u003cbr/u003eThe Management Prescriptions Review Panel Asks: u003cstrongu003eIs there a clear confirmation that the increase in exploitable methane mass in Lake Kivu is not discernible within the next 50 years? u003c/strongu003e

u003cstrongu003eu003cbr/u003e u003cemu003e(A) In reply to the following comment: “On the matter of non-biogenic sources of methane and sudden inflow events and significant recharge of methane”:u003c/emu003e u003c/strongu003eu003cbr/u003e u003cbr/u003eThere is no credible scenario for a non-biogenic inflow of methane into the lake. Fossil methane is speculated to have formed in the Graben underlying lake Kivu. The proximity of hot volcanic zones under and to the north of the lake may compromise the potential of such a source of methane to exist for the long term. Also, fossil methane would almost always include ethane/propane/ butane in the mix. These are not present.u003cbr/u003eu003cbr/u003eBiogenic production remains a more plausible explanation for u0022sudden inflowu0022, but only in a scenario where doubling the resource may take say ~100 years instead of 200. It won’t be instantaneous.u003cbr/u003eOn the matter of recharge: A better statement is that Schmid's results, using not-fully-proven measuring techniques in the deep lake conditions, can neither confirm nor reject a significant recharge. What other credible source of methane exists?u003cbr/u003eu003cbr/u003eIf this is proposed as a conclusion, it is far-reaching and extremely important to properly verify. What is the alternate hypothesis on the origin of the methane? The measurement method may be subject to significant error. For example, if the error is -20%, the opposite conclusion could be drawn. u003cbr/u003eu003cbr/u003eThe conclusion raises questions and does not establish an incontrovertible conclusion yet. The techniques used were not yet convincingly calibrated for this purpose, for the mix of constituents or for the depth of resource. The measurement tool is however promising as a method and deserves consideration. But any gain in the lake methane content, or even unexplained reduction as may be proposed here, is dependent on other factors not mentioned here. For example:u003cbr/u003e · The range of result in the Boehrer paper shows methane figures such as 18.0 +/- 1.0 mmol/l. at depth. That variability is +/- 5.5%. What is the comparable variance with other methods?u003cbr/u003e · Is there a comparable commentary on the accuracy/variance of numbers back in 1975 and 2003? Could we have a combined variance of between 10-15% from then to now? If so, are any of the conclusions that can justifiably be drawn outside the potential error range and therefore statistically significant, or not? This is not explained.u003cbr/u003e u003cbr/u003eu003cstrongu003e u003cemu003e(B) u003c/emu003eThe panel report states that: “u003cemu003eThe conclusion of this research is that the risk of a gas blow-out is not increasing, and additionally that also the lake’s methane resource is not renewable i.e. equivalent to a fossil fuel source.” u003c/emu003e u003c/strongu003eu003cbr/u003e u003cbr/u003eIf this is a conclusion, what is the alternate hypothesis on the origin of the methane? The measurement method may be subject to significant error. If the error is -20%, the opposite conclusion could be true. This is by no means conclusive or acceptable yet. Years more data are needed to provide proof for such slow change. The measurement error range is equivalent of 10-20 years of earlier assessments of rate of change.u003cbr/u003e u003cbr/u003eu003cstrongu003e u003cemu003e(A) The panel report further states that:u003c/emu003e u003cemu003e“At some depth gases released from the riser flow are captured in a separator being a container at some specific depth (read hydrostatic pressure) were dissolved and free gases are in equilibrium.” u003c/emu003eu003c/strongu003eu003cbr/u003eu003cbr/u003e This statement is neither good, nor scientifically correct, nor valid in any engineering sense. Gas release is not instant and therefore not in equilibrium in separators. Static systems over a long time reach equilibrium, but dynamic systems do not over a short time. That's false.u003cbr/u003e u003cbr/u003eu003cstrongu003e u003cemu003e(B) The panel report states in this same section: “The natural ratio of methane to carbon dioxide in Lake Kivu appears to be too low to run biogas engines.” u003c/emu003eu003c/strongu003eu003cbr/u003eAppears? It is, at 20% methane, too low by a large margin. You can use that mix to put a fire out instead. 50% is close to the minimum combustible methane in gas for engines. u003cbr/u003e u003cbr/u003eu003cemu003eu003cstrongu003e (C) A further panel comment is “The less-favoured alternative by the expert group was the Density Gradient Draw-Down Method (GDM) though this method does appear as plan B in the MPs, see below.” u003c/strongu003eu003c/emu003eu003cbr/u003e In response, this u0022GDMu0022 was not just u0022less-favouredu0022, but absolutely and comprehensively rejected by all other experts in the group. The GDM (which is NOT the same as Plan B) has a destructive impact on the natural stability structure of the lake. It also brings vast quantities of nutrients from deep water into shallow water. A principal reason for its rejection was the long-term instability of the lake. It comes from existing and (if and when new gas generation produced) fresh gas, that it would no longer be contained in the lower half of the lake. The same applies to all gas remaining after the first 50-year harvest.u003cbr/u003e u003cbr/u003eu003cstrongu003e u003cemu003e(D) The MPs are not clear whether this is per concession or per production unit and what should be the geographical dispersion of the production platforms.u003c/emu003eu003c/strongu003eu003cbr/u003ePlan A1 requires smaller production units to reduce the impact of large volume extraction and re-injection flows on the gradient layers. A limit of 5 MWe in the output capacity was agreed at the 2008 and 2009 conferences of the experts. It was not an absolute figure but the best guidance at the time. The sensitivity of the gradient layers (260 m and 310 m) to large volumetric flows was the major concern. This is one of many contraventions by KivuWatt in its design. u003cbr/u003eu003cbr/u003eu003cstrongu003e(E) u003cemu003e A further panel comment is “The less-favoured alternative by the expert group was the Density Gradient Draw-Down Method (GDM) though this method does appear as plan B in the MPs, see below.” u003c/emu003eu003c/strongu003eu003cbr/u003e Tietze lobbied for this alternative on the grounds that he could u0022inventu0022 a method of extracting all nutrients. He proposed that this could be part of the process of releasing the gas from the deep water. He could not offer any clue as to how this nutrient extraction idea could be achieved. He has not managed to do so in the ten years since. Therefore, to raise the GDM as a viable option is both dangerous and retrogressive science.u003cbr/u003eu003cbr/u003eIn the end Plan B turned out to be impossible to implement, as the required drop in density could not be achieved, without dilution causing the consequent u0022loss-of-useu0022 of much of the gas in the URZ. Plan B should be disregarded as a viable option, as noted in the comment above, and deleted from the MPs.u003cbr/u003e u003cbr/u003eu003cstrongu003e(F) u003cemu003e A footnote in the panel report says: “The MPs are not clear whether this is per concession or per production unit and what should be the geographical dispersion of the production platforms.”u003c/emu003eu003c/strongu003eu003cbr/u003eThe MPs do not imply that 5 MWe is a limit on the size of a single production platform, nor for the capacity a concession. That is a mis-read. What it suggests is that a number of 5 MWe modules could be attached to a single barge/platform. i.e. Five such modules could produce 25 MWe and ten could produce 50 MWe. This is simple arithmetic, in case anyone missed the point. However, the spacing between individual 5 MWe production modules still had to be at least 100 m.u003cbr/u003eu003cbr/u003eKivuxxxx has placed four larger modules (80% over-sized) within 50 m of each other in their design. 50 m is too close. The only way this would have worked for them was to re-inject their degassed water into the PRZ, where the consequences are damage to the critical density gradient. It was ultimately a poor solution, perhaps their least worst available, but a destructive one at that.

What were the concerns of the Expert Working Group about short-circuiting?

u003cstrongu003e(Au003cemu003e) Hence, dilution of the URZ without energy production should be avoided to exploit this resource in the future. Yet, the gas pressures in the URZ are nearest to saturation limits, see Figure 2.4, though still at a safe level.u003c/emu003eu003c/strongu003eu003cbr/u003e This may have been Kivuxxxx's (mis)interpretation of the MTRs. The requirement clearly states that it should use the URZ first, as the zone more sensitive to poor re-injection practice. Symbion had a worse interpretation They assumed that they can re-inject degassed water to the URZ.u003cbr/u003eu003cbr/u003eThis litany of bad design practice may have included extraction modules being too large (u003e5MWe, Kivuxxxx u0026amp; Symxxxx). Some were too close together (Kivuxxxx, Symxxxx), or unable to create a re-injection density sufficiently lower than that of the URZ (Kivuxxxx, Symxxxx, KP1). The depth had to be greater than at the centre of the 260 m Main Gradient. This density must be achieved by having the uppermost separator between 10-12 m below the lake's surface. This requirement was not complied with by either Kivuxxxx or Symxxxx in their designs, with their top (only) separator at about 20-26 m below surface.u003cbr/u003eAt first here may have been slight inaccuracies in the Chen-Millero re-injection density calculator provided by EAWAG. But any error was not nearly as gross as the 20+ m separator depth selection made by Kivuxxxx and Symxxxx (or perhaps Axxxxxx who carried out their engineering). u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e (B) The MPs do not specify the consequences of short-circuiting; we infer short-circuiting reduces (i) the methane concentration at the intake level as well as (ii) the upward flow in the risers because the gas lift is less powerful, reducing the upward methane flux even further.u003c/strongu003eu003c/emu003eu003cbr/u003eShort circuiting results in the problem described in detail in Michel Halbwachs' paper, quoted in this paper. The consequences are progressive dilution of the resource zone and premature failure of degassing. This problem was clearly identified in the development of the MPs. So was the need to position the top-most separator at a level that prevents mixing and hence this form of dilution.u003cbr/u003eu003cbr/u003eSo, of course short-circuiting would do that. Some things are obvious enough that the MPs do no need to spell them out in great detail. Short-circuiting from a poorly executed design was a warning in the guidance section of the MPs. It was only inserted as a rule to the extent that water had to re-stratify above the resource water through density difference. One should expect designers to have some logical capacity in their thinking. u003cbr/u003e Similarly, one expects that Halbwachs would understand that one has to separate re-injectate from the resource water. The separation works by re-injecting above the resource water at a density difference, as stated. This is why it is written up so in the MPs. The overriding need was u003cemu003enot u003c/emu003eto place the re-injectate u003cemu003eabove u003c/emu003ethe Main Gradient, due to much more serious consequences like destroying the Main Gradient. There was therefore no need to calculate the consequences of getting this wrong, writing a paper on the subject and blaming the MPs for making a mistake that it clearly warned against. u003cbr/u003eu003cbr/u003eu003cstrongu003e (C) u003cemu003eComment on p19: “The intake and the discharge in the same 40-50m thick depth range of the URZ may cause short-circuiting”u003c/emu003eu003c/strongu003eu003cbr/u003eu003cbr/u003e To repeat the above point: It may cause short circuiting if the density of the reinjection is not reduced sufficiently to create a sub-layer above the URZ. The control mechanism for densioty control is the depth of the uppermost (or single) separator used. KP1 has a single separator too deep to achieve the required density.u003cbr/u003eu003cbr/u003eTo repeat the above point: It may cause short circuiting if the density of the reinjection is not reduced sufficiently. The control mechanism is the depth of the uppermost (or single) separator used. KP1 has a single separator, which is too deep to achieve the required density.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e (D) Given the suggested 20 years lifetime of Plan A1/A2 this example would involve 34-35 platforms with anchoring, risers, and pipelines distributed over Lake Kivu. This number of plants may be too extensive for commercial exploitation and investments and required spatial distribution over the lake (see also chapter 7 on concessions).u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eThe question is built on a simplistic and incorrect assumption. Clusters of u00225MWeu0022 modules can be spaced out around a single platform. This solution is neither too extensive nor too expensive as implied. As described several comments above, it is a simple engineering decision. Use multiple, dispersed modules around a platform. u003cbr/u003eu003cbr/u003e Kivuxxxx and Symxxxx both used multiple modules, but grouping them too close to achieve the needed effect of minimising negative impact on gradient layers. There are better designs available to fit the requirement, most likely even cheaper than Kivuxxxx's design. They include appropriate anchoring for the modules.u003cbr/u003eu003cbr/u003eIt is a simple engineering decision to use multiple, dispersed modules around a platform. There are designs available to fit this spacing requirement. They are most likely much cheaper than Kivuxxxx's design. u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e (E) Comment on p19: “No context is presented for allowing to change from Plan A1/A2 to Plan B.”u003c/strongu003eu003c/emu003eu003cbr/u003ePlan A1/A2 were conceived at a time that the detailed density calculations to support their operation were uncertain. That density calculation by Chen-Millero was confirmed subsequently. The engineering needs to achieve the combination of A1 and A2 were confirmed. u003cbr/u003eu003cbr/u003ePlan B was inserted as an alternate, potentially simpler plan to be tried treat the URZ and LRZ as a single zone. It required drawing resource water from the bottom of the LRZ and re-injecting degassed water above the top of the URZ, but below the centre-line of the Main Gradient. It proved unnecessary. Furthermore, the calculator proved that Plan B was much more difficult to design for, as it required the top separator to work under partial vacuum. No transition to Plan B is needed.u003cbr/u003eu003cbr/u003eTo continue from the above point: Plan B is problematic to operate and expensive to design, build and operate. One foresaw it as a standby option, but it proved to be of no value. One can demonstrate this in an engineering calculation, performed using the Chen-Millero calculator. It shows that the separator needs to have negative pressure to achieve the required density and restratification. u003cbr/u003eu003cbr/u003e In the panel review document, Plan B is several times referred to being the same as KivuWatt’s design or Wuest’s PR1 concept. Neither is true because they both discharge degassed LRZ water into the PRZ. These options are highly damaging to the Main Gradient and must be banned.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e (F) Comment on p19: “Subsequently, the MPs propose Plan B (Figure 2.8) in which riser water is taken from the LRZ but allowed to be re-injected in the now methane-poor URZ. The MPs define the latter circulation as Gradient Draw-Down Method (GDM) of the URZ-LRZ density gradient or interface, originally at 310m depth. Obviously, Plan B ends if short-circuiting occurs when the URZ-LRZ density gradient sinks below the riser inlet depth and methane concentrations drop to methane-poor URZ level, still leaving some deep volume of methane rich water not easily exploitable.”u003c/strongu003eu003c/emu003eu003cbr/u003eThere seems to be added confusion in the panel review on Plan B's intent. Plan B was introduced to harvest the combined URZ and LRZ as one. This followed if there was a failure to harvest the zones independently by A1/A2. It is not the same as Tietze's Gradient Drawdown Method, which is banned in the MPs. Although the intent of Plan B is repeated in the statement above, it gets mis-read and incorrectly confused with the GDM Method. u003cbr/u003eu003cbr/u003eIf one works with the Chen-Millero model, it can calculate the level of a separator vessel required to achieve a desired density. From a desired depth of water extraction, one can work out the installation depth. If the depth is above surface, i.e. to operate in a partial vacuum, one can see how Plan B becomes very difficult and expensive to implement. KivuWatt sought an easy way out and re-injected the water back into the PRZ. This has turned out to be disastrous for the Main Gradient, which is in the process of being weakened and ultimately will be destroyed by KivuWatt. This is why all the experts warned against KivuWatt’s plan and rejected the ESIA in July 2010.

Is there a clear confirmation that the increase in exploitable methane mass in Lake Kivu is not discernible within the next 50 years?

