THE STABROEK SURRENDER

THE 592 GUARDIAN ♦ Independent Accountability Journalism  ·  Guyana

EDITORIAL

THE STABROEK SURRENDER

Part IV of IV  ·  Pollute As Much As You Want

Pollute As Much As You Want, Provided You Can Pay For It

Guyana was promised zero flaring at the Stabroek Block. Instead, ExxonMobil has burned off more than a billion cubic feet of gas into the Atlantic sky, paid a fraction of what independent analysts say the pollution is worth, and won in court when Guyanese citizens tried to force a stricter permit. This is the enforcement gap at the heart of Guyana’s oil era — and the final installment of this series.

Parts I through III of this series traced the arithmetic of the 2016 Production Sharing Agreement (PSA), the stability clause that froze that arithmetic beyond Parliament’s reach, and the decommissioning liability Guyana is quietly pre-funding with no guarantee the money will still exist when it is needed. Part IV closes the series by asking a simpler question: when the Contractor breaks its own environmental promises, what actually happens?

The answer, on the public record, is: not very much

The Promise: Zero Flaring

When the Government of Guyana approved the environmental permit for the Liza Phase 1 project, it did so on the strength of a specific commitment. ExxonMobil’s own environmental impact assessment represented that the project could achieve zero non-routine gas flaring — that associated gas produced alongside crude oil would be captured and reinjected into the wells rather than burned off into the atmosphere. The Minister of Natural Resources at the time stated unequivocally that under no circumstances would there be flaring of the gas.

“That promise did not survive first production. Faulty compression equipment aboard the Liza Destiny FPSO caused ExxonMobil to begin flaring within weeks of the field coming online in December 2019, and it has continued in one form or another ever since.”

What the Satellite Data Shows

Independent verification, rather than company self-reporting, has driven most of what the public knows about the scale of the problem. Satellite monitoring compiled through the Every Last Drop project using SkyTruth data, cross-referenced with figures from the environmental rights organization Arayara Institute, documented 1,298 separate flaring events at the Stabroek Block between 2019 and 2023 alone, releasing an estimated à 1.32 million tons of CO2 — comparable to the annual emissions of roughly 287,000 cars. The analysis found the block’s flaring had made Guyana the second-largest gas-flaring emitter in the entire Amazon basin, trailing only Ecuador.

By July 2021, the Government’s own figures put cumulative flared gas at more than 15.1 billion cubic feet. That volume represents energy roughly equivalent to Guyana’s entire national electricity consumption for a year, burned into the sky rather than captured.

The Permit Was Weakened, Not Enforced

The regulatory response to this pattern was not tightening. It was loosening. In April 2021, environmental activists including Sherlina Nageer, using satellite evidence they had gathered independently, formally alerted the Guyana Environmental Protection Agency (EPA) to the scale of ongoing flaring. Within a month of that complaint, the EPA revised ExxonMobil’s environmental permit — not to strengthen the zero-flaring requirement, but to extend the allowable flaring period from three consecutive days to sixty.

Citizens challenged the legality of that modification in court, arguing that a permit change of this magnitude, made without a new environmental impact review, was unlawful. In 2023, Chief Justice Roxanne George ruled in ExxonMobil’s favour, finding that it had not been proven the modified permit was causing additional adverse environmental effects, and that nothing in Guyanese law prevented the issuance of a modified permit on those terms.

“The government is basically saying: pollute as much as you want, provided you can pay for it.”

That assessment came from Dr. Vincent Adams, the former Head of Guyana’s Environmental Protection Agency and a thirty-year veteran of the US Department of Energy, responding to the court’s ruling. Dr. Adams has been a recurring, credible critic of the regulatory posture Guyana’s institutions have taken toward ExxonMobil throughout this series’ reporting, and his assessment of the flaring permit fits the broader pattern: technically lawful concessions, made in response to the Contractor’s operational failures, that leave the public paying the environmental cost while the Contractor pays a fee calibrated well below the damage.

