In 2018, Ghana National Petroleum Corporation (GNPC) began decommissioning the Mr. Louie platform in the Saltpond oil field, Ghana's first-ever decommissioning exercise. The process was meant to be a proud moment of environmental responsibility but became a textbook case of what happens when the Fisheries Commission is not involved. The commission was not formally involved in the decommissioning process, which led to several issues, including the lack of a biological baseline, fishermen becoming afterthoughts, and an explosion in costs.
The decommissioning process lacked a biological baseline, as no fisheries stock assessment was done before the exercise. There was no record of what fish bred in the area, what species were sensitive, or what sediment chemistry would support recovery. As a result, Ghana National Petroleum Corporation could certify that steel was removed but could not certify that fish could return. The restricted zone was declared, but artisanal fishers from Nkotomso and Saltpond were informed late, in English, without Chief Fishermen.
The cost of decommissioning the Saltpond oil field has been estimated at $200 million, a significant increase from the initial expectations. The field earned Ghana $10 million in 55 years but is now costing close to $200 million to clean. The cost includes a $96 million contract to Hans & Co, $89 million spent by 2024, and a structure still present, with $81 million more demanded. The scope kept changing due to contaminated sediments, unplugged wells, and unstable seabed issues, which a fisheries environmental survey would have identified upfront.
Ghana is preparing for a much bigger decommissioning bill, with $704 million in a Decommissioning Trust Fund at the Bank of Ghana for Jubilee alone, to be ready by 2036. The engineering plan is to cut, lift, and dispose, but engineering questions are not fisheries questions. The Fisheries Commission can provide critical information on fish habitats, spawning grounds, migration corridors, and upwelling zones. Petroleum engineers cannot answer these questions, but the Fisheries Commission can with data from 20 years of trawl surveys, canoe frame surveys, and VMS tracks.
The Fisheries Commission can perform four critical functions in future decommissioning exercises. Firstly, it can provide a Biological Clearance Certificate before decommissioning, which includes a Fish Habitat Baseline. After decommissioning, it must issue a Biological Restoration Certificate, not just "steel removed" but "sediment clean for fish breeding, water TPH below 0.1ppm, fish tissue safe." This protects Ghana from EU export bans, which could collapse the country's $425 million export market if hydrocarbons are detected in Ghana's fish.
The Fisheries Commission also holds Ghana's only map of Critical Fish Habitats, including spawning grounds, migration corridors, and upwelling zones. In future exercises, it must overlay decommissioning plans on this map to declare No-Go periods. For example, "No seabed disturbance in Cape Three Point Basin between June-August, which is peak spawning of small pelagics." This costs the government zero but saves fish recruitment worth billions. The commission can also advise on community compliance and asset-to-reef conversion, creating fishing grounds and dive tourism sites while saving removal costs.
The way forward is not to create new laws but to implement existing ones. The Petroleum (Decommissioning) Regulations should be amended to state that no decommissioning plan shall be approved by the Minister without a Fisheries Impact Assessment endorsed by the Fisheries Commission, a Navigation Safety Clearance by the Ghana Maritime Authority, and a post-decommissioning biological monitoring plan to be executed by the Fisheries Commission. The cost to the government with regards to this amendment in legislation is negligible, if not zero. The benefit to the government is a defensible, internationally compliant decommissioning that protects food security, exports, and maritime safety.
Key points
- Involving the Fisheries Commission in decommissioning exercises can save costs and ensure environmental sustainability.
- Ghana's $200 million lesson from the Saltpond decommissioning exercise can inform future decommissioning processes.
- The Fisheries Commission can perform critical functions in future decommissioning exercises, including providing biological clearance certificates and advising on community compliance and asset-to-reef conversion.
