PhD Law Papers

Order Description

-Impact of WAGP on environment and host communities
-Legislation for protecting environment and host communities
-West African Gas Pipeline Act 2004, Part 7 (Responsibility for environmental damage)
-Pipeline safety issues: overcoming pipeline failures especially offshore section of the pipeline, which leads to severe economic, human, and environmental consequences for Nigeria.
-laws governing social and environmental management of the pipeline to prevent irreparable damage to livelihoods and lands in each of the four countries: their strengths and weaknesses
•The Republic of BENIN
•The Republic of GHANA
•The Federal Republic of NIGERIA
•The Republic of TOGO
-the role of WAPCO shareholders (ChevronTexaco, Shell, NNPC, VRA, Bengaz & Sotogaz) in addressing legal and ecological difficulties facing the WAGP

 

Answer

Title: WEST AFRICAN GAS PIPELINE

 

Contents

Introduction. 2

The Legal Regime for the WAGP Project 4

The WAGP Treaty and the International Project Agreement (IPA) 4

Enabling legislation. 5

Pipeline Safety and Ecological Issues. 6

Legislation for Protecting Environment and Host Communities. 11

The Federal Republic of Nigeria. 12

The Republic of Ghana. 17

Benin and Togo. 21

The Role of WAGPCo in Addressing Legal and Ecological Difficulties Facing the WAGP. 22

WAGPCo’s Adherence to Technical Integrity. 24

The Role of Regulatory Framework in WAGPCo’s Ecological Conservation Efforts. 26

Conclusion. 29

References. 31

 

Introduction

The West African Gas Pipeline (WAGP) is a newly constructed natural gas pipeline for transporting natural gas from Nigeria to markets in Ghana, Togo, and Benin. The company responsible for the development and operation of the pipeline is the West African Gas Pipeline Company Limited (WAGPCo or WAPCo). Other companies that have a stake in the development of the pipeline include Chevron, Shell, Nigerian National Petroleum Corporation (NNPC), Société Togolaise de Gaz (Sotogaz), Bengaz SA, and The Volta River Authority of Ghana (VRA).

The project was initiated as a way of gaining access to markets for Nigerian gas, which has traditionally continued going to waste because of gas flaring. The project was also promoted based on the idea that it was cheaper, cleaner, and more secure source of energy for Ghana, Togo, and Benin.[1] WAGP is also a core component of regional economic integration in West Africa under the auspices of Economic Community of West African States (ECOWAS). More importantly, its construction set a precedent for other regional projects.

Despite these benefits, environmental concerns have been expressed in relation to the construction and operation of the pipeline project. The pipeline has environmental consequences for the 680 km it covers from Nigeria to Ghana. For example, on 28 August 2012, a section of the pipeline in Lome (Togo) was damaged, leading to gas leakages. Such leakages are threat not only to the environment but also the safety of those who live nearby. During the dewatering process on 30 October 2012, which was undertaken  after the repair of the pipeline, multiple fatalities occurred, leading to a disruption of commissioning.

To address these environmental concerns, efforts have been made to create an appropriate legal, fiscal, and investment framework governing its operations.  The framework also seeks to harmonize operations across all four participating states. The three core mechanisms that have implemented to achieve the goal of regime standardization include the WAGP Treaty, enabling legislations passed by each of the four countries, and the International Project Agreement (IPA). Additionally, several regulatory documents have been drawn out, which include  WAGP Technical Regulations, Access Code, Pipeline Development Plan, Pipeline Licenses, and Environmental Impact Assessment and Management Plan.[2]

A major challenge in this project is differences in the environmental laws established in the four countries. These differences have caused immense challenges for the sponsors and operators of the project in terms of addressing ecological challenges.[3] Failure to address environmental problems constitutes a major challenge because it is a threat not only to the sustainability of the project but also the health and lives of people who live near the pipeline network. The aim of this paper is to examine the legal regime of the WAGP analytically to determine its suitability in addressing the ecological difficulties affecting the project. The thesis of this paper is that the environmental laws of Nigeria, Togo, Benin, and Ghana need to be harmonized in order to enable project stakeholders to address ecological difficulties relating to the WAGP project. The paper analyzes the various enabling legislations to determine how they address environmental problems and concerns arising from the construction and operation of the West African Gas Pipeline.

The Legal Regime for the WAGP Project

The WAGP Treaty and the International Project Agreement (IPA)

A core component of the legal regime is the WAGP Treaty. This treaty outlines the establishment of WAGPA as the sole regulatory authority for the project. It also establishes various bodies for handling emerging legal and fiscal issues. Moreover, it outlines the measures to be taken to promote commitment to the implementation of the IPA as well as the sharing of all fiscal and environmental commitments among countries. The Treaty also forms an excellent reference point for guidelines on the day-to-day operations of the pipeline by all stakeholders.

In the sections on facilitative and regulatory functions, the Treaty outlines the functions that the WAGP Authority should perform to maintain the sustainability, safety, and efficiency of the pipeline. In terms of facilitation, the main functions include facilitating the grant and renewal of all project authorizations subject to the provisions of the IPA, receiving and reviewing the Conceptual Design Package for the pipeline, and responding to the Pipeline Development Plan. In terms of environmental protection, the Treaty provides a framework for the review of the Environmental Impact Assessment and Environmental Management Plan. On this basis, guidelines on the coordination and facilitation of all appropriate environmental approvals are generated. Similarly, the Treaty confers upon the WAGP Authority the responsibility of coordinating activities aimed at amending the Environmental Management Plan. Other important facilitative functions assigned to the WAGP Authority by the Treaty include administrative services relating to the operations of the Fiscal Review Board, analysis of reports on adherence to WAGP and IPA Regulations , and notification on the occurrence of emergency conditions to relevant agencies.

The WAGP Treaty also spells the regulatory functions that the WAGP Authority should perform. The core ones include responding to various grant approvals, enforcing WAGP Regulations in relation to the construction and operation of the WAGP system, and intervening to ensure that all State Parties and State Authorities comply with the International Project Agreement. The WAGP Treaty also mediates between the pipeline company and aggrieved parties who wish to become shippers. The wording of these facilitative and regulatory roles creates the impression that those who drafted the Treaty were conscious of the need to address ecological concerns. However, implementation of the project in accordance with these provisions may be a different issue altogether. This assertion may be justified in light of concerns about differences in the environmental legislations of participating states and unwillingness by the gas companies involved to address environmental concerns.

