THE SHELL LEAKS FILES: 26 SEPTEMBER 2026
SLF-2007-069
The Sakhalin Papers LIX: The 120-Day Test — When Shell’s $20 Billion Project Was Put Out for Public Judgment
In December 2005, the European Bank for Reconstruction and Development decided that Sakhalin II’s environmental and social documentation was sufficiently developed to enter formal public consultation. That was not project approval and it was not a loan decision. During the following 120 days, critics challenged the project in London, Moscow, Sakhalin and Hokkaido over whales, salmon rivers, seismic risk, oil-spill preparedness and consultation itself. Sakhalin Energy maintained that it was complying with Russian law and improving its environmental controls. Then, before the financing question could be resolved, the argument changed character. Russian regulators moved against a crucial environmental approval, Gazprom was seeking entry into the project, and EBRD said the resulting legal uncertainty prevented it from progressing its financing decision.
Archive reference: SLF-2007-069
Collection: The Sakhalin Papers
Principal institutional record: European Bank for Reconstruction and Development Sakhalin II records and Independent Recourse Mechanism file
Authenticated corporate record: The Shell Sustainability Report 2006
Contemporaneous reporting: AFP, Oil & Gas Journal, RIA Novosti, The Guardian, El País
Campaign submissions: WWF, Friends of the Earth, The Corner House and Friends of the Earth Japan
Later judicial context: Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin)
Evidence standard: EBRD determinations are distinguished from campaign-group interpretations of them. Sakhalin Energy statements are attributed to the company. Russian environmental allegations are distinguished from contemporaneous claims that regulatory action was being used to influence Gazprom’s entry into the project. No court identified in this file determined that the 2006 Russian enforcement campaign was either fabricated or politically motivated.
Introduction
The previous file ended with an audit.
This one begins with a public examination.
By December 2005, prospective lenders had been examining Sakhalin II for years. The project had already accumulated controversy over western gray whales, salmon rivers, pipeline construction, oil-spill preparedness and contractor performance.
Yet construction continued.
The project cost had doubled to approximately $20 billion.
And Shell remained the 55 per cent shareholder in Sakhalin Energy. Shell News
The European Bank for Reconstruction and Development now faced a question.
Was the project ready to move from technical assessment into the final stage of public scrutiny before a financing decision?
Its answer was:
Yes — but only for consultation.
1. “Fit for the purpose of consultation” did not mean approved
On 14 December 2005, EBRD decided that Sakhalin II’s environmental and social documentation was:
“fit for the purpose of consultation.”
Its Independent Recourse Mechanism record preserves that date and decision. EBRD
Contemporaneous Oil & Gas Journal reporting explained the practical consequence: the determination opened a 120-day period of public disclosure and consultation concerning environmental, social, health and safety issues and proposed mitigation measures. Shell News
That phrase has to be handled carefully.
It did not mean the project had passed every environmental test.
It did not mean EBRD had approved financing.
And it did not mean all earlier deficiencies had disappeared.
It meant the documentation had reached the point at which the Bank considered public consultation capable of proceeding.
2. EBRD itself had already identified procedural shortcomings
The environmental organisations later relied heavily upon wording from EBRD’s own December 2005 press release.
Their April 2006 submission to the UK Export Credits Guarantee Department reproduced EBRD’s acknowledgment that procedures prescribed in its Environmental Policy:
“were not fully followed in the planning phases”
in relation to important aspects of Sakhalin II.
The same submission quoted EBRD as saying that the decision-making process for the siting of an oil-production platform had not been in conformity with the Bank’s policy. WWF Europe
That evidence requires a qualification.
The wording is preserved in a contemporaneous campaigning submission citing the EBRD press release; the original release is no longer readily retrievable through the Bank’s current website.
But it materially changes the historical picture.
The consultation did not begin because EBRD had concluded that nothing was wrong.
It began despite the Bank having identified planning-stage shortcomings which it believed subsequent documentation had addressed sufficiently to permit consultation. WWF Europe
3. London heard the first arguments
By March 2006, consultation had already taken place in London.
A later submission by WWF, Friends of the Earth and The Corner House records that critics supplied the London meeting with a list of approximately 100 press articles concerning Sakhalin II and its environmental and governance controversies. WWF Europe
The significance was not the number itself.