The papers and data sets from Boehrer (2018) and Schmid 2019 are not yet nearly sufficient to throw out all others. Their method used lacks well-proven validity over the depth range assessed as it was never previously calibrated for the depth or concentration of gas. u003cbr/u003eThe method will require repeated surveys over multi-year intervals in order to establish either that there is a trend, or lack of any trend. u003cbr/u003eFurther cross-referencing is important in order to establish Schmid’s hypothesis and claims of no-growth in the resource. u003cbr/u003eUncertain measurement, including ~6% plus/minus data range uncertainty, along with any of a number of equipment failures in other measurement methods used from 1937 to 2004, could result in similar variances. i.e under-reporting or over-reporting is possible in any of the data series. u003cbr/u003eSimilar measurement and calibration problems, including failure to account for sample leakage and temperature change, may well have compromised other tests. It is therefore way to soon to make or justify the conclusions put forward by Schmid, which have far-reaching consequences if correct.u003cbr/u003eFurther, if accepted, the data suggest that methane is disappearing from the deeper resource zones. It was up to now common cause that the Main Gradient act as an impenetrable barrier to gas diffusion from below to above the gradient. u003cbr/u003eOnly gas extraction or some form of organic consumption of methane could show otherwise. Neither seems likely nor is either proposed to account for a disappearance of methane. One or more set of measurements must be in error for such a thesis to stand, and Schmid is curiously selective on which data he proposes to ignore.u003cbr/u003eThere are several scientific issues to consider, but the key references are: u003cbr/u003e • Every report on the gas concentration surveys from 1937 to 2019, which references are appended to the panel report and the MPs (up to 2004)u003cbr/u003e • The 1st Law of Thermodynamics (i.e. Matter can neither be created nor destroyed).u003cbr/u003eu003cbr/u003eThis finding of Schmid would effectively throw out all work done on Lake Kivu in the past and have all parties having to reset 83 years of past scientific work and measurement, his included. The physics, chemistry, microbiology, limnology, hydrology, geochemistry and other papers on gas extraction written on the subject would need to be withdrawn or re-written to support his hypothesis. u003cbr/u003eu003cbr/u003eThe MPs would need to be re-written to account for a static or declining methane load, and perhaps the carbon dioxide inventory too. The gas extraction methods actually still need to be the same to preserve the lake safety.u003cbr/u003e u003cemu003eOru003c/emu003e, we could check the measurements, past and present for errors.

How was the development of anchorage of KW barge?

If one evaluates the litany of engineering errors by developers to date, including:u003cbr/u003e • In 2006 the first methane extraction pilot plant REC experienced a riser breakage and sank (not correct, it was unseaworthy and sank)u003cbr/u003e • In 2008 the second methane extraction pilot plant REC experienced a structural/stress failure from poor design, was sinking. It was then ordered to be removed before it broke up and sank.u003cbr/u003e • KP1 experienced gas leakage, failing monitoring instruments and a riser that broke off, shutting down the plant for years.u003cbr/u003e • Kivuxxxx experienced problems with gas being over-saturated in wash-water, causing gas bubbling to the surface around the barge.u003cbr/u003e • The Kivuxxxx barge’s anchors began do drift in soft, spongy bottom strata, not allowed for in the anchor design, causing the barge to drift in high wind and current conditions.u003cbr/u003e • Kivuxxxx failing to design according to the MTRs 3 u0026amp; 4, among others, causing problems with the stability and longevity of the Main Gradient layer.u003cbr/u003e Therefore, one can see a persistent trend of bad engineering, whether through incompetence or lack of know-how, but compounded by the impact of refusing to submit to (or a lack of imposing) the oversight of designs by competent experts. These requirements are set out in the 2009 MPs in great detail thus:u003cbr/u003e u0022u003cemu003eMAR1: Before applying for permission to proceed with the construction of gas extraction facilities, concessionaires must be able to thoroughly demonstrate that: u003cbr/u003e a) their plant designs and operational procedures will be in compliance with the provisions of this document; and u003cbr/u003e b) their Environmental Impact Assessments take these provisions into consideration. u003cbr/u003e Should existing facilities become non-compliant with an updated version of this document, the Bilateral Regulatory Authority will notify the operator of the non-compliance and the two parties will negotiate a mutually-agreed plan for bringing the facility into compliance.u003cbr/u003e MAR2: The locations of water intake and re-injection equipment will be approved by the Bilateral Regulatory Authority based on their depth, horizontal separation, and flow volumes.u003cbr/u003e MAR3: Prior to construction, design drawings must be submitted to the Bilateral Regulatory Authority for approval. This information will be kept confidential. Submitted designs must include at least all configurations of: underwater pipes, pumping systems, separators, gas lines, gas treatment facilities, gas buffer storage tanks, water mixing systems, compressors and blowers; power supply systems on off-shore barges; and gas flaring systems. All submerged materials of construction for underwater pipes and anchoring systems must be part of the documentation submitted. u003c/emu003eu003cbr/u003e u003cemu003e Design drawings must include process flow diagrams (PFDs) and piping and instrumentation diagrams (Pu0026amp;IDs) prepared in accordance with ISO 10628. The design will have been subjected to the HAZOP process, and the HAZOP report must be submitted with the design drawings. This information will be kept confidential. The process flow diagrams (PFDs) shall as a minimum include the basic information as per section 4.2.1 plus items a (mass balance for all gases plus water), b, c, and d from section 4.2.2 of ISO 10628, and the Pu0026amp;IDs shall as a minimum contain the basic information as per section 4.3.1 plus items c, d, e, f and g from section 4.3.2.u003c/emu003eu003cbr/u003e u003cemu003eMAR4: Relevant design data that will be reported at the design stage for all single extraction facilities, and that will be made public, include but are not limited to:u003cbr/u003e a) depth of all extraction and re-injection pipe openings;u003cbr/u003e b) design of the extraction and re-injection pipes: diameter, elasticity, heat conductivity, shape of pipe mouth to achieve internal mixing of re-injected water with surrounding water, ejector/diffuser, etc.;u003cbr/u003e c) design flow rates for all water extracted from or re-injected into the lake;u003cbr/u003e d) design flow rates including full mass balance, and expressed in SI Units (t/h or normal m3/h or km3/h etc.) for all gas streams produced during the extraction process;u003cbr/u003e e) the concentrations of methane, carbon dioxide and hydrogen sulphide in said water and gas streams, showing the extraction efficiencies and gas losses;u003cbr/u003e f) detailed and verifiable calculations of expected re-stratification levels for degassed water and for washing water; andu003cbr/u003e g) amounts of sellable power and of all internal power consumption in gas extraction.u003cbr/u003e Any subsequent changes to the above data must be submitted to the Bilateral Regulatory Authority for approval.u003c/emu003eu003cbr/u003e u003cemu003eMAR5: The Bilateral Regulatory Authority has the right of access to gas extraction facilities for inspection at any time, and will provide facility operators with sufficient notice of such inspections. The operator has overall responsibility for safety at the facilities, and thus for granting access. The Bilateral Regulatory Authority personnel will have all necessary safety training as required by the operator for access to the offshore facilities. The operator will provide such training.u003cbr/u003e MAR6: At start-up of a new or modified gas extraction facility, a concessionaire must engage a qualified third party to carry out monitoring in the lake (e.g. salinity and temperature profile measurements) around the point of re-injection. This monitoring will, with sufficient reliability and precision, demonstrate the shape of the plumes of any re-injected water (degassed and washing water). u003c/emu003eu003cbr/u003eu003cemu003eThe purpose is to measure and report, from start-up until sufficient results have been reached, that there are no deviations from re-stratification levels as defined in this document. If necessary, adjustment of density control must take place followed by renewed monitoring until a satisfactory result has been obtained. The third party report will be submitted to the Bilateral Regulatory Authority. u003c/emu003eu003cbr/u003eu003cemu003e MAR7: Operators of gas extraction facilities must report certain operation and monitoring data electronically to, and in a manner and frequency defined by, the Bilateral Regulatory Authority. Operators must be prepared to carry out automatic, online reporting if required by the Bilateral Regulatory Authority. u003c/emu003eu003cbr/u003eu003cemu003eThese data will be made public and used together with other data to develop better scientific understanding of the lake and guidance of extraction concession design, safety and operations. u003c/emu003eu003cbr/u003eu003cemu003eOperator shall ensure that sample points for all major streams are installed, with suitable valving, for taking the necessary samples and for the Regulator’s appointed third party to take samples on request. Facilities shall be designed to allow carrying out tests with injection of tracers (through sample points).u003cbr/u003e Data to be reported include the following parameters:u003cbr/u003e a) Hourly averages of flow rates for all water extracted from and re-injected to the lake, plus the rates of produced gas or electrical power (MW) and cumulative production. Flow meters shall be calibrated once a year and copies of the calibration reports submitted to the Bilateral Regulatory Authority; u003cbr/u003e b) Monthly average values of flow rates for all gas streams produced by the extraction process, including mass balances showing the methane extraction efficiency and the relative carbon dioxide removal rate; andu003cbr/u003e c) Monthly average values of water temperature, conductivity and salinity, as well as concentrations of methane and of carbon dioxide, hydrogen sulphide and nitrogen in said water and gas streams, as well as calculated and/or measured densities of the re-injection water.u003c/emu003eu003cbr/u003e u003cemu003eOther data may be added if concerns for the lake so require.u003cbr/u003e Once a month, a full set of water parameter analyses shall be made in an agreed laboratory on samples of extracted and re-injected water.u003cbr/u003e MAR8: Concessions should be limited to a time frame considered appropriate by the Bilateral Regulatory Authority. In considering an application for the renewal of a concession, the Bilateral Regulatory Authority should consider, among other things: u003cbr/u003e a) the overall gas reservoir management plan for the lake;u003cbr/u003e b) the availability of more efficient and sustainable gas extraction methods; u003cbr/u003e c) the potential need to change the extraction or re-injection depth and/or location; and u003cbr/u003e d) the potential need to change the carbon dioxide removal rate. u003cbr/u003e The Bilateral Regulatory Authority has the right to determine what technical renewal conditions will be required. u003cbr/u003e MAR9: A precondition for permission to start operation of any gas extraction facility is that the Bilateral Competent Authority or its representative has been given the opportunity to inspect all underwater piping and their fittings (as well as the materials they are made of) when assembled onshore but prior to installing these under water. u003c/emu003eu0022u003cbr/u003eu003cbr/u003e Frankly, Nothing More Needs to Be Said. u003cbr/u003e • Kivuxxxx failed on 9/9 MARs u003cbr/u003e • So did REC/Halbwachsu003cbr/u003e • So too did KP1, although it was largely built before the MPs were published.u003cbr/u003eTo correct this: Repeat the same requirements (barring Plan B) in any version of the MPs, only with a stronger BRA and far harsher penalties for transgressions.

u003cbr/u003e u003cstrongu003eUnder what conditions has KivuWatt been licensed?u003c/strongu003e

u003cemu003eu003cstrongu003eFrom the statement on p22 of the panel review: “The set-up of Kivuxxxx is similar to Plan B in the MP, though with re-injection in the Potential Resource Zone (scenario PR1 in (Wüest et al., 2009)). Such a design would not comply with the MP, which calls first for Plan A1/A2 followed by Plan B.”u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003e This statement shows that Kivuxxxx/Antxxxx did not understand (or chose not to apply) Plan B's essential requirements. They modified Plan B by re-injecting into the PRZ. This utterly compromises the intent to protect the Main Gradient. Vaguely similar is not good enough; that’s as close as saying a bus is similar to a car as it has four wheels.u003cbr/u003eu003cbr/u003eThis design element is directly in conflict with one of the more important MTRs in the MPs. Kivuxxxx is unable to comply with many of the 14 MTRs, including the most important. A Kivuxxxx-negotiated concession has stripped the GoR of any control over the mis-use of the resource. The lack of a BRA to enforce the MPs (MTRs and MARs) granted KivuWatt a sense of entitlement and immunity to sanction. u003cbr/u003eu003cbr/u003e Concessional requirements have been abused to an extent illustrated by the lawsuit and arbitration case brought by KivuWatt against the GoR for issuing the 2009 MPs. The basis for the suit was “Change in Law”. This is despite the lack of any substantial difference between the Draft 2008 MPs document and the formally issued 2009 MPs on the MTRs and MARs that KivuWatt has flouted.u003cbr/u003eu003cbr/u003eKivuxxxx’s grievances on the above legal issue seem misplaced. They are trying to attach blame to others for what is a growing litany and engineering and design errors and failures. u003cbr/u003eScientific background is substantiated by the MPs and the body of work that went into its formation. u003cbr/u003eu003cbr/u003eThe few known operational issues are largely anecdotal since Kivuxxxx publishes virtually none of the required data and reportage required under the MARs. For example:u003cbr/u003e • From the initial design data put forward in 2010 as “design information” to support Kivuxxxx’s ESIA application and application for MIGA support, the quality of information, its completeness and its accuracy was laughably inadequate. A few hand sketches, lacking even the basic engineering notation, were put forward for review. u003cbr/u003e • The absence of any design review or compliance review required by the above-copied MARs is a critical non-compliance. u003cbr/u003e • Their design, placed four large separators and their intake and re-injection pipes within a 50 m linear arrangement. It was against the guidance of the MPs.u003cbr/u003e • The report-back to the February 2011 Rubavu stakeholders conference, where the country manager of Kivuxxxx, reported that Kivuxxxx and its engineers “simply did not know how to design a re-injection system for degassed water to comply with the MPs.”u003cbr/u003e• Reportage of incidents, such as the aborted plant start-up in 2014/15. The resulting cloud of bubbles rising up under the platform from over-saturated wash water, was never reported. u003cbr/u003e • Their need to re-design and rebuild the gas washing system to correct the above design defect. Kivuxxx claimed this as a cost due to “change-of-law”, an absurd claim at best and fraudulent at worst.u003cbr/u003e • Kivuxxxx's need to double-up on anchoring systems due to the failure of the original anchors to perform under the lake’s changeable seasonal wind and current conditions. This shows bad design practice.u003cbr/u003e • Most serious of all is the evidence from LKMP monitoring of the lake-wide weakening of the Main Gradient. Monitoring shows alarming evidence of the impact of degassed water re-injection into the PRZ. This contravention alone should require the immediate shut-down of their GEF.u003cbr/u003e • The overuse of resource, due to extremely poor process efficiency, plus the sole use of the resource volume in the band between 310 and 355 m depth, means that Kivuxxxx is accessing well below 50% of the available resource but overusing that band beyond its share. Arguably, Kivuxxxx uses or sequestrates between 3-5 times as much resource as the best available technology for the same net power output.u003cbr/u003e u003cbr/u003eAll the evidence above indicates that the MPs were substantially correct in requiring the technical compliances and administrative compliances. From my review of the MPs, there are many potential additions and one required deletion to the MTRs. The additions are written up in a joint paper written by Hirslund and Morkel, published in Elsevier’s Journal of African Earth Science, January 2020.u003cbr/u003eu003cbr/u003ePerhaps a proper review would have thus dissuaded Kivuxxxx from building this GEF at all. Or it would have at least saved itself from so many embarrassingly incompetent design and engineering errors. u003cbr/u003eThe former would have saved both the countries from expensive wastage of resource, not to mention an increase in the danger levels of the lake. The latter would have saved KivuWatt from tens of millions of dollars of wasted expenditure and years of delayed start-up.u003cbr/u003eu003cbr/u003eAs noted in the panel review document, the BRA was a necessary institution that should have been created to police the many infractions committed by Kivuxxxx. This need is even greater now, as the sense that developers can use political-legal mechanisms to flout the MPs seems to have become the u0022ruling precedentu0022.u003cbr/u003eu003cbr/u003eWe noted that Symxxxx proceeded in virtually the same manner in engineering and design of their proposed GEF. Most of the same design non-compliances were repeated by their engineers. Antares, also did similar poor work on the KivuWatt design. The design changes incorporated only modestly address deficiencies in Kivuxxxx’s GEF design.u003cbr/u003e u003cbr/u003eFortunately, REMA has seen fit to reject the ESIA put forward by Symxxxx/Shema, which has at least one design element that is worse than Kivuxxxx’s, with respect to re-injection.

