An important element of the environmental assessment process is to prevent or reduce the significant impacts of development by the use of mitigation measures. These have been considered in terms of:

 

- Preventative/repressive measures - these measures aim to control environmental effects at source or at the discharge point by design alteration and environmental management (Prevention is complete avoidance of the effect; Repression is the minimisation of the effect);
- Curative/compensative measures - these measures aim to respond to environmental effects by reinstatement/restoration or compensation (Curative measures make damage good through restoration of affected areas; Compensation is payment either in kind or cash).

The approach adopted by NLNG is that, wherever possible, efforts should be made to prevent or repress environmental effects. NLNG has already implemented some of the mitigation measures that are required for the NLNGPlus project as part of the Base and Expansion project's Health, Safety and Environmental Management System (HSE-MS). Mitigation measures presented in this report represent commitments for NLNG and these actions will, therefore, be implemented by NLNG. The means of implementing these commitments is through (environmental, social, health) management plans as part of the HSE-MS.

The main preventive and repressive mitigation measures proposed are:

- Claim on space: the new perimeter road in the safety and sterile zone will be designed to be well drained, maintain hydrological continuity and prevent soil erosion in adjacent swamp forest.
- Claim on space: NLNG will - in consultation with local authorities and land owners –ensure effective control over the safety and sterile zone to enforce the safety rules applicable to this area and to prevent squatter villages.
- Road design, improvements and repairs: NLNG will plan road improvements and/or repairs as part of a traffic management plan. Major roads will be metalled with parallel, regularly maintained ditches to facilitate run-off and protect adjoining wetlands and forest.
- Conservation of the environment: NLNG will support local leaders and competent authorities to execute their responsibility to control existing off-site, non-project related developments and control clearance and exploitation of the forest for settlements and agriculture. NLNG will monitor the level of access and exploitation of the forest areas and assist local authorities with public enlightenment to conserve forests areas.
- To deal with the job situation (i.e. providing alternative employment outlets for non-successful applicants for NLNG jobs) NLNG will use the micro-credit scheme to assist in diversifying employment opportunities on the Island in the short, medium and long term.
- NLNG will also develop specific skills training programmes for gifted young trainees to make them employable for NLNGPlus high-tech semi-skilled construction jobs.
- NLNG will monitor all discharge sources on a monthly basis for compliance with legislative requirements and HSE Premises and report on performance regularly.
All emission sources will be monitored once-off through actual stack measurements to validate the estimated/calculated emissions. Ambient air quality and noise levels in the plant area and at the fence will be monitored and reported on a quarterly basis for compliance with legislative requirements and HSE Premises. A programme of periodic ambient air quality monitoring will be set up in receiving communities (particularly Bonny Town and Finima) to measure air quality for local people for compliance with FMENV and international standards.
- NLNG's Community Assistance programmes, instigated during the Base and Expansion projects, will continue and NLNG will continue to develop and implement their existing public information, public liaison and community involvement programmes (Stakeholding).
- Disease and health: Current NLNG health awareness programmes for workforce and local communities will continue. Control and prevention programmes aimed at vector, water, and lifestyle related diseases will be implemented on all work sites and camps.
- NLNG shall apply the existing emergency/contingency plan of the Base and Expansion projects to NLNGPlus construction and operations phases and shall update plans if required, e.g. on spill clean-up resources, training, etc.
- NLNG will continue its waste management and waste-tracking programme, in which it will monitor and report on a monthly basis the handling and disposal of all types of waste.
- Compliance with HSE Premises: NLNG will manage site activities to ensure compliance with HSE Premises during both construction and operation. This relates to emissions, effluents, solid wastes, noise and contingency planning for spillage.

The main curative and compensative mitigation measures proposed are:

- Claim on space: part of the new land-take for the safety and sterile zone will be cleared, levelled and in-filled to provide space for the construction laydown and Third Country Nationals (TCN) camp. The rest of the zone will not be cleared and, as part of NLNG's control over this area, the Company will aim to conserve the natural situation. Indirect compensative mitigation for the new land-take will be the formal designation of a Nature Reserve in forest surrounding the Residential area. The Nature Reserve will be patrolled and managed for nature conservation and minimise the risk of timber extraction or hunting for wildlife. Regular wildlife and ecological surveys will be carried out continually to review the areas conservation status.
- NLNG will duly compensate for any unavoidable relocation of people as a result of any of its activities. Exploitation of natural resources: NLNG will investigate the level of access and exploitation of forest, and liaise with local communities as well as implement programmes to increase environmental awareness towards sustainable management and use of forest.
- Reinstatement and restoration programme: NLNG will implement a restoration plan for the Nigerian labour camp on completion of construction, and will ensure that the site is restored back to the original state, as far as is possible, if the Community agrees and do not desire to retain it. Alternatively, if the area becomes permanently occupied on the Community's request, NLNG will undertake liaison with the local authorities to establish future responsibility for the site.
- Minimising social disruption: Nigeria LNG's public information and liaison programme and involvement in community projects will continue and be enhanced.
- Monitoring and response during construction: NLNG will monitor the effectiveness of the measures proposed in the preventative/repressive mitigation, including: the control of effluents discharged from the construction site and Contractor's camps, the monitoring of pollution/spill incidents, solid waste disposal, effluent, emissions and noise monitoring, the repair of damaged roads, the restoration of the Nigerian labour force camp and diseases control and prevention. NLNG will respond with curative/compensative measures as required.
- Monitoring and response during operations: NLNG will maintain the existing programmes of monitoring of environmental performance to evaluate compliance with HSE Premises, in terms of emissions, effluents, solid wastes and noise and implement curative/compensative measures if required.
- NLNG will complete the current monitoring and reporting programme with indicators to measure performance on Sustainable Development.
- Health monitoring and response: Workforce health will be monitored and health awareness and treatment programmes will be implemented in response as required. Medical statistics on certain diseases will be selected to monitor health trends in the community.

During the consultation phase of the Impact Assessment exercise, a number of existing issues were raised by stakeholders. These existing issues are not direct impacts of the NLNGPlus project but relate to previous phases of NLNG development on Bonny Island and require continued management attention.

 

Existing issues include:

- In general, NLNG's host communities harbour high expectations with regard to employment, contracts, social investments and community development support from the Company.
- Some factions in New Finima expressed the view that they have not been sufficiently compensated for their land being used by NLNG.
- Some factions in New Finima claim that previous promises have not been met on time or with the right standards. In particular, they say that there are outstanding promises of additional housing.
- The continuing leadership dispute in New Finima makes it very difficult for the Company to engage the community in any meaningful dialogue.

 

Proposed activities to resolve these issues include:

- The Company will work towards the speedy fulfilment of its promises and commitments in the Bonny Agreement and the Memorandum of Understanding between the Joint Industries on Bonny Island and the community.
- The Company will continue to engage in sustainable development initiatives, which encourage skills acquisition, local enterprise and improvements in health and the environment of its host communities.
- The Company will continue to support non-contentious projects within New Finima which receive broad support form all its inhabitants.
- Where unconstrained by legal or safety issues, the Company will be prepared to engage community representatives from New Finima with a view to addressing unresolved issues and grievances.
- NLNG will complete an Information Centre on Bonny for easy access to information for the Community.