The IPA was entered into between the participating governments and the project company. It establishes the regulatory and commercial conditions under which the WAGP business should be conducted. It also seeks to harmonize the investment regime with a view to facilitate the operations of WAGPCo as a single entity in the four countries. The agreement also identifies WAGPCo as the entity that owns the pipeline systems and is thus responsible for its operation and maintenance. The enablers of this operational and maintenance role as stipulated in the agreement include Pipeline Development Plan Outline, Tariff Methodology Principles, Pipeline Access Code Principles, and the Environmental Impact Assessment and Management Plan.

Enabling legislation

The purpose of the enabling legislation is to provide revisions, changes, as well as new legislation governing operations of the pipeline network. Each of the four participating countries involved in the project have a crucial role to play in terms of enacting enabling legislation. All of them (Nigeria, Ghana, Benin, and Togo) have already performed this role. In this regard, the national legislations that have enacted include West African Gas Pipeline Act, 2005 (Nigeria); Régime juridique et fiscal applicable au project du GAO (Bénin);West African Gas Pipeline Act, 2004 (Ghana); and Régime juridique et fiscal applicable au project du GAO (Togo).

Each of these national legislations seeks to validate the legal regime governing the WAGP. The national laws were also enacted in response to the requirement by the WAGP Treaty that each of the participating countries do so. By so doing, the countries had in effect confirmed the role of the WAGP Authority in the operation of the pipeline system. The laws authorize the Authority to own and operate the project in each of the countries. They also outline the roles that different national stakeholders such as the NNPC and VRA should play in the construction and operation of the gas pipeline system. This way, the national laws constitute the most candid attempt by the four countries to integrate pipelines operations in order to maximize the benefits that come with it while at the same addressing emerging challenges in a well-coordinated manner. Any genuine efforts by the countries to confront ecological challenges in a similar manner would undoubtedly lead to amicable solutions.

Pipeline Safety and Ecological Issues

Numerous safety and ecological issues have been raised in relation to the construction and operation of the West African Gas Pipeline. A major concern in this regard is that the negative effects of WAGP on environment as well as host communities by far outweigh its economic benefits.[4] These concerns have triggered a heated debate in scholarly, corporate, and government circles over ways of overcoming environmental failures particularly in offshore sections of the pipeline, which may lead to severe human, economic, and environmental consequences for the four countries.[5]

In Nigeria, most discussions on the environmental impact of the pipeline focus on the Niger Delta Region, where it originates.[6] When the construction of the project commenced, host communities in the Niger Delta Region expressed opposition to it, arguing that it would cause irreparable damage to their land and livelihoods. The fears of these communities understandably arose from their past grievous experiences arising from oil exploitation activities. With gas being tipped to take over the role that oil has played for decades in the global economy, the communities are worried that this will trigger new ways of exploitation by gas exploration companies.[7]

In  efforts to stop gas wastage, the Nigerian government sought to commercialize gas production by initiating projects that would facilitate its transportation to viable markets in neighboring markets.[8] It is against this backdrop that the WAGP project was initiated. In rendering support to this project, the Nigerian government was well aware of the threats it posed to human security in the Niger Delta region primarily through ecological problems. Nevertheless, in its quest to mobilize support for the project, the Nigerian government has chosen to focus on the positive side of the project. This positive environment impact is evident in the sense that the project seeks to tap into the gas that was traditionally being flared as a byproduct of oil extraction.[9] With the commissioning of the WAGP project, less gas would be flared, leading to a drastic reduction in greenhouse gas emissions.

Prior to the commencement of the WAGP project, communities in the Niger Delta regions lived with gas stacks flaring gas 24 hours a day at extremely high temperatures.[10] This gas flaring has put Nigeria to the position of one of the leading contributors of green house emissions globally. Ecological experts have warned that gas flaring is responsible for reduced crop yields and stunted crop growth across the region.[11] Based on this information, the Nigerian government argued that the supply of  the cleaner-burning gas to neighboring countries by WAGP would greatly reduce gas flaring in oilfields. It is not clear whether the project will achieve this ambitious goal.

Doubts about WAGP’s ability to achieve this goal have been heightened by the company’s failure to prove that the gas being flared (associated gas) will indeed be tapped into by the pipeline. These doubts led environmental groups in Nigeria to demand information indicating that this would be the case. This was the right thing for the groups to do since the fields that will constitute the source of gas for WAGP in Western Niger Delta are non-associated gas fields. The implication of this situation is that the company would most likely drill additional wells instead. The choice of non-associated gas also seems plausible for the company since it is cheaper to produce than associated gas. This is likely to create a situation where WAGP sets a precedent for making decisions solely based on profit margins instead of the best interests of the people of the four participating countries.

A central talking point for safety and ecological issues affecting the pipeline is the Environmental Impact Assessment (EIA). The WAGP Treaty provides a framework for EIA as well as an environmental management plan. Environmental protection should be given priority because the environment is the repository of all the natural resources that humans continue to exploit today. It is for this reason that an environmental impact assessment for the pipeline project was necessary. During the Rio Declaration in Brazil, participants in the World Summit of 1992 agreed that impact assessments should be conducted on all projects that are likely to have a negative impact on the ecosystem. In response to this requirement, all the states participating in the WAGP project enacted appropriate laws. These laws include the Nigerian Environmental Impact Assessment Law 1992, the Ghanaian Environmental Protection Agency Act, 1994, the Code de l’Environement en République du Togo, 1998, and the Lois Cadres Sur l’Environement en République du Benin, 1999.

The objective of EIA is to determine how a project may affect the environment and how these effects can be mitigated. In situations where a project is deemed to have severe environmental consequences, it may be abandoned altogether. In the case of the WAGP, there are concerns that a comprehensive environmental impact assessment was not carried out. These views have mostly been expressed by local communities living in areas where the onshore pipeline passes. Environmental lobby groups such as Oilwatch, Environmental Rights Action (ERA), and Friends of the Earth clam that gas sale contracts have been signed, agreements have already been negotiated, yet host communities do not know much about the project.[12] These views contradict those expressed in the WAGP website, which indicate that comprehensive EIA was carried out in accordance with the WAGP Treaty.

Chevron, the corporation leading the implementation of the project, claims to have carried out EIA. A major concern is that although the EIA was carried out, host communities were kept at the fringes. In April 2006,  12 host communities submitted a petition to the World Bank, expressing concern that the project would bring about environmental devastation, communal conflicts, human rights violations, and impoverishment of host communities.[13] These host communities pointed out that the problem of oil pipeline explosions, which was a recurring source of injuries and mortality, would be replicated in the gas pipeline system.

