010, almost 485,000 square kilometres along the north coast of Alaska were designated as “critical habitat” for the polar bear, as a result of a partial settlement in an ongoing lawsuit brought by the Center for Biological Diversity, the Natural Resources Defense Council (NRDC) and Greenpeace against the U.S. federal government. This designation under the Endangered Species Act is intended to safeguard the habitat that is vital to the polar bears’ survival and recovery. At the same time, the federal government is considering whether to allow oil companies, especially Shell, to drill for oil and gas in the polar bear’s newly designated critical habitat in the Chukchi and Beaufort seas off Alaska.

The polar bear is listed as a threatened species under the U.S. Endangered Species Act. The bowhead whales and several other types of whales occurring in the Chukchi and Beaufort seas are listed as endangered.

Shell wants to drill

In 2008, Shell paid USD 2.1 billion for 275 leasing blocks in the Chukchi sea. The company also has 137 leases in the Beaufort sea, acquired in 2005. If viable reservoirs are discovered through exploratory drilling, Shell would be the main company producing gas and oil in the shallow waters of Alaska’s Arctic coast. According to a YouTube-video on its plans, Shell wants to execute “a safe, sustainable drilling program that benefits Alaska and the nation with new jobs, new energy and new life for the TransAlaska pipeline.” Shell wants to start drilling exploration wells soon in both the Beaufort and Chukchi sea. After the first exploration activities it will take up to ten years before the production phase is started. It is estimated that production, mainly by Shell, in the Beaufort and Chukchi Outer Continental Shelf (OCS) could amount to almost 9 billion barrels of oil and 15 trillion cubic feet of gas through 2057.

Shell’s incomplete oil spill preparedness

In November 2010, the NGO Pew Environment Group published a technical report about oil spill prevention and response in the Beaufort and Chukchi seas. According to this report, darkness, extreme weather and shifting sea ice could delay efforts to stop an oil well blowout for six months or more, trapping spewed oil in ice for up to a decade. Shell’s spill response system was found to be inadequate. The Pew Environment Group concluded that “at present, offshore oil and gas drilling in the Arctic Ocean cannot be undertaken with any level of assurance that the marine environment can be protected from a spill or that industry can respond effectively.” Based on the report’s technical analysis, the Pew Environment Group documented several recommendations to reform the federal government’s approval and oversight of Arctic Ocean oil and gas activities.

Shell submitted an Oil Discharge Prevention and Contingency Plan (C-plan) for the Chukchi sea to the relevant federal agency MMS in May 2009. The MMS approved the C-plan in December 2009. The plan was considered sufficient to clean up a well blowout of 5,500 barrels per day over 30 days. Shell finalized its plan in March 2010.

The authors of the Pew report mention various arguments why Shell’s plan is inadequate:

− The uncontrolled well flow may be significantly higher than 5,500 barrels per day. Other North Slope wells have had production rates in excess of 10,000 barrels per day when first drilled.

− The two most recent well blowouts, the Montara platform blowout in the Timor Sea and the Deepwater Horizon blowout in the Gulf of Mexico, involved explosions and fires that damaged the drilling structure. Shell assumes that its Noble Discoverer drillship be undamaged by a well blowout, and could drill its own relief well if a subsea blowout should occur. This is highly unlikely.

− The Montara blowout took more than 70 days to control, in part because the first four attempts to drill a relief well were unsuccessful. Thus, drilling the relief well may take longer than 30 days.

− Shell assumes that it would contain or recover 90 percent of the oil offshore and another 5 percent nearshore. The much more moderate recovery estimates from the Deepwater Horizon spill (20 percent contained or recovered, 5 percent burned) make the 95 percent assumption highly unrealistic.

− Shell’s blowout scenarios fall short of the regulatory requirement to plan for a “worst case discharge under adverse weather conditions”. Under this requirement, adverse weather conditions means “weather conditions found in the operating area that make it difficult for response equipment and personnel to clean up or remove spilled oil or hazardous substances. These include, but are not limited to: fog, inhospitable water and air temperatures, wind, sea ice, current, and sea states.” In the offshore Chukchi Sea, the combination of wind, waves and dynamic sea ice can severely hamper or even preclude oil spill clean-up.