Panel Review Statement: u0022Remove the scientific doubts between these conflicting views, record it and publish it.u0022

u003cemu003eu003cstrongu003eFrom the reported conflict on p22: Hirslund (2012) argues that in Lake Kivu chemoclines (constituent or dissolved-gas levels) or isopycnals (density levels) are moving upward by inflows to the deeper parts of the lake. These come from water sources with different salinities (citation from abstract Hirslund, 2012). From these inflows and consequent forced upward movement, Hirslund argues that local gas saturation increases. Thus there is an increase in the probability of gas eruption. Hirslund therefore proposes mitigating actions to limit the rise of chemoclines.u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eSchmid and Wüest (2012) object to these mitigations. While they acknowledge that observed thinning of the chemoclines from below is poorly understood, they hold that sub-aquatic sources maintain the chemoclines at their present levels. u003cbr/u003eu003cbr/u003eHaving been at the periphery of both of these arguments, I was part of a discussion on the merits of each. My initial take was that Schmid u0026amp; Wüest were correct. They argue that the sub-lacustrine inflows would “shave off” tops of any rising chemoclines, keeping their levels constant despite thinning. u003cbr/u003eu003cbr/u003eMoreover, in arguing this matter with Hirslund in favour of the view of Schmid u0026amp; Wüest, Hirslund showed that the top fraction of a chemocline may be subject to this dilution/shaving effect, but that the body of the chemocline was not. DDL can explain the same phenomenon. u003cbr/u003eu003cbr/u003eHe also argued that sub-lacustrine inflows will settle at their own level, determined by the inflow’s density. Measurement from 1975 to 2004 showed that the gradients' centre-line (or peak density change) was indeed migrating upwards. The impact of the moving centre-line is material over the long term mass balance changes. u003cbr/u003eu003cbr/u003eHowever, much of the disagreement hasn't been debated scientifically, but expressed more on a basis of personal animus and pride of authorship. It comes down to protecting one's own thesis rather than doing a simple mass-balance to show that sub-lacustrine inflows will push up gradients.u003cbr/u003eu003cbr/u003eWith the combined effects of double diffusive layering, the sharpening the gradients, data also also shows that the peak of the gradient is perceptibly, and justifiably, rising. I now accept Hirslunds version of the mechanism and result, although less convenient than EAWAG's. It creates lake management problems that will need long-term solutions.u003cbr/u003eu003cbr/u003eTo say that rising chemoclines is a myth and has no impact is wrong. Simple engineering mass balance puts that proposition down. The volume of water under each chemocline is increasing. Operationally, rising chemoclines cause a growing and significant problem later on with extraction of gas. Rising chemoclines accelerate the rising partial pressure of gas where it presently peaks, just under the 260 m and 310 m chemoclines. This rising pressure persists even if, as Schmid 2019 postulates, no new gas is being generated. u003cbr/u003eu003cbr/u003eRising chemoclines will gradually, certainly not drastically, impact the Plan A1/A2 creation of new sub-layers in the URZ and PRZ. This is because with scaled-up production, the sub-layers will thicken faster than the rate of rise of the chemoclines. u003cbr/u003eu003cbr/u003eIn this context, mechanisms for rejecting degassed water to the Biozone need sober debate. Degassed water injected to the Biozone has multiple undesirable impacts on the Biozone ecology that must be measured against the safety impacts of rising partial pressures of gas at the top margins of the URZ and PRZ. But something will have to give over time and the alternatives need more study.u003cbr/u003eu003cbr/u003eExtraction mechanisms proposed by Symbion/Shema do nothing to mitigate the problems of rising partial pressures at the present peak. This peak, at ~265-275 m depth, migrates upwards and grows to be more of a concern. u003cbr/u003eu003cbr/u003eIronically, KivuWatt’s method does slightly mitigate present rising partial pressure peaks at ~265-275 m depth and the 315-325 m as their mass redistribution to the PRZ slows the rate of rise of these 260 m and 310 m chemoclines. It does, however, still accelerate the rise of the 190m chemocline.u003cbr/u003eu003cbr/u003eThe 2009 MPs do not address the issue of rising chemoclines. Once the data and proven or disproven theories and mechanisms are settled, hopefully before another 5-10 years have passed, the matter can be addressed by qualified hydrologists added to the mix of experts.u003cbr/u003eMTRs 3 u0026amp; 4 are affected by the discussion. A question of new MTRs to address the control of the level of key chemoclines must be addressed in concert with MTRs 3 u0026amp; 4. While the LKMP and other researchers can help with providing more data, it is the wider set of expertise that will be equipped to address mitigation measures. u003cbr/u003eu003cbr/u003eThe matter is not one to be settled by Deltares and LKMP as they lack the requisite capabilities.u003cbr/u003e

What arguments were used to prefer Plan A1/A2?

u003cemu003eThis is a short question that requires a detailed and wide-ranging answer to many issues, including: u003c/emu003eu003cbr/u003e (A) Halbwachs’ studies deserve the following response summary that we share in our evaluation - Reference is made to non-unanimity in the MPs expert group on the optimal extraction of methane.u003cbr/u003e A 5:1 majority was acceptable in the circumstances, particularly as Tietze did agree several times during detailed debates. He had agreed with our convincing technical arguments, data and models, only to renege days or weeks later. It was a regular pattern he exhibited over three years. In particular, throughout the 2009 finalisation of the MPs, Tietze agreed with the draft until the last day. u003cbr/u003eu003cbr/u003eThe rationale for the Expert Group rejecting the dissent of Tietze was overwhelming. His and Halbwachs' views were rejected for good, reasoned arguments on the stability breakdown that would eventuate. They both argued for a method that would have destroyed the future stability of the lake by breaking up the important density structure. u003cbr/u003eA major safety problem reoccurs well after the completion of 50 years of gas harvesting. That is u003cemu003eif u003c/emu003egas content is regenerated after the initial gas harvest (as argued in this panel review). Their (Halbwachs and Tietze's) harvest approach would have destroyed the existing density structure, resulting in a mixed layer taking up the entire lake. This results in a single density layer, like Lake Tanganyika.u003cbr/u003eu003cbr/u003eHalbwachs issued his paper on the eve of the 2011 Gisenyi conference of stakeholders. The Expert Group nominated Morkel and Hirslund, at the request of Rwanda’s Minister of State for Energy – Dr Albert Butare, to prepare a reply to Halbwachs. The response, repeated here in full and unedited, was provided to him on 18 February 2011: u003cbr/u003eu003cbr/u003eu003cemu003e u0022To all Stakeholders in Lake Kivu Gas Extraction,u003cbr/u003e Re: Comments by Prof Halbwachs on Management Prescriptions (MPs) and in particular Plan A1, A2 and B Methodsu003c/emu003eu003cbr/u003eu003cemu003eu003cbr/u003e Dear Colleagues,u003cbr/u003e As members of the International Expert Group we wish to respond to all parties addressed by the above correspondence, issued to most workshop attendees very shortly before it commenced. As such, we comment on the Halbwachs’ note and its attached YLec report from September 2009. Being addressed as late as it was, to almost all attendees, these were delivered as an “ambush” tactic to gain attention without allowing an opportunity of a timely rebuttal by the experts.u003cbr/u003e Nevertheless, we are obliged to properly consider the merits or otherwise of any communication on the MP’s, and to provide all those addressed with a sober evaluation and response. Both the Management Prescriptions and the conference have channels in place for the hearing of objections to the contents of the MP’s, neither of which was used by Prof Halbwachs. It is therefore principally to allay any concerns that could have been raised in the minds of other delegates that we reply as below. u003c/emu003eu003cbr/u003eu003cbr/u003e u003cemu003eThe MPs have been conceived as Society's tool to prevent future cataclysmic eruptions of the lake while extracting the gas. They are the only known tool to prevent this, and this is why the issue of adherence to the MPs is of exceptional importance. The comments by Prof Halbwachs do not qualify as sufficient reason to change this situation, as described below. If we were to follow these ideas of Prof Halbwachs, we would instead increase the certainty of many future eruptions of the lake. u003cbr/u003eu003cbr/u003e u0022Pour tous ceux qui s’occupent de l'extraction du gaz du lac Kivu,u003cbr/u003e Note sur les commentaires par le professeur Halbwachs sur les prescriptions de gestion (les PG) de lac Kivu, et notamment les méthodes Plan A1, A2 et B u003c/emu003eu003cbr/u003eu003cemu003eu003cbr/u003e Chers collègues,u003cbr/u003e Comme membres du Groupe international d'experts nous souhaitons répondre à toutes les parties intéressées par la correspondance ci-dessus, délivrée aux participants de l'atelier à Gisenyi juste avant qu'il ne commence. En tant que tel, nous ne commentons que la note du Prof. Halbwachs et sa pièce jointe de Septembre 2009, s'adressant si tard à la totalité des participants de l'atelier, l’intention claire a été d‘attirer l'attention des participants d’un côté et de l’autre de ne pas laisser la possibilité d'un échange et surtout d’une réponse par les experts avant que l'atelier ne commence.u003c/emu003eu003cbr/u003eu003cemu003eu003cbr/u003e Néanmoins, nous sommes obligés de prendre dûment en compte le bien-fondé ou non de toute communication sur les PG, et à fournir à toutes questions qui ont été adressées, une évaluation et une réponse mesurées. Pour les PG ainsi que pour la conférence des moyens ont été mis en place pour permettre d’adresser les questions et objections sur le contenu des PG, ceux-ci n’ayant malheureusement pas été utilisés par le Professeur Halbwachs. Il nous semble donc absolument nécessaire d’apaiser les inquiétudes qui pourraient naître dans l'esprit des différents délégués et c'est justement dans ce but que nous répondons ci-dessous.u003c/emu003eu003cbr/u003eu003cemu003eu003cbr/u003e Les PG ont été conçus comme l'outil de la Société servant à prévenir de futures éruptions cataclysmiques du lac lors de l'extraction du gaz. Les PG sont les seuls outils connus pour éviter cela, et c'est pourquoi la question de l'adhésion aux PG est d'une importance capitale. Les commentaires du professeur Halbwachs ne changent en rien cette situation comme décrit ci-dessous. Si par hasard ces idées du Prof. Halbwachs étaient suivies, cela conduirait presque à une certitude de futures éruptions gazeuses du lac. u003c/emu003eu003cbr/u003eu003cbr/u003eu003cemu003eu0022u003cstrongu003eBackground Issuesu003c/strongu003eu003c/emu003eu003cbr/u003eu003cemu003eOn the matter of their being included as part of the creation of the MPs, Prof Halbwachs and Dr Klaus Tietze are long-standing members of the Lake Kivu scientific community whose views are well circulated in publications. There are many parallels and commonalities in their viewpoints and opinions and, as such, one of the two was invited to be represented on the formative Expert Group in March 2007.u003c/emu003eu003cbr/u003eu003cemu003eu003cbr/u003eThe broader scientific, consulting engineering, environmental and extractive technology community was similarly to be included in the group to make it properly qualified and representative. In addition, the group’s appointed members bring with them a broad set of additional skills which have markedly benefited the discussion and development of the MP’s. As such the group was properly and reasonably constituted and was not unduly biased in favour of or against any one particular set of opinions.u003c/emu003eu003cbr/u003eu003cemu003eu003cbr/u003eFurther, in succeeding stages of the development of the Management Prescriptions, between October 2007 in Kastanienbaum and May 2009 where the final draft was prepared, open sessions of the experts were held and successive drafts issued for public comment. The opportunity to attend the May 2009 session was not taken up by Prof Halbwachs and comments on the draft MP’s were refused to be submitted on the “misguided” document on the grounds that he “knew better”. In the final issue of the MPs Dr Tietze was given a right to note his concerns over some elements of the MP’s and to reserve the right to prepare further research on his position and revert with proposed changes with justifications. To date none have been received for consideration.u003cbr/u003eThe MP’s were issued as final in June 2009, and presented to the two governments in July 2009. After receiving copies of widely circulated negative comments on the MP’s, the Minister of State for Energy of Rwanda and the Deputy Minister of Hydrocarbons of the DRC both wrote to Prof Halbwachs to warn him against continued vilification of the MP’s and its authors through the press, including the writing of similar e-mails to the broader community. He was advised to deal with such matters through the relevant authorities, as appointed, and not in the public media.u003c/emu003eu003cbr/u003eu003cbr/u003eu003cstrongu003eu003cemu003eSpecific Objectionsu003c/emu003eu003c/strongu003eu003cbr/u003eu003cemu003eOn the water re-injection method used after degassing, the YLec consultant’s competencies in fluid dynamics referred to are relevant to the argument on the predicted results of the extraction and re-injection piping and methods, but less relevant to the general safety of the lake. The public safety consideration always supersedes the economic priorities of either country, or any developers, in the order of precedence established in the guiding principles.u003cbr/u003eIn the development of the Plan A1, A2 and Plan B as described in the MPs, these more detailed methods were instituted precisely because of the loss of gas recovery potential through dilution of the resource zones. It was well understood that dilution, caused by re-injection water distributing throughout the two mixed resource zones (URZ and LRZ), would render as much as 40-50% of the methane unrecoverable. Much of the research and discussion that preceded inclusion of these detailed extraction methods centred on their practicality and the relative improvement of gas recovery compared to the dilution method.u003c/emu003eu003cbr/u003eu003cbr/u003eu003cstrongu003eu003cemu003eHydraulic Evaluation of MP’su003c/emu003eu003c/strongu003eu003cbr/u003eu003cemu003eIn Copenhagen in both May 2008 and May 2009, two hydraulics specialists were mobilised by COWI to assist with evaluations. Before, during and after these sessions they advised on the 3-D impact of flows deriving from a variety of configurations of re-injection piping and the impact on flow regimes from the design of nozzles. These experts enjoy at least the same reputation as Yves Lecoffre of YLec, more especially in their hydrology experience of large unconfined bodies of water such as lakes rather than in piping systems.u003cbr/u003eThese independent experts were called in to comment on and verify or dispute the opinions of persons in the expert group. Several of the Expert Group members have experience in the hydraulics of water bodies and flows. They had proposed certain configurations designed to vertically segregate the re-injected water from the underlying resource water in each zone. Detailed simulations were performed by these supplementary experts, based on the flow, density, and other data including the configurations of re-injection piping. Their results were used to determine the resultant shapes of plumes and re-injected water lenses in the lake, especially on the ratio of lens spread to thickness.u003cbr/u003eWhere water of the precise density of the lower half of the relevant gradient layer was re-injected through a correct nozzle configuration, the re-injection lens was shown to stratify very widely, with a limited vertical penetration. With the correct parameters and designs, simulations showed lateral transport of 10 km or more being achieved with a vertical lens thickness of no more than a few metres, a ratio of the order of a thousand times. This spreading potential and segregation of the re-injected water is the basis of both Plan A1 and Plan A2 configurations.u003c/emu003eu003cbr/u003eu003cbr/u003eu003cstrongu003eu003cemu003eAssumptions as Basis of Objectionsu003c/emu003eu003c/strongu003eu003cbr/u003eu003cemu003eThe fundamental assumptions given to or used by YLec, gives rise to a serious bias in the results of their analysis. There are nine parameters that need to be well understood in a 3-D simulation, of which too few are mentioned in the analysis provided. Some are assumptions are made correctly, some incorrectly to the extent of being misleading, and too many are not even considered:u003cbr/u003e• The potential influence of the currents, even if for a transient condition, is discussed;u003cbr/u003e• YLec’s shape, configuration and flow parameters of re-injection nozzles are unlike any considered by the experts, and they do affect the analysis markedly;u003cbr/u003e• The assumption of re-injection density being the same as the mixed zone average density leads to the worst case result of zone dilution. Instead, this density should be assumed to being lower than the mixed zone, some 10 % lower than the difference between the mixed zone and the centre-line of the gradient above. This density is made possible by removal of the majority of the CO2 content of the resource water;u003cbr/u003e• Other parameters such as lens shape, the use of diffusers, selective withdrawal designs, flow rate, double-diffusivity effect on vertical and horizontal mixing should also be properly considered.u003cbr/u003eWith the third point above, where the average density of the mixed-zone is assumed by Halbwachs to be the re-injection density, any resultant YLec simulation is not on a comparable basis with the Expert Group’s simulations. This assumption is wrong and designed to produce a misleading result.u003c/emu003eu003cbr/u003eu003cbr/u003eu003cstrongu003eu003cemu003eConclusions Drawnu003c/emu003eu003c/strongu003eu003cbr/u003eu003cemu003eThe statement by Prof Halbwachs that his conclusions are final is rejected. The inherent bias, in both assumptions and modelling methodology, renders the work unacceptable as a basis for such conclusions or for recommending a change to the MP’s. Specifically:u003cbr/u003eThe re-injected water can form a distinct lens, even becoming a distinct layer that forms above the mixed zone of the individual URZ or LRZ layers. During the conference, the simple example given of a cocktail that a barman can make with multiple coloured layers shows the alleged “impossibility” to be false. It’s a matter of skill and precision being demonstrated with fluids of very similar density.u003cbr/u003eThat the dilution of a resource zone leads to a reduced extraction plant’s effectiveness is well understood. The extraction plans in the MP’s were drawn up precisely in order to minimise and delay this effect and then to be able to respond to the eventual drop in effectiveness of Plan A1 after some 20 years by switching to Plan B.u003cbr/u003eGiven all the above, Prof Halbwachs’ conclusion that the description of the technology described in the MP’s as being “totally unrealistic” and “impossible to control” is (in itself) misleading, unfounded and without merit.u003c/emu003eu003cbr/u003eu003cemu003eThe issue of operating to Plan A1 and A2 will remain a concern for the designers and operators of gas extraction facilities, but the effort is necessary to maximise their commercial benefit from their respective concessions while preserving the density gradient layers.u003c/emu003eu003cbr/u003eu003cemu003eu003cbr/u003eu003cstrongu003eExpert Conclusionsu003c/strongu003eu003cbr/u003eThe clear, but unstated, inference from the Halbwachs report’s conclusions is that the MP’s should be based on the original legacy extraction method where the entire Resource Zone is displaced into the Intermediate Zone after degassing. This was the extraction method long-supported by Dr Tietze as well. However, this method unavoidably leads to weakening and, after 50 years methane harvesting, to the destruction of the key stability structures that have evolved to protect the lake for the past 1000 years from self-destruction.u003cbr/u003eA detailed set of quantitative evaluations and simulations of this methodology was analysed by EAWAG in 2007, with comparisons checked against the new proposed alternatives. The simulations of time-based variations to all parameters established the complex and long-term changes to the lake structure, and the dangers and effects of the total mixing of the lake’s zones. These included:u003cbr/u003e• The total loss after 50 years of protective density gradient layers that are essential to keep the future gas production retained safely, deep in the bottom half of the lake;u003cbr/u003e• The virtual certainty that after 50 years, the new gas accumulating will lift to just under the Biozone and will eventually result in frequent smaller eruptions of the lake;u003cbr/u003e• The injection of gas-bearing water of high gas partial pressure just below the Biozone which will, in time, increase the gas eruption risk with saturation levels up to 100%;u003cbr/u003e• The lifting of high nutrient concentrations to just below the Biozone will lead to significant impact on the biozone, including possible eutrophication. In the worst case this eutrophication leads to a dead lake unable to support sustainable fish life and can lead to seasonal releases of methane and hydrogen sulphide, in addition to carbon dioxide, from the surface as oxygen periodically depletes;u003cbr/u003e• The danger of the lake becoming a no-go zone for any surface vessels in the future is contemplated due to outbursts of gas originating just below the biozone. Frequent gas releases could lead to the shores of the lake becoming uninhabitable in the long term.u003cbr/u003eAfter considerable debate in the Expert Group on the need to consider the long-term after the 50-year harvest window, it was clear that the top two principles (Public Safety and Environmental Protection) would be considerably at risk from then onwards. It is quite obvious too that the social benefit from the lake, the third principle, would also be severely compromised for future generations.u003c/emu003eu003cbr/u003eu003cemu003eIt was therefore a clear and irrefutable decision by the experts that the Zone Mixing approach to lake harvesting had to be rejected completely in favour of the newer lake stability approach. The sacrifice of a small percentage of potential harvest in the medium-term (50 years) is not a high price to pay in the circumstances. These two divergent extraction methods are also completely incompatible so there is no room for accommodating both side-by-side on the lake at greater than experimental scale, as the chosen method relies on the stability and positional integrity of the density gradient layers to operate and perform.u003cbr/u003eWe are not opposed to further hydrological and hydraulic evaluation and testing of the proposed extraction methods in the MP’s, and in fact encourage it. We would however insist on the proper use of both verifiable assumptions and models to ensure that a correct result is obtained.u003cbr/u003eYours sincerely,u003cbr/u003eDr Finn Hirslund P Engu003cbr/u003ePhilip Morkel Pr Eng.u0022u003c/emu003eu003cbr/u003eu003cbr/u003eOur opinion expressed in the above letter remains substantially unaltered since 2011. No response or rebuttal to the above letter was received by the Expert Group nor arose until the process of this panel review commenced in 2019. The Halbwachs paper has been unaltered in the intervening years to cater for faulty assumptions made then.u003cbr/u003eConsistent with the opinion in the letter above, in response to Halbwachs contentions, no updates or corrected versions of his paper are published, to our knowledge. One assumes that correcting flawed assumptions and applying generally acceptable modelling techniques may have deflated the desired impact of the Halbwachs paper.u003cbr/u003eThat said, if after nine years there has been no apparent advance by Halbwachs on improving the paper. The 2019/2020 re-issue of it to this review panel should equally questioned for validity of assumptions. So too the veracity of the results as a basis to argue against Plan A1/A2.u003cbr/u003e