The persistent lack of formal guidelines on participation by environmental groups and local communities may be attributed to a lack of a legal framework in each of the four countries.[14] Although the WAGP Treaty contains a section on EIA, implementation challenges are rife because of the absence of clear supporting legislation. This situation is worsened by the lack of commitment by gas companies, who are interested first and foremost on the economic gains to be realized from the commencement of the project.

An ideal legal framework should not just address aspects of EIA; it should also provide guidelines on how stakeholders in the project seek to undertake environmental management work even after the project becomes operational.[15] Three of the four countries involved in the pipeline project (Benin, Togo, and Ghana) have limited experience in pipeline operations.[16] This means that the legal regime governing such operations is yet to develop. This situation puts communities in the three countries at risk of cultural dislocation as gas companies seek to take advantage of loopholes in the legal framework and the vulnerability of weak host communities to maximize profits. For instance, once mangroves are destroyed to create a path for the pipeline, efforts should be made to restore them since they are symbols of millennial cultures. Failure to restore them would amount to depriving host communities of their primary source of cultural pride. Yet it is highly unlikely that the gas companies will initiate environmental management plans aimed at promoting reforestation due to the absence of laws that require them to do so.

Legislation for Protecting Environment and Host Communities

Laws governing social and environmental management of the pipeline should ideally seek to prevent irreparable damage to livelihoods and lands in each of the four countries.[17] There are similarities as well as differences in the challenges faced by these countries as well as the legal regimes they have put in place to address them.[18] At the same time, the WAGP Treaty forms an ideal platform that brings these countries together with a view to forge a common plan of action that is firmly anchored in law. Those who drafted the Treaty envisaged that it would lead to operational efficiency for WAGP through the enactment of supporting legislation by each of the countries. This section examines the situation in each of the countries in terms of legal challenges and the measures being taken to address them particularly in regards to the environmental effects of the WAGP.

The Federal Republic of Nigeria

Of the four countries involved in the WAGP, Nigeria has the most extensive experience in the oil and gas industry. The country has encountered numerous environmental problems arising from oil exploitation in the past. In response, several laws have been passed. Following the Rio Declaration in Brazil during the World Summit of 1992, all countries were required to establish laws that would provide guidelines on the conduct of EIA on projects that are likely to have a negative impact on the ecosystem. Nigeria responded to this Declaration by enacting the Nigerian Environmental Impact Assessment Law 1992.

The authority responsible for the administration of EIA in Nigeria is the Federal Environmental Protection Agency (FEPA). Since 1994, FEPA has been preparing and reviewing reports about the country’s EIA policies and practices. Some of the problems identified in these reports include restriction of public involvement, prioritization of participation by proponents, restriction of access to EIA reports by public, and project delays arising from interagency conflict.[19]

The EIA law, also known as the EIA Decree, requires proponents to receive the approval of FEPA before commencing with project implementation. The decree provides elaborate definitions of important concepts such as project and environment. These definitions emphasize biophysical and socioeconomic aspects. They also cover aspects of proposed activities, practical activities involved, an assessment of possible environmental impacts, and an identification of measures that can mitigate adverse environmental impacts. The decree also creates room for the assessment of gaps in knowledge, which may arise from challenges in computing information. Moreover, by providing information in a non-technical way, the EIA Decree seeks to promote comprehensibility to local communities.[20] This is particularly the case for the oil and gas industry, which happens to dominate the list of projects that ought to be subjected to environmental impact assessment.

It is unfortunate that despite the enactment of the EIA Decree, host communities in oil and gas belts across the country continue to complain about the adverse environmental effects of oil and gas extraction activities.[21] It was widely expected that EIA’s administrative arrangements as provided for in the Decree would end this menace. This problem may be attributed to failure of harmonization efforts, such that different laws address environmental issues in bits and pieces instead of providing an integrated approach

Although FEPA is the agency that is legally mandated by the EIA Decree to oversee the administration and enforcement of provisions on EIA, various government bodies keep stepping in to perform supervisory and approval work, thereby triggering interagency conflict. Such conflict only delays efforts to carry out systematic environment impact assessments of projects as provided for under existing laws.[22] Interagency conflict arises mainly because of the fact that different bodies have been established at local, state, and federal levels. It is common for these agencies to deliver contradicting verdicts. Many public and private companies take advantage of this conflict to commence operations. Differences in verdicts are normally caused by various factors, including conflict of interest, local politics, and strategic considerations.

It is unfortunate that such conflict among agencies continues to emerge despite the existence of a uniform procedure for EIA. The EIA Decree requires all EIAs to be undertaken based on the following procedure: project proposal, screening, draft final report by EIA, final EIA report, decision-making by technical committee, project implementation, mitigation compliance monitoring, and environmental auditing. Open access to EIA documents to the public should be promoted to facilitate a candid review of each of these stages. Based on this review, interested parties can arrive at a conclusion regarding whether implementation challenges should be blamed on legal deficiencies or administrative failures on the part of the agencies overseeing the implementation process.

The enactment of environmental laws in Nigeria, starting with the EIA Decree was a step, albeit a modest one, in the right direction. This is particularly true when viewed in the context of social tensions, and wanton destruction that continues to be perpetuated in mineral producing areas. With the WAGP project fully on course, the country’s lawmakers have a responsibility to ensure that its operations do not follow in the footsteps of all previous oil projects in the country. Similarly, the country must seek to set an example for Benin, Togo, and Ghana, which lack extensive experience on petroleum operations.

Today, the supervisory role of FEPA is under threat from conflicts with the agency that has traditionally undertaken supervisory work in the oil and gas industry: The Department of Petroleum Resources (DPR). The establishment of the DPR was sanctioned by the Petroleum Regulations Act 1969. Its core mandate was supervising aspects of drilling and production in the Nigerian petroleum industry. Industry operators who were used to seeking compliance from DPR must also seek clearance from FEPA as well. In such a situation, the risk of inter-agency conflict becomes high. Moreover, it subjects oil and gas companies to frustration because of the delays and costs they have to contend with to fulfill the dual requirements. One may expect WAGP to be experiencing similar challenges since both DPR and FEPA are still operational.

