THE SHELL LEAKS FILES: 26 AUGUST 2026
SLF-2007-038
The Sakhalin Papers XXVIII: The Financing That Never Arrived — ECGD, EBRD and the Environmental Test That Outlived the Loan
Britain considered roughly $650 million of public-backed support. The EBRD spent years assessing a Phase 2 loan. Neither financing package was ultimately issued — but the scrutiny they generated left behind one of the richest independent records of Sakhalin II.
Archive reference: SLF-2007-038
Collection: The Sakhalin Papers
Principal record: European Bank for Reconstruction and Development Independent Recourse Mechanism record, updated 17 January 2007; Export Credits Guarantee Department letter to Sakhalin Energy, 4 March 2004; National Audit Office case study on Sakhalin Phase II; Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin)
Supporting record: ECGD Annual Review and Resource Accounts 2007–08; House of Commons and Hansard material; contemporaneous reporting on the Gazprom restructuring; Shell regulatory filings; Japan Bank for International Cooperation financing announcement of 16 June 2008
Evidence standard: This instalment distinguishes a conditional indication of support from a final guarantee; an environmental due-diligence process from an environmental liability finding; EBRD’s withdrawal from the then-current financing proposal because of the ownership restructuring from rejection on environmental grounds; and Sakhalin Energy’s later withdrawal of its ECGD application from a refusal by the British Government.
Introduction
For years, some of the most important environmental scrutiny surrounding Sakhalin II was conducted by institutions that ultimately did not finance the project.
The European Bank for Reconstruction and Development had been considering a Phase 2 financing package of about $600 million. Britain’s Export Credits Guarantee Department was considering approximately $650 million of support connected with UK supplies and services. The broader contemplated financing structure also included Japanese and US export-credit support, commercial lending and shareholder equity. (UK Parliament)
Neither the EBRD Phase 2 package nor the British ECGD guarantee ultimately materialised.
Yet the process generated:
environmental impact reviews;
independent monitoring;
the HSES Action Plan;
more than 2,000 project commitments;
Western Gray Whale safeguards;
the Remedial Action Plan;
Freedom of Information and Environmental Information Regulations disputes;
an Information Tribunal ruling;
a High Court judgment;
Parliamentary scrutiny;
and a permanent documentary trail.
The money disappeared from the story.
The evidence did not.
1. An Important Qualification: EBRD Had Financed Sakhalin II Before
The headline requires precision.
It would be wrong to say that the EBRD never financed Sakhalin II at all.
The Bank’s own project record shows earlier participation in Phase 1, including a senior loan of approximately $116 million, with co-financing from the US Overseas Private Investment Corporation and Japan Export-Import Bank. (EBRD)
The financing that did not arrive was the later Phase 2 package.
That distinction matters because EBRD was not an outsider arriving late to a project it knew nothing about.
It had a prior lending relationship with Sakhalin Energy and had already established environmental-monitoring expectations around the development. (EBRD)
2. Phase 2 Put the Bank Through Years of Environmental Scrutiny
The EBRD spent roughly five years considering the later Sakhalin II financing proposal.
The process became controversial enough to activate the Bank’s Independent Recourse Mechanism.
In July 2005, a complaint concerning disruption to fishing was registered. The EBRD’s eligibility assessor recommended that the complaint could proceed toward a problem-solving initiative, although not toward a full compliance review. (EBRD)
That procedural distinction is important.
The EBRD had not found that the Bank itself had violated its environmental policy.
It had found that the complaint was suitable for a problem-solving mechanism.
3. December 2005: “Fit for the Purpose of Consultation”
On 14 December 2005, EBRD decided that the Sakhalin II documentation was:
“fit for the purpose of consultation.” (EBRD)
That phrase has sometimes been interpreted too broadly.
It did not mean:
the loan had been approved;
the project had passed every environmental test;
all Western Gray Whale concerns had been resolved;
or every pipeline problem had disappeared.
It meant the documentation had reached the stage at which the formal public consultation process could proceed.
The EBRD’s own accountability record preserves that chronology explicitly.
4. The Financing Process Was Generating Its Own Accountability Record
The EBRD complaint continued alongside commercial discussions.
The Bank’s record shows settlement negotiations between Sakhalin Energy and affected fishing businesses during 2005 and 2006.
One negotiated settlement was reached in March 2006, while discussions continued with other affected parties. (EBRD)
This is worth recording because the lender process was already doing more than asking whether Sakhalin Energy could repay debt.