The consultation was becoming a forum in which prospective lenders were being asked to assess not simply an engineering project, but the credibility of Shell and Sakhalin Energy’s environmental management.
That was precisely what the 120-day procedure was designed to expose to challenge.
4. Moscow produced six hours of opposition
In March, the consultation moved to Moscow.
AFP reported that lawyers, environmentalists, geologists and community representatives spent approximately six hoursarguing that Sakhalin II should not receive EBRD financing.
Their objections included western gray whale risks, salmon spawning rivers, seismic instability and alleged breaches of Russian law. Royal Dutch Shell Group .com
Those were allegations made by project opponents.
Sakhalin Energy did not accept them.
A company representative responded that while opponents were entitled to pursue legal challenges, the company was confident that it would be found to be complying with the law. Royal Dutch Shell Group .com
That exchange captures the 120-day process in miniature.
The critics were not merely demanding mitigation.
Some were saying the project should not qualify for EBRD support at all.
Sakhalin Energy was saying the project remained lawful and manageable.
5. The consultation extended beyond Russia
The Moscow report said consultation had already occurred in London and would continue on Sakhalin and in Hokkaido, Japan. Royal Dutch Shell Group .com
Hokkaido was especially significant because Sakhalin lies only tens of kilometres from northern Japan and a major marine spill could have transboundary consequences.
Friends of the Earth Japan records an EBRD consultation meeting in Hokkaido on 10 April 2006. 国際環境NGO FoE Japan
The organisation strongly criticised how that meeting had been conducted and argued that local concerns had not been given sufficient weight.
That was FoE Japan’s assessment of the consultation process, not an EBRD finding.
But the fact that Hokkaido was included at all demonstrates that Sakhalin II’s environmental risk was no longer treated as exclusively Russian.
6. Oil-spill planning remained one of the hardest questions
WWF’s February 2006 submission argued that Sakhalin Energy still lacked an adequate comprehensive response plan for a major spill under winter sea-ice conditions.
It maintained that conventional response techniques such as booms could be severely constrained by ice and that dispersant use raised separate ecological concerns. Royal Dutch Shell Plc .com
Those were WWF’s assertions.
They should not be converted into a finding that no spill plan existed.
As earlier files have documented, lender records show that Sakhalin Energy had produced contingency plans and that EBRD experts had reviewed oil-spill arrangements during Phase I. EBRD
The dispute was therefore more precise:
not whether Sakhalin Energy had any oil-spill planning,
but whether the planning was adequate for the scale, remoteness and winter conditions of Sakhalin II.
7. The whale issue had not gone away either
WWF continued to argue during the consultation that the protections for the western gray whale were insufficient.
The organisation said independent whale specialists remained unconvinced that the project could proceed without significant risk to a population then estimated at roughly one hundred animals. Royal Dutch Shell Plc .com
Shell’s later 2006 Sustainability Report presents the company side.
It says Sakhalin Energy had rerouted the offshore pipeline approximately 20 kilometres farther from the whales’ feeding grounds, imposed vessel controls and acoustic monitoring, and helped establish a long-term scientific advisory panel convened by the World Conservation Union, now IUCN. Shell
Both facts belong in the archive.
Scientific criticism continued.
Mitigation measures also changed.
8. The salmon rivers provided Shell with an uncomfortable admission
The pipeline crossed approximately 180 sensitive salmon rivers.
Shell’s own 2006 Sustainability Report records that some contractors had failed to follow required low-impact crossing techniques during the winter of 2004–05.
Sakhalin Energy stopped work, strengthened controls, sought outside expertise and brought in independent observers and environmental-agency representatives to monitor subsequent crossings. Shell
Shell also acknowledged that some rivers experienced more sedimentation than planned, while maintaining that the likely effects on spawning habitat were limited and temporary. Shell
This was therefore not an argument in which Shell simply denied every environmental problem.
Its own reporting acknowledged failures and remedial measures.
The dispute was over their seriousness and whether remediation was sufficient.
9. The project was already being built while the public was being consulted
This was one of the fundamental tensions.
Environmental organisations argued that meaningful consultation was difficult when construction was already far advanced.
By April 2006, WWF and its partners described the project as already roughly two-thirds constructed. WWF Europe
That matters because consultation normally implies the possibility of changing what is proposed.