In some cases, the wording of environmental laws targeting gas and oil operations is obscure and contradictory. It is also common for the laws to contain erroneous cross-references, which greatly hinders their effectiveness. Moreover, the legislation is on the most part reactive. A case in point is the EIA process, which, according to the EIA Decree, should commence after notice of a project has already been given. The ideal situation should be one where rural, urban, and regional development plans are outlined. In such a situation, project owners only need to refer to existing plans to know which areas are best suited for their projects. This means that the development plans should be based first and foremost on a proactive assessment of environmental implications.

A core objective of environmental laws should be to maintain a balance between environmental conservation and economic development. Unfortunately, Decree 86 does not provide any information on how different locations should be selected to facilitate optimal achievement of biophysical, socioeconomic, and political outcomes. This situation has led to an undesirable practice, whereby project owners select sites and locations without putting into consideration alternatives prior to seeking Environmental Impact Assessment approval from FEPA.

Moreover, the sheer magnitude of the WAGP project has created a situation where the ruling class misuses the exclusion in the EIA Decree. Because of the transnational nature of the project, high economic and political stakes exert tremendous influence on all EIA processes. This has increased the probability of host-communities’ concerns being swept aside. This demonstrates the serious challenges affecting the policy-making processes in most developing countries such as Nigeria. In many democratic societies, public input is accorded a lot of weight in decision-making, particularly in issues attached to EIA. Unfortunately for the Nigerian legal regime, the exact opposite is true; the IEA Decree lacks provisions that can facilitate broad involvement by the public.[23] This seems to be the crux of the problem of marginalization, which affects communities living in gas-producing regions in Nigeria such as the Niger Delta.

Nigeria ushers the operation phase of the WAGP project at a time when there is a need for environmental laws.[24] This sad fact casts a shadow of doubt regarding the chances of success in the realization of the objective of reducing gas flaring in the Niger Delta region. The EIA process for WAGP was facilitated through a faulty mechanism. To redress these faults, the country’s policymakers may need to review and amend existing laws. Once the amendments are made, a reassessment of the approval processes should be undertaken with a view to identify operational areas that should be changed. The changes to the existing legal provisions should be made as a matter of urgency before the window of opportunity closes. As the operations of the pipeline system become institutionalized through changes to the way the pipeline links to upstream networks, it may be soon too late to adopt any corrective measures. In such a situation, the only available option will be to shut down the pipeline system altogether.

The Republic of Ghana

Ghana has enacted several laws to address environmental issues arising from various projects particularly in the mining industry. Just like in Nigeria, the notion of environmental impact assessment was embraced because of the declaration made in the Brazil Summit in 1992. As a corollary to this declaration, the country enacted the Ghanaian Environmental Protection Agency Act, 1994. The Act contains provisions for mapping the mandate, structure, and functions of the Ghanaian Environment Protection Agency (EPA). The EPA formulates environmental policy for the Ghanaian government. It also makes recommendations for environmental protection. It seeks to ensure that all EIA procedures outlined are in accordance with the resolutions of the Rio Declaration.

Although the environmental regulatory regime in Ghana extends beyond the Environmental Protection Act, this legislation occupies a pivotal position in this area of policymaking because of its anchorage to a major international instrument of environmental protection. Therefore, it forms an ideal reference point for an in-depth assessment of the ecological issues arising from the WAGP project. Some of these issues relate to the control of waste discharges, deposits, emissions, and other forms of pollutants.

The Act is a core component of the enabling legislation envisaged in the WAGP Treaty. However, its functionality also depends heavily on the existence of other regulatory instruments, for example, the Environmental Assessment Regulation, 1999. Under this regulation, all companies that engage in oil and gas activities in the country are required to obtain an Environmental Permit. For WAGP operations to commence in the country, the companies involved had to obtain this license.

A major problem with Ghanaian laws, which have had an adverse impact on efforts to protect environmental pollution emanating from projects such as WAGP, is the near-absence of specific regulations.[25] The EPA regulations that existed at the time the pipeline project was being commissioned failed to address themselves succinctly to both onshore and offshore petroleum operations. At the same time, there is a corresponding lack of technical regulations on environmental protection. This problem is especially prevalent in relation to matters that extend beyond the environmental rules that are applicable to all industries. Some of the regulatory requirements of the petroleum industry require highly specialized knowledge and analysis of technical information. No law in Ghana contains a provision for the establishment of a repository for such information or the mobilization of skilled human resources to address such technical aspects of environmental protection.

The dearth of technical information created a situation where the WAGP project was not properly appraised in terms of EIA. Some of the issues that were not properly addressed because of legal challenges include operator equipments, disposal of waste, regulations on suspension of regulations, production testing regulations, and specific regulations on emissions to air. Similarly, Ghana lacks a legal regime governing investigation of pipeline accidents, discharge of chemicals, experimental equipment, as well as inspections and testing. This means that the existing regime lacks the capacity to address substantive and specific ecological issues arising from a project of WAGP’s magnitude. Issues such as equipment quality may trigger not just technical concerns but also far-reaching environmental consequences. It only makes sense for the country to be prepared to handle such problems whenever they arise, or better still, to take proactive measures that can prevent them from happening. Policymakers in Ghana are largely to blame for failing to heed to the directive of the WAGP Treaty regarding the enactment of enabling legislation.

The legal framework that was used to assess the ecological impact of the WAGP in Ghana include the Constitution of Ghana, the Environmental Protection Agency Act, 1994; the Mining and Environmental Guidelines, 1994; the Environmental Impact Assessment Procedures, June 1995; the Ghana Environmental Assessment Regulations, 1999; and the West African Gas Pipeline Act, 2004. In addition to these regulations, implementers of the project were also bound by the provisions outlined in the WAGP Treaty.

Despite the regulatory deficit of the Ghanaian petroleum industry, WAPCo did fairly well in using the WAGP Treaty and the West African Gas Pipeline Act, 2004 as core reference points.[26] These two laws were (and continue to be) used to conduct an assessment ecological problems confronting the pipeline system across Ghana and ways of mitigating them. The impact assessment activities entailed undertaking sensitization of and consultations with communities regarding various methods of livelihood restoration and community development. To achieve this objective, the company held weekly village consultations to gather first-hand information about the environmental impact of the project.