It had become part of the environmental and social accountability structure surrounding the project.
5. Then the Ownership of Sakhalin II Changed
During 2006, Sakhalin II entered its extraordinary confrontation with the Russian state.
Russian environmental authorities intensified enforcement activity.
Costs had doubled.
Gazprom wanted entry into the project.
And contemporary reporting described Shell as being subjected to intense administrative and regulatory pressure while negotiations over control proceeded. (The Guardian)
The eventual commercial agreement was formalised through a protocol dated 21 December 2006 and completed on 18 April 2007.
Gazprom acquired 50 per cent plus one share for $7.45 billion. Shell’s interest fell from 55 per cent to 27.5 per cent, while Mitsui and Mitsubishi also reduced their holdings. (London South East)
The House of Commons Foreign Affairs Committee later described Shell as having agreed under administrative pressure to sell Gazprom a controlling stake. (UK Parliament)
6. 11 January 2007: EBRD Stops the Existing Phase 2 Financing Process
The ownership restructuring had an immediate financing consequence.
On 11 January 2007, the EBRD decided that it would no longer finance Sakhalin II under the proposal it had been considering.
Its own Independent Recourse Mechanism record states the reason succinctly:
the change in ownership of Sakhalin Energy.
A contemporaneous copy of the EBRD press release explains the logic more fully.
The change in shareholders and financing structure constituted a material change to the project under consideration. EBRD said it was no longer feasible to continue with the existing financing package, although it left open the possibility that the newly structured company might seek EBRD involvement in future. (国際環境NGO FoE Japan)
7. This Was Not an EBRD Environmental Rejection
That distinction is essential.
Environmental organisations had spent years urging the EBRD not to finance Sakhalin II.
They raised serious arguments concerning whales, fisheries, rivers, indigenous communities and the adequacy of project safeguards.
But the documentary record does not show that the EBRD’s January 2007 decision was a final ruling that Sakhalin II had failed the Bank’s environmental standards.
The EBRD record gives the reason as the ownership change.
Accordingly, the archive should not state:
EBRD rejected Sakhalin II because Shell failed its environmental test.
That is not what the authenticated EBRD record says.
8. The Bank’s Complaint Mechanism Closed With the Financing
The ownership decision also affected the fishing complaint.
On 17 January 2007, the complainants were told that because EBRD was no longer financing the project, the Bank’s Independent Recourse Mechanism no longer had jurisdiction to continue processing the complaint.
The record nevertheless expressly left open the possibility of reinstatement if EBRD later decided to finance Sakhalin II.
Again, procedure followed finance.
When the Bank stepped away, its formal accountability jurisdiction stepped away with it.
9. Britain Did Not Step Away
The British Export Credits Guarantee Department followed a different course.
Sakhalin Energy had approached ECGD in 2003 seeking support for a prospective loan of approximately $650 millionconnected with UK goods and services.
The National Audit Office later identified UK suppliers including AMEC, Parsons and Rolls-Royce in describing the case. (UK Parliament)
ECGD classified Sakhalin II as both potentially sensitive and a project with high potential environmental impact.
Its Business Principles Unit worked with other export-credit agencies and financial institutions to assess whether the project met international standards. (UK Parliament)
10. ECGD Found the Project Did Not Yet Meet All Relevant Standards
The National Audit Office’s retrospective case study is unusually useful.
It says the financing institutions concluded that Sakhalin II did not fully meet some relevant World Bank Group guidelines, but believed there was scope for Sakhalin Energy to take action to bring the project into line. (UK Parliament)
This is a much more precise historical statement than saying either:
Britain approved Sakhalin II environmentally.
or:
Britain rejected Sakhalin II environmentally.
Neither happened at that stage.
ECGD chose what it called constructive engagement.
11. The 4 March 2004 Letter: Conditional Support Was Real
An actual ECGD letter survives.
It is dated 4 March 2004 and addressed to Sakhalin Energy Investment Company.
The letter says ECGD was able to support specified preliminary contracts subject to conditions.
Among those conditions were ECGD’s satisfaction with measures proposed or taken to identify and mitigate adverse environmental and social effects, acceptable project financing arrangements, further applications concerning individual contracts and any additional due diligence ECGD considered necessary.
The letter also required continuing disclosure of material information concerning the project and its financing.
