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Letter to SETENA from Environmental Defense

January 11. 2002

Dear SETENA Administrators:

We are writing on behalf of the 300,000 members of Environmental Defense to express our strong concern about the current proposal by Harken Energy and MKJ Exploration to drill an initial offshore exploratory well in the Caribbean near the port of Moín. Our concern stems from the fact that this proposal poses an unacceptable level of risk to the Caribbean and to the ecosystems, fisheries, and wildlife of Costa Rica's Limón province. The global significance of this region is highlighted by the adjacent UNESCO World Patrimony Site, including the Cahuita National Park, the Ramsar site at the Gandoca-Manzanillo National Wildlife Refuge, and areas reserved for three indigenous ethnic groups.

The government of Costa Rica has made remarkable advances in protecting its environment and natural resources, and responsible ecotourism provides an important contribution to the economy of the nation. We therefore strongly urge SETENA to deny Harken/MKJ permission to proceed with exploratory drilling until the company can provide conclusive, peer-reviewed scientific evidence that the environment can be fully protected. This evidence must incorporate a credible oil spill emergency preparedness response plan tailored to all types of habitat in the region. In addition, disclosure of anticipated cumulative impacts likely to occur during all phases of operations must be prepared and independently reviewed by qualified scientific authorities.

Present offshore drilling technologies have, unfortunately, demonstrated an inability on the part of hydrocarbon operations to prevent environmental harm. A recent study of toxic contaminants adjacent to U.S. Gulf of Mexico drilling rigs has confirmed the presence of dangerously elevated levels of harmful mercury in fish around the oil operations. In addition, even state-of-the-art oil spill containment and cleanup techniques can, at best, recover only a small fraction of any oil spill, even in calm seas. Important lessons can be learned from tragic accidents involving operations similar to that being proposed for the Moin site. In November 1985, an offshore exploratory well on the drilling rig Ranger blew out off the coast of Texas, and 6.3 million gallons of oil spilled into the sea. On June 3, 1979, the IXTOC I exploratory well blew out on a U.S. rig operating in the Bay of Campeche off Ciudad del Carmen, Mexico. By the time the damaged rig was finally brought under control—not until well into the following year in 1980—an estimated 140 million gallons of oil had leaked out. At one time during this spill, approximately 10 percent of the Gulf of Mexico was covered with an oily slick or sheen, and sticky tar balls washed ashore as far away as Padre Island in Texas and damaged tourism revenues there.
In light of the highly sensitive biological resources at risk in the vicinity of the proposed Harken/MKJ project, to permit this operation to proceed in light of these significant risks and routine adverse impacts would be extremely ill advised. The area of the proposed project is very fragile, composed of vibrant coastal reefs, lagoons, beaches and tropical jungle, including the most pristine and extensive mangrove lagoon in Costa Rica. Access to the shoreline for the purposes of removing spilled oil would be impossible in many areas, and mangroves and wetlands represent two of the most sensitive and difficult-to-remediate types of habitat in the event of a spill. The animal species at risk are unique to the region and depend on these habitats for survival. Sea turtles use this area as their breeding grounds, including the green, leatherback, hawksbill and great-headed turtle. The population of green turtles in the area is the largest in the Western Hemisphere. Together with the leatherback, they represent the fourth largest sea turtle population in the world. Even so, this species remains at risk for extinction, according to the Convention on International Trade in Endangered Species (CITIES).

The coral reefs jeopardized by the Harken/MKJ project are the most diverse, productive and well-established in all of Costa Rica. These reefs provide refuge and breeding areas to many species of fish important to the local economy. The fishing industry supports between 600 and 800 jobs in the province of Limón, and many more people depend upon tourism generated by the presence of the Caribbean coral reefs. Damage to the marine environment would translate directly into unemployment and long-term adverse social consequences in the region.

Onshore support facilities required by drilling offshore are also an area of concern. Air pollution, routine spills, and other industrial impacts inevitably accompany the necessary onshore processing of produced oil. In the event of petroleum discoveries, numerous barge and tanker trips from processing plants to refining centers would elevate the risk of a large oil spill causing impacts over a significant geographic area.

Environmental Defense encourages SETENA to reject the Harken/MKJ proposal at this time, since this plan poses an unacceptable level of risk to the economic and ecological foundation of Costa Rica and to living resources of international significance.Sincerely,

Richard Charter
Marine Conservation Advocate
Ken Lindeman, Phd.
Marine Scientist
Azur Moulaert
Coastal Resources AnalystEnvironmental Defense
Oceans Program
257 Park Avenue South
New York, NY 10010
212 505-2100

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