WAPCo also introduced a livelihood restoration program as a response to earlier findings indicating that the project would trigger considerable alterations to livelihood and income of local communities. Afterwards, independent consultants were brought in to carry out socio-economic surveys aimed at providing insights into the effectiveness of existing compensation programs. These measures provide short-term and medium-term reprieve to residents; it is unlikely to resolve long-term environmental consequences of the gas business in the country. The approach that WAPCo adopted in its environmental impact and management plan reflects the scope that was provided for in the WAGP Treaty. If the treaty contained provisions for the assessment and management of environmental consequences on a long-term basis, WAPCo may have adopted a more sustainable approach to environmental management.

Ghana continues to face ecological challenges by adopting the WAGP project for various reasons. These reasons relate in one way or the other to the country’s legal regime. One of them is the limited access to public information. Other reasons include confidentiality of documents between the EPA and the pipeline company, failure by the government agencies to put the interests of Ghanaians in front of those of the WAGPCo, and lack of effective enforcement mechanisms for existing environmental laws on the part of the government agencies. For instance, the Ghanaian government depended heavily on the EIAs conducted by WAGPCo. This explains why the EIAs failed to provide an accurate prediction of the real impacts of the project on the environment. Companies tend to inevitably be biased and overly optimistic about the possibility that their operations may have an adverse impact on the environment; they spend a long time trying to assuage fears of such adverse environmental effects. In such situations, civil society plays a critical role in campaigning against EIA processes and public hearings that are in favor of the pipeline company.

Benin and Togo

Benin and Togo face numerous challenges similar to those of Nigeria and Ghana. Their legal regime is poorly developed. However, the problem appears slightly more serious, since all major projects in the two francophone countries are based on a blend of local and international provisions. In the case of WAGP, the main reference point on legal issues was the WAGP Treaty. This treaty required Benin to enact supporting legislation specifically outlining the operations of the pipeline. It is for this reason that Benin and Togo enacted the Lois Cadres Sur l’Environement en République du Benin (1999) and the Code de l’Environement en République du Togo (1998) respectively.

Destruction of forests and livelihoods is the main challenge expressed by local communities in Benin since the construction of the pipeline. The communities complain that the government has not been steadfast in addressing the issue in an objective manner. They accuse corrupt government officials of colluding with WAGPCo officials to enter into dubious deals that have no backing in law. In most cases, the persistence of corruption cases in relation to the awarding of WAGP-related tenders may be attributed to the absence of a coherent body of laws and regulations governing the oil and gas industry. At the same time, there is a dearth of literature on the two countries’ experience with interactions between petroleum companies and host communities over ecological issues. In such a situation, it becomes difficult for stakeholders to develop a candid discussion on the need to enact proactive environmental laws that are in tune with current international practices.

In the meantime, Benin and Togo continue to benefit from the pipeline while trying to respond to any emerging adverse environmental effects. There is immense optimism by the civil society that WAGPCo will implement its environmental protection programs based on the letter and Spirit of both the WAGP Treaty and the respective enabling legislations. Such optimism belies the level of desperation of the countries’ environmental activists regarding the inability by their governments to enact harmonized legislation that puts the interests of the public before those of oil and gas companies.

The Role of WAGPCo in Addressing Legal and Ecological Difficulties Facing the WAGP

As the company that bears the responsibility of operating the West African Gas Pipeline, WAGPCo has an important role to play in ensuring that ecological challenges facing the project are addressed. However, these challenges cannot be addressed amicably in the absence of an effective legal and regulatory framework. Whereas the ineffectiveness of the existing legal framework is largely to blame for the existing ecological problems, WAGPCo has also contributed to these failures by pursuing profits in a manner that neglects aspects of environmental sustainability. This section examines the role that WAGPCo has played/should play vis-à-vis the existing realities of diversity of laws, lack of a harmonious legal framework, and laxity/willingness on the part of government agencies in implementing existing environmental laws.

The construction of the gas pipeline was initiated at a time when the world started turning away from oil as the primary source of energy.[27] Natural gas is quickly emerging as the most preferred source of energy because it is abundantly available, cost-effective, and environmentally friendly. As producing countries such as Nigeria seek to deliver their gas to the market, new plans for the construction of trans-national gas pipeline projects are being conceived. However, unbeknown to many people in government circles, these plans tend to come with unintended environmental challenges and consequences. In the oil industry, few people would have anticipated the wanton destruction of livelihoods and entire ecosystems that would have been occasioned by oil extraction activities in most parts of the world. Allowing the gas industry to face similar challenges and leaving them unaddressed at a time when the industry is at its take-off stage would be a serious mistake. It would create a bad precedent for future gas pipeline projects in terms of the environmental impact assessment and management mechanisms put in place.

In most cases, gas pipeline projects tend to involve transnational and multi-dimensional programs as well as partnerships between the formal and informal sectors, thereby triggering numerous legal challenges. In the case of WAGP, four different countries, each with a unique legal regime and culture, have come together to harness resources for the betterment of their national economies. The governments of the four countries feel obliged to ensure that the project succeeds because it is a key pillar in the ongoing strategy of integrating and optimizing the energy sector of ECOWAS. This explains why a lot of focus is on the ecologies difficulties being experienced by WAGPCo, the formulation of environmental laws to address them, and the willingness by the company to steer the project towards the path of sustainability. Some of the main aspects of WAGPCo’s (potential) contribution include technical integrity, regulatory frameworks, environmental awareness campaigns, and avoidance of project delays.

WAGPCo’s Adherence to Technical Integrity

One of the main causes of ecological disturbances in the world is hydrocarbon pipeline failure.This failure impacts negatively translates to numerous losses for stakeholders across the board, and hence should not be blamed on the absence of environmental laws. Since the largest part of the WAGP is offshore, any pipeline failure would pose a risk of hydrate formation and its attendant problems such as fire outbreaks, chronic poisoning, loss of life, and climate change.

The responsibility of the pipeline company to adhere to technical integrity should be viewed in the context of the provisions made in the WAGP Treaty. Article III of the treaty requires state parties to enact enabling legislation as well as WAGP Regulations in a manner that excludes any other regulations or legislation on the same issue. It also requires each of the four states to take measures, through laws and regulations, to ensure that the WAGP Authority is fully empowered to ensure that the project complies with all WAGP regulations. In situations where inter-agency conflicts emerge during EIA processes, the company may claim to have been denied the autonomy necessary to carry out its mandate.