− A spill that occurs right before fall freeze-up (October or November) might not allow enough time to drill a relief well before sea ice conditions make it unsafe to continue drilling. Under such a scenario, the well could continue to blow out through the winter ice season until well control could be attempted after the spring thaw in May or June. Shell does include a response scenario nine days before freeze-up, but makes a number of assumptions and concludes that at some point, the ice will preclude further response and that it will track the oil until spring. This is not an adequate response. To the contrary of what Shell assumes, an oil spill occurring late in the drilling season could lead to oil trapped under multiyear ice, remaining in the marine environment for many years.

Government to re-assess spill risks

On 4 March 2011, the federal agency Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE, earlier MMS) determined that it would be appropriate to update its spill risk assessment, and include a very large oil spill analysis from an exploration well blowout in the Chukchi sea. BOEMRE has yet to define the volume of such a spill. The agency had received over 150,000 comments on a supplemental Environmental Impact Statement (EIS), which was opened for public comments during late 2010. Due to the Deepwater Horizon oil spill, many commenters requested an analysis that takes into account the possibility of a blowout during exploration. The Environmental assessment conducted by MMS on the Chukchi exploration plans had ignored the risks from a blowout, stating, “the probability of a large spill occurring during exploration is insignificant and, therefore, this [environmental assessment (EA)] does not analyze the impacts of large spills from exploration operations.”

BOEMRE anticipates that a final version of the supplemental EIS will be completed by October 2011, after a public comment period. Exploration plans for the Chukchi Sea may be submitted for the year 2012. The supplemental EIS was needed after Alaska Native and conservation groups had won a court case.

According to Leah Donahey, western Arctic and oceans program director for the Alaska Wilderness League, a plaintiff in the court case that is still pending, the initial environmental study lacked information in “hundreds of areas”. In a statement she said: “BOEMRE must take into account the fact that there is no known way to clean up a spill in the Arctic’s icy, extreme conditions.” Curtis Smith, a spokesman for Shell Oil, stated: “We already took into account worst-case discharge when we built a world-class Arctic oil spill response fleet for Alaska, so it’s hard to imagine raising the bar even higher than we already have in that arena.”

Shell’s incomplete air pollution permit

During the open water period from July to October 2011, Shell wanted to send its Noble Discoverer drillship to drill exploration wells in the Beaufort Sea. However, on 30 December 2010 the Environmental Appeals Board of the U.S. Environmental Protection Agency (EPA) ruled that Shell had not provided enough information on air pollution. The permits for both Beaufort and Chukchi were not in line with the U.S. Clean Air Act, and thus cancelled. The Noble Discoverer and its associated fleet of support ships, such as icebreakers and a supply ship, could not run out. Alaska native and conservation groups had challenged the permits. The Environmental Appeals Board received motions for modification and/or clarification from Shell and the regional EPA-office that had earlier issued the permits. On 10 February 2011, the Environmental Appeals Board rejected the requests from Shell. Among other, the permits would not be reinstated and new permits would have to be issued following applicable standards at the time of their issuance. Shell now hopes to get the necessary permits in time to drill in 2012. Brendan Cummings, senior attorney for the Center for Biological Diversity, one of the organisations that had challenged the permits, stated: “If Shell wants to be permitted fast, they need to submit a permit application that actually complies with the law.”

THE COMPLETE 73 PAGE REPORT (with reference sources)

From pages 17, 18 & 19 of “Royal Dutch Shell and its sustainability troubles” – Background report to the Erratum of Shell’s Annual Report 2010

The report is made on behalf of Milieudefensie (Friends of the Earth Netherlands)
Author: Albert ten Kate: May 2011.

A Shell pesticide factory

For a decade or more, beginning in 1977, Shell produced organochlorine pesticides (aldrin, dieldrin, endrin etc.) and other pesticides at a plant located near Paulínia, about 125 kilometres north-west of São Paulo, Brazil. The plant covered approximately 40 hectares.78 Due to its severe health impacts, by 1990 the use of aldrin and dieldrin was totally banned in the USA and Brazil.

After negotiations starting in 1993, in 1995 Shell sold the Paulínia facility to the companies American Cyanimid and BASF. A sales condition was that Shell would assume legal responsibility for the pollution at the site. In 2000, BASF took full ownership of the facility.79 In 2002, BASF shut it down the facility after a ban by the Brazilian Ministry of Labour, in view of existing contamination and serious risks to human health.

