Who gains from saving nature
Ledger 1 : 33 — For each dollar financing nature-based solutions in 2023, about $33 financed activities harmful to nature. (UNEP)
Cases / Oil, gas and coal operations · Kazakhstan · 2013–2018

Embamunaigas sour-gas flaring at the Prorva fields (Atyrau, 2014 and 2018)

Nature's voice · report
No measurement of the harm done to me here is on record.
Did nature suffer? Not measured. Disputed
What the record lacks: 3 none on record · 1 not disclosed · 1 not measured · 3 disputed See the gaps
Accounts of the harm differ
Whether associated gas was still being flared after 2014
  • Company or project RD KMG (2014): As of today, associated gas is not vented. Forbes.kz
  • Press and investigations Kursiv (2018), citing the Atyrau regional environment department: Embamunaigas flared sour associated gas at Prorva without an environmental permit from 1 November 2017 to 12 June 2018. Kursiv

The Atyrau environmental department ordered Embamunaigas and RD KMG to pay KZT 37.2 billion in 2014 for flaring sour associated gas at the Prorva fields; after appeals the order was reduced to KZT 1.9 billion. In 2018 a fine of KZT 8.9 billion was cut by a court to KZT 6.68 billion and collected.

KZT 37.2bn → 1.9bnEnvironmental damage order for gas flaring at Prorva, 2014
Reduced after the company's appeals to the Prosecutor General's Office and a specialised economic court; Forbes.kz reported the reduced amount paid by RD KMG on 31 July 2014.

Status As of December 2018: a court had ordered a halt to sour gas flaring at Prorva (not yet in force); the KZT 7.835 billion damage order was unpaid; later outcomes are not on record.

What?
State orders and fines against Embamunaigas and RD KMG for flaring sour associated gas without permits at the Prorva fields: a KZT 37.2 billion order in 2014 reduced to KZT 1.9 billion, and fines and damage orders in 2018 including a KZT 6.681 billion fine collected after a court reduction. Forbes.kz
Where?
Prorva group of fields, Zhylyoi district, Atyrau region, Kazakhstan. Forbes.kz
When?
Order in early 2014, reduced order reported paid 31 July 2014; emissions without permit 1 November 2017 to 12 June 2018; Kursiv report 6 December 2018. Kursiv
Who?
Gained
  • Kazakh state budget — KZT 1.9 billion (2014) and a court-reduced fine of KZT 6.681 billion (2018) Kursiv
Lost
  • Embamunaigas and RD KMG — Paid the reduced 2014 order and the 2018 fine; a KZT 7.835 billion damage order was unpaid at publication Kursiv
Harmed
  • Air at the Prorva fields — Sour associated gas flared without permits in 2013–2014 and from November 2017 to June 2018; volumes not stated Kursiv
Why?
Flaring of sour associated gas without permits; RD KMG pointed to associated-gas processing capacity added at Vostochny Makat and S. Balgimbaev. Forbes.kz
How?
Orders and fines by the Atyrau regional environment department after prosecutors' inspections, reduced after appeals to the Prosecutor General's Office, a specialised economic court and, in 2018, a court. Kursiv
6 of 6 questions answered from the record

What happened

The record, in order.

In June 2013 inspectors filmed gas venting at three Embamunaigas fields other than Prorva (Vostochny Makat, Novobogatinsk Yugo-Vostochny and Vostochny Zhanatalap); the company paid a fine of KZT 55,000 for those. After a regional prosecutor's inspection, the Atyrau regional environmental department ordered RD KMG and Embamunaigas JSC, a subsidiary of KazMunayGas Exploration Production, to pay KZT 37.2 billion for damage from flaring sour associated gas without permits at the Prorva group of fields. After the company appealed to the Prosecutor General's Office and a specialised economic court, the department issued a new order for KZT 1.9 billion, which Forbes.kz reported on 31 July 2014 as paid by RD KMG.