Whenever pipeline failure occurs, WAGPCo officials tend to invoke provisions of the Treaty that grant the WAGP Authority autonomy over state laws. This is an erroneous claim because rights go hand in hand with obligations. Although the Authority has legal personality, it has a responsibility to the state parties to ensure that incidents of pipeline failure resulting from technical problems of any kind are kept at the barest minimum. The drafters of the Treaty were well aware of the fact that the project is susceptible to problems of corrosion. It is on this basis that they put in place provisions aimed at conferring a sense of duty to the company to ensure that hazardous impacts on the ecosystems are avoided.

An important area of focus as far as technical integrity is concerned is the points of discharge in Togo, Benin, and Ghana. High pressure at these points makes the discharge systems highly vulnerable to catastrophic incidents. An example of a catastrophe resulting from an underwater pipeline is the one that occurred in Cameroon in 1986, where a large volume of accumulated carbon dioxide was released to the atmosphere, killing 1,700 people up to 25 kilometers away.[28] Such a catstrophic scenario can be avoided in the WAGP through WAGPCo’s goodwill as well as the company’s compliance to the existing legal framework.

The WAGP Authority is the international institution that is mandated by the WAGP Treaty to make all major decisions relating to the operations of the WAGPCo. For instance, the Authority’s consent should be sought whenever changes are about to be made to the company’s legal corporate structure. Additionally, the Authority is responsible for monitoring the company’s compliance to its obligations as provided for in the International Project Agreement. It should also give approvals for the pipeline system design as well as plans for its construction. These responsibilities demonstrate the importance of the WAGPA Authority in the maintenance of technical integrity of the transnational pipeline project.

Other important technical aspects whose operational framework has been provided for in the WAGP include the Conceptual Design Package, the Front End Engineering Package, and the Pipeline Development Plan. Any failure in these technical processes may be attributed to inefficiency on the part of both the WAGPA Authority and WAGPACo. It would mean that the two institutions failed in their responsibility of negotiating and agreeing on various terms and conditions of approval, thereby leading to the construction of a substandard gas pipeline. In this case, it would be correct to put the blame for any resulting ecological damage on the two institutions and not the legal regime. The only exception in this case is the situation where local environmental laws at local, state, and federal levels provide contradictory information on the statutory technical requirements for the pipeline.[29] Such a lack of harmony in local environmental laws and regulations poses a major threat to the overall safety and ecological viability of the pipeline system.

The Role of Regulatory Framework in WAGPCo’s Ecological Conservation Efforts

WAGPCo operates in four countries with diverse working laws and cultures. This poses a challenge to the company’s ecological conservation efforts because it entails reference to four different legal regimes. If these legal regimes were harmonized to form an integrated regulatory framework, the company would be in a better position to coordinate environmental conservation efforts. Such a framework would also enable WAGPCo to achieve its project objectives. The move by the four states to enact legislative acts aimed at providing such a framework was a step in the right direction. The purpose of these WAGPA laws was to create a uniform, enforceable code containing instructions on how the pipeline system would be designed, constructed, and operated. ECOWAS has been instrumental in helping the four countries to harmonize their regulatory policies and frameworks.

It is worthwhile to point out that the regulatory framework covers numerous aspects of the WAGP project, and this entails an in-depth analysis of technical details. It is also noteworthy that the harmonization process is an ongoing endeavor that WAGPCo should contribute to by sharing its experiences. At any given time, the existing regulatory framework should be viewed as a dynamic model that ought to be fine-tuned constantly with a view to achieve the overarching objective of ecological conservation and regional integration.

Unfortunately, there are some situations in the past where WAGPCo seems to have used its powers under the WAGP Treaty to challenge decisions aimed at bringing about greater benefits in terms of resolving ecological difficulties. The company succeeded because the WAGP Treaty accords WAGPCo the power to challenge the decisions made by the Director General of the WAGP Authority. This provision seeks to protect the rights of the company as provided for under the International Project Agreement. Given the fact that the provisions of the IPA may have been created based on erroneous EIA reports, the cause of the problem should ultimately be traced back to weaknesses (such as a lack of harmonization) on the part of the existing legal framework. These means that the company sometimes tends to take advantage of legal deficiencies within the system to advance its economic interests at the expense of the needs of local communities.

The existing regulatory framework seems to favor WAGPCo over host communities. This is mainly because of the problem of marginalization as well as the fact that proper democratic structures are yet to take shape in the developing world. This situation makes it extremely difficult for the goal of environmental protection to be realized. The challenge may also be attributed to the corporate world’s failure to advocate for enhanced representative democracy. Instead, most oil and gas companies particularly in Nigeria focus primarily on profits.

The fact that WAGPCo has greatly contributed to the cessation of gas flaring in the Niger Delta makes it less exposed to government scrutiny at local, state, and federal levels. Many government officials at the lower levels of the governance structure feel intimidated by the sheer power and influence exhibited by senior WAGPCo officials. On the other hand, senior government officials often seek to cover up for their failure to promote relevant legislative agenda by failing to act upon claims of violations of environmental regulations by the company.

Today, claims that potentially catastrophic accidents can occur, particularly in parts of the Lagos beach pipeline that were built a long time ago continue to fuel controversy within government circles. This controversy relates to the issue of laxity on the part of environmental protection agencies as well as the legislative arm of the government. The resulting debate casts the spotlight on the importance of enacting new environmental laws. However, it also poses a risk of a move by the Nigerian legislature to pass laws hurriedly, thereby potentially jeopardizing the quality of the laws enacted.[30] Nevertheless, a positive side of the debate has started to emerge; efforts are being made to implement existing environmental laws, a move that offers a ray of hope in efforts to salvage the situation in the natural gas industry.

In some cases, the right course of action would be to amend some of the said laws. Some of the environmental laws that have being put in the spotlight include the Land Use Act, the Associated Gas re-injection Act, the Hydrocarbon Oil Refineries Act, the Exclusive Economic Zone Act, the Water Resources Act, the Petroleum Products and Distribution (Management Board) Act, the Oil Pipelines Act, the Sea Fisheries Act, and the Petroleum Act. During the amendment process, reference should be made to the WAGP Treaty as well as the existing enabling legislation in efforts to establish a harmonized legal framework governing the operations of the West African Gas Pipeline project.

Conclusion

This paper has highlighted various ecological difficulties arising from the implementation of the West African Gas Pipeline project. These problems arise primarily because the four countries involved (Nigeria, Benin, Togo, and Ghana) are yet to harmonize their legal framework. Host communities continue to express concerns about environmental damage following the commissioning of the pipeline. The biggest source of hope for this newly constructed pipeline in terms of the legal regime is the WAGP Treaty. However, the treaty only provides an operational framework. It is upon the participating states to enact enabling legislation for ecological issues to be addressed.