Pollution at the factory site

There have been many cases of pollution at the factory site: − Between 1998 and 1985 three leaks in a waste-water storage tank were officially reported. − Over the years, CETESB (São Paulo State Environmental Protection Agency) had issued three warnings that the plant’s incinerator was not operating within acceptable standards. − March 2001, the Justice Department listened to the testimony of a former company employee, Antonio de Marco Rasteiro. He confirmed the existence of four clandestine landfills inside the plant area, and accused Shell of dumping ash from its incinerator and waste from its manufacturing process in these landfills. He also confirmed that Shell’s incinerator sold its services to third parties, for example to DuPont. He also reported that drums with toxic wastes were buried in other areas inside the plant.

Pollution spreading across farmlands

Later, several studies of the area revealed that the contamination had moved into the groundwater under the farms located between the plant and the Atibaia River. For example, in February 2001, the Dutch environmental consulting company Haskoning/Iwaco, hired by Shell, produced a technical report with soil and groundwater analysis in nine sites located in the farms near the industrial site. Levels of contamination by dieldrin as high as 17 parts per billion (ppb) in soil and 0.47 ppb in water were found. The water contamination levels were higher than the levels allowed by Brazilian law (Administrative Rules 36/1990 and 1469/2000 – Ministry of Health – Highest Permissible Level: 0,03 ppb of dieldrin). However, no decontamination work had begun in the area. In February 2001, Shell admitted that it had contaminated the groundwater and sections of the nearby community, and was ordered by CETESB to begin a clean-up.

Pollution creating severe health problems

Both aldrin and dieldrin are highly toxic to humans, the target organs being the central nervous system and the liver.83 A report at the request of the Paulínia local government, produced by August 2001, showed that 156 of the 181 examined residents living near the factory had some degree of contamination from metals or pesticides which could result in various cancers, liver disorders, or neurological problems. Shell dismissed the Paulínia report, saying it used very low thresholds to measure contamination compared with those recommended by the World Health Organization. Shell also claimed its own tests showed no human contamination. “If there is proof of contamination with the products that we handled there, we will assume the responsibility immediately, which is our policy worldwide,” said Jose Cardoso, a Shell manager in Brazil. “But so far, there is no data indicating that.”84 Maria Lucia Braz Pinheiro, vice president of Shell- Quimica for Latin America, described the report as “another report with technical inconsistencies and lacking a scientific base.”

In a doctoral dissertation approved in February 2005, an analysis was made on the existing health data from a group of 62 former Shell/Cyanamid/BASF workers. Three cases of thyroid cancer were confirmed. The author concluded that the incidence of thyroid cancer among the estimated 1,120 workers of Shell/Cyanamid/BASF was 166 times greater than the incidence in the male population of Campinas, a county within Sao Paulo state. The chance of finding three cases of thyroid cancer out of a random selection of 1,120 men living in Campinas would be less than 1 out of 1,000,000.

At the beginning of 2009, it became publicly known that the Center for Excellence in Occupational Health (Cerest) of Campinas had examined 69 former employees of Shell / Cyanamid / BASF. Ten malignant cases of cancer to the prostate and thyroid were diagnosed. There was also a case of myelodysplastic syndrome (MDS, formerly known as “preleukemia”). There were 34 cardiovascular diseases, of which 21 related to hypertensive heart diseases. There were also an unspecified number of liver diseases. In 30 cases there was a prevalence of repetitive strain injury (RSI). In total 56 ex-workers had serious problems with reproductive organs and the urinary system, with prostate disorders, changes in fertility and impotence.

August 2010: Shell/BASF ordered to pay severe fine

In 2007, the public prosecutor Ministério Público do Trabalho (MPT) filed a case to ensure funds for health treatment of former employees, along with compensation for damages. The Association of Workers Exposed to Chemical Substances (ATESQ) and another union of workers had also filed a case against Shell and BASF. ATESQ was created by Antonio de Marco Rasteiro, a former employee of the Shell/BASF plant in Paulínia. He worked there for 21 years. In his role as ATESQ Coordinator, Mr Rasteiro has led the struggle of nearly a thousand former workers. In November 2009, he won the International Health & Safety Award of the American Public Health Association.