But substantial infrastructure, pipelines and offshore facilities were already committed.
The consultation therefore operated partly as an examination of mitigation for decisions already taken.
That was one reason opponents questioned whether the process could genuinely influence the project.
10. 21 April 2006: the consultation period closes
WWF recorded 21 April 2006 as the closing date of EBRD’s consultation.
Its final submission again urged the Bank not to finance Sakhalin II without stronger environmental safeguards, particularly concerning the western gray whales. Royal Dutch Shell Plc .com
At this point the next expected step was relatively straightforward.
EBRD would digest the submissions.
Its technical and environmental teams would continue their work.
And eventually the Bank’s board would decide whether to lend.
But Sakhalin II was about to stop behaving like an ordinary project-finance case.
11. There was already another negotiation in the background
While EBRD was conducting its environmental consultation, Shell was separately negotiating with Gazprom.
Contemporaneous reporting records that Shell had signed a memorandum of understanding under which Gazprom was expected to obtain 25 per cent of Sakhalin Energy in exchange for Shell receiving an interest in a major Siberian gas field. Royal Dutch Shell Group .com
The prospective transaction was commercial.
But it placed the Russian state-controlled gas champion directly beside the environmental financing process.
And another problem was developing.
Sakhalin II’s cost estimate had doubled.
12. The $10 billion project became a $20 billion project
The cost escalation was enormous.
Contemporaneous reporting records Sakhalin II’s projected cost increasing from roughly $10 billion to $20 billion. Shell News
That increase affected more than Shell’s shareholders.
Under the production-sharing agreement, development costs were recoverable from project revenues before Russia received some of the profits it expected.
The cost revision therefore had implications for the Russian state.
It also disrupted the commercial logic of the contemplated Gazprom asset swap.
Contemporaneous reporting described Gazprom as dissatisfied that the economic basis of the earlier arrangement had changed. El País
Environmental controversy and commercial negotiation were now moving toward each other.
13. September 2006: the regulatory confrontation erupts
In September, Russia’s Ministry of Natural Resources moved against a crucial environmental approval for Sakhalin II.
RIA Novosti reported that the Ministry annulled the project’s Sakhalin Environmental Expert Review, originally approved in 2003, citing environmental concerns including landslide risks around pipeline construction. Royal Dutch Shell Plc .com
The action threatened substantial delays.
A Sakhalin Energy executive warned publicly that withdrawal of the approval could delay the project by 17 months and put thousands of jobs at risk. Royal Dutch Shell Group .com
This was no longer a lender asking questions.
It was the Russian state exercising regulatory power over a project already deep into construction.
14. Were the environmental objections genuine — or leverage?
This is where the documentary record must resist a tempting simplification.
Environmental concerns surrounding Sakhalin II were real and long pre-dated the 2006 ownership dispute.
EBRD, independent scientists, environmental groups and even Shell’s own reports had documented problems concerning river crossings, whales, spills and contractor compliance.
It would therefore be inaccurate to dismiss every Russian environmental complaint as invented.
But contemporaneous observers also interpreted the sudden escalation of regulatory action as pressure on Shell to improve the terms on which Gazprom could enter Sakhalin II.
El País reported explicitly that Russia was pressuring Shell while Gazprom sought a stake and noted that the original asset-swap understanding had been destabilised by the project’s cost doubling. El País
The Guardian later described months of pressure from Russia’s natural-resources and environmental authorities preceding the ownership negotiations. The Guardian
Those were contemporary interpretations.
They were not judicial findings.
15. The Russian government denied that interpretation
Russian officials publicly rejected accusations that foreign investors were being driven from the energy sector.
Foreign Minister Sergei Lavrov said the environmental inspections did not necessarily mean termination of the production-sharing agreement and described claims that Russia intended to squeeze out foreign investors as groundless.
Natural Resources Minister Yuri Trutnev likewise said the authorities hoped to avoid shutting the project but insisted that environmental violations had to be corrected. Royal Dutch Shell Plc .com
That position must be recorded alongside the allegations of political pressure.
The Russian government said the issue was regulatory compliance.
Critics and market observers suspected strategic leverage.
The surviving record establishes the simultaneity of environmental enforcement and ownership negotiations.
It does not, by itself, prove the motive behind every regulatory decision.