What arguments were used to prefer Plan A1/A2? (Continued)

u003cemu003e(B) Comment on p25: “Re-injection in the (same) zone of extracted water creates dilution and should be prohibited, notably for Plan A1.”u003c/emu003eu003cbr/u003eu003cbr/u003eThis view was known at the time of the 2009 issue and had been discussed. Halbwachs failed to acknowledge that this hypothesis applied only to reinjection of degassed water at the same density of the resource zone (URZ).u003cbr/u003eBut the stated requirement in the MPs was to reinject at density less than the URZ zone's density. The difference must be sufficient to form a new sub-layer in the u0022kneeu0022 of the density profile. The density difference must be enough to remain separate from the URZ zone.u003cbr/u003eThe detailed proceedings of discussions at the 2008 conference of the Expert Group were not published to provide as a reference. Parties to the conference, include several hydrology experts from COWI, with whom options were discussed. They include respondents to these questions. The collective opinion, after interrogation, was that the idea of re-injection to form a new sub-layer of the URZ or LRZ was accepted. The MPs were written accordingly. Dr Finn Hirslund must still have access to the same experts and can confirm the evaluation.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(C) Comment on p25: “A minimum efficiency in first stage separation should be imposed (75-80% is suggested.)” and “A maximum fraction of methane in re-injected water should be imposed (less than 20% is proposed)” and “A risk analysis of the evolution of a gaseous explosion is needed.” And “Thorough hydrodynamic simulations of the consequences of re-injection by an expert company are required (see below)”.u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eThis imposition of these suggestion is not necessary or justifiable as a rule. Experts drafting the MPs were clear in saying that the process of extraction and gas scrubbing is a u0022black boxu0022. The black box is the domain of the developer. However, all inputs and outputs from the u0022black boxu0022 are regulated, including their depths within the lake. It should stay that way otherwise the potential for innovation and design flexibility are lost.u003cbr/u003eWhat if there were ten separation stages? Would one stage have to do 80% of the work? That is silly and it is not the domain of the regulator to specify internal elements of the design. The regulator must, however, be convinced that the design is practical, adequately pilot-tested or full-scale demonstrated to allow it to be permitted.u003cbr/u003eThe origins of these highlighted statements is not known, but they display a poor understanding of chemical engineering process design. The suggestions must be discarded as they make no sense and have no applicability to the broader options of plant design.u003cbr/u003eu003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(D) Comment on p25: “The pie-shaped sub-division of the lake into concessions each having access to the deepest part of Lake Kivu located north-east of Idjwi Island is hardly feasible near the end (in time and depth) of exploitation. For access to the deepest parts gas-pipe lines should cross the lake to Rwandese or DRC shores with access to high-voltage electricity pylons respecting terrain and owners; a single concession should take over at the end.”u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eThe pie-shape was the only way to give each concession access to the deepest water in each country. It is thus able to produce until the end of the concessions’ lifetime with the illustrated arrangement.u003cbr/u003eSafety and fairness of concession allocations were behind this choice. This alternative presented is unhelpful and barely comprehensible. The author of this suggestion is unknown, but he/she would be better served by withdrawing this statement.u003cbr/u003eThere is no place for these “narrow interest, no context or self-serving” forms of comment or inclusion in the MPs. This is not in the domain of a regulator.u003cbr/u003eWe must assume that a developer hires a competent engineer and that engineer can design to conform with regulated boundary conditions. They must perform engineering according to industry standards and with the necessary HAZOP or HAZID actions at the appropriate time. If any regulation should be applied to GEFs, it is this paragraph’s italicized sentence!u003cbr/u003eFurther, these ideas apply to the type of legacy design which is inherently unable to operate within the bounds of the MPs. So these have no relevance to the discussion.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(E) Halbwachs’ study and more items on your p25 from the YLec Consultants paper have been quoted here with questions raised. They question items such as “The exploitable minimum…”, “A diffuser set-up…”, “Short-circuiting…”, “Single available study on gas lift…” etc.u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eConsistent with the overall opinion in the above letter response, here are some specifics that show the opinions not to useful, applicable, true etc. For example:u003cbr/u003eThis 5 mol methane per m3 limit is highly dependent on the design efficiency of plant alternatives. It's certainly true of designs for Kivuwatt, KP1 and probably Halbwachs. It is not true for multi-stage alternatives, which can operate where single-separator designs are unable to do so.u003cbr/u003eu003cbr/u003eThis diffuser set-up has been argued above already. The assumption made by Halbwachs and YLec are the same, that the density of reinjected water is the same as the zone. The MTR specifically calls for sufficient density difference to remain a separate sub-zone of the URZ. The problem is thus preventable and the conclusion unsupportable.u003cbr/u003eThe argument, once again, only applies to the inherent weakness of designs. Examples include (1) single-separator designs, and (2) a failure to use the available controls of density. These ensure that densities are sufficiently different to remain unmixed in the URZ. The balance of this argument falls away as the base assumption is wrong.u003cbr/u003eThe argument was simple and clear. The fundamental and best protection of the lake against eruption is to retain the current density structure. This must be retained forever, if possible, even if that requires long-term intervention to keep it stable. By re-injecting deep water into shallow water, the main gradient layer (chemocline) will weaken and then disappear. It may then take centuries to re-establish the stability structure and the safety it ensures.u003cbr/u003eu003cbr/u003eIf there is a theory that this will create a stable and static new Main Gradient, it is wishful thinking at best. Due to the stronger sub-lacustrine inflows above the current Main Gradient, this gradient will migrate upwards and disappear faster than before. The 190 m gradient is too high to retain much pressure (~19 bar vs ~26 bar) and therefore less gas storage.u003cbr/u003eu003cbr/u003eAs the gradient weakens, gas can migrate through it and will sharply increase gas partial pressure below the 190 m gradient. All benefits of stability will be rapidly lost. The lake will be a more dangerous place before the first harvest period of 50 years is complete. This theory is dangerous. KivuWatt is practicing this now at a smaller scale. It is already showing evidence of weakening the main gradient and compromising lake safety.u003cbr/u003eu003cbr/u003eThis Fig. 3.2 graphic has a fundamental weakness. It is an equilibrium-state calculation, not based on a dynamic state. Let me put this simply: If you open a beer and leave it so for 24 hours, most of the CO2 gas will have escaped. But it only approaches equilibrium 24 hours later. But the residence time in an extraction system is 2-3 minutes, over which time a far smaller fraction of a beer's CO2 will escape. u003cbr/u003eu003cbr/u003eDynamic curves are very different. Likewise even the green curve, %CH4 recovered, is over-ambitious. 100% recovery is reached at much shallower depth in a dynamic system. It won't get there with 2-3 minutes residence time. The curves are probably 50% over-stated. Halbwachs apparently lacks the data to show a dynamic curve. After all, his theory in 2003 was that it's impossible to extract gas with a separator deeper than 20m. His own test-work failed to collect the relevant data. Hydragas is able to extract and separate gas at 65 m depth by contrast.u003cbr/u003eu003cbr/u003eIf the review panel has no objections to Halbwachs’ proposal, it has much to learn on this critical subject. This statement shows a worryingly low level of subject appreciation and knowledge. It cannot identify glaring and proven problems with Halbwachs' proposal. Considering KivuWatt's dangerous application of it, it is time to get some help. It's really time to u0022go back to schoolu0022 to learn not to make such dangerous statements.u003cbr/u003eu003cbr/u003eThe statement “Plan A1/A2 and Plan B require conditions of the hydrodynamic stability of Lake Kivu” is an example. It's confused and out of touch. It is simplistic and uninformed, akin to one made in 2007 by Dr Tietze. His view was that u0022The only good lake is a dead lake. Take the gas out quickly and completely in 50 years. Then we are done.u0022 u003cbr/u003eHis view was dissected thoroughly and rejected for its many flaws by the Experts in 2007-2009. Fundamental to our rejections was that the world still needs to be safe well after 50 years. The lake will be there, biogenesis will be there (despite Schmid's revelation that methane is fossil). People will be around the lake and they will be placed in mortal danger. The danger arises mainly by elimination of the best natural protection against gas eruptions. That protection is the density structure. It must be kept as-is.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003eOn the statement “We conclude on (Halbwachs, 2011a,b,c ; Guillaume, 2009) as follows. u003c/strongu003eu003c/emu003eThe definition and function of concessions is of major concern. The reduced performance of gas-lift driven flow-rate in risers is not explicitly referred to in the MPs but of concern for determining the end of-exploration.”u003cbr/u003eu003cbr/u003eNothing stated above establishes any such rationale for your concern. Despite his theory of di-phasic flow, Halbwachs’ ability to create high-performing gas-lift is lagging the leaders. This u003cemu003eitalicisedu003c/emu003e statement in the panel review shows a concerning bias. It provides little justification that stands up to inspection. u003cbr/u003eu003cbr/u003eThere seemingly exists an implicit distrust of the prior work Expert Group members. This is despite not having tested the arguments against Halbwachs' paper. These are now provided. Two eminent COWI hydrologists did simulations and made presentations to the Experts in Copenhagen. They established that a stable re-injection lens could form in the given conditions. It would be a couple of metres deep and up to 20 km wide. u003cbr/u003eu003cbr/u003eIt is concerning again too that Halbwachs never sought to correct or update his paper for this panel review. It is nine years after it was issued and largely built on false assumptions. But he threw it again into the mix in a hope of not being found out for flawed assumptions. I suggest you set up a proper debate on the subject. It's preferable to listening to one side only and pronouncing the above conclusion.u003cbr/u003eThe Expert Group never issued published, formal working papers from its proceedings. Much of the work was consolidated by Hirslund in a 400-page treatise, shared among some members. This is still not published. u003cbr/u003eu003cbr/u003eHalbwachs publicised his 2011 study to refute the MPs. But he made invalid assumptions in the paper as the basis of his argument. As a result, his paper is only true for a case mixing equal density discharges into the URZ. For the Plan A1 and supporting MTRs it is invalid.u003cbr/u003eThe Expert Group spent almost two years, from 2007-09, dissecting Halbwachs and Tietze's theories. They found them to be grossly flawed sometimes. So it is time-consuming to have to debunk them all over again. A major underlying flaw is their shared prediliction to destroy the lake's density structure. This key structure is still widely acknowledged as the best natural protection against a lake eruption.u003cbr/u003eHirslund has published a number of papers to describe his work and findings on Lake Kivu since 2009. I have taken the time to study them. Although few are in my field of expertise, they are a valuable source of insights into behaviours of Lake Kivu. One paper, jointly authored with me, is now published in Elsevier’s Journal of African Earth Science, January 2020.u003cbr/u003eu003cbr/u003ehttps://www.sciencedirect.com/science/article/pii/S1464343X19303279. In this paper there is in-depth investigation of issues and ideas put forward by other authors in the field since 2009. There are also new ideas and findings on improving the safety of extraction.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(F) Comment on p28 (KivuWatt 2015-present): “However, to some degree the strategy followed by KivuWatt does comply with the MPs in the aspect of depth of re-injection and the diffuser designs which agree with the primary intention of the MPs.”u003c/strongu003eu003c/emu003eu003cbr/u003e14 MTRs have vital requirements, serious requirements and good practice requirements. KiwuWatt is compliant with some less serious needs and non-compliant with the more serious.u003cbr/u003eBut the MTRs are not a smorgasbord. They are mandatory, all 14 of them. Complying u0022to some degreeu0022 is not adequate. One good diffuser design does not excuse half a dozen non-compliances in other areas.u003cbr/u003eIf anything, more MTRs are needed to tighten up KivuWatt's further bad practices on a poorly engineered plant. Lawsuits initiated by KivuWatt are a political-legal argument against complying with the 2009 MPs. But these MPs were written six years before KivuWatt commissioned their platform.u003cbr/u003eu003cbr/u003eTheir lawsuit claims a u0022change-in-lawu0022. KivuWatt reportedly preferred a u0022bootlegu0022 2008 early draft copy of the MPs, that a government official provided. But KivuWatt had been present, represented by their project technical director and ContourGlobal counsel in Copenhagen in 2009. Examination of the claims made in the lawsuit indicate that virtually all related to their poor engineering, rather than any change in law.u003cbr/u003eIt may be legal practice to argue that prior law is u0022grandfatheredu0022 when it is updated. But this argument must be refuted when used to excuse placing millions of lives at greater risk. However, in this case there was no prior law. u003cbr/u003eu003cbr/u003eNeither engineering nor construction were even started by time the MPs were first formally issued in June 2009. The relevant elements of the 2008 and 2009 MPs do not differ.u003cbr/u003eu003cbr/u003eShould there be any access to view the proceeds of the KivuWatt vs GoR, there would be documentary evidence. Evidence both on behalf of the proponent and the defendant can be found there.