In August 2010, a Brazilian court (Tribunal Regional do Trabalho de Campinas) ruled that Shell and BASF should assume responsibility for the medical treatment of all former employees of the Paulínia facility, and pay a total of 1.1 billion Brazilian Real (about EUR 490 million89) in connection with the More than 1,000 former employees of the companies were covered by the court order, and also the children of employees who were born during or after services and independent contractors.

Some extracts from the court ruling in August 2010: − “Workers were constantly exposed to harmful substances in water and air, without any use of protective clothing. This exposure took place during and after work, during breaks, in the vicinity of the site, as well as through the use of water on site. Therefore, the simplistic explanation of Shell that the presence of harmful substances in the bodies of the workers do not constitute evidence of intoxication is unacceptable”

− “(…) Although it is not certain that all employees will develop diseases such as cancer, it is not excluded. Certainly it has been determined that among the employees exposed to the pollutants, cancer occurs much more frequently than normal.” − “(…) The most shocking is that the accused companies, especially Shell, were since 1970 fully aware of the harmful effects of substances used by them. After the production was banned in the U.S., Shell coolly moved its plant to Paulínia. BASF also has not taken precautionary measures: it was aware of the pollution at the site, which was already raised and well known in Paulínia. Nevertheless, BASF located itself in the same place, in the full knowledge that this place was not appropriate, with the result that its employees were exposed to obvious risks”.

Shell and BASF appealing

Soon after the court order in August 2010, Shell and BASF announced that they would appeal the decision. “We expect that the Brazilian courts at a higher level will eventually establish that we were not responsible for alleged health impacts and other claims”, a Shell spokesman told press agency Reuters.

Jennifer Moore-Braun, a spokeswoman for Basf told press agency Bloomberg: “We are of the opinion that the environmental damage was caused by Shell, and we will appeal the decision.” Shell was quoted saying: “We are convinced there is no link between our operations and injury to people’s health based on blood tests of local residents, medical assessments of former workers and expert medical opinions.”93 In April 2011, the Tribunal Regional do Trabalho de Campinas denied an appeal filed by Shell and BASF against the decision, and maintained the sentence. Shell and BASF may appeal the decision at the Superior Labour Court (TST) in Brasilia.

THE COMPLETE 73 PAGE REPORT (with reference sources)

How do farmers prove that Shell has polluted their lands, what lengths people have to go through to get their rights?

From pages 35, 36 & 37 of “Royal Dutch Shell and its sustainability troubles” – Background report to the Erratum of Shell’s Annual Report 2010

The report is made on behalf of Milieudefensie (Friends of the Earth Netherlands)
Author: Albert ten Kate: May 2011.

Farmers, scientists, NGOs, a Dutch princess, a business tycoon, a long-distance swimmer, a Facebook account with already 6,500 members as of 19 April 2011. Royal Dutch Shell is facing strong opposition to its plans to get an exploration license to seek shale gas in South Africa’s semi-desert Karoo region.

The consulting firm Golder Associates, working on behalf of Shell, drafted an Environmental Management Plan (EMP) for three exploration areas, each comprising 30,000 kilometres. Until 5 April 2011, the public was allowed to comment to these plans. The drilling of a maximum of 24 wells was not expected to commence before 2012. Golder stated in its conclusions to the EMPs that there was no material evidence that a small number of exploration wells could result in an unacceptable level of environmental impact, and that therefore the determination of the resource potential of the Karoo shale gas formations not should be prevented or delayed. As long as the siting and management of the wells would be controlled through a rigorous, scientific Environmental Impact Assessment process, it would be unlikely that the construction would result in unacceptable environmental damage, the company continued.

Scientists of the U.S. Environmental Protection Agency (EPA), under this administration and at the direction of U.S. Congress, are currently undertaking a study on the practice of hydraulic fracturing to better understand any potential impacts on drinking water and groundwater. The results of this study are not expected before late 2012. Golder stated that there was no need to wait with handing over an exploration license, because Shell’s application did not involve production. Before any licensing of a production well field is considered, the EPA-study should however be considered, according to Golder.

Thousands of comments to the Environmental Management Plan (EMP) of Golder were submitted. The strong public resistance against fracking the Karoo resulted in a moratorium by the government on licenses in the Karoo where fracking is proposed. On Wednesday 20 April 2011, the South African Cabinet endorsed the decision by the Department of Minerals to invoke this moratorium. The Department of Minerals will lead a multi disciplinary team including the Departments of Trade & Industry, Science and Technology, amongst others, to fully research the full implications of the proposed fracking. It was stated that the Cabinet had made it very clear that clean environment together with all the ecological aspects will not be compromised.