16. The EBRD process is overtaken by events
By 26 September 2006, the financing process had stalled.
AFP reported that EBRD had expected to reach a decision on potential financing during the summer or by September.
Instead, the Bank said that uncertainty surrounding the project’s legal position:
“does not allow the EBRD to progress.” Royal Dutch Shell Group .com
This is an important turning point.
The 120-day public consultation had been completed.
The environmental submissions had been gathered.
But the lender could not proceed toward a decision because the legal and regulatory status of the underlying project had become uncertain.
The environmental financing process had collided with Russian state action.
17. That did not amount to an EBRD environmental rejection
This distinction is crucial because the later history is often compressed.
EBRD did not announce in September 2006:
Shell has failed our environmental test and we refuse to lend.
It said the Russian legal uncertainty prevented the financing process from progressing. Royal Dutch Shell Group .com
Environmental issues remained central to the Bank’s assessment.
But the immediate obstacle had changed.
The project itself was now being challenged by the state whose resources it was developing.
18. By the end of 2006, control was moving
The eventual outcome is documented in an SEC filing.
On 21 December 2006, Gazprom, Shell, Mitsui and Mitsubishi signed a protocol under which Gazprom would acquire 50 per cent plus one share of Sakhalin Energy for $7.45 billion.
Shell’s interest would fall from 55 per cent to 27.5 per cent. SEC
The filing records that Phase II was then more than 80 per cent complete and that approximately $12 billion had already been invested by the end of the third quarter of 2006. SEC
Shell’s own 2006 Sustainability Report later called the year:
“tumultuous.”
It welcomed Gazprom’s entry and presented the new ownership arrangement as helping the project move toward completion. Shell
The corporate language was conciliatory.
The change in control was undeniable.
19. The later court record supplies an independent institutional frame
Two years later, the English High Court considered a dispute over access to British government environmental information relating to proposed ECGD support.
In Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin), Mr Justice Mitting recorded that Shell had held the majority stake when British support was originally sought, while Gazprom subsequently acquired a 50 per cent interest.
He also recorded that approximately US$650 million of UK-backed project finance had been under consideration and described the project as potentially having major effects on western gray whale habitat. vLex
The case did not decide whether the Russian regulatory pressure of 2006 had been politically motivated.
It did not decide whether EBRD should have financed Sakhalin II.
And it did not adjudicate whether individual environmental allegations were correct.
Its value here is narrower.
It confirms that the financing and environmental controversy surrounding Sakhalin II became serious enough to generate formal litigation over what the British government knew.
Documentary Findings
Established
EBRD decided on 14 December 2005 that Sakhalin II’s documentation was fit for public consultation, thereby opening the final 120-day disclosure and consultation process. That was not a loan approval. EBRD
Consultation occurred internationally, including meetings in London and Moscow, with further consultation in Sakhalin and Hokkaido. The Moscow meeting included extensive opposition from environmentalists, lawyers, scientists and community representatives. Royal Dutch Shell Group .com
EBRD’s December 2005 position, as reproduced in contemporary submissions, acknowledged that some procedures required by its Environmental Policy had not been fully followed during project planning. WWF Europe
WWF and other organisations opposed financing and raised concerns over whales, oil-spill preparedness, salmon rivers, indigenous communities, seismic risk and the effectiveness of consultation. Those were campaigning assessments, not judicial findings. Royal Dutch Shell Plc .com
Shell’s own reporting acknowledged contractor failures at some sensitive river crossings and described subsequent remedial controls, independent monitoring and mitigation measures. Shell
The 120-day consultation closed in April 2006. Royal Dutch Shell Plc .com
Russia’s environmental authorities moved against a key Sakhalin II environmental approval in September 2006 while Gazprom was simultaneously pursuing entry into the project. Royal Dutch Shell Plc .com
EBRD then delayed its financing decision because the project’s legal position had become uncertain. Royal Dutch Shell Group .com
On 21 December 2006, a protocol was signed under which Gazprom would obtain 50 per cent plus one share for $7.45 billion and Shell’s stake would fall from 55 per cent to 27.5 per cent. SEC
Shell and Sakhalin Energy’s stated position
Sakhalin Energy maintained during the consultation that it was complying with Russian law and that environmental issues were being addressed. Royal Dutch Shell Group .com
Shell’s authenticated reporting records strengthened river-crossing controls, outside expert involvement, independent monitoring and measures to protect western gray whales. Shell
After the 2006 ownership agreement, Shell publicly welcomed Gazprom’s participation and portrayed the restructuring as a step toward completing the project and meeting environmental and community commitments. Shell
The critics’ stated position
Environmental organisations argued that Sakhalin II still failed to meet EBRD standards and that major risks remained unresolved despite years of review.
