October 8, 2004
Thank you for finally responding our letter dated on September 24th, regarding the meetings which Sakhalin Energy Investment Company (SEIC) is planning to hold in Tokyo and Hokkaido on October 12th and 13th on Sakhalin II oil and gas development project (Sakhalin-II).
First of all, we welcome that the EIA addendum will be translated into Japanese. On this point, we would like to urge you to consult with Japanese stakeholders which part of the addendum should be translated into Japanese. In addition, other important documents including Environmental Action Plan also should be translated into Japanese.
We carefully read the response letter. We regret that SEIC doesn't accept the fundamentally important matters which we raised regarding the process, to have real engagement and meaningful dialogue at the meetings in Japan. The transparent and accountable process is an essential key to achieve best practice, to undertake appropriate environmental and social considerations, and to prevent or minimize the impacts by the development project.
From the response, these fundamental points regarding the meetings are completely failed. For example, SEIC stated that the minutes of previous meetings are on the website to ensure the transparency. However the minutes are too simplified as only 2 pages long even for a whole day meeting. They are hardly to understand how the discussion went and what were the outcomes and/or pending issues of the meetings. Besides, SEIC have had meetings twice, each in Sapporo and Tokyo. The minutes of two of these meetings are not on the website.
SEIC said in the letter, "What we can say is that any constructive proposals will be studied by the Company (SEIC) and may be implemented if it is technically and economically feasible." According to the Guideline for Confirmation of Environmental and Social Consideration of Japan Bank for International Cooperation (JBIC), "Environmental impact which may be caused by a project must be assessed and examined.." "Such examination must include analysis of environmental costs and benefits in as quantitative terms as possible and be conducted in close harmony with economic, financial, institutional, social and technical analysis of the project." The current attitude of SEIC is clearly against the requirement of the guidelines. The environmental aspects should be ranked equal with the economical and technical aspects.
As the results of seriously consideration, we came to a conclusion that we will not participate the meetings again this time, although it was not an easy decision to make since we have serious demands to SEIC.
Sincerely,
Friends of the Earth Japan
3-17-24-2F Mejiro, Toshima-ku, Tokyo 171-0031, Japan
TEL: +81-3-3951-1081 FAX: +81-3-3951-1084