How would this in your view affect the current set of MPs or current operational practises?u003cbr/u003e(please specify the current number of the MPs that would possibly be affected)

It appears that the review panel scoured the earth for every negative sentiment, or every aggrieved proponent of debunked theories. This applies whether they were dealt with in the past or not. The same arguments are presented, without having addressed identified errors, false assumptions and unsubstantiated data. These prompted a previous debunking of the findings, conclusions and hypotheses in their work.u003cbr/u003eu003cbr/u003eCuriously too, the work of KivuWatt has been presented here as a u0022good exampleu0022. In fact it has been more characterised by engineering and design flaws and lack of compliance. It demonstrates outright avoidance of compliance with technical and administrative rules. This lack of oversight provides clear evidence of no real knowledge and insight by the review panel. There is seemingly a willingness to believe anyone with a grievance.u003cbr/u003eu003cbr/u003eAs a result, there seems to be scarce constructive value emanating from this panel review. It is assembled with a suspicious mind-set, with most of the suspicion directed at the established experts and little directed at their critics.u003cbr/u003eu003cbr/u003eThis panel document did not identify the one MTR that was actually flawed. We acknowledge that MTR 5 on Plan B was flawed in its construct. But the panel document has falsely identified problems with other MTRs. These u0022issuesu0022 have not been established with any validity.

Why are conclusions offered in 3.1.5 on a series of contentions statements?

On p29 is a summary of Conclusions is offered in the panel report. Most of these are somewhat contentious and unproven, including:u003cbr/u003eu003cbr/u003eu003ccodeu003eu003cemu003eu003cstrongu003e3.1.5 Our conclusions on previous discussions on the MPs. Before we continue presenting our review, we summarize as follows the existing recommendations and amendments about the MPs. 1. The concerns and proposals presented by Halbwachs (2011a,b,c) and (Guillaume, 2009) are explicitly related to the methane extraction procedures of the MPs and point to voids in the MPs definition of concessions.u003c/strongu003eu003c/emu003eu003c/codeu003eu003cbr/u003eDealt with before in 2011 and can be rejected again and again for the same reasons. The detailed letter of 2009 to Halbwachs stands, unanswered to date.u003cbr/u003eu003cbr/u003eu003ccodeu003eu003cemu003eu003cstrongu003e2. At least the part of Halbwachs’ proposal to re-inject de-gassed URZ water into the PRZ (Table 3.1) deserves closer attention.u003c/strongu003eu003c/emu003eu003c/codeu003eu003cbr/u003eThis is dangerous, not improving on retrospectively approving KivuWatt's bad engineering and failure to conform to the MPs. It deserves closer attention again to justify its rejection and continued banning.u003cbr/u003eu003cbr/u003eu003ccodeu003eu003cemu003eu003cstrongu003e3. The discussion by Tedesco et al. and Nayar invites risk assessment for cases where methane extraction is relevant or significant.u003c/strongu003eu003c/emu003eu003c/codeu003eu003cbr/u003eThe opposite was true. MTRs in the MPs were made more difficult to comply with in order to prioritise safety of methane recovery. The principles in order were (1) people safety, (2) environmental safety, (3) community benefit and finally (4) developer benefits. We did not deviate and that is why KivuWatt, Halbwachs and Tietze all found the MPs difficult to comply with when issued. Their objections followed.u003cbr/u003eu003cbr/u003eu003ccodeu003eu003cemu003eu003cstrongu003e4. The methane extraction by KivuWatt since 2015 can serve as probe for the practical applicability of the MPs rules and guidelines for safety, inspection, on-site and nearfield monitoring, concession demarcation, legal instruments etc.u003c/strongu003eu003c/emu003eu003c/codeu003eu003cbr/u003eKivuWatt’s practice, both before and since the 2105 start-up, demonstrates gross errors in engineering. They show failure to comply with the MPs. They adopt their own interpretations of the MPs – neither grounded in the letter or intent of the MTRs and MARs.u003cbr/u003eKivuWatt failed to consult or take heed of the advice of experts. They didn't even to attempt to understand the mandatory requirements for design. It is not a probe for practical applicability. Theirs is a lesson on how not to engineer, design, build and operate a gas extraction facility.u003cbr/u003eIt could, however, be a lesson on how to stress-test the rules. They provide a check on authorities’ ability to verify and monitor circumvention of compliance.u003cbr/u003eu003cbr/u003eu003ccodeu003eu003cstrongu003eu003cemu003e5. Despite the exhibited knowledge of many aspects of Lake Kivu and methane extraction, we may appreciate Hirslund’s arguments more if his papers where u003c/emu003eu003c/strongu003eu003c/codeu003eu003cemu003eu003cstrongu003e(sic)u003c/strongu003eu003c/emu003eu003ccodeu003eu003cstrongu003eu003cemu003e more concise and his papers discuss the observations of, and with e.g. Ross and Sommer of EAWAG.u003c/emu003eu003c/strongu003eu003c/codeu003eu003cbr/u003eThis statement is rich. The MPs are criticised for being too concise to explain the reasons behind all the Plan A1/A2 etc. When the rationale is presented by Hirslund in detail, his papers need to be more concise. Damned if you do, damned if you don’t.u003cbr/u003eThere is virtually no material in this section of the panel review that seems to come close to being a valid basis for overturning any of the content of the MPs. The exercise seems to have been completed by calling up all aggrieved parties to do their best to undermine a respectable body of work by any means possible.

What did the Expert Working Group use as reference to derive and prioritize their recommendations. What was their utmost danger, in what case/scenario did methane extraction reduce or increase lake safety?

u003cemu003eu003cstrongu003e(A) From the statement on p30, “Introduction: The initial objective of the MPs was to extract methane safely from Lake Kivu for power generation, while reducing the risk of a gas blow-out under the conditions of preserving density gradients. The MPs demand the safe design of installations. This review panel, however, is not aware whether the MPs prioritized recommendations on risk assessments in which methane extraction may contribute. Neither is the panel informed whether such risks have been assessed and mitigated in the design of methane extraction facilities.”u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eu003cstrongu003eOn the Initial Objective:u003c/strongu003eu003cbr/u003eThis statement is a basic mis-read of the MPs. The MPs were written in good faith to ensure safety of the lake from a catastrophic limnic eruption. Extraction of methane for power generation was a government priority. In the process of finding that methane extraction was a key method for reducing the risk, the techniques of extraction became the focus to ensure that the method delivering the greatest safety would be determined and therefore enforced.u003cbr/u003eAll methods that failed to improve safety, or degraded the natural safety mechanisms of the lake, would be rejected.u003cbr/u003eUnfortunately, this review seems to be taken up as an opportunity to win arguments that were thoroughly rejected last time around. Hence the u0022afflicted partiesu0022, such as Halbwachs and perhaps Tietze, are offering the same debunked theories again. It is as though they were never found to be so flawed in 2007-09.u003cbr/u003eu003cbr/u003eu003cstrongu003eOn Risk Assessment:u003c/strongu003eu003cbr/u003eIndeed, the whole three-year exercise was a total risk assessment in many parts about stratification, limnology, meteorology, microbiology, hydraulic stability, hydrology, biochemistry, water chemistry etc.u003cbr/u003eWe were aware of risks from volcanism, seismic rifting, drought and toxicity that are within and specific to the lake. We studied them and consulted experts, such as Dario Tedesco and visited the Goma Volcanic Observatory. We modelled the impacts of reinjection of degassed water at many levels to figure out plume dispersion and double-diffusive layering.u003cbr/u003eu003cbr/u003eAs a team of experts in several fields, we set out to define the nature and extent of a full limnic eruption, as experienced at Lakes Monoun and Nyos, but in this case for a lake 10,000 times bigger. We wrote internally about that and quantified the possible casualties (2-4 million), the carbon release (~2 gigatons) to the environment and the impact of tsunamis on the lake as well as a surge in the lake level (major destruction of all lakeside cities and the severe flooding of Bujumbura on Lake Tanganyika.u003cbr/u003eu003cbr/u003eWe modelled the extent of toxic gas clouds including 2000 ppm H2S. We rightly feared that it was not our role to scare the people living there, but rather to reduce and remove the threat. We called for monitoring and warning sirens. Some of this is published in postings on Wikipedia as part of an exercise to elicit wider comment.u003cbr/u003eKnowing that there was little that we could do to prevent volcanic eruptions, or seismic rifting, we looked for how we could change the contents of the lake over time to reduce risks more precisely and with lasting safety effect. We didn't want to go public with scare-mongering tactics. That was discouraged.u003cbr/u003eu003cbr/u003eWhat is inferred in the highlighted statement is that we spent three years figuring out how to extract gas profitably, then failed to set up a one-day HAZOP review to determine the risks. Some of us figured out extraction economics independently, but it was never part of the discussions. It was, after all, the lower priority.u003cbr/u003eu003cbr/u003eIn fact the opposite is true: it was a three year risk and hazard assessment, with many mitigations, followed by an action planning exercise on safety matters and deeper protections. During these discussions I admit we failed to actually sit down and work out how gas extraction could be done profitably. The background to our discussion, with more recent and amplified learnings, was published in a 50-page detailed article in the Journal of African Earth Science in January 2020.u003cbr/u003eu003cbr/u003eThe point is made that we should have HAZOP'd the extraction plants. Since these plants are all unique designs, they must be HAZOP's as they are designed. This is a mandatory administrative requirement (MAR) in the MPs. Inasmuch as KivuWatt failed in its HAZOP of its design, failing to involve external expertise as required in the MAR, does not justify the review panel's curious lack of awareness of the risk stance in the MPs. As someone who reviewed some of KivuWatt's design failures after the fact, there is nothing more to be done within the MPs to protect against such poor engineering practice. A review was mandatory, and no expertise was called. Nor was there a Bilateral Regulatory Authority created to enforce one.u003cbr/u003eu003cbr/u003eu003cstrongu003eOn Natural Risks Analyses:u003c/strongu003eu003cbr/u003eFirstly, has the BRA re-appeared after 10 years waiting? It was a primary recommendation of the MPs in 2009.u003cbr/u003eSecondly, the proposed risk scenarios were assessed in great detail before. But, as explained above, the multi-disciplinary exercise was completed as the focus and main purpose of the many meetings and years of correspondence between experts. I don't believe that any of the experts was unaware of the reports issued by Tietze, Halbwachs, Kusakabe etc. The reference list of the MPs attests to that.u003cbr/u003eIt was out of such exercises (we didn't use the word scenarios) that the fundamental methods of gas extraction, including those proposed by Halbwachs afterwards, or used by KivuWatt afterwards in conflict with the MPs, were tested against many eventualities. They failed because they increase the levels of danger in the lake.u003cbr/u003eu003cbr/u003eNone of the ten listed scenarios escaped our review. Perhaps your list should be extended to show a limnic eruption with a toxic gas release (2000 ppm H2S release is fatally toxic within a minute or two). We have as experts been consulted by oil exploration companies, for example. We recognise that marine design included designing for such eventualities such as collision by large vessels. We studied the flight paths of aircraft taking off from Goma and Gisenyi airports, flying directly overhead some installations.u003cbr/u003eu003cbr/u003eAs mentioned above, HAZOPs, attended by experts at the request of a u0022BRAu0022, would have at least prevented (1) KivuWatt from building multiple non-compliances to the MPs, especially re-injection into the PRZ (2) Halbwachs from failing to design seaworthy platforms on two occasions, (3) KivuWatt and KP1 from deploying improper anchors for the bottom conditions, (4) All platforms built to date being without sonar and other detection of underwater eruptions, combined with warning sirens, sealed escape rooms with fresh air supply, and (5) All vessels being built to float over a cloud of gas bubbles that reduces a vessel's buoyancy in water by up to 50%.u003cbr/u003eu003cbr/u003eIn simple terms, all of the above was considered, but since most of the items are location specific and plant-design specific, the MPs are only written to specify that a comprehensive HAZOP process must be followed for each installation, with invited experts. Compliance is BRA or national government responsibility, not allocated to the authors of the MPs.u003cbr/u003eu003cbr/u003eFor earthquakes and volcanic eruptions, no design is adequate to exclude a risk. Once again, if an installation is close to shore the response is different to another far from shore. The best we can do for averting the ultimate limnic eruption is to try to ensure safe reduction of gas within the first 25 years. This is to ensure that the level of danger reduces below 1% of what it is now. That is slow but it cannot be done without building gas production facilities, with the right designs, and operating them for 20+ years.u003cbr/u003eu003cbr/u003eu003cstrongu003eOn Anthropogenic Risks:u003c/strongu003eu003cbr/u003eIn retrospect the anthropogenic risks come from a rash of non-compliant installations such as KivuWatt, KP1 and a few other proposed installations by Halbwachs, Tietze, Symbion Power. There seems to have been rampant cases of poor engineering, misinterpretation of the MPs, flagrant disregard of the MPs and the rules therein.u003cbr/u003eThat is why such risks were considered, identified and then they were excluded in the MPs and specifically through the MTRs. Despite that and notwithstanding warnings to the authorities, bad practice has continued to cause a rise in anthropogenic risk. The lack of a BRA enabled bad practice to proceed unhindered. It is ironic that this panel review seems to disregard such risks and focuses an grievances against the MPs instead.u003cbr/u003eu003cbr/u003eu003cstrongu003eOn the Lack of Risk Assessments in the MPsu003c/strongu003e:u003cbr/u003eThe Review panel is made up of fully paid professionals appointed for the purpose of this review and compensated for every word they read or write. The more time spent, the greater the cost of the total review. It is rich that the review panel expects us Experts, who wrote the MPs, to have read and referenced everything in the literature. The highlighted listing is random and vaguely referenced work, much post-dating the 2009 publication of the MPs.u003cbr/u003eu003cbr/u003eAll Experts that wrote the MPs, however, donated all their time on a pro-bono basis. That amounted to three years of part-time work, costing each Expert between 1000 to 3000 hours of non-paying commitment. If viewed as an opportunity cost, their contributions were worth anything from $150,000 up to say $500,000. For some the work continued with thousands of additional hours in research and writing of papers, particularly Hirslund.u003cbr/u003eu003cbr/u003eMuch of the expertise applied to the creation and updating of the MPs derived from lifetimes of personal experience, observations on the lake, working on experimental platforms, data gathering vessels and gas extraction platforms. In a field where there was a dearth of experience, a lack of data and too much misinformation, the effort and result were both remarkable. The intent and commitment to the principles ensured a good result after much internal debateu003cbr/u003eThe unsubtle implication in the review panel's report of lack of completeness in research, method and know-how by the Experts is petty and mean. As a counterpoint, the review panel's authors have a seemingly naive or scatter-gun approach to information presented herein, demonstrating distinct biases against the Expert Group, scepticism and an alarming inclination to be misled.u003cbr/u003eu003cbr/u003eThis apparent bias tends to question or demean the original Experts and highlight the information and opposition of their detractors. Some radical new theories about the methane being fossil-based and non-biogenic are inexplicably taken on board as u0022probably trueu0022 in defiance of almost a century of prior evidence to the contrary.u003cbr/u003eu003cbr/u003eu003cstrongu003eOn Underwater Hazards – Turbidity Currents, Internal Seiches:u003c/strongu003eu003cbr/u003eThe u0022importanceu0022 of turbidity currents, being called “lacking” in the MP’s assessment, better reflects the reality than this vague and alarmist statement. There is a localised incidence of small rivulets and streams entering the east and west sides of Lake Kivu. They deposit some sand and turbid water, but at levels that are uncharacteristically low for such large lakes. Lake Kivu’s catchment is uncharacteristically small, being little larger than the lake’s surface area.u003cbr/u003eu003cbr/u003eOn the north shore, where the major portion of the lake’s rain catchment is located, the lava beds have no surface rivers nor sediments flowing into the lake, but rather sub-lacustrine inflows through lava strata. To suggest that turbidity currents from the north constitute a major factor is misleading.u003cbr/u003eu003cbr/u003eMost gas extraction plants will therefore be far from any influence of such turbidity currents. As a factor of importance to any but the KP1 and Halbwachs platforms, it is virtually irrelevant. It may be a design factor in anchoring pipelines to shore, where some anchors may be closer to sand fans.u003cbr/u003eu003cbr/u003eu003cstrongu003eOn “massive landslides” and “strong internal seiches”u003c/strongu003e u003cbr/u003eI don't believe these are even of the size and impact to be rated in the top 10 risks for gas extraction plant. By comparison, volcanic and seismic events are at the top end of the clear risks. In our discussions in preparing the MPs, we made reference to energy requirements equivalent to multi-megaton nuclear explosions being required to lift gas-rich water sufficient to create an erupting plume.u003cbr/u003eu003cbr/u003eFor a lake of this size, it is known as having a very small catchment, relatively small river inflows and little sediment other than the likes of this one sandy stream at the Sebeya river. This stream does deposit sand onto a steeply-shelving bottom, as evidenced by the lake bathymetry. This can, and reportedly has led to occasional slumps of sand, with slips occurring up to 1km from the river mouth. Local reporting refers to swimmers that disappear swimming off the beach at the nearby Serena Hotel in Gisenyi. This is a localised problem far from the likely locations of GEFs.u003cbr/u003eu003cbr/u003eHowever, these are small instances. Some of them have been observed, causing a rising plume of bubbles. One was photographed by the KP1 construction crew in ~2008-9. Some canoes, carrying sometimes dozens of people, are reputed to have sunk in the same area. These same boats often travel with 100-150mm of freeboard, making them highly vulnerable to sinking even if the boat is rocked. Loss of buoyancy of such vessels is an ever-present problem due to generally poor marine safety practice on the lake.u003cbr/u003eu003cbr/u003eSince most of the gas extraction plants will be located in 350 m or preferably 400 m plus depths, these small, localised sand deposits will not reach the 5-10km minimum distance from the east or west shore to the GEFs.u003cbr/u003eu003cbr/u003eThis potential is completely absent when accessing the lake from the north shore, made up by several hundred metres depth of lava beds. The bathymetric survey identifies deep cavities over 300 m depth within 1.5 km of the shore and more open deep water within 2 km of the shore. There is no potential for sand deposition on the north shore, anywhere west of the Sebeya river, other than sand that flows from that river mouth. u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003eIn a related statement under 3.3.1, which states “Although open for discussion we consider landslides and river sediments yielding turbidity currents by fluffy bed layers the potentially most dangerous external phenomena that may displace anchors, break risers, pipes, anchor chains, and create platform instabilities.”u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eThe above text is overstated as being dangerous phenomena. The only thing remotely testing anchor systems is the wind-induced surface currents and any induced counter-currents below. Having spent six months on the lake, building and operating pilot plant, the strongest currents were at surface, driven by the May-to-September dry-season winds, have a circular pastern around Idjwi Island.u003cbr/u003eu003cbr/u003eLocally the direction of winds was not all south-to-north, but could be from such surface currents turning back south as they approached the north coast. In our pilot-plant location 1.5km off Cap Rubone, there was a WNW direction of the surface current of up to 1 m/s. Later in May the strength of the currents was greater but difficult to measure. This direction of current flow is borne out by maps in the following page 40.u003cbr/u003eu003cbr/u003eA greater u0022dangeru0022 was posed by fishermen at night. On two occasions they had boarded the platform and cut anchor ropes to steal some length of the polyurethane rope used. On this occasion the unanchored platform drifted 2km south-west overnight, driven by current rather than wind.u003cbr/u003eu003cbr/u003eIn a related statement under 3.3.3, which states “For creating a level playing field for constructors, investors, insurers, and operators official references to extreme meteorological conditions (wind, lightning etc.), surface waves and currents need to be formulated and prescribed as boundary conditions..”u003cbr/u003eu003cbr/u003eIs this a Eurocentric view of u0022extremeu0022? Lightning is a regular seasonal thing in tropical Africa, occurring frequently, throughout the wet season. The southerly, stronger winds are a diurnal feature of the u0022dryu0022 seasons, with medium-strength winds prevailing every afternoon.u003cbr/u003eu003cbr/u003eThe waves patterns arising from this wind are highly predictable and are part of a normal design basis for barge or platform construction. Design for fatigue conditions is essential, an element of design missing from the two platforms designed by Halbwachs in 2006-2008.u003cbr/u003eSlightly less predictable are the afternoon squalls that arise from almost daily tropical storms in the wet season. The wind arises and subsides within minutes.u003cbr/u003eu003cbr/u003eIt is clear from viewing different designs of floating platforms on Lake Kivu that a range of standards may have been adopted. High-end guidance is available for the design of oil platforms in the Gulf of Mexico, which must design for sustained gale-force or hurricane-force winds and the simultaneous collision with an untethered vessel of the type commonly used in the body of water. This was the standard I deployed when completing a feasibility study. Clearly some designs, such as Symbion’s, do not adopt as strict a standard. They have designed platforms that weld sea containers together. Such containers are lacking in structural strength.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003eIn a statement under 3.3.4, it states “For more discussion we refer to the review by the environmental committee about GHG emissions and renewable energy sources and we just quote their comment: “Formally, only the regenerated fraction of the methane can be considered as a truly renewable energy source. The other fraction should be considered a fossil fuel”. This is in line with BP1.1a which states that, “in the long term, the total rate of methane extraction from all operations should equal the rate of estimated natural increase”.u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eIs this conclusion at best hasty and far from being consensus? Considering all the potential reasons for a survey or surveys that indicate a reduction of methane in situ, one should examine potential causes of an apparent halt or reversal of methane accumulation. Is there a thesis on how u0022fossil methaneu0022 gets into the lake? Is it from the purported but unproven graben underlying Lake Kivu?u003cbr/u003eu003cbr/u003eThe following questions are not asked or answered in the text:u003cbr/u003e(1) Was the new method accurate in the recent surveys?u003cbr/u003e(2) Was the method or equipment adequate or accurate in any or all of the previous surveys of equivalent concentration and depth?u003cbr/u003e(3) What are the comparable trends in carbon dioxide inventory?u003cbr/u003e(4) What are the partial pressure measurements of the same surveys?u003cbr/u003e(5) is there evidence of a die-off of the bacterial and other organisms responsible (methanogens)?u003cbr/u003e(6) Tietze wrote about the errors in methods used by prior lake surveys, relating to the equipment used to collect the gas samples. Has the method used resolved any, let alone all the deficiencies?u003cbr/u003eWijdeveld has rightly questioned the equal-weighting of the new methodology deployed by Schmid with a series of earlier methods of more proven efficacy.u003cbr/u003eu003cbr/u003eThe conclusions apparently drawn by Schmid in 2019 are a hair-raising departure from virtually all past findings. I would question the method inasmuch as it does not seem to be well proven at depths where the main gas resource is stored within the lake.u003cbr/u003eThis set of measurements is hardly a basis for overturning all past work. It raises a concern, but requires comprehensive proof before one can redirect from the underlying thesis that has sustained all work on the lake's development since 1986, but specifically from 2003-2019.u003cbr/u003eu003cbr/u003eThis conclusion on whether there is no detectable increase in methane mass and whether methane is renewable, is concerning and potentially serious departure from the science of the past 83 years. One of the few conclusions that may be drawn from the Schmid conclusion is that there has been a complete die-off of the bacteria responsible for methane generation. This is curious and unexplained in this report. Not even a simple test such as carbon-dating the methane or looking at isotopic counts of the carbon is referenced in this summary. More work is required to consider overturning our understanding of the nature of Lake Kivu.u003cbr/u003eu003cbr/u003eThe current set of MPs, despite the extensive criticism and even defamation have held up under inspection. The aggrieved parties questioning their content have failed this far to elaborate any substantiated problems with the work and its development.u003cbr/u003eMembers of the original Expert Group see a need to tighten up on bad practice, as it is evidently proliferating without a BRA in place to ensure compliance and to sanction avoidance or non-compliance. Further rules may be required to tighten up on loopholes and new areas of concern.u003cbr/u003eu003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(A) There seems to be a lack of insight and clarity in the panel review on this topic, i.e. “The theoretical maximum electrical energy (example given below and in Appendix C) derived from methane stored in the lake is fairly well defined or, given a limited period of extraction, also the upper limit in electrical power generated is fairly well defined with a 10% tolerance in economically extractable methane volume.”u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eThe actual power derived from the lake varies by extraction technology, parasitic energy consumption, power conversion efficiency and by the amount of the gas reserves that can be accessed by any one extraction method. The variability of all of these factors is significant, each introducing greater than 10% variance.u003cbr/u003eu003cbr/u003eOverall, the variance may go from 15% to 60% in net energy output. If the MPs are applied to the Plan A1/A2 model, consistent output is possible. Figure 3.6 seems to adopt a fade-out of capacity as the source is diluted, but no basis is shown to confirm that underlying hypothesis. It is impractical as a plan or a solution.u003cbr/u003eu003cbr/u003eA more thorough analysis is required than this loose set of assumptions. It would be more appropriate to evaluate each available technology in play and evaluate the factors based on a particular design of extraction plant, its operating set up, its power output based on equipment selection and gas quality.u003cbr/u003eu003cbr/u003eOnly then can any evaluation be made of total potential output, based on who gets to do the project. Averaging the ranges quoted as a basis for projections is essentially meaningless. This Figure 3.6 Leest graphic is not useful information. The graphic is misleading as it does not relate to how one would develop electrical power from the resource. One does not start with high production and then decline over 50 years for economic reasons. One starts with a ramp up of installations, builds up to a plateau and then sustains at that value until exhausted.u003cbr/u003eThe graph starts at Year 10, so no ramp-up curve is shown. The apparent fade in power output and the efficiencies shown are not fully representative of all possibilities, looking a bit too much like the Halbwachs resource dilution theory.u003cbr/u003eu003cbr/u003eOne should create incentives to operators for achieving maximum overall efficiencies, in agreement with one of the objectives of the present MPs (Section 4.1, MT12). Such an incentive should be licensing the volume of pumped-up water from the relevant depth zones rather than licensing the extracted methane mass or the electrical power. This has been a consistent theme of the experts in the MPs and in subsequent presentations to forums on lake development. Insofar as this chapter reinforces that imperative, it is useful.u003cbr/u003eu003cbr/u003eKivuWatt has been non-compliant in its reporting of operational data, including power output. In the MPs, a mandatory administrative requirement was this reporting. At best it has been sporadic, and in the case of KivuWatt it has been a consistent non-compliance. This requirement was way beyond annual reports, it was needed at least monthly and preferably recorded on a daily basis to an accessible database.