The opponents of the exploratory plans are however not re-assured: − Business tycoon Johann Rupert: “We don’t think the legal framework was designed for this fracking method and we are very, very scared about the irreversibility of the ecological damage, should it occur.” − Professor Doreen Atkinson of the Centre for Development Support at the University of Free State (UFS): “There is a prima facie case to put a hold on any decisions around fracking until studies have been done. These studies may take at least 3 to 5 years. It would also be prudent to first see the results of the American Environmental Protection Agency (EPA) which has embarked on a study. Its results are only expected in late 2012.”

− Long-distance swimmer Lewis Gordon Pugh: “Growing up in Grahamstown I learnt how scarce water is in the Karoo. Why on earth would we allow a foreign company to come and drill for gas in a vulnerable ecosystem? Why would we risk contaminating our water supply? It is morally wrong. It also makes poor economic sense. We must look after our water for future generations.”

− Dr Anthony Turton, a well-known trans-disciplinary water scientist: “In the absence of certainty, it is prudent to assume the worst and respond accordingly. In the case of fracking, there are many unknowns technologically. At best it is chasing a highly marginal resource. Invariably the costs exceed the benefits if one takes potential environmental damage into consideration. But because the benefits are so few, if things go wrong, there is not enough to pay for environmental remediation.”

− Geologist and palaeontologist Professor Bruce Rubidge of the University of Witwatersrand’s Bernard Price Institute: “The fact that companies like Shell are saying that they will use sea- and brack- water for the fracking may have unwelcome effects on the salinity of the groundwater. Also in the fracking process there will undoubtedly be some of this sea and brack water which has been contaminated with chemicals and which will spill out on the surface, as has happened in many recorded cases in America. What will it do to the soil?”

− Ernest Pringle, president of Agri-Eastern Cape and a farmer in the Karoo: “I spent all my time trying to pump up more groundwater to keep going. So we want to know with certainty what the effects will be to the underground water supply.”

− Mark Botha, head of conservation at environmental group WWF South Africa: “We’ve got some serious concerns about fracking, it is as yet an unproven technology with unacceptable risks for fresh water abstraction and pollution.”

− Derek Light, a lawyer representing a number of Karoo land owners: “We are very concerned about the environmental impact, especially because fracking is not regulated in South Africa.”

− Princess Irene of the Netherlands (this sister of the queen owns land in the Karoo): “There are other ways to generate energy, for which we do not exploit nature but cooperate with it. With wind or solar energy nothing gets polluted, nothing gets broken. More companies are recognizing that we are partners of nature. Shell is stuck in its old patterns.”

− At the beginning of April 2011, several scientists and consultants responded to Shell’s application with an extensive 104-page critical review.

Even in the case that the fracking operations by Shell could be performed without compromising a clean environment together with all the ecological aspects, there is still the issue of where Shell would get the massive amounts of water needed. The company has made a commitment “not to compete with the people of the Karoo for their water needs.” One of the options Shell considers is to get water from sea. Shell has also stated it is commuted to provide full compensation to any landowner with evidenced direct negative impact or loss on their land as a result of its activities. This may however seem less re-assuring than it looks like. How do farmers prove that Shell has polluted their lands, what lengths people have to go through to get their rights?

A further extract from the report will be published in the coming days.

THE COMPLETE 73 PAGE REPORT (with reference sources)

Shell’s modus operandi – of giving out information only on what appears to be a need-to-know basis – is not good enough. The public needs to know, and has a right to know.

ENERGY giant Shell is facing mounting criticism over its secrecy about an oil leak in the North Sea, as the spill was revealed to be twice as large as previously thought.

Five days after the leak from the Gannet Alpha rig was spotted about 112 miles east of Aberdeen, Shell finally responded to pressure to reveal the volumes of oil involved.

It confirmed 216 tonnes had spread into the sea – the equivalent of 1,300 barrels of oil. The Scottish Government said at the weekend it involved only about 100 tonnes.

However, a raft of questions today remain unanswered, including how the leak started, why Shell has not yet been able to stop the flow of oil, where exactly the spill is in the North Sea, and whether any seabirds or other wildlife are caught up in it.