That is stronger than an informal expression of interest.
But it was still conditional.
12. Conditional Support Was Not a Final $650 Million Guarantee
This distinction subsequently became contentious.
Environmental groups argued that ECGD’s 2004 commitment had substantive legal and practical significance and challenged the timing of the decision.
ECGD continued to maintain that it had not taken the final substantive decision to issue the guarantee. (UK Parliament)
The later official records support the narrower formulation.
The National Audit Office says that by early 2008, ECGD had still not made a substantive decision whether to issue the guarantee. (UK Parliament)
ECGD’s own 2007–08 Annual Review says the same thing: the project company withdrew before ECGD made the substantive decision.
So both facts belong in the archive.
A conditional support commitment existed.
A final guarantee did not.
13. The Conditional Process Had an Environmental Effect
Although the British money was not eventually issued, the financing institutions continued engaging with Sakhalin Energy.
The NAO records that this process contributed to the much more comprehensive environmental and social documentation published in late 2005.
The resulting HSES Action Plan contained more than 2,000 commitments, and AEA Technology monitored the project on behalf of the financial institutions. (UK Parliament)
The lender process also contributed to expert intervention over the Western Gray Whale and to rerouting an offshore pipeline away from feeding grounds. (UK Parliament)
Later, as the previous instalment documented, monitoring of the onshore pipelines led into the August 2007 Remedial Action Plan.
The financing decision remained unresolved.
The environmental governance machinery was already operating.
14. The British Government Had Been Consulting Internally Since 2003
There was another side to the ECGD process.
Because Sakhalin II was considered particularly sensitive, ECGD sought comments from other government departments.
The later High Court judgment records that on 28 February 2003, ECGD contacted DEFRA, DFID, DTI, the Foreign Office, the Ministry of Defence and Trade Partners UK.
Responses were received from the Foreign Office, DEFRA and DTI. (vLex)
Those internal responses would eventually become the subject of a separate battle.
Not over whether to build the pipeline.
Over whether the public was entitled to know what Whitehall itself had said about it.
15. Friends of the Earth Asked to See the Government Advice
On 11 March 2005, Friends of the Earth requested the interdepartmental correspondence under the Environmental Information Regulations.
ECGD released its own request for departmental views but refused to disclose the responses, relying on the exemption covering internal governmental communications. (vLex)
Friends of the Earth challenged that refusal.
The Information Commissioner initially sided with ECGD in September 2006.
Friends of the Earth appealed to the Information Tribunal. (vLex)
16. August 2007: The Information Tribunal Orders Disclosure
On 20 August 2007, the Information Tribunal allowed the appeal.
It concluded that ECGD had not demonstrated a sufficiently strong public interest in withholding the departmental responses to outweigh the public interest in disclosure. (vLex)
This finding needs to be kept within its legal boundary.
The Tribunal was not deciding:
whether Shell had damaged the environment;
whether the whale population would decline;
whether Russian regulators were right;
or whether ECGD should ultimately finance Sakhalin II.
It was deciding whether government environmental information should be disclosed.
17. ECGD Appealed to the High Court
ECGD did not accept the Tribunal ruling.
The matter proceeded to the Administrative Court as:
Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin).
Mr Justice Mitting heard the appeal.
The judgment provides unusually authoritative background.
It records Shell’s original majority position, Gazprom’s later participation, the approximately $650 million support sought and the potentially grave environmental significance of Sakhalin II for the Western Gray Whale. (vLex)
But once again, those observations supplied context to a transparency case.
They were not findings of environmental liability.
18. The Financing Application Died Before the Court Ruled
Then came an extraordinary chronological twist.
The High Court judgment records that on 29 February 2008, Sakhalin Energy withdrew the ECGD application.
No final British financing decision would therefore ever be made. (vLex)
The High Court judgment followed on 17 March 2008.
The financing issue was already dead.
The information dispute was not.
19. The High Court Dismissed ECGD’s Appeal
Mr Justice Mitting ultimately declined to disturb the Tribunal’s decision.
The appeal was dismissed and the order requiring disclosure remained in place. (CaseMine)
The legal result is important but narrow.
The court confirmed that the public-interest balancing exercise concerning environmental information had been lawfully resolved in favour of disclosure.
It did not hold that ECGD had acted unlawfully by contemplating financial support for Sakhalin II.
It did not hold that Shell had violated environmental law.