How to deal with granting concessions before these are well defined after this Review of MPs?u003cbr/u003eu003cemu003e(A) The Review Panel gives undue credence to Halbwachs for his opposition to concession policy as follows: “The applicability of defining a geographic concession in a free-moving water body rather than in low permeable rock or soil such as in oil and gas recovery requires more clarification than the MPs provide. In paragraph 3.1 we referred to earlier discussions by Halbwachs (2011c) and in workshops (NCEA, 2007, 2009; LKMP, 2011).u003cbr/u003eThe report (Halbwachs, 2011c) presents with comments and details the potential concessions in the Democratic Republic of Congo as well as in Rwanda, whereas other studies are devoted to Rwanda only. The report (Halbwachs, 2011c) notes that a much wider optimisation of concessions is needed considering all criteria cited. The non-existing Bilateral Regulatory Authority (Figure 4.2) could have directed such studies and observations more equally among DRC and Rwanda territories.”u003c/emu003eu003cbr/u003e

These two paragraphs spell out nothing more than Halbwachs taking issue with concessions, along with his opposition to every other element of the MPs. The concession policy would not normally have been a function of the Expert Group, except that the government of Rwanda recognised that they needed guidance and asked the Experts for it in Copenhagen in 2008.u003cbr/u003eu003cbr/u003eThat guidance came in the form of two parts: mapping geographic location of GEFs and allocating resource quantification.u003cbr/u003e(1) First we recommended that a concession needed to separately define geographic space for a concession (hence the development of a u0022pie-diagramu0022, centred on the deepest point along the common DRC/Rwanda border to give access to deep water, allowing each concession to work for the full lifetime of the resource.u003cbr/u003eu003cbr/u003e(2) Secondly we quantified (with the information validated by 2009) the resource by zone (LRZ, URZ and PRZ). The total resource was divided by 10, while the resource by zones was also divided into 10 slices. This was displayed in terms of a u0022Resourceu0022 pie-chart, with an indication of the potential; for power generation by zone. While these power potential production figures may no longer be accurate, at least the volumetric draw-down, calculable in cubic metres per hour of resource water by zone, should be close to correct (assuming 50 years is the duration of a concession's total life).u003cbr/u003eu003cbr/u003eHalbwachs' difficulties are not explained in the Section 3.3.8 notes. However, his notation in papers issued at about the time identified several deep-water points close to shore as proposed extraction sites. This concession methodology is not useful and cannot be made fair to all concessions. It suits his GEF design because they are small units without much scalability, other than by numbering up, and therefore need a shore location. Given that, none of these locations had depth close to 450 m, which would be desirable for long-life concessions. Given that he is asking for optimisation of concessions, he has offered examples of plant sites which are in no way capable of optimisation of everyone's concession, nor are they capable of evening out re-injection across the width of the lake.u003cbr/u003eu003cbr/u003eA final point should again be emphasized: The legacy method(s) of gas extraction, i.e. those of Halbwachs, Tietze, KP1, KivuWatt, Symbion/Shema, cannot coexist with compliant systems as they impact the level of the Main Gradient and its strength. These changes will compromise proper implementation of Plan A1/A2. This latter point requires precise levels of re-injection into the u0022knee-pointu0022 of a density gradient, just below its centre-line. Horizontal dispersion is then effective in creating a lake-wide re-injection lens that deepens with the accumulated re-injection flows.u003cbr/u003eu003cbr/u003eIf this concept is difficult for anyone to understand, we can arrange a presentation on its functionality to all that need to understand it.u003cbr/u003e

How to deal with granting concessions before these are well defined after this Review of MPs?u003cbr/u003eu003cemu003e(B) Some misguided examples are being presented such as: “A subject treated generally in the present MPs is avoiding and monitoring interactions between concessions that may reduce density gradients or mutually hinder the execution and time span of Plan A1/A2. Though the MPs set some limiting rules for mixing and recommend detailed computational fluid dynamics (CFD) simulations about local mixing of and with dedicated mixing devices for re-injected water (MP, MTR5).”u003c/emu003eu003cbr/u003e

The CFD simulation attributed to Morse in 2016 and illustrated in Fig 3.10 follows a similar misconception that Halbwachs and YLec wrote about in 2012. It completely misses the key requirement of the Plan A1 implementation. That key requirement is the re-injection at a controlled density, equal to the lake water density about 5m below the centre of the main gradient, at 265 m.u003cbr/u003eu003cbr/u003eThe figure shows re-injection water colour-coded to have a density of 1001.8 at 280 m. It should have been colour-coded green at a density of 1001 kg/m^3. The flow is shown to be initially horizontal for a few metres before it plunges through the weaker 310 m gradient to settle at about 320 m. This set-up is exactly how KivuWatt and Symbion are set to operate, i.e. designed-to-fail to comply with the MPs. It proves nothing other than KivuWatt/Symbion have not tried nor understood how to design a water circulation and processing system to comply with the MPs.u003cbr/u003eu003cbr/u003eThe Chen-Millero calculator provided by EAWAG in 2009, including to KivuWatt, provided the data to calculate the depth at which to separate water. It was designed and issued to calculate how to assess how water, extracted from any given depth, would re-settle at a required depth in the same zone. The controllable variable is carbon dioxide removal, which is determined by the depth of the uppermost separator and the depth of extraction.u003cbr/u003eu003cbr/u003eWhile there are limits to what can be achieved, extracting water from 355 m and resettling at say 315 m is well within the achievable range. That is how to achieve plan A2. For Plan A1, water extracted from say 305 m can be made to resettle at 265 m. i.e. Plan A1/A2 works.u003cbr/u003eu003cbr/u003eHowever, achieving Plan B, which was conceived as a fall-back plan in case of not being able to run Plan A1, does not yield a practical, economic solution. This is because the uppermost separator would have to operate under a partial vacuum to achieve sufficient carbon dioxide removal to yield re-injection water of low enough density (equivalent to 265 m depth). That is likely way too expensive to be economic. Changing the point of re-injection to 240 m makes the situation even worse, causing critical long-term damage to the Main Gradient.u003cbr/u003eu003cbr/u003eKivuWatt, despite being offered assistance to resolve this and other issues at the 2009 Copenhagen conference, refused to engage in any discussion. I approached them to offer my assistance on resolving their technical difficulties with developing a compliant solution. The ContourGlobal lawyer present ensured that the KivuWatt technical lead was there to listen and was not permitted to comment, discuss issues or to answer questions. Simply put, KivuWatt u0022u003cemu003eshot themselves in the footu003c/emu003eu0022 with their uncooperative attitude and disregard for the MPs and the Experts.u003cbr/u003e