 Enabling legislation provides revisions, changes, as well as new legislation governing operations of the pipeline network. The participating countries have not fully played their roles in safeguarding environmental protection. The only major step that the states have undertaken is the enactment of national legislations aimed at paving the way for the commencement of construction and operation of the pipeline. These laws include West African Gas Pipeline Act, 2005 (Nigeria); Régime juridique et fiscal applicable au project du GAO (Bénin);West African Gas Pipeline Act, 2004 (Ghana); and Régime juridique et fiscal applicable au project du GAO (Togo).

Laws governing social and environmental management of the pipeline should ideally seek to prevent irreparable damage to livelihoods and lands in each of the four countries. Of the four countries involved in the WAGP the Federal Republic of Nigeria has the most extensive experience in the oil and gas industry. The country has encountered numerous environmental problems arising from oil exploitation in the past. This experience greatly contributed to the country’s readiness to embrace the Rio Declaration  during the World Summit of 1992 by enacting requisite legislation. Ghana, Benin, and Togo followed suit by enacting similar laws.

            Finally, WAGPCo, the company in charge of the operating the entire pipeline system, also has a crucial role to play in addressing legal and ecological difficulties facing the WAGP. However, the company’s contribution can only be felt in the presence of harmonized legislation on the environment. Failure by participating states to enact relevant laws have created a culture where WAGPCo adopts a laid-back approach to important issues such as technical integrity, maintenance of aging pipeline systems, and participation in ecological conservation efforts. In conclusion, this paper confirms the thesis that the environmental laws of Nigeria, Togo, Benin, and Ghana need to be harmonized in order to enable project stakeholders to address ecological difficulties relating to the WAGP project.

 

References

Abaza, Hussein., Ronald Bisset and Barry Sadler. Environmental Impact Assessment and Strategic Environmental Assessment: Towards an Integrated Approach. Nairobi: UNEP, 2004.

Adomokai, Rosemary and William Sheate. “Community participation and environmental decision-making in the Niger Delta.” Environmental Impact Assessment Review, 24, no. 5 (2004): 495–518.

Appiah-Opoku, Seth. “Environmental impact assessment in developing countries: The case of Ghana.” Environmental Impact Assessment Review, 21, no. 1, (2001): 59–71.

Ariweriokuma, Soala. The Political Economy of Oil and Gas in Africa: The Case of Nigeria. New York: Routledge, 2009.

Asamoah Joseph. “The Significance of the West African Gas Pipeline project.” African Energy, 4, no. 2 (2000): 52-60.

Ayodele-akaakar, Femi. Appraising the Oil and Gas Laws: A Search for Enduring Legislation for the Niger Delta Region. New York: Free Press, 2007.

Banks, Ferdinand. “An introduction to the economics of natural gas.” OPEC Review 27, no. 1 (2003): 25–63.

Bassey, Nimmo. Oil and Gas in Africa: Ecological Debt Huge as the Sky. Retrieved from http://www.debtwatch.org/documents/enprofunditat/Deute_ecologic/oilandgas.doc  on September 24, 2014.

Costantini, Valeria and Francesco Gracceva. “Security of energy supply: Comparing scenarios from a European perspective.” Energy Policy 35, no. 1 (2007): 210–226.

Donkoh, Elani., Amponsah, Sani and Kelvin Darkwah. “Optimal Pipeline Connection for the West African Gas Pipeline Project.” Research Journal of Applied Sciences, Engineering and Technology 3, no. 2, (2011): 67-73.

Dorian, James & Herman Franssen. “Global challenges in energy.” Energy Policy 34, no. 15 (2006): 1984–1991.

Dunlaney, Michael and Robert Merrick. “Legal Issues in Cross-Border Oil and Gas Pipelines”. Journal of Energy & Natural Resources 23, no. 4 (2005): 247-265.

Economides, Michael and David Wood. “The state of natural gas.” Journal of Natural Gas Science and Engineering 1, no. 1 (2009): 1–13.

Energy Information Administration. West African Gas Pipeline (WAGP) Project. March 2003, retrieved from http://www.eia.doe.gov/emeu/cabs/wagp.html  on September 24, 2014.

Frynas, Jedrzej and Manuel Paulo. “A New Scramble for African Oil? Historical, Political, and Business Perspectives.” African Affairs 106 no 423 (2007): 229-251.

Goodland, Robert. “Oil and Gas Pipelines Social and Environmental Impact Assessment: State of the Art.” Oil, Gas & Energy Law 4, no. 1 (2006): 1-19.

Haruna, Godwin. Maintaining a Balance between Development and Environmental Impacts. London: Routledge, 2007.

Ishisone, Michiko. Gas Flaring in the Niger Delta: the Potential Benefits of its Reduction on the Local Economy and Environment. Boston: Penguin Books, 2012.

Knight, Richard. “Expanding Petroleum Production in Africa.” Review of African Political Economy 30, no. 96, (2003): 335-339.

Malumfashi, Garba. “Phase-out of gas flaring in Nigeria by 2008: The prospects of a multi-win project.” Review of the Regulatory, Environmental and Socio-Economic Issues 2, no. 6 (2006): 29-36.

McAdam, Doug. ““Site Fights”: Explaining Opposition to Pipeline Projects in the Developing World.” Sociological Forum 25, no. 3, (2010): 401–427.

Ndulu, Benno. “Infrastructure, Regional Integration and Growth in Sub-Saharan Africa: Dealing with the disadvantages of Geography and Sovereign Fragmentation.” Journal of African Economies 15, no. 2 (2006): 212-244.

ObaniJesu, Ejioma. “West African Gas Pipeline (WAGP) Project: The Prospect, Associated Problems and Possible Remedies.” LAUTECH Journal of Engineering & Technology 4, no. 2 (2007): 21-45.

Omonbude, Ekpen. “The transit oil and gas pipeline and the role of bargaining: A non-technical discussion.” Energy Policy 35, no. 12 (2007): 6188–6194.

Onuoha, Freedom. “Is This Yet Another False Start? The West African Gas Pipeline Project and the Host Communities in the Niger Delta Region.” Human Security Journal 7, no. 1 (2008):

Onuoha, Freedom. “Why the Poor pay with their Lives: Oil Pipeline Vandalization, Fire Disaster and Human Security in Nigeria.” Disasters 12, no. 5, (2010): 19-27.

