Environmental Management System
Tullow operates an ISO 14001 certified Environmental Management System in its London Headquarters and by doing so demonstrates via external assurance that the systems and processes which we apply to our business in the management and determination of environmental risk are robust.
We identify and assess risk throughout the project lifecycle and have publicly committed to stringent evaluation prior to determining whether to conduct operations in areas of natural or cultural sensitivity. Specifically: -
- Tullow will not operate within designated UNESCO World Heritage areas in line with the public commitment made in 2015
- Tullow will risk assess the potential impact of our operations in areas adjacent to UNESCO World Heritage areas as part of the decision-making process prior to any activity
- Tullow will seek Board of Director approval for proposed activities in IUCN Category I-IV protected areas, Ramsar Wetlands and Natura 2000
- Tullow will publish annually a list of these protected areas within which there are Tullow operations
Tullow accepts its responsibility to comply with applicable biodiversity protection laws and regulations in areas where we operate. We therefore endeavour not to adversely impact biodiversity and natural habitats through our presence and operations. Specifically, we have committed to: -
- Ensuring that areas of high-level environmental risk related to biodiversity and natural habitats continue to remain an integral part of project reviews, and project ‘go/no go’ decision-making processes
- Assessing the impacts of our activities on biodiversity and natural habitats and implementing mitigation initiatives, taking into account the overall scope and scale of our operations
- Maintaining transparency in our decision-making and approach to biodiversity issues in relation to our operations
- Align our Development planning work to IFC PS6
- Engage with expertise and industry initiatives that further our understanding of biodiversity assessment and mitigation
In Kenya, for example, Tullow has committed to undertaking assessments of potential impacts on biodiversity features and ecosystem services to meet national permitting requirements, Tullow requirements and Good International Industry Practice (GIIP) as described in IFC Performance Standard 6. The Biodiversity Management Framework for our Kenya operations is published here.
Tullow acknowledges the global threat posed by climate change and recognises the need to reduce greenhouse gas (GHG) emissions. We accept our responsibility to comply with emerging climate change legislation and regulation, and to reduce our GHG emissions as far as is reasonably practical through appropriate initiatives.
As an Africa-focused company, we appreciate that emerging oil and gas producing nations are confronted with complex trade-offs to negotiate, as they seek to maximise the value of their natural, human and financial resources, whilst building the foundation for a lower-carbon future. Tullow is also aware of the increasing demands for transparency by stakeholders on demonstrating how climate considerations are accounted for within business decisions.
Tullow is committed to aligning with the actions that our host Governments take to manage the impacts of climate change, and we will continue to support them in this area.
Demand for energy is forecast to grow, and we expect fossil fuels to continue to play a role in the global energy mix over the coming decades. We will continue to support our host Governments as they seek to use oil revenues to promote sustainable and inclusive economic development, and we will align with the actions that they take to manage climate change. Specifically, Tullow will: -
- Aim to minimise the GHG emissions potential of our activities and implement appropriate reduction initiatives, considering the overall stability of our operations
- Adopt a business strategy that is responsive to applicable legal and regulatory developments designed to address climate change
- Maintain transparency in our performance reporting and openness in our engagement about climate change
Given the established fossil fuel asset base and the ever-increasing demand for secure, low cost energy, we expect oil and gas to continue to play a vital role in meeting the world’s energy requirements for decades to come. Tullow’s assets in West and East Africa are low-cost sources of fossil fuels, which remain economic, even at lower oil prices, and carbon pricing assessments are designed to help Tullow consider ways to future proof our developments.
We recognise that evolving legislation aimed at reducing GHG emissions may, over time, have an impact on demand/prices, and we are actively seeking to anticipate and respond to this change, for example by applying notional carbon pricing to test the viability of major capital projects for Full Field Developments (as outlined above).
The process for calculating the Net Present Cost of GHG emissions over the lifetime of new projects is set out in our IMS Investment Appraisal Standard, making it an integral part of Tullow’s financial appraisal process for new developments.
We are committed to adopting a business strategy that is responsive to applicable legal and regulatory developments designed to address climate change, and Tullow’s Non-Technical Risk Standard requires that for all new developments, greenhouse gas emissions are estimated over the lifetime of the project. The Net Present Cost (NPC) of these emissions must be calculated by using a shadow carbon price. We use a shadow carbon price of $40/te of CO² equivalent emissions to calculate the NPC, a value which is in line with industry standards.
Energy consumption, Scope 1 emissions, and methane emissions
Over 95% of Tullow’s energy consumption and Scope 1 emissions come from our two offshore operated assets in Ghana (Jubilee and TEN), the two main areas of emissions1 being gas flaring and energy consumption.
Tullow has over the years disclosed data on our energy consumption and Scope 1 emissions in our Annual Report & Accounts and other required external reports including the Carbon Disclosure Project and International Oil & Gas Producers association. Last year, we responded to specific requests from the International Energy Agency through IPIECA and disclosed our methane emissions data and basis of reporting. Of our total carbon emissions, 98% are driven by flaring, 2% of which are in relation to fugitive emissions. We continually assess our operations to seek opportunities to reduce the flaring levels via process or procedural controls and continue to seek opportunities for further reductions in Jubilee and TEN FPSO’s.
Tullow is committed to minimising the GHG emissions potential of our activities and implement appropriate reduction initiatives, considering the overall stability of our operations. Our Non-Technical Risk Standard sets out mandatory requirements for managing emissions on existing facilities, which includes monitoring and reporting of energy use, quantified inventories of GHG emission sources, operationally and financially viable energy optimisation2.
Industry-specific pollutants (NOx, Sox, VOCs, PM)
At our operational sites, we record and trend our air emissions performance with regards to the above-mentioned industry pollutants. We conduct periodic third party or internal stack emissions monitoring and air quality monitoring and compare the results of this to emissions guidelines including those of World Health Organisation, the US Environmental Protection Agency and the International Finance Corporation. In Ghana, we took additional steps of conducting air quality monitoring in the coastal communities adjacent to the location of our offshore assets. This study concluded that our offshore activities had no effect on ambient air quality in the onshore coastal communities.
Water Risk Management
Tullow recognises that water is a critical and limited natural resource, essential to life, health and sustainable social and economic development. Water is also a key component of Tullow’s operations and as such we accept our role in the responsible and efficient use of this scarce resource.
Tullow commits to identify, monitor and mitigate impacts on water supplies associated with our operations. Locations deemed as high risk will have detailed water management plans in place in line with the requirements of our Safe and Sustainable Operations Policy. We commit to engaging with all stakeholders to improve our understanding of the most effective ways to manage this important issue.
Water risks, and how we manage them, differ depending on the geographical locations of our projects. In our Kenya development, water utilisation is a primary focus of the development concept and as such requires both a robust technical solution but more importantly one that is inclusive the needs of the community within which we operate including the potential for shared infrastructure.