How to deal with granting concessions before these are well defined after this Review of MPs?u003cbr/u003eu003cemu003e(C) The following assertions, though generally on subject, pick bad examples and misdirection to try disprove the MPs on Concession issues i.e.:u003c/emu003eu003cbr/u003eu003cemu003e(1) “Yet, horizontal differences in salinity, temperature and gas concentrations created per concession/platform in the depth zones where deep water or wash water are re-injected (such as in the Upper Resource Zone for circulation A1) may induce weak horizontal density-driven currents. u003c/emu003eu003cbr/u003eu003cemu003e(2) In addition, natural phenomena such as wind-induced internal oscillations, horizontal eddy patterns (vortices, Figure 3.7) and general horizontal circulation may contribute to an uncontrolled exchange of matter between the upper resource zones of the concessions. u003c/emu003eu003cbr/u003eu003cemu003e(3) The MPs do not consider these larger scale 3D hydrodynamic phenomena nor provide the licensing authority a methodology for controlling or monitoring interactions between concessions. For simulations of hydrodynamics and transport are required very precise specification of the density of the returned water and the receiving water, including the temperature of the return water. Small density differences between the model assumptions and in-situ operation will result in large errors for model predictions. The horizontal exchange and dispersion becomes an urgent issue in view of reported ongoing plant developments.”u003c/emu003eu003cbr/u003e

(1) This sentence on u0022horizontal differencesu0022 is vague and unconvincing. The collective factors affecting density and driver of horizontal dispersion of the re-injectate are sufficiently modelled in the Chen-Millero spreadsheet to ensure that the level of re-injection is close enough to sustain the desired horizontal dispersion of a lens. After all, with the passage of years of operation, weather factors, salinity changes and other nuanced variations will vary the relative density of re-injectate and the water at the calculated depth. The likely changes are not enough to compromise the re-settling of the plume into the right depth.u003cbr/u003eu003cbr/u003e(2) With the wonderful benefits of ten years more research, monitoring and data from operations, none of which was available to the Experts in 2007-2009, this statement on the impact of oscillations and vortices displays no better insight than we had back then. It only questions us on why we didn't have the data and models at the time.u003cbr/u003eu003cbr/u003eWe were similarly concerned about the same oscillations and current patterns causing perturbations that could affect mixing of layers. There were many discussions about 1-D, 2-D and even 3-D models. The outcome was that we did not have the funds nor the time to perform 3D models, as much as we liked the idea. 1-D models were considered irrelevant because they could not represent the lake effectively.u003cbr/u003eu003cbr/u003eWe settled on 2-D models, which provided a clear, if not totally irrefutable conclusion on many of the problems created by bad practice - such as what is illustrated (in 2-D) in Fig 3.10. That genre of bad practice was the far bigger problem, but in the text here too much is made of u0022wind-induced oscillations and eddiesu0022 that are frankly very minor problems by comparison at 265 m or 315 m depths. It is wonderful to call for giant 3-D models to resolve understanding of marginal effects, while at the same time minimising or ignoring the gross effects of much more important malpractices of re-injecting at the wrong levels. Get some perspective!u003cbr/u003eu003cbr/u003e(3) For the first part of this statement, see the response above. For the second all of that was provided for in the MPs by setting a precise plan, i.e. Plan A1/A2, with ongoing measurement of data and monitoring of plumes. To spell it out clearly, that provided both a methodology and monitoring. The statement is therefore both false and misleading.u003cbr/u003eu003cbr/u003e(4) The specifications are precise, i.e. u0022the re-injected water must settle at 265 m.u0022 With the Chen-Millero model, this density is precise to five significant digits. How much more precision is required by this statement? The last sentence on u0022result in large errors for model predictionsu0022 is therefore nonsensical.u003cbr/u003eu003cbr/u003eHorizontal dispersion, if implemented to the rules, will not present a problem. By contrast, the gross distortions of the lake stratification caused by KivuWatt, and similarly proposed by Symbion, and carried out at small-scale by KP1, were all problems of significantly larger impact.u003cbr/u003eu003cbr/u003eThe urgent issue is not as described in this paragraph. It is to get the concessions to work to the rules in the MPs (Plan A1/A2), which are still a far better solution than the outright failures of KivuWatt and others to engineer accordingly. They are creating a significant potential for destabilising the lake permanently.u003cbr/u003eu003cbr/u003eInasmuch as a proposed concession policy was inserted into the MPs at the government of Rwanda’s request, it has been included there as guidance for the authorities responsible for their implementation and licensing. There is still a need as demonstrated by the poorly constructed concessions in play.u003cbr/u003eu003cbr/u003eThe elements of importance to governments, in order to control their resource use and licensing process requires the following:u003cbr/u003e(1) Geographic locations or areas for a concession-holder to operate and route pipelinesu003cbr/u003e(2) A defined resource quantity and draw-down rate provide equal resources to each to useu003cbr/u003e(3) A defined term for exploitation of the resource quantity is decided by governments, but was recommended as two terms of 25 years.u003cbr/u003e(4) Any concession designated by output (i.e MW power output) should be cancelled and issued as a resource-defined concession as in (2).

Are the 2015-2019 near-plant reports evaluating horizontal spreading of reinjected water in agreement with the desired function of concession? See previous discussion/section.u003cbr/u003eu003cemu003eThe question on this section asks whether the desired function of the concession matches the reporting on monitoring results. The opposite must be asked, i.e. does the data show compliance with the concession’s intent and requirements? To illustrate how this is misdirected, some examples:u003cbr/u003e(A) The granting of concessions may proceed faster than the acceptance of clear rules for concession governance and monitoring, see the lawsuit in chapter 2.u003c/emu003eu003cbr/u003e

This is a KivuWatt-favouring statement, implying that rules were unavailable on time for their concession negotiations. This is only partly true, because the 2008 bootleg copy of the MPs did contain similar graphics (updated in 2009), the same guidelines on geographic concession outlines and the same resource-sharing concession concept. At the time the detailed survey and official concession policy map by Hirslund was not in place but was available in 2011. There are some differences in the shoreline intersections, which did not affect KivuWatt.u003cbr/u003eu003cbr/u003eThe 2008 bootleg copy of the MPs was one of at least seven different drafts internally circulated that year. The core summary statement of concessioning policy was:u003cbr/u003eu0022To achieve these flexibilities, it is recommended that the two governments concession gas extraction operations to co-allocate a geographic area of operation and a portion of the gas resource to each concession.u0022u003cbr/u003eu003cbr/u003eDespite this guidance, ContourGlobal - KivuWatt managed to secure a concession that was expressed only in output terms, i.e. to produce 100 MW of grid-power. It had no reference to the inputs required.u003cbr/u003eAt (1) the relatively low efficiency at which KivuWatt extracts gas, (2) the limited (single - LRZ) zones from which it extracts, (3) the high consumption of parasitic energy to run the barge operation, and finally (4) the modest efficiency of the selected gas engines, it over-uses resources relative to policy.u003cbr/u003eu003cbr/u003eAt these overall modest efficiencies, a fully developed concession of 100 MWe of output power could consume 30% more than Rwanda's total resource allocation. That is more than was recommended to have been allocated equally to five Rwandan concessions. It also appears that KivuWatt has the intent to extract only from the deepest LRZ zone, which is richer in gas content than the URZ. Symbion had no intent of extracting from the URZ at all, but elects to destroy it through dilution with re-injectate.u003cbr/u003eu003cbr/u003eFurther, although KivuWatt had not fully designed or built any GEF before the June 2009 first issue of the official MPs, they “leaned” on the government implying legal action if made to comply with them. In fact, their GEF designs did not comply with MTRs 3, 4, 5, 6, 9, 10, and 12 of the 2008 version. They have not complied with MARs 1, 2, 3, 4, 6 and 7 either. Symbion/ Shema is similarly failing to try to comply with them.u003cbr/u003eIf one references the June 2009 Final issue of the MPs, KivuWatt was non-compliant with the very same MTRs as above, which were substantially the same. Of the two additional MTRs, 13 could not be complied with while 14 added no additional problems for KivuWatt. Some of the MARs were defined more explicitly, but the subject matter was unchanged. MAR 9 was added, requiring inspection of underwater equipment before installation. The same non-compliances were present if judged against the 2008 or 2009 versions. Symbion also planned to repeat the same MTR non-compliances, but at least made a better start on complying with MARs.u003cbr/u003eu003cbr/u003eIf KivuWatt asserted in a lawsuit that there was a substantial u0022change in lawu0022 between the bootleg 2008 version and formally issued 2009 version, this is not in evidence. The project was pursued in an unchanged manner in defiance of directly-comparable clauses in both versions.u003cbr/u003eu003cbr/u003eIn fact, KivuWatt pursued a legacy process design that was prohibited by both versions, but a little more explicitly in the final and formal issue. This more explicit version of 2009 was issued as, by then, the Expert Group had more time to simulate the comparable extraction methods and their dangerous impacts on the lake. By 2019, after four years of operation, the feared impacts were evident in monitoring data. At this point a BRA would have at least suspended KivuWatt operations.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(B) Let us illustrate the previous challenge by first inferring some operational conditions of KivuWatt and subsequently demonstrating consequences for concession management.u003c/strongu003eu003c/emu003eu003cbr/u003eThis sentence on p42 is difficult to understand, even after six readings. Does it perhaps suggest that KivuWatt is experiencing difficulty with operating, not due to the outcomes of poor design and subsequent non-compliance, but because of the award of a concession was too early to have clarity?u003cbr/u003eu003cbr/u003eIt's difficult to answer this question without being able to discern its clear meaning or intent. But let me say this: The design period used by KivuWatt ran from 2008 to about 2012, while the company was struggling to raise funding. There was plenty of time, i.e. 4 years, to do some thinking, and some design work, and to ask some questions of the experts, but it seems that no-one applied their minds over this very long interval. KivuWatt and its engineers got no closer to a viable solution and showed no curiosity on what that might be. Either they didn't know how much they didn't know (likely) or didn't care to know by being wilfully ignorant.u003cbr/u003eu003cbr/u003eKivuWatt's country manager, in a presentation at the 2011 Gisenyi conference of the experts, candidly admitted that they (KivuWatt) had little clue on how to resolve the engineering problem posed by Plan A1/A2. I appreciated his candour, it was refreshing, especially from an organisation that seemed to lack any candour or openness.u003cbr/u003eu003cbr/u003eThe outcome seemed to be to choose the u0022least-worstu0022 non-compliant design and go with it, while trying to get away with it by disclosing none of what was required by the MPs. It's a real curiosity: perhaps they had their lawyers making all the engineering and PR decisions.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(C) The density of 355m deep water subsequently re-injected methane-poor at about 240-250 m (Figure 2.1) cannot be matched to the water density in the Potential Resource Zone (Figure 2.2) by just reducing its carbon dioxide concentration.u003c/strongu003eu003c/emu003eu003cbr/u003eThis single sentence was enough for KivuWatt to know that their chosen solution could never be made to work. Why then did they persist in trying? It only got their design problems worse, and worse, and then worse again. This is the point at which someone should have made the decision to ask for expert help. It never happened. Instead it was left to the lawyers to sue the government to recover some of the losses while their engineers muddled on.u003cbr/u003eu003cbr/u003eThe KivuWatt plant's litany of engineering and design errors, cartoonish mistakes and multiple miscalculations makes interesting but depressing reading. The balance of these four paragraphs on p43 is like reading the proverbial story of the person who dug a hole too deep to climb out, so he decided to keep digging deeper. I find little point in commenting on the numbers as that's a fool's errand. I will say though, that the dilution plan in the PRZ is a compounding error, rather than a solution to the problems of KivuWatt’s bad practice.u003cbr/u003eu003cbr/u003eThe urgency needed here has less to do with u0022active concession managementu0022 but more for KivuWatt to stop the disaster that they are making. They could perhaps re-start, with some proper engineering and design work that complies with the rules, or maybe just give up and get out of the way. LKMP is starting to see the dire outcomes of the above lunacy. The impacts are becoming more serious by the day and the operation needs to be suspended for cause.u003cbr/u003eu003cbr/u003eu003cstrongu003eu003cemu003e(D) On the “Preliminary conclusions and observations” u003c/emu003eu003c/strongu003ein 3.4, the provocation promised is delivered, and therefore the answers are provided in similar tone to each statement. These are asked and answered as numbered on p43:u003cbr/u003eu003cstrongu003eu003cemu003e(1) An expert panel should assess and order risks involved in methane extraction for evaluating safety regulations and evaluating (our) additions of the Management Prescriptions.u003c/emu003eu003c/strongu003eu003cbr/u003eu003cbr/u003eI have disputed above-stated notion that risk assessment was not done or done insufficiently. It was thorough and deep, working in a domain where some scattered data had been gathered, where no valid production data was available, but also where widespread and really deep subject matter understanding of a unique freak of nature was lacking. This latter case persists, if some of the narrative in this panel review is weighed up.u003cbr/u003eu003cbr/u003eThe MP's drafting process was very substantially a risk assessment. For that reason, it turned what was supposed to be a week-long exercise called by the NCEA in March 2007, to affirm the 1986 Socigaz Rules (the first equivalent of the MPs). A week was never enough. But it was a start of what turned into a three-year deep-dive of risk assessment of a lake that is a risk-laden phenomenon.u003cbr/u003eu003cbr/u003eI can supply graphic examples in dozens of email exchanges that led to calling a series of conferences to question and discuss the risks and issues in a group setting, first in October 2007 where the size of the problem was simulated and risks realised. Then in May 2008 we began to match solutions to the risks and issues. The exercise continued through individual efforts and email communication for another year. Only then, a final May 2009 conference was convened again by the NCEA. Despite the trenchant resistance of one expert with his own unsupported theory, there was unanimity among the rest in publishing the MPs under pressure from the GoR and the NCEA.u003cbr/u003eu003cbr/u003eAfter lengthy debate, assessments, modelling, data searches and solution-crafting, the MPs created a set of constraints and rules within which safe engineering solutions could be created and operated. The panel should review its own understanding (and unsubtle criticisms) of this process and its drivers, that resulted in the key decisions that are now embedded in the MPs. It was thorough and productive and completed by volunteers with great commitment to seeking answers and consensus.u003cbr/u003eu003cbr/u003eNothing that has surfaced in the above 43 pages of the panel report adequately questions or convincingly undermines the basis or substance of the outcomes embedded in the 2009 MPs. With hindsight some improvements are possible, some loopholes can be closed, some data and hypotheses can be reworked. Some models can be improved with further data collected.u003cbr/u003eu003cbr/u003eActually, just maybe we can stretch provocative theory to its limits. There is this new theory of everything from the same place that Einstein developed his theory of everything. The gas is all fossil origin. Big Oil snuck it in there while we weren't watching. The biogas was all a Big Hoax by the Ukrainians, or maybe the Left-Wing Press. Dead algae is only there to mess up anchoring systems. The 1st Law of Thermodynamics was also a hoax. See, I have the best words. I know more than all the scientists. The lake erupting is another hoax, believe me. Excuse the interruption, at this point you can lead me away in a straitjacket.u003cbr/u003eu003cbr/u003eActually, this was why the MPs themselves called for this review. There is, however, hardly any justification in the panel report to overturn the principles, methods and findings. But the debunked theories of ten years back must seemingly be debunked all over again. They lacked essential substance and merit then, as they do now. But we shall persist as it is too important to do otherwise. u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(2) “1. Their report should serve as mandatory technical reference for licensing”u003c/strongu003eu003c/emu003eu003cbr/u003eAs one of the previous experts, we shall review this panel's work to see if its quality and value supersedes the rigour, depth and breadth of the previous work, even with its budget 20 times higher than ours. Then we can judge whether the outcome is worthy as a mandatory technical reference. Is the plan to replace the MPs with it or to supplement them?u003cbr/u003eu003cbr/u003eA biblical cautionary tale reads: u0022Judge Not Lest Ye Be Judged.u0022 Do the work first and then decide whether it's also a worthy u0022mandatory referenceu0022.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(3) “2. In-situ, on-platform, and on-line observations and forecasting of meteorology (wind, lightning etc.) and hydrodynamics (surface waves, currents preferably over the full depth) or platform motions should be included in licenses of GEFs as these are essential for safeguarding operations and are essential for determining the probability of exceedance for safe platform designs.”u003c/strongu003eu003c/emu003eu003cbr/u003eThis is a u0022cart-before-the-horseu0022 moment. i.e. Go and do all the observations, meteorology and forecasting after you built the platform, model it all and then decide whether you built the right platform? What if you hadn't built it right? Start it all over again? Not a bad idea for KivuWatt!u003cbr/u003eWhat is the directive here? Do five years of all these measurements before you do anything? Is it perhaps, do constant weather forecasts to see if your platform was built strong enough?u003cbr/u003eu003cbr/u003eu003cstrongu003eu003cemu003e(4) “3. The adapted MPs should acknowledge the following. The increase in exploitable methane mass in Lake Kivu is not discernible and within 50 years should not accounted for.”u003c/emu003eu003c/strongu003eu003cbr/u003eWho writes this? New sets of readings, with uncalibrated equipment, show that some methane has disappeared relative the prior data sets. So, the theory of biogenesis gets discarded, along with the 1st Law of Thermodynamics. It is replaced with u0022No discernible increase in exploitable methane mass means that methane is of fossil-origin, can't be renewable, so the methanogens were all imaginary and, therefore, we don't need to look for any again in the next 50 years.u0022u003cbr/u003eu003cbr/u003eThis is so startlingly “ballsy”; it can be put into a Monty Python show along with their Great Theory on Dinosaurs. Send it rather to John Cleese and his colleagues.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(5) “4. The adapted MPs should acknowledge the following. The upper and lower resource zones (beyond 260m depth) contain all economically extractable methane (concentration) of 40 ± 4 STP km³ (STP equals 1 bar and 0°C). Any increase in methane concentration in the potential resource zone or in the resource zone proper should not be accounted for in its present exploitation, concession governance, nor in the direct future (next 50 years), allowing time for formulating an equitable extraction policy between the different concessionaires.u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eThis is deja-vu all over again…. a corollary of Point No 3! But this time we slip in a new formulation of equitable resource sharing. It's simpler than that: Stop KivuWatt from robbing all of Rwanda's LRZ resource and 30% of the DRC's. Then do more measurement. Rinse and repeat for five or ten more years. That is the necessary proof. Then re-evaluate the resource trends and adjust the concessions up or down as necessary. A simple clause in the concession should allow for that.u003cbr/u003eThe KivuWatt concession overuse is a much bigger problem and will cost both countries billions in lost resources, much more than this particular suggestion can hope to resolve.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(6) “5. The adapted MPs should replace Plan A1/A2 by scenario PR1 in (Wüest et al., 2009), and suggested by (Halbwachs, 2011b), with methane extracted from the Upper Resource Zone and with deep water re-injected into the Potential Resource Zone. Compared to Plan A1/A2 this safe alternative is intended to facilitate a larger-scale, and economically-feasible energy production while safeguarding the lake’s safety, ecology and methane resources in both URZ and LRZ but neglecting potential profits from the Potential Resource Zone.”u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eReally? PR1 was studied as part of the discussion in the Expert Group reviews that led to the published MPs. It received no support. Neither did Halbwachs' (2011b) look-alike version of the disaster that is KivuWatt's design at the 2011 conference. The destruction of the Main Gradient and its likely consequences is a crime against humanity for its reckless endangerment of a population of millions in the Kivu valley. Is that how provocative you want to be?u003cbr/u003eu003cbr/u003eThe alternative is neither safe, nor productive, nor economical (see KivuWatt's resource and economic performance if you wonder why).u003cbr/u003eu003cbr/u003eu003cstrongu003eu003cemu003e(7) “6. The adapted MPs should acknowledge the following: The variability in overall efficiencies in producing electrical energy is significantly larger than the ±10% uncertainty in methane storage. Hence, incentives for maximizing efficiencies in methane to electricity conversion are first priority, as well as monitoring the performance in terms of electricity produced versus extracted deep water.”u003c/emu003eu003c/strongu003eu003cbr/u003eu003cbr/u003eI’m shocked. After the u0022gong-showu0022 going on in items 1-6, finally some reality. But there's more.u003cbr/u003eThe first and major efficiency is in gas extraction, which can be improved to more than double KivuWatt's. The second is in parasitic energy, which can be cut by 90%. The third is in power generation, which can be increased by 50-60% with better quality gas and generation equipment that needs that quality to perform. Good engineering and design is needed.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(8) “7. Some minimum of overall efficiency of energy production versus energy contained in extracted methane should be included in licenses of GEFs.”u003c/strongu003eu003c/emu003eu003cbr/u003eNow we're on a roll! Two valid, good ideas in a row.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(9) “8. Operational conditions such as fluid and gas fluxes and pressure on the platforms and their energy production should be provided on-line to the surveying authorities and should be included in licenses of GEFs.”u003c/strongu003eu003c/emu003eu003cbr/u003eToo good to be true. This was in the MPs already, so yes again.u003cbr/u003eu003cbr/u003eu003cstrongu003eu003cemu003e(10) “9. The MPs should define the physical function and define monitoring the intended evolution of a concession e.g. lake-wide horizontal diffusion and horizontal circulation of re-injected water.u0022u003c/emu003eu003c/strongu003eu003cbr/u003eYes, once again - the proposed monitoring that LKMP has been trying to do with limited funding.u003cbr/u003eu003cbr/u003eu003cstrongu003eu003cemu003e(11) “10. The scientific community should be granted (what: permission, funding?) to continue monitoring size and depth of chemoclines/isopycnals, the exploration of all major aquatic and sub-aquatic sources of water, heat and constituents, and the development and application of related instruments.u0022u003c/emu003eu003c/strongu003eu003cbr/u003eu003cbr/u003eCollect data for how long - 10, 20, 50 years? And then we can find something that we didn't think of today. By then how much would have happened? Perhaps then we can explain in detail why we lost the lake's stability and how everything went south from there.u003cbr/u003eu003cbr/u003eWhat we had in the MPs is good. Actual concession drafting was disastrous. Enforcement was worse. Acceptance of poorly conceived and executed engineering and design was a disaster.u003cbr/u003eu003cbr/u003eItems 1-5 on the above summary list are marginal to very poor recommendations.u003cbr/u003eItems 6-9 have merit and should be considered for inclusion with existing MPs.u003cbr/u003eItem 10 is not clear in its request for granting something, nor from whom. Is it a Christmas wish?