And it did not decide the merits of the wider allegations surrounding Sakhalin Energy.
20. ECGD’s Own Annual Report Confirms How Much Work the Case Consumed
The British Government’s official accounting record gives another revealing perspective.
ECGD’s 2007–08 Annual Review says its Management Board spent considerable time examining the developing evidence concerning Sakhalin II’s environmental and social impacts.
It records that Sakhalin Energy withdrew its application before ECGD made the substantive support decision.
The Export Guarantees Advisory Council went further.
Its annual report said the work of ECGD’s Business Principles Unit had been dominated during the year by the need to develop advice on Sakhalin II. (GOV.UK Assets)
This is striking institutional evidence.
A guarantee that was never issued nevertheless consumed a major share of the specialist environmental-policy work inside Britain’s export-credit agency.
21. Britain Still Had Significant Environmental Concerns in Early 2008
Only weeks before the withdrawal, the question remained open.
In January 2008, Trade and Investment Minister Malcolm Wicks told Parliament that ECGD had received submissions concerning Sakhalin II’s environmental impacts and would consider financial, technical and environmental factors before deciding whether to support the project. (UK Parliament)
In later evidence to the Environmental Audit Committee, Wicks said ECGD had significant concerns about aspects of Sakhalin II, particularly its environmental impacts, but that the assessment was never completed because the application was withdrawn. (UK Parliament)
That is probably the safest official summary.
Concern existed.
A final judgment did not.
22. A Separate Judicial Review Challenge Also Fell Away
WWF and The Corner House had launched a different judicial-review challenge concerning ECGD’s earlier conditional support and environmental-assessment process.
When Sakhalin Energy withdrew its application on 29 February 2008, those organisations decided not to proceed with that case. (UK Parliament)
Their later evidence to Parliament continued to criticise ECGD’s handling of the matter.
Those criticisms form part of the historical record.
But because the case was abandoned after the financing application disappeared, the court never adjudicated those particular arguments.
They therefore remain claims made by the campaigning organisations, not judicial findings.
23. EBRD Did Not Finance Phase 2. ECGD Did Not Finance It Either.
By March 2008, two major Western public-finance routes had therefore disappeared.
The EBRD had stopped considering its existing Phase 2 package after the ownership restructuring.
The UK ECGD process ended when Sakhalin Energy withdrew its application before a substantive guarantee decision.
It is tempting to compress that history into:
Western banks rejected Sakhalin II.
The documents do not justify that formulation.
The EBRD decision arose from a material ownership and financing restructuring.
The ECGD process ended through sponsor withdrawal.
Environmental concerns were substantial in both histories.
But neither documentary sequence records the simple final verdict:
Rejected for environmental reasons.
24. The Project Was Not Left Without Finance
There is an equally important correction to the headline.
The disappearance of EBRD and ECGD support did not leave Sakhalin II unable to raise project finance.
On 16 June 2008, the Japan Bank for International Cooperation signed a financing agreement providing up to $3.7 billion.
A consortium of commercial banks supplied another $1.6 billion.
Total project finance: $5.3 billion. (JBIC)
Shell’s subsequent regulatory filing records the same financing package and its 27.5 per cent interest in Sakhalin Energy.
The financing had not vanished.
Its composition had changed.
25. Japan’s Decision Had Its Own Strategic Logic
JBIC’s official announcement makes the rationale clear.
Japan viewed Sakhalin II as important to diversification of energy supply and energy security.
More than half of the planned LNG output was expected to go to Japan, with the project geographically close to the Japanese market. (JBIC)
That underscores another historical point.
Different public financial institutions were balancing different mandates.
The EBRD had a transition-development mandate.
ECGD existed to support UK exports while applying its business and environmental policies.
JBIC was heavily concerned with Japanese energy security and overseas resource supply.
It should not be assumed that one institution’s withdrawal required the others to reach the same result.
26. The Environmental Test Outlived the Proposed British Loan
This is the central documentary paradox.
ECGD never issued the guarantee.
But the standards against which it and the other prospective lenders assessed the project had already affected Sakhalin II.
The expanded environmental documentation remained.
The HSESAP remained.
The independent monitoring remained.
The whale-panel recommendations remained.
The onshore-pipeline compliance findings remained.
The Remedial Action Plan remained.
The Information Tribunal decision remained.
The High Court judgment remained.
And the departmental correspondence eventually had to emerge.
