I think it can be said that the Train 7 project and other oil and gas initiatives of the Nigeria Liquefied Natural Gas Limited (NLNG) and other international oil and gas companies (IOCs) are prosperity generating initiatives in contemplation but whether this can be said when implementation is considered is another discussion altogether.

But a critical look at the Train 7 project unveils avenues as to how the Bonny Kingdom Local Content Compliance Committee (BKLCCC) can bring prosperity to the host communities leveraging the various provisions of the Nigerian Oil and Gas Industry Content Development (NOGICD) Act, especially, its Community Content Guidelines (CCG).

While these submissions are not exhaustive, these are just some ways the BKLCCC, as the local content and community interest gatekeeper and aggregator, can leverage on the NOGICD Act and the NCDMB Community Content Guideline (CCG) to bring prosperity to the Host Communities affected by these oil and gas activities.

1. DEVELOPMENT OF THE LOCAL CONTENT COMMITTEE

I. This Committee should be made up of people with impeccable track record of excellence and INTEGRITY. Bonny LGA has a long list of captains of industries, internationally recognised corporate giants as well as men and women with high degree of integrity, let them 100% of this HCLCC.

II. For Competence, the LCC should hire Consultants for the various key Disciplines, Oil & Gas, Project Management, Legal and Environmental. If they cannot afford the services of Consultants, then they should have these people among its LCC members.

– The Oil & Gas Expert understands the Technical Scope and Philosophy driving the Project and can guide the Team. He/she understands the minimum international best practices attainable in the oil and gas sector.

– The Project Management Expert can assist with assessing and measuring Project Deliverables like Schedule and Resourcing (Men, Machine & Materials all through the Project Lifecycle), Construction Strategy (Early Works, Site Fabrication, Offsite Fab, Modularisation, Use of 3D-Printing).

– The Legal Expert would guide both Contractor and Community to achieve Legal Compliance

– The Environmental Expert guides on ensuring Compliance on the Environmental, Social and Management Plan (ESHMP), Environmental Protection and Conservation as well as Biodiversity.

2. DEVELOPMENT OF THE PROJECT HOST COMMUNITY LOCAL CONTENT PLAN (HCLCP)

I. By the NOGICD Act, all Capital Projects in Nigeria should have a Nigerian Content Plan developed and from that NC Plan the LCC can work out a Plan for the Host Community which would be the Host Community Local Content Plan for the Project. This could be developed by the LCC.

II. Best practice is to develop this HCLCP before Contractor mobilises to Site

III. The HCLCP should follow the NCDMB Community Content Guideline Template, which has elements such as Project Office, Employment and Human Capital Development, Procurement of Goods, Funding and Governance Framework

IV. The HCLCP may use Percentages or fixed Rates for some variables, but percentages may be best like stating:

– What Percentage of Nigerian Procurement for Piping and Heavy Steel should go to Host Community Contractors?

– What Percentage of Engineering Design should go to Host Community Contractors?

– What percentage of Nigerian Contractors given Entrepreneurial Training and Credit/Loans /Support should go Host Community?

– What Percentage of Nigerian Construction should go the Host Community?

IV. A Terms of Reference (TOR) should be developed for every Project and that TOR would guide the HCLCC and this should be made public so everyone knows the mandate and scope of LCC.

3. DEVELOPING KEY PERFORMANCE INDICATORS (KPI’S) FOR MONTHLY/BI-MONTHLY/QUARTERLY EVALUATIONS AND ENGAGEMENTS

I. The NOGICD Act and the NCDMB Community Content Guideline have stipulated Parameters for Employment, Contracting and all these should be used to develop the Host Community Local Content Plan (HCLCP) and this should be made public.

II. The HCLCP should develop SMART (Specific, Measurable, Achievable, Realistic and Timely) Parameters for Monitoring and Tracking of its implementation.

III. This Parameters would be agreed by all Parties and signed off before Commencement of Construction and monitored immediately Project commences.

IV. Parameters could be developed by the Project Management Expert, benchmarking the Implementation of the HCLCP as against the Schedule and Progress of the Project, for example

– at 20% of the Project, xx Nos of Host Community Contractors should have executed N100million (for example) volume of Contracts. (Verify and if there are gaps, get commitments to close gaps at agreed time.)

– at 20% of Project, XXNos of Host Community Youths should have been employed or trained. (Verify and if there are gaps, get commitments to close gaps at agreed time.)

V. These Engagements should be held in corporate settings that can provide space for Civil Society Organisations and Media to participate and cover.

VI. The Reports or Minutes of these Meetings should be made public within the Key stakeholders (I don’t know if time would allow for me to talk on Stakeholder Mapping as a crucial tool here).

VII. These Reports can even be in Monthly or Quarterly Magazines (even e-Mags) or periodic Roadshows showcasing the works and achievements of the HCLCC.

VIII. The HCLCC should have an Official Tool (Magazine, Social Media, Roadshow) wherein it disseminates information.

IX. Feedback and Complaint Mechanism should be in place and active.

4. CONSEQUENCE MANAGEMENT AND CONFLICT MANAGEMENT

I. With periodic monitoring of implementation, non-compliance can be detected and if incidences of non-compliance are deliberate after exhausting all cordial approaches, then the HCLCC can activate the Consequence Management Clauses as provided by the NOGICD Act on the Contractor and on the Client if necessary.

II. If any of the team members of the HCLCC is seen violating his/her trusts, such should be made to subjected to a Fair Hearing and if found guilty is taken off the Committee.

III. A Conflict Resolution Strategy should be developed as part of the HCLCP to manage Conflicts and Crisis Resolutions.

Promise Wilcox, an Health, Safety and Environment (HSE) Professional, Energy Analyst and Development Strategist, wrote in this article from Bonny Island, Rivers State.