Politicians and environment groups have increased their calls for Shell to be more open about the leak. Government figures show it is four times the entire quantity of oil discharged into the North Sea in 2009, and by far the largest spill in UK waters for more than a decade.

The Scotsman’s attempts to get Shell to give specific details about the leak were yesterday met by silence. And the firm refused to take part in BBC Scotland’s flagship news programme Good Morning Scotland.

Environment secretary Richard Lochhead urged the company to “make information available on an open, transparent and regular basis” and said the Scottish Government was taking the spill “very seriously”.

Shell, headed by chief execuive Peter Voser, insisted the leak on the flow line system that serves the Gannet Alpha platform remained “under control”, and industry insiders insisted the firm would be doing everything it could to tackle the leak.

However, critics said the company’s response had been a disaster. Jack Irvine, executive chairman of public relations firm Media House International, criticised Shell’s handling of the situation. “This is not a big spill in global terms, but by delaying their announcement, Shell are made to look very guilty and the public may suspect it’s worse than it really is,” he said.

“When handling a major crisis, the accepted wisdom is that you have got to get the first blows in before your detractors get a chance. And if you know the truth of the matter, you should tell the truth. Shell should have known that organisations like RSPB and Greenpeace are never slow to turn a crisis into a catastrophe, and they appear to have done just that.

“One had hoped that oil companies had learned from the BP Deepwater Horizon mess, but it appears that history has taught them little.”

Scottish Lib Dem environment spokesman Jim Hume said: “Shell’s lack of clarity has been a worry over this incident. It has taken days for information to start to come forward.”

Juliet Swann, head of campaigns at Friends of the Earth Scotland, said: “We are deeply worried that we still, even five days after the leak was detected, know far too little about the environmental impact of the spill, how it could impact wildlife, and the scale of the threat to Scotland’s coastal communities and the marine environment that they rely on for their income.”

RELATED ARTICLE: So many questions, so few answers from Shell

13 August 2011 Last updated at 03:02

Oil giant Royal Dutch Shell has said it is working to stop a leak at one of its North Sea oil platforms.

The leak was found near the Gannet Alpha platform, 180 km (113 miles) from Aberdeen, Scotland.

The company would not say how much oil may have been spilt so far, though it said it had “stemmed the leak significantly”.

One of the wells at the Gannet oilfield has been closed, but the company would not say if production was reduced.

The company says it has sent a clean-up vessel to the location and has a plane monitoring the surface.

The leak was found in a flow line connecting an oil well to the platform.

‘Finite amount’

Shell confirmed the leak was continuing but said it was being reduced and was “not a significant spill”.

The UK Department of Energy and Climate Change said it was in contact with Shell and investigating the incident in the usual way.

The department’s spokesman added that it understood from Shell that there was a “finite amount of oil that can be dispersed” but stressed that regulators were taking the leak seriously.

The Health and Safety executive confirmed it was monitoring the situation.

A Scottish government spokesman also said it was monitoring the situation and would update ministers, adding that Marine Scotland, which manages Scotland’s waters, was in close contact with key organisations including Shell.

A Shell spokesman said it was “managing” the leak.

“We deployed a remote-operated vehicle to check for a sub-sea leak after a light sheen was noticed in the area.

“We have stemmed the leak significantly and we are taking further measures to isolate it.

“The sub-sea well has been shut in, and the flow line is being de-pressurised,” he added.

It is unknown how much oil may already have been spilt.

The Gannet oil field reportedly produced about 13,500 barrels of oil per day between January and April of this year.

Friends of the Earth Scotland said the spill showed the dangers of offshore drilling in the North Sea.

“Any spill, however small, should serve as a warning sign and encourage us to look to a clean, renewable energy future, rather than continuing to invest in dirty oil,” said Juliet Swann, head of campaigns at the environmental group.

The field is co-owned by Esso, a subsidiary of US oil firm Exxon but operated by Shell.

SOURCE ARTICLE

From pages 32, 33 34 & 35 of “Royal Dutch Shell and its sustainability troubles” – Background report to the Erratum of Shell’s Annual Report 2010

The report is made on behalf of Milieudefensie (Friends of the Earth Netherlands)
Author: Albert ten Kate: May 2011.

Shell: nothing wrong with fracking and unconventional gas

In its communication, Shell makes no difference between conventional and unconventional gas in terms of environmental and health risks. The company generally refers to natural gas as being cleaner-burning than coal in power plants and as being a bridge to a low-carbon energy future.

