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Environmental Management Plan

Project activities are guided by one of the most rigorous Environmental Management Plans (EMP) in the history of sub-Saharan Africa. The EMP was developed in consultation with environmental and cultural experts, economists, the governments of Chad and Cameroon, NGOs, the World Bank and local communities. Learn more at ExxonMobil.com.

It contains precise and detailed specifications on a wide range of environmental and socioeconomic protections and mitigation measures the project must undertake in the operations areas.

Voluntary external monitoring to ensure EMP compliance

For the past 13 years, an independent external monitor, the Italian consulting firm D’Appolonia S.p.A., has evaluated the project’s performance in implementing its environmental and socioeconomic commitments as defined by the EMP. Loan covenants between the project and the World Bank and other lenders required this monitoring while the loans were outstanding. Although the loans have been repaid, the project voluntarily conducts an annual environmental and socioeconomic review by the same independent third party to help ensure its continuing compliance with the EMP.

The D’Appolonia team spends several weeks at a time in Chad and Cameroon to analyze environmental and socioeconomic factors and to confer with company staff, affected populations, NGOs and other stakeholders. The work identifies any gaps in performance and opportunities for the project to make improvements.

  • Eugenio Napoli, Consultant, D’Appolonia “Although our involvement in this project is no longer mandatory, our scope of work for this mission is the same – to perform a comprehensive review of the company’s environmental and socioeconomic practices. The project has invested heavily in this EMP system, having recognized this framework benefits their business by providing an extra layer of risk management and protection from complaints or issues. An independent evaluation is a plus for the whole system, as it adds more weight, credibility and transparency to their operations.”

EMP requirements

The EMP contains guidelines on a number of comprehensive topics, such as:

  • Providing fair and transparent compensation to land users and communities for land used by the project
  • Making preferential purchases of goods and services from local and national businesses when possible
  • Providing employment opportunities to local residents and citizens of host countries, with preference being given to communities directly affected by the project
  • Delivering job training opportunities to qualified employees
  • Establishing safety procedures which meet or exceed U.S. and international safety standards
  • Developing and implementing appropriate emergency response plans
  • Identifying and safeguarding cultural artifacts and properties when appropriate
  • Protecting biodiversity by restricting access to sensitive areas along the pipeline right of way
  • Providing medical care to employees and educating communities about relevant health issues
  • Conducting regular consultation sessions with stakeholders
  • Utilizing a well-defined mediation process to resolve ongoing stakeholder disputes
  • Conducting regular monitoring and audits to ensure compliance with the EMP
  • Collaborating with independent international monitoring and oversight agencies

The EMP adopted by EEPCI, COTCO and TOTCO requires new operators wishing to connect to the Chad/Cameroon pipeline to develop individual EMPs, which adhere to the core principles (e.g., consultation, compensation and environmental protection) of the project’s EMP.

FEDEC: A broadened mission and improved sustainability

The Foundation for Environment and Development in Cameroon, also known as FEDEC, was created to help the project meet its EMP commitments to protect the people and environment near its operations in Cameroon. Since 2000, COTCO has contributed $5 million to help FEDEC’s biodiversity protection and conservation efforts in two of Cameroon’s national parks, and to support the Bakola/Bagyeli, an indigenous people living in the forest area between the towns of Kribi and Lolodorf.

Recently, FEDEC made significant changes to broaden its mission and strengthen its sustainability to attract additional private sector partners. Some of the changes included:

  • A new executive director and headquarters in Yaoundé
  • A strategic plan for the future which outlines an expanded, more sustainable mission and funding plan
  • A new board president and additional member to the board of directors, bringing the total to seven
  • Increased capacity for collecting and communicating the impact of the organization’s work through well-defined metrics
  • Development of a website and other communications materials

  • Anne Virginie Edoa, Executive Director, FEDEC

    “With the vision of our foundation and our credibility and expertise, we can help companies in Cameroon efficiently manage their environmental and socioeconomic commitments and create measurable positive impacts over the long-term.”

EMP reportables

The EMP includes reporting standards for non-compliance situations. The three-level ranking system is designed to provide an early warning mechanism to detect issues and help correct non-compliant behaviors and practices well before they become serious enough to cause damage. The project had zero Level II or Level III NCS’ in 2014.

Non-compliance situations

Spills

The EMP requires the reporting of all spills equal to or greater than one barrel of oil, 10 barrels of produced water or 100 kilograms of a chemical.

The project had a spill this year of one barrel, and used it as a teachable moment to test its oil spill response (OSR) capability and equipment and make sure the response teams stay alert and fresh. As a part of the project’s commitment to continuously improve its ability to protect the environment, the incident was also used to investigate solutions that could be effective with potential future incidents, such as the use of drones to rapidly observe potentially impacted areas and better inform response activities.

Successful resolutions through mediation

The EMP outlines a mediation process to settle outstanding disputes with local communities and other stakeholders. Under this arrangement, the World Bank’s Compliance Advisor/Ombudsman (CAO) can initiate mediation upon receiving notification of a dispute that has not been resolved through the project’s formal grievance resolution program. The CAO uses a mutually agreeable and flexible mediation process to help improve social and environmental outcomes on the ground. The project is methodically working through the handful of CAO cases that were activated in Chad and Cameroon in 2011.

In Cameroon, three of the four cases that were brought by individuals have been successfully resolved, and one is ongoing. Regarding communities involved with the CAO process, COTCO is focused on finding long-term, collaborative solutions to often complex issues that work for both parties.

Spotlight: Berthe's Sewing Shop

The story of Berthe’s Sewing Shop in Nanga Eboko, Cameroon, is illustrative of the collaborative spirit with which the project approaches the CAO cases.

Berthe Ongono became ill while working as a cook for a project subcontractor during construction of the pipeline. Berthe registered a grievance claiming that her condition was the result of project activities and triggered the CAO dispute resolution process.

A comprehensive investigation and mediation process found no linkage between Berthe’s health issues and project activities, but as her health degraded over the years, COTCO’s staff looked for ways to support her through the company’s social programs. The Association des Femmes de COTCO (ASFEC) is a volunteer organization formed and funded by female COTCO employees to help underprivileged women and children in Cameroon. ASFEC stepped in to help Berthe, donating the necessary equipment and materials to get her sewing shop dream started.

Sadly, Berthe passed away in 2014 before she was able to open her business. However, nuns from the local Catholic Diocese and other friends of Berthe are committed to running the shop to teach and support orphans in their care. Among the orphans are Berthe’s two children, aged 12 and 16 years old.

We were very close with Berthe – when she was sick, we were the ones to care for her. We hope to use the shop to develop the young girls here, support our orphans and provide for Berthe’s family. We are very happy with the COTCO women’s association because even after Berthe passed away, they came back and showed us that this is an honorable company.

Sister Marie France, Obala Catholic Diocese

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