Pegg, Scott. “Can policy intervention beat the resource curse? Evidence from the Chad–Cameroon pipeline project.” African Affairs 105, no. 418 (2006): 1-25.

Sonibare, Jani. “Natural gas domestic market development for total elimination of routine flares in Nigeria’s upstream petroleum operations.” Energy Policy 34, no. 6, (2006): 743–753.

Stanley, Onwukwe. “Gas-to-Liquid technology: Prospect for natural gas utilization in Nigeria.” Journal of Natural Gas Science and Engineering 1, no. 6, (2009): 190–194.

WAGP Authority. Bank management response to request for inspection panel of the Ghana: West African Gas Pipeline Project (IDA Guarantee No. B-006-0-GH). Ibadan: University of Ibadan Press, 2006.


End Notes

[1] Asamoah Joseph. “The Significance of the West African Gas Pipeline project.” African Energy, 4, no. 2 (2000): 52-60.

[2] Omonbude, Ekpen. “The transit oil and gas pipeline and the role of bargaining: A non-technical discussion.” Energy Policy 35, no. 12 (2007): 6188–6194.

[3] Dunlaney, Michael and Robert Merrick. “Legal Issues in Cross-Border Oil and Gas Pipelines”. Journal of Energy & Natural Resources 23, no. 4 (2005): 247-265.

[4] Bassey, Nimmo. Oil and Gas in Africa: Ecological Debt Huge as the Sky. Retrieved from http://www.debtwatch.org/documents/enprofunditat/Deute_ecologic/oilandgas.doc  on September 24, 2014.

[5] Abaza, Hussein., Ronald Bisset and Barry Sadler. Environmental Impact Assessment and Strategic Environmental Assessment: Towards an Integrated Approach. Nairobi: UNEP, 2004.

[6] Ariweriokuma, Soala. The Political Economy of Oil and Gas in Africa: The Case of Nigeria. New York: Routledge, 2009.

[7] Dorian, James & Herman Franssen. “Global challenges in energy.” Energy Policy 34, no. 15 (2006): 1984–1991.

[8] Costantini, Valeria and Francesco Gracceva. “Security of energy supply: Comparing scenarios from a European perspective.” Energy Policy 35, no. 1 (2007): 210–226.

[9] Knight, Richard. “Expanding Petroleum Production in Africa.” Review of African Political Economy 30, no. 96, (2003): 335-339.

[10] Haruna, Godwin. Maintaining a Balance between Development and Environmental Impacts. London: Routledge, 2007.

[11] Malumfashi, Garba. “Phase-out of gas flaring in Nigeria by 2008: The prospects of a multi-win project.” Review of the Regulatory, Environmental and Socio-Economic Issues 2, no. 6 (2006): 29-36.

[12] Goodland, Robert. “Oil and Gas Pipelines Social and Environmental Impact Assessment: State of the Art.” Oil, Gas & Energy Law 4, no. 1 (2006): 1-19.

[13] McAdam, Doug. ““Site Fights”: Explaining Opposition to Pipeline Projects in the Developing World.” Sociological Forum 25, no. 3, (2010): 401–427.

[14] Ishisone, Michiko. Gas Flaring in the Niger Delta: the Potential Benefits of its Reduction on the Local Economy and Environment. Boston: Penguin Books, 2012.

[15] WAGP Authority. Bank management response to request for inspection panel of the Ghana: West African Gas Pipeline Project (IDA Guarantee No. B-006-0-GH). Ibadan: University of Ibadan Press, 2006.

[16] Frynas, Jedrzej and Manuel Paulo. “A New Scramble for African Oil? Historical, Political, and Business Perspectives.” African Affairs 106 no 423 (2007): 229-251.

[17] Energy Information Administration. West African Gas Pipeline (WAGP) Project. March 2003, retrieved from http://www.eia.doe.gov/emeu/cabs/wagp.html  on September 24, 2014.

[18] Appiah-Opoku, Seth. “Environmental impact assessment in developing countries: The case of Ghana.” Environmental Impact Assessment Review, 21, no. 1, (2001): 59–71.

[19] Donkoh, Elani., Amponsah, Sani and Kelvin Darkwah. “Optimal Pipeline Connection for the West African Gas Pipeline Project.” Research Journal of Applied Sciences, Engineering and Technology 3, no. 2, (2011): 67-73.

[20] Onuoha, Freedom. “Is This Yet Another False Start? The West African Gas Pipeline Project and the Host Communities in the Niger Delta Region.” Human Security Journal 7, no. 1 (2008):

[21] Stanley, Onwukwe. “Gas-to-Liquid technology: Prospect for natural gas utilization in Nigeria.” Journal of Natural Gas Science and Engineering 1, no. 6, (2009): 190–194.

[22] Sonibare, Jani. “Natural gas domestic market development for total elimination of routine flares in Nigeria’s upstream petroleum operations.” Energy Policy 34, no. 6, (2006): 743–753.

[23] Ndulu, Benno. “Infrastructure, Regional Integration and Growth in Sub-Saharan Africa: Dealing with the disadvantages of Geography and Sovereign Fragmentation.” Journal of African Economies 15, no. 2 (2006): 212-244.

[24] Ayodele-akaakar, Femi. Appraising the Oil and Gas Laws: A Search for Enduring Legislation for the Niger Delta Region. New York: Free Press, 2007.

[25] ObaniJesu, Ejioma. “West African Gas Pipeline (WAGP) Project: The Prospect, Associated Problems and Possible Remedies.” LAUTECH Journal of Engineering & Technology 4, no. 2 (2007): 21-45.

[26] Adomokai, Rosemary and William Sheate. “Community participation and environmental decision-making in the Niger Delta.” Environmental Impact Assessment Review, 24, no. 5 (2004): 495–518.

[27] Economides, Michael and David Wood. “The state of natural gas.” Journal of Natural Gas Science and Engineering 1, no. 1 (2009): 1–13.

[28] Pegg, Scott. “Can policy intervention beat the resource curse? Evidence from the Chad–Cameroon pipeline project.” African Affairs 105, no. 418 (2006): 1-25.

[29] Onuoha, Freedom. “Why the Poor pay with their Lives: Oil Pipeline Vandalization, Fire Disaster and Human Security in Nigeria.” Disasters 12, no. 5, (2010): 19-27.

[30] Banks, Ferdinand. “An introduction to the economics of natural gas.” OPEC Review 27, no. 1 (2003): 25–63.

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