On fracking, Shell states on its website: “This is a safe and proven technique according to the U.S. Environmental Protection Agency (EPA), which is now carrying out a new study into hydraulic fracturing and its potential impact. Fracturing has been used by oil and gas companies for over 60 years.” The company does not mention that there are great differences between the traditional fracking and the present high-volume fracking, that the EPA has been presently accused of hiding some severe impacts of fracking, and that the U.S. government has not been able and/or willing to monitor the booming U.S. shale gas business adequately.

Environmental and health risks caused by unconventional gas extraction

In this section, the environmental and health risks of the present high-volume fracking are considered more in-depth.

1) Enormous water use

According to the U.S. Environmental Protection Agency, the volume of water needed for hydraulic fracturing varies by site and type of formation. Fifty thousand to 350,000 gallons of water may be required to fracture one well in a coal-bed formation, while two to five million gallons of water may be necessary to fracture one horizontal well in a shale formation. A gallon stands for 3.78 litres.

Shell stated in September 2010 that hydraulic fracturing requires 1 to 5 million gallons of water per well and that it re-uses some of the water. For its Groundbirch tight gas operations in British Columbia (Canada) Shell claims to use 5 to 8 million litres per well, sourced locally from the Peace River, fresh water wells and some 20-40% recycled from producing wells. As with most unconventional gas operations presently going on, the Groundbirch operations have just been starting up. As of June 2010 Shell had drilled 103 wells, with almost 3,000 wells yet to come. Shell’s future aspiration is to use reclaimed water from a waste treatment plant at Groundbirch, transported via pipelines so the present disposal by trucks can be reduced.

To explore the shale gas possibilities of the Karoo region in South Africa, Shell states it may decide to hydraulically fracture vertical and horizontal exploration wells. It expects to need up to 2.2 million litres of water for hydraulic fracturing a vertical exploration well and up to 6 million litres for an exploratory horizontal well section. Whenever Shell is allowed to explore the Karoo region, and it does find gas it could produce on an economically basis, one wonders how Shell would cope with the enormous amounts of water needed in the semi-desert Karoo region. Shell has not yet shared its thoughts about this.

2) Pollution of water resources

There are several ways in which water could be polluted through high-volume fracking. With shale gas production, the two major pathways to water contamination are activities at the surface and errors below ground: − Once in the ground, a large portion of the fracturing fluid may be trapped in the target formation. The rest, however, comes back to the surface (flowback), combined with water produced from the formation itself. Both flowback and produced water represent large waste streams. If flowback and produced water are disposed of improperly, waste water may threaten public and environmental health.

− Errors below ground can endanger water resources as well. Improperly cased wells may contaminate penetrated aquifers. Potential shallow pockets of natural gas in formations above the target layer may enter into ground water.

− Trucks transporting water to the site for fracturing and from the site for disposal may stress nearby stream banks, contributing to erosion and adding sediment to surface water.

Experiences in Pennsylvania, United States

In February and March 2011, the New York Times published several articles about the pollution caused by drilling in Pennsylvania State, USA. During nine months the newspaper had obtained more than 30,000 pages of documents from state and federal agencies/officials.

The shale gas business is booming in Pennsylvania, sitting atop the enormous reserve called the Marcellus Shale. In 2010, drilling companies were issued roughly 3,300 Marcellus gas-well permits in Pennsylvania, up from just 117 in 2007.

The New York Times estimated that more than 1.3 billion gallons of wastewater was produced by Pennsylvania wells over the past three years. Based on the obtained documents, the newspaper estimated that some 10 to 40 percent of the water sent down the well during hydrofracking returns to the surface, carrying drilling chemicals, carcinogenic materials, corrosive salts and, at times, naturally occurring radioactive material. Most of the wastewater was sent by trucks to treatment plants not equipped to remove many of the materials, and ended up in rivers providing drinking water for millions of people. The U.S. Environmental Protection Agency states that it is dangerous when radioactive wastewater contaminates drinking water or enters the food chain through fish or farming. Once radium enters a person’s body, by eating, drinking or breathing, it can cause cancer and other health problems, many federal studies show.