RD KMG's deputy head of public relations said at the time that, following the appeal, the department had issued a new order with a reduced amount, and that as of 2014 associated gas was not vented. The company's gas-utilisation measures included an associated-gas processing plant at Vostochny Makat (40 million cubic metres a year, end of 2013) and a gas unit at S. Balgimbaev (20 million cubic metres a year).

In 2018 Kursiv reported that Embamunaigas had flared sour associated gas at Prorva without an environmental permit between 1 November 2017 and 12 June 2018. Inspections ran from April to June 2018 and from 12 June to 10 October 2018. The first 2018 fine was KZT 8.908 billion, which a court reduced to KZT 6.681 billion and which was collected; an environmental damage order of KZT 7.835 billion was unpaid at the time of publication in December 2018; a second fine of KZT 6.862 billion and an assessed damage of KZT 6.032 billion were also reported.

In late November 2018 a court ordered a halt to sour gas flaring; Kursiv reported that the ruling was not yet in force. Associated gas output from January to October 2018 was 135.96 million cubic metres, 1.38 million above plan; the volume flared is not stated.

  1. 2013Inspectors film gas venting at three other Embamunaigas fields; KZT 55,000 fine (Jun)
  2. 2014Atyrau department orders KZT 37.2bn for flaring at Prorva; after appeals a new order of KZT 1.9bn; reported paid by RD KMG (31 Jul)
  3. 2018Emissions without permit 1 Nov 2017–12 Jun 2018; inspections Apr–Oct; fine of KZT 8.908bn reduced by a court to KZT 6.681bn; court orders a halt to sour gas flaring, not yet in force (late Nov)

What was said

Claims, in the words of those who made them.

“Following the appeal, the department of ecology issued a new order with a reduced amount – 1.9 billion tenge”

RD KMG deputy head of public relations (translated) · 2014 · translated from Russian · Forbes.kz

“As of today, associated gas is not vented.”

RD KMG deputy head of public relations (translated) · 2014 · translated from Russian · Forbes.kz

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

Size of the court's reduction of the first 2018 fine
Press and investigations
Kursiv (6 December 2018), one passage

The court reduced the KZT 8.908 billion fine by 25% to KZT 6.681 billion.

Kursiv
Press and investigations
Kursiv (6 December 2018), another passage

The reduction was 30%.

Kursiv
Whether associated gas was still being flared after 2014
Company or project
RD KMG (2014)

As of today, associated gas is not vented.

Forbes.kz
Press and investigations
Kursiv (2018), citing the Atyrau regional environment department

Embamunaigas flared sour associated gas at Prorva without an environmental permit from 1 November 2017 to 12 June 2018.

Kursiv

How it looked

What was shown, beside what was recorded.

Shown

  • Headline: “RD KMG paid 1.9 bn tenge for environmental damage”.
    Forbes.kz, citing Ak Zhaik, 31 July 2014 · Forbes.kz
  • The 2018 fines and orders were reported with the Atyrau regional environment department and RD KMG's nine-month 2018 interim report cited as sources.
    Kursiv, 6 December 2018 · Kursiv

Recorded

  • Order of KZT 37.2 billion (2014), replaced after appeals by an order of KZT 1.9 billion.
  • 2018 fines and damage orders: KZT 8.908 billion fine reduced by a court to KZT 6.681 billion and collected; KZT 7.835 billion damage order unpaid at publication; KZT 6.862 billion second fine; KZT 6.032 billion assessed damage.
  • A court ordered a halt to sour gas flaring in late November 2018; the ruling was not yet in force.
  • Associated gas output January–October 2018: 135.96 million cubic metres, 1.38 million above plan.

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
Remediation or restoration funded by the orders and fines—
None on record.