The Fines Do Not Match the Harm

Guyana calculates flaring penalties under the Polluter Pays Principle set out in its 1996 Environmental Protection Act. The rate has increased over time — from US$30 per tonne of CO2-equivalent under the original permit, to US$45, and now to US$50 under the renewed five-year Liza 1 permit issued in 2025. By late 2021, the EPA confirmed it had collected approximately G$930 million, or roughly US$4.5 million, in cumulative flaring payments from ExxonMobil.

The Institute for Energy Economics and Financial Analysis (IEEFA) found that figure hard to square with the scale of the pollution. Using a benchmark rate of US$75 per tonne — a level IEEFA characterized as more realistic — the organization calculated ExxonMobil should have paid closer to US$26 million for the flaring recorded through mid-2021: roughly six times what it had actually paid. ExxonMobil separately paid an US$8.4 million penalty in 2022, a sum that registers as a rounding error against a company that recorded tens of billions of dollars in global annual profit in the same period.

For comparison, when ExxonMobil flared gas on American soil, the U.S. Environmental Protection Agency and Department of Justice fined the company US$2.5 million in 2017 and required a further US$300 million outlay for pollution-control technology at its domestic facilities. Guyana’s cumulative flaring collections, spread across years and multiple incidents, remain a fraction of what US regulators extracted for a single enforcement action.

A Pattern Consistent With the Rest of the Series

Read against Parts I through III, the flaring record is not an isolated environmental footnote. It is the same structural imbalance this series has documented in the fiscal terms, the stability clause, and the decommissioning liability, now visible in environmental enforcement:

A Contractor whose commitments were not met, a regulator whose response was to relax the rule rather than enforce it, a judiciary that found the relaxation lawful, and a public that bears the atmospheric and reputational cost while the financial penalty remains, by independent estimate, a fraction of the damage.

The scale of what is now at stake is only growing. Stabroek Block output surpassed 918,000 barrels per day in February 2026, with the consortium targeting 1.7 million barrels per day by 2030 and ExxonMobil now seeking environmental authorization for a further 35-well exploration campaign running through 2033. Guyana’s environmental regulator has, for the first time, requested a cumulative impact study covering that new campaign alongside all other offshore activity — a modest but real acknowledgment that project-by-project review has not been sufficient. Whether that acknowledgment translates into enforcement, rather than another accommodation, is the question this series leaves the public, and the Government, to answer.

What The 592 Guardian Is Asking

In concluding this series, we are putting the following questions on the public record, to the Environmental Protection Agency, the Ministry of Natural Resources, and the Department of Energy:

1. What is the current cumulative total, in both Guyana dollars and US dollars, that ExxonMobil and its partners have paid in flaring penalties since December 2019, broken down by year and incident?
2. What analysis, if any, did the EPA conduct before extending the permitted continuous flaring window from three days to sixty days in 2021, and will that analysis be published?
3. Does the Government consider the current US$50-per-tonne flaring penalty rate to reflect the actual environmental and climate cost of the emissions, and if not, what rate would it consider adequate?
4. In light of the cumulative impact study now being requested for the proposed 35-well exploration campaign, will the EPA apply the same cumulative standard retroactively to the flaring record of the currently producing FPSOs?

We extend the Government and the Contractor an open invitation to respond in full; any response received will be published without alteration alongside this editorial.

This concludes The Stabroek Surrender. Across four parts, this series has examined the fiscal terms, the stability clause that locked them in place, the decommissioning liability Guyana is pre-funding without safeguard, and the flaring record that has outpaced enforcement. ,The throughline is consistent: a Government that entered a defining national contract from a position of weakness, and has since treated every mechanism for correcting that weakness — renegotiation, arbitration exposure, financial safeguards, environmental enforcement — as a fixed cost of doing business rather than a lever available to a sovereign state. The 592Guardian will continue reporting on the audit void and the question of government complicity in a future series.

— The Board, The 592 Guardian