The newspaper was able to map the wastewater released from 149 wells. The federal drinking water standards were exceeded for the carcinogenic benzene (41 wells), gross alpha (128 wells, gross alpha is a type of radiation caused by emissions from uranium and radium), uranium (4 wells), and radium (42 wells).203 At least 116 wells produced wastewater exceeding the federal standards for radium or other radioactive materials in drinking water more than 100 times.

3) Greenhouse gas emissions

The three main greenhouse gases (GHGs) that are relevant to the petroleum and natural gas industry are methane (CH4), carbon dioxide (CO2), and nitrous oxide (N2O). Methane’s chemical lifetime in the atmosphere is approximately 12 years. Its relatively short atmospheric lifetime, coupled with its potency as a greenhouse gas, makes methane a candidate for mitigating global warming over the near-term (25 years or so). Methane is about 33 and 105 times more powerful at warming the atmosphere than carbon dioxide (CO2) by weight, for a 100-year and 20-year horizon respectively.

New estimates U.S. Environmental Protection Agency

Recently, the U.S. Environmental Protection Agency (EPA) has re-estimated the GHG emissions from the petroleum and natural gas industry. It’s earlier estimations were from 1996. At that stage methane emissions were not considered to be so powerful at warming the atmosphere. In its new study, published in November 2010, the EPA found that CH4-emissions had been significantly underestimated. In its new estimate, the U.S. petroleum and natural gas industry emitted 317 million tonnes of greenhouse gases (measured in CO2 equivalents) in 2006. This is a 57% increase compared to the outdated calculation method. Of the total 317 million tonnes, the natural gas industry accounted for 261 million tonnes CH4 (measured in CO2 equivalents). The EPA had revised four emission sources that were believed to be significantly underestimated: well venting for liquids unloading; gas well venting during well completions; gas well venting during well workovers; centrifugal compressor wet seal degassing venting.

The EPA also made a distinction between the GHG emissions of conventional gas wells and unconventional gas wells. For unconventional wells, it estimated that the emission factors for venting during well completions and well workovers exceed emission factors of conventional wells by a factor 200. It was assumed that all unconventional wells were completed with hydraulic fracturing of tight sand, shale or coal bed methane formations. The water that is returning to the surface is accompanied by large quantities of methane. This is the main cause of the greater methane emissions than conventional wells.

Study Cornell University

In a study published in the journal Climatic Change, the Cornell University in New York assesses the likely GHG footprint of natural gas in comparison to coal.208 The study builds, among other, upon the recent findings of the EPA. The study acknowledges that natural gas produces less greenhouse gas emissions than coal when burned. However, the authors also take into account the GHG emissions that occur during the production of coal and natural gas. This lifecycle approach of GHG emissions from coal and natural gas presents a different picture. The authors compare the lifecycle GHG emissions of shale gas, conventional natural gas (both with low and high estimates for methane emissions to the atmosphere), coal from surface mines, coal from deep mines and diesel oil.

Largely based upon the recent EPA-study, the authors estimate that 3.6% to 7.9% of the methane from shale gas production escapes to the atmosphere through venting and leaks. This is 1.3 to 2.1 times more than from conventional gas operations. The higher emissions from shale gas occur when wells are hydraulically fractured – as methane escapes from flowback return fluids – and during drill out following the fracturing.

Calculated on the basis of a 20-year horizon, the authors conclude that the lifecycle GHG emissions of shale gas are at least 20% greater than the lifecycle GHG emissions of coal. For conventional natural gas, the emissions of coal fall between the high and low estimate.

The 20-year approach by the authors reflects the need to mitigate climate change in the near- term. As methane is known to have a relative short lifetime in the atmosphere, it especially causes climate change on a short-term. The authors also calculated the lifecycle GHG emissions for a 100-year horizon. Over the 100-year frame, the GHG footprint is comparable to that for coal: the low-end shale-gas emissions are 18% lower than deep-mined coal, and the high-end shale-gas emissions are 15% greater than surface-mined coal emissions.

As for Shell, it is not known how many GHG emissions it releases in the air due to venting and leaking CH4. The company promotes natural gas (including unconventional gas) as a replacement for coal. Natural gas is seen by Shell as a bridge to a low-carbon energy future, something for the near-term. However, for unconventional gas the opposite seems true: the GHG emissions increase compared to coal in the near-term.

A further extract from this section of the report will be published in the coming days.

THE COMPLETE 73 PAGE REPORT (with reference sources)