Gained elsewhere

Not totalled
Fine for venting at three other fields (2013)0.06m
Window: 2013
KZT 55,000.
Environmental damage order, 2014 (original)37.2bn
Window: 2014
Reduced order, reported paid by RD KMG (July 2014)1.9bn
Window: 2014
First 2018 fine after court reduction (collected)6.7bn
Window: 2018
Original fine KZT 8.908 billion.
Environmental damage order, 2018 (unpaid at publication)7.8bn
Window: 2018
Second 2018 fine6.9bn
Window: 2018
Assessed damage tied to the second fine6bn
Window: 2018
Currency: KZT · Window: 2013–2018 (mixed — see each line). Figures cover different periods and are not compared as a ratio. * Estimate built from cited figures.

Responses on record

  • RD KMG (2014): Following the appeal the department of ecology issued a new order with a reduced amount of KZT 1.9 billion; as of 2014 associated gas was not vented. · Forbes.kz

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

  1. 2014–2014Reduced on appealKZT 1.9bn reduced order, reported paid by RD KMG
    Appeal by RD KMG and Embamunaigas against the KZT 37.2bn damage order
    Specialised economic court and Prosecutor General's Office (company appeals) · Appeal · RD KMG and Embamunaigas → Atyrau regional environmental department

    After a regional prosecutor's inspection the department ordered KZT 37.2 billion for flaring sour associated gas at Prorva; following the company's appeals the department issued a new order for KZT 1.9 billion. Forbes.kz

  2. 2018–2018Claimant wonKZT 6.68bn fine after court reduction from KZT 8.908bn; collected
    Atyrau regional environment department v. Embamunaigas (fine for gas flaring without permit, 2017–2018)
    Court not named · Administrative · Atyrau regional environment department → Embamunaigas JSC

    The court reduced the first 2018 fine by 25% (the article also says 30%) to KZT 6.681 billion, which was collected; a damage order of KZT 7.835 billion was unpaid at the time of publication. Kursiv

  3. 2018–2018Ongoing
    Court order to halt sour gas flaring at Prorva
    Court not named · Civil · Not stated in the source → Embamunaigas JSC

    A court ordered a halt to sour gas flaring in late November 2018; the ruling was not yet in force when Kursiv published on 6 December 2018. Kursiv

Insurers

No insurer decision on record.

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Damage order for flaring at Prorva, 2014
KZT 37.2bn → 1.9bn
Reduced after appeals
2018 fine after court reduction
KZT 6.681bn
From KZT 8.908bn; collected
Period of emissions without permit, 2018
1 Nov 2017–12 Jun 2018
Per Kursiv; volumes flared not stated

What we don't know

Undisclosed, unproven, untried: recorded as data.

Nature

  • Not measured Harm to nature: The record holds no measurement of harm to nature.
  • Disputed Whether associated gas was still being flared after 2014

Money

  • None on record Remediation or restoration funded by the orders and fines — None on record.

Accounts

  • Disputed Size of the court's reduction of the first 2018 fine

Record

  • Not disclosed Not disclosed: the volume of gas flared at Prorva in 2018; the source gives only associated gas output of 135.96 million cubic metres for January–October 2018.
  • None on record None on record: payment of the KZT 7.835 billion damage order; Kursiv reported it unpaid as of December 2018.
  • Disputed Figures differ: Kursiv describes the court's reduction of the first 2018 fine as 25% in one passage and 30% in another.
  • None on record None on record: measured environmental data, and insurance cover or payments.

Did the harm stop?

RD KMG said in 2014 that associated gas was no longer vented; Kursiv reported flaring without a permit again from 1 November 2017 to 12 June 2018, and a court order to halt it in late November 2018, not yet in force.

Who paid?

RD KMG paid the reduced KZT 1.9 billion order in 2014, and Embamunaigas had paid a court-reduced fine of KZT 6.681 billion by December 2018; the KZT 7.835 billion damage order was unpaid at that date. Use of the money for nature is not on record.

Sources

Voices on record: — Company or project— Government and regulators— Courts✓ Press and investigations— Communities and civil society— Researchers

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