Some also argued that meaningful consultation was compromised because much of the project was already under construction before the final 120-day process began. WWF Europe
Those assessments remain attributed to the organisations making them.
The Russian government’s stated position
Russian officials said the 2006 inspections and environmental enforcement concerned compliance with the project’s obligations.
They rejected claims that the purpose was to force foreign companies from Russian energy projects or to terminate the production-sharing agreement. Royal Dutch Shell Plc .com
Those were the Russian government’s stated explanations.
Not established
It is not established that EBRD approved Sakhalin II environmentally in December 2005.
It is not established that EBRD rejected Sakhalin II on environmental grounds after the 120-day consultation.
It is not established that every environmental criticism made by NGOs during consultation was correct.
It is not established that Sakhalin Energy was free of environmental non-compliance; Shell’s own reporting acknowledged some contractor failures.
It is not established that Russia’s September 2006 regulatory action was fabricated solely to obtain control of Sakhalin II.
It is not established that the Russian enforcement campaign was entirely divorced from the commercial negotiations with Gazprom.
It is not established by any court record identified here that Shell was unlawfully coerced into selling control.
And the 2008 English High Court case did not adjudicate the motives of the Russian government, EBRD’s financing merits or Shell’s environmental liability.
Commentary
The 120-day consultation is important because it marks the last moment when Sakhalin II still looked primarily like an environmental-finance problem.
The questions were difficult but recognisable.
Were the whales adequately protected?
Could oil be contained under sea ice?
Were salmon rivers being crossed properly?
Were contractors obeying the rules?
Could local communities influence decisions?
Did the project satisfy the standards required for public-backed finance?
Those were questions a development bank was equipped to examine.
Then the ground moved.
The same environmental issues that international lenders had been scrutinising became instruments within a confrontation involving the Russian state, a strategic gas asset, a production-sharing agreement, a doubled project budget and Gazprom’s demand for entry.
At that point, environmental governance and energy politics became almost impossible to separate.
The most important distinction
The documentary record does not permit either of the two easiest stories.
The first easy story is:
Russia invented environmental complaints and stole Shell’s project.
That ignores years of documented environmental concern preceding the ownership battle.
The second is:
Russia simply enforced environmental law and Gazprom’s acquisition was unrelated.
That ignores the extraordinary timing, the contemporaneous reporting, the simultaneous ownership negotiations and the eventual transfer of control.
The evidence supports a more disciplined conclusion.
Environmental problems existed.
Regulatory pressure escalated dramatically.
Gazprom wanted into the project.
The earlier asset-swap economics had been disrupted by the doubling of costs.
And within months, Shell surrendered majority control.
Those facts can be established.
The precise mixture of environmental enforcement, commercial bargaining and state strategy behind them remains a matter requiring evidence, not assumption.
What the 120-day test actually achieved
EBRD never reached the simple yes-or-no conclusion many participants expected during the consultation.
But the process was not meaningless.
It forced disclosure.
It created records.
It exposed project assumptions to outside challenge.
It required Shell and Sakhalin Energy to respond publicly to issues involving whales, rivers, spills and local communities.
And it preserved an evidential trail later available to parliaments, courts, journalists and this archive.
The loan decision was overtaken by politics.
The documents survived.