A financing process that produced no British guarantee nevertheless generated evidence that historians can still use nearly two decades later. (UK Parliament)
Documentary Findings
Established
Sakhalin Energy sought approximately $650 million of ECGD-backed support in connection with UK goods and services for Sakhalin II Phase 2. The contemplated Phase 2 financing structure also included approximately $600 million from EBRD, Japanese and US export-credit support and commercial lending. (UK Parliament)
ECGD issued a conditional support letter on 4 March 2004 covering preliminary contracts and imposing environmental, financing, disclosure and due-diligence conditions.
The EBRD declared Sakhalin II documentation fit for public consultation in December 2005. That was not final loan approval. (EBRD)
On 11 January 2007, EBRD decided not to pursue the then-current Phase 2 financing because the ownership of Sakhalin Energy had materially changed.
Gazprom’s acquisition of 50 per cent plus one share was completed in April 2007, reducing Shell’s interest to 27.5 per cent. (London South East)
Friends of the Earth sought disclosure of UK interdepartmental advice concerning Sakhalin II. The Information Tribunal ordered disclosure in August 2007. (vLex)
Sakhalin Energy withdrew its ECGD application on 29 February 2008, before ECGD had made a substantive guarantee decision. (vLex)
On 17 March 2008, the High Court dismissed ECGD’s appeal against the Information Tribunal disclosure ruling. (CaseMine)
In June 2008, JBIC and commercial banks subsequently supplied $5.3 billion in Phase 2 project finance. (JBIC)
Established with important qualification
Environmental concerns materially affected both EBRD and ECGD scrutiny.
The NAO records that Sakhalin II did not initially meet some relevant World Bank Group guidelines and that the financial institutions pursued improvements through continuing engagement. (UK Parliament)
The financing process contributed to detailed environmental commitments, independent monitoring and corrective programmes.
But the EBRD’s January 2007 Phase 2 financing decision was formally attributed to the ownership restructuring, not to a final environmental rejection.
Similarly, ECGD retained significant environmental concerns but never completed its final assessment because Sakhalin Energy withdrew the application. (UK Parliament)
Not established
It is not established that EBRD rejected Sakhalin II Phase 2 because the project failed its environmental standards.
It is not established that ECGD rejected Sakhalin II.
It is not established that the withdrawal of the ECGD application constituted an admission that Sakhalin Energy could not satisfy environmental requirements.
It is not established that the High Court ruled Shell had damaged the environment.
It is not established that the Information Tribunal or High Court adjudicated the Russian environmental allegations.
It is not established that WWF and The Corner House’s separate judicial-review allegations were judicially proved; that case was not pursued after the financing application was withdrawn.
And it is plainly incorrect to suggest that Sakhalin II Phase 2 ultimately received no project financing at all: $5.3 billion of JBIC and commercial-bank finance was signed in June 2008. (JBIC)
Commentary
There is something deeply instructive about a loan that never happened.
Normally, finance disappears from history when the cheque is not written.
Sakhalin II did the opposite.
The possibility of public money attracted scrutiny.
Scrutiny demanded documentation.
Documentation produced commitments.
Commitments produced monitoring.
Monitoring produced evidence of non-compliance.
Non-compliance produced remediation.
And attempts to keep part of the governmental assessment confidential produced litigation.
The result is an unusual inversion.
The British taxpayer never ultimately guaranteed the Sakhalin II financing under consideration.
Yet the consideration of that guarantee helped create records of enduring public value.
The EBRD story is equally revealing.
It would be convenient for critics to say that the Bank studied Shell’s environmental record for five years and finally rejected the project.
The authenticated EBRD record does not permit that claim.
The financing package was discontinued because the ownership and financing structure had materially changed after Gazprom’s entry.
That fact should be preserved even though environmental controversy formed a major part of the preceding due-diligence history.
Likewise, it would be convenient for Shell’s defenders to point out that ECGD never rejected the project and stop there.
That too would be incomplete.
ECGD’s own records show that Sakhalin II occupied extraordinary amounts of official attention.
The project was classified as high-impact.
Some relevant international standards were initially not met.
The Business Principles Unit spent years assessing it.
The Management Board examined the developing environmental evidence.
A minister later acknowledged significant environmental concerns.
The application disappeared before the Department had to pronounce a final verdict.
The truth is therefore less dramatic and more interesting.
EBRD did not issue the proposed Phase 2 loan.