Source Record
The European Bank for Reconstruction and Development Independent Recourse Mechanism record preserves the 14 December 2005 determination that Sakhalin II documentation was fit for consultation and records the wider accountability process. EBRD
EBRD — Sakhalin II Independent Recourse Mechanism record
Contemporaneous Oil & Gas Journal reporting explains that the EBRD determination triggered the 120-day disclosure and consultation period and notes the project’s rising cost and continuing environmental controversy. Shell News
Oil & Gas Journal — Sakhalin II Phase 2 clears EBRD consultation hurdle, December 2005
AFP’s March 2006 account records the six-hour Moscow consultation, the objections raised by lawyers, environmentalists, scientists and community representatives, Sakhalin Energy’s response, the preceding London consultation and planned meetings in Sakhalin and Hokkaido. Royal Dutch Shell Group .com
AFP/TODAY — EBRD urged to refuse Sakhalin II finance, March 2006
The WWF, Friends of the Earth and The Corner House submission of 28 April 2006 reproduces relevant wording from EBRD’s December 2005 press release and sets out the organisations’ criticism of the project. It is advocacy evidence and is treated as such. WWF Europe
WWF/Friends of the Earth/The Corner House — Sakhalin II submission
Friends of the Earth Japan’s contemporaneous submission records the 10 April 2006 Hokkaido consultation and the organisation’s criticisms concerning transboundary effects and consultation procedures. 国際環境NGO FoE Japan
Friends of the Earth Japan — Sakhalin II consultation submission, April 2006
WWF’s statements during and at the close of the consultation document its objections concerning western gray whales, spill response, pipeline construction and EBRD financing. These remain WWF’s assessments. Royal Dutch Shell Plc .com
WWF — EBRD should not fund Sakhalin II, 28 February 2006
WWF — Consultation closing statement, 21 April 2006
The authenticated Shell Sustainability Report 2006 records Shell’s account of the year, its remedial measures on sensitive river crossings, western gray whale mitigation and the December 2006 Gazprom agreement. Shell
Shell — Sustainability Report 2006
RIA Novosti’s September 2006 reporting records the Russian environmental action, the government’s stated rationale and Foreign Minister Sergei Lavrov’s rejection of claims that Russia intended to drive foreign investors out. Royal Dutch Shell Plc .com
RIA Novosti — Sakhalin II inspections and environmental approval, 27 September 2006
Contemporaneous El País reporting records the parallel Gazprom negotiations, the earlier asset-swap arrangement, the doubling of project costs and international concern over Russian regulatory pressure. El País
El País — Russia pressures Shell over Sakhalin II, 20 September 2006
AFP reported on 26 September 2006 that EBRD had delayed its financing decision because the project’s legal position had become too uncertain to permit progress. Royal Dutch Shell Group .com
AFP — EBRD delays Sakhalin II financing decision, 26 September 2006
The SEC filing of December 2006 provides the authenticated corporate terms of the Gazprom protocol: $7.45 billion for 50 per cent plus one share, reducing Shell’s interest from 55 per cent to 27.5 per cent. SEC
US SEC — Gazprom, Shell, Mitsui and Mitsubishi Sakhalin II protocol, December 2006
The later judicial context is Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin). Mr Justice Mitting recorded the proposed approximately $650 million of UK-backed finance and the potentially significant environmental implications of Sakhalin II. The judgment concerned disclosure of environmental information and did not adjudicate Russian motives or Shell’s environmental liability. vLex
High Court — Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin)
Archive disclaimer: This instalment distinguishes EBRD determinations, Shell statements, NGO submissions, Russian government statements, contemporaneous journalistic interpretation and later judicial context. The coincidence of environmental enforcement and negotiations over Gazprom’s entry is documented; motive is not treated as judicially established. “Fit for consultation” is not represented as environmental approval or financing approval.
Site-wide disclaimer applies.
Next instalment
The Sakhalin Papers LX: The Permit War — When Russia Turned Environmental Enforcement Against Shell’s Flagship Project
By September 2006, the 120-day EBRD consultation was over.
But Russia’s own environmental authorities were only beginning.
Inspectors moved across pipeline routes, forests, rivers and Aniva Bay.
A crucial environmental approval was challenged.
Natural Resources Minister Yuri Trutnev warned that violations had to be corrected.
Sakhalin Energy warned of delays and thousands of lost jobs.
Foreign governments demanded legal certainty.
And behind the environmental confrontation stood an unresolved commercial question:
On what terms would Gazprom enter Sakhalin II?
Within three months the answer would be extraordinary.
Gazprom would not receive the 25 per cent stake originally contemplated.
It would obtain:
50 per cent plus one share.
The next file will reconstruct the September–December 2006 regulatory offensive, separate documented environmental violations from allegations of political coercion, and follow the pressure campaign to the meeting at which Shell finally surrendered control of the project.
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