ECGD did not issue the proposed guarantee.
Neither institution made the environmental rejection that is sometimes implied.
Both helped generate environmental scrutiny that changed the project and survived the financing process itself.
And when Sakhalin Energy no longer wanted British support, the British court was still deciding what the British public was entitled to know.
The finance could be withdrawn.
The documentary record could not.
Source Record
The principal EBRD record is the Independent Recourse Mechanism Sakhalin II file, Request 2005/01, updated 17 January 2007. It records the July 2005 fishing complaint, the December 2005 decision that project documentation was fit for consultation, the subsequent settlement process and the Bank’s 11 January 2007 decision not to finance the project under the existing proposal because of Sakhalin Energy’s ownership change. (EBRD)
The principal British contractual record is ECGD’s 4 March 2004 letter to Sakhalin Energy Investment Company, later released following an information request. The document confirms conditional support for specified preliminary contracts subject to environmental, financial, due-diligence and disclosure requirements.
The principal institutional retrospective is the National Audit Office briefing on ECGD and sustainability, whose Sakhalin Phase II case study reconstructs the financing structure, the $650 million ECGD application, the initial standards gap, subsequent HSESAP commitments, lender monitoring, the 2007 Remedial Action Plan and the withdrawal of the application before a substantive ECGD decision. (UK Parliament)
ECGD’s own Annual Review and Resource Accounts 2007–08 confirms that the Department’s Management Board considered the developing environmental and social evidence and that Sakhalin Energy withdrew before a substantive support decision. The Export Guarantees Advisory Council recorded that Sakhalin II had dominated much of the Business Principles Unit’s work.
The principal judicial record is Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin). It reconstructs the 2003 interdepartmental consultation, the environmental-information request, ECGD’s refusal, the Information Commissioner’s initial decision, the Information Tribunal’s disclosure order, the 29 February 2008 withdrawal of the financing application and the subsequent High Court appeal. (vLex)
The ownership transition is independently recorded in Shell-related regulatory material and the April 2007 corporate announcement implementing the December 2006 protocol under which Gazprom acquired 50 per cent plus one share and Shell’s stake fell to 27.5 per cent. (London South East)
Contemporaneous British reporting documents the regulatory and political pressure surrounding the 2006 negotiations with Gazprom. The later House of Commons Foreign Affairs Committee also described the disposal of control as having occurred under administrative pressure. (The Guardian)
The subsequent financing record is supplied by the Japan Bank for International Cooperation, which announced on 16 June 2008 that it would provide up to $3.7 billion alongside $1.6 billion from commercial banks. Shell’s subsequent US regulatory filing records the same $5.3 billion package. (JBIC)
Archive disclaimer: The withdrawal or non-issuance of a proposed financing package does not by itself establish environmental non-compliance or wrongdoing. EBRD’s January 2007 decision concerned the material change in Sakhalin Energy’s ownership and financing structure. ECGD never completed its substantive decision because Sakhalin Energy withdrew the application. The 2008 High Court judgment concerned access to environmental information, not Shell’s environmental liability or the truth of individual Sakhalin II allegations.
Site wide disclaimer also applies.
Next Archive File
SLF-2007-039 — The Sakhalin Papers XXIX: The Hidden Whitehall Warning — What DEFRA Told ECGD About Shell’s Sakhalin II Project
The financing dispute produced one further documentary trail.
In February 2003, ECGD quietly asked Whitehall departments what they thought about possible British support for Sakhalin II.
Three departments replied.
The Foreign Office.
The Department of Trade and Industry.
And DEFRA.
For years, those responses remained out of public view.
Friends of the Earth asked for them.
ECGD refused.
The Information Commissioner initially agreed with ECGD.
The Information Tribunal reversed that decision.
ECGD appealed.
The High Court dismissed the appeal.
Only then did the departmental advice have to emerge. (vLex)
What the documents revealed was not a single government view.
One department concentrated on Britain’s strategic relationship with Russia.
Another raised a stark warning about the possible environmental consequences, including the endangered Western Gray Whale.
And that raises the next documentary question:
What did Whitehall actually tell ECGD about Shell’s Sakhalin II project before conditional British support was offered — and how much weight did those warnings receive?
SLF-2007-039 will reconstruct the hidden interdepartmental correspondence, distinguish each department’s position, and follow the three-year battle that finally forced the advice into the open.
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