u003cbr/u003eThe Management Prescriptions Review Panel Asks: u003cstrongu003eIs there a clear confirmation that the increase in exploitable methane mass in Lake Kivu is not discernible within the next 50 years? u003c/strongu003e

u003cstrongu003eu003cbr/u003e u003cemu003e(A) In reply to the following comment: “On the matter of non-biogenic sources of methane and sudden inflow events and significant recharge of methane”:u003c/emu003e u003c/strongu003eu003cbr/u003e u003cbr/u003eThere is no credible scenario for a non-biogenic inflow of methane into the lake. Fossil methane is speculated to have formed in the Graben underlying lake Kivu. The proximity of hot volcanic zones under and to the north of the lake may compromise the potential of such a source of methane to exist for the long term. Also, fossil methane would almost always include ethane/propane/ butane in the mix. These are not present.u003cbr/u003eu003cbr/u003eBiogenic production remains a more plausible explanation for u0022sudden inflowu0022, but only in a scenario where doubling the resource may take say ~100 years instead of 200. It won’t be instantaneous.u003cbr/u003eOn the matter of recharge: A better statement is that Schmid's results, using not-fully-proven measuring techniques in the deep lake conditions, can neither confirm nor reject a significant recharge. What other credible source of methane exists?u003cbr/u003eu003cbr/u003eIf this is proposed as a conclusion, it is far-reaching and extremely important to properly verify. What is the alternate hypothesis on the origin of the methane? The measurement method may be subject to significant error. For example, if the error is -20%, the opposite conclusion could be drawn. u003cbr/u003eu003cbr/u003eThe conclusion raises questions and does not establish an incontrovertible conclusion yet. The techniques used were not yet convincingly calibrated for this purpose, for the mix of constituents or for the depth of resource. The measurement tool is however promising as a method and deserves consideration. But any gain in the lake methane content, or even unexplained reduction as may be proposed here, is dependent on other factors not mentioned here. For example:u003cbr/u003e · The range of result in the Boehrer paper shows methane figures such as 18.0 +/- 1.0 mmol/l. at depth. That variability is +/- 5.5%. What is the comparable variance with other methods?u003cbr/u003e · Is there a comparable commentary on the accuracy/variance of numbers back in 1975 and 2003? Could we have a combined variance of between 10-15% from then to now? If so, are any of the conclusions that can justifiably be drawn outside the potential error range and therefore statistically significant, or not? This is not explained.u003cbr/u003e u003cbr/u003eu003cstrongu003e u003cemu003e(B) u003c/emu003eThe panel report states that: “u003cemu003eThe conclusion of this research is that the risk of a gas blow-out is not increasing, and additionally that also the lake’s methane resource is not renewable i.e. equivalent to a fossil fuel source.” u003c/emu003e u003c/strongu003eu003cbr/u003e u003cbr/u003eIf this is a conclusion, what is the alternate hypothesis on the origin of the methane? The measurement method may be subject to significant error. If the error is -20%, the opposite conclusion could be true. This is by no means conclusive or acceptable yet. Years more data are needed to provide proof for such slow change. The measurement error range is equivalent of 10-20 years of earlier assessments of rate of change.u003cbr/u003e u003cbr/u003eu003cstrongu003e u003cemu003e(A) The panel report further states that:u003c/emu003e u003cemu003e“At some depth gases released from the riser flow are captured in a separator being a container at some specific depth (read hydrostatic pressure) were dissolved and free gases are in equilibrium.” u003c/emu003eu003c/strongu003eu003cbr/u003eu003cbr/u003e This statement is neither good, nor scientifically correct, nor valid in any engineering sense. Gas release is not instant and therefore not in equilibrium in separators. Static systems over a long time reach equilibrium, but dynamic systems do not over a short time. That's false.u003cbr/u003e u003cbr/u003eu003cstrongu003e u003cemu003e(B) The panel report states in this same section: “The natural ratio of methane to carbon dioxide in Lake Kivu appears to be too low to run biogas engines.” u003c/emu003eu003c/strongu003eu003cbr/u003eAppears? It is, at 20% methane, too low by a large margin. You can use that mix to put a fire out instead. 50% is close to the minimum combustible methane in gas for engines. u003cbr/u003e u003cbr/u003eu003cemu003eu003cstrongu003e (C) A further panel comment is “The less-favoured alternative by the expert group was the Density Gradient Draw-Down Method (GDM) though this method does appear as plan B in the MPs, see below.” u003c/strongu003eu003c/emu003eu003cbr/u003e In response, this u0022GDMu0022 was not just u0022less-favouredu0022, but absolutely and comprehensively rejected by all other experts in the group. The GDM (which is NOT the same as Plan B) has a destructive impact on the natural stability structure of the lake. It also brings vast quantities of nutrients from deep water into shallow water. A principal reason for its rejection was the long-term instability of the lake. It comes from existing and (if and when new gas generation produced) fresh gas, that it would no longer be contained in the lower half of the lake. The same applies to all gas remaining after the first 50-year harvest.u003cbr/u003e u003cbr/u003eu003cstrongu003e u003cemu003e(D) The MPs are not clear whether this is per concession or per production unit and what should be the geographical dispersion of the production platforms.u003c/emu003eu003c/strongu003eu003cbr/u003ePlan A1 requires smaller production units to reduce the impact of large volume extraction and re-injection flows on the gradient layers. A limit of 5 MWe in the output capacity was agreed at the 2008 and 2009 conferences of the experts. It was not an absolute figure but the best guidance at the time. The sensitivity of the gradient layers (260 m and 310 m) to large volumetric flows was the major concern. This is one of many contraventions by KivuWatt in its design. u003cbr/u003eu003cbr/u003eu003cstrongu003e(E) u003cemu003e A further panel comment is “The less-favoured alternative by the expert group was the Density Gradient Draw-Down Method (GDM) though this method does appear as plan B in the MPs, see below.” u003c/emu003eu003c/strongu003eu003cbr/u003e Tietze lobbied for this alternative on the grounds that he could u0022inventu0022 a method of extracting all nutrients. He proposed that this could be part of the process of releasing the gas from the deep water. He could not offer any clue as to how this nutrient extraction idea could be achieved. He has not managed to do so in the ten years since. Therefore, to raise the GDM as a viable option is both dangerous and retrogressive science.u003cbr/u003eu003cbr/u003eIn the end Plan B turned out to be impossible to implement, as the required drop in density could not be achieved, without dilution causing the consequent u0022loss-of-useu0022 of much of the gas in the URZ. Plan B should be disregarded as a viable option, as noted in the comment above, and deleted from the MPs.u003cbr/u003e u003cbr/u003eu003cstrongu003e(F) u003cemu003e A footnote in the panel report says: “The MPs are not clear whether this is per concession or per production unit and what should be the geographical dispersion of the production platforms.”u003c/emu003eu003c/strongu003eu003cbr/u003eThe MPs do not imply that 5 MWe is a limit on the size of a single production platform, nor for the capacity a concession. That is a mis-read. What it suggests is that a number of 5 MWe modules could be attached to a single barge/platform. i.e. Five such modules could produce 25 MWe and ten could produce 50 MWe. This is simple arithmetic, in case anyone missed the point. However, the spacing between individual 5 MWe production modules still had to be at least 100 m.u003cbr/u003eu003cbr/u003eKivuxxxx has placed four larger modules (80% over-sized) within 50 m of each other in their design. 50 m is too close. The only way this would have worked for them was to re-inject their degassed water into the PRZ, where the consequences are damage to the critical density gradient. It was ultimately a poor solution, perhaps their least worst available, but a destructive one at that.

What were the concerns of the Expert Working Group about short-circuiting?

u003cstrongu003e(Au003cemu003e) Hence, dilution of the URZ without energy production should be avoided to exploit this resource in the future. Yet, the gas pressures in the URZ are nearest to saturation limits, see Figure 2.4, though still at a safe level.u003c/emu003eu003c/strongu003eu003cbr/u003e This may have been Kivuxxxx's (mis)interpretation of the MTRs. The requirement clearly states that it should use the URZ first, as the zone more sensitive to poor re-injection practice. Symbion had a worse interpretation They assumed that they can re-inject degassed water to the URZ.u003cbr/u003eu003cbr/u003eThis litany of bad design practice may have included extraction modules being too large (u003e5MWe, Kivuxxxx u0026amp; Symxxxx). Some were too close together (Kivuxxxx, Symxxxx), or unable to create a re-injection density sufficiently lower than that of the URZ (Kivuxxxx, Symxxxx, KP1). The depth had to be greater than at the centre of the 260 m Main Gradient. This density must be achieved by having the uppermost separator between 10-12 m below the lake's surface. This requirement was not complied with by either Kivuxxxx or Symxxxx in their designs, with their top (only) separator at about 20-26 m below surface.u003cbr/u003eAt first here may have been slight inaccuracies in the Chen-Millero re-injection density calculator provided by EAWAG. But any error was not nearly as gross as the 20+ m separator depth selection made by Kivuxxxx and Symxxxx (or perhaps Axxxxxx who carried out their engineering). u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e (B) The MPs do not specify the consequences of short-circuiting; we infer short-circuiting reduces (i) the methane concentration at the intake level as well as (ii) the upward flow in the risers because the gas lift is less powerful, reducing the upward methane flux even further.u003c/strongu003eu003c/emu003eu003cbr/u003eShort circuiting results in the problem described in detail in Michel Halbwachs' paper, quoted in this paper. The consequences are progressive dilution of the resource zone and premature failure of degassing. This problem was clearly identified in the development of the MPs. So was the need to position the top-most separator at a level that prevents mixing and hence this form of dilution.u003cbr/u003eu003cbr/u003eSo, of course short-circuiting would do that. Some things are obvious enough that the MPs do no need to spell them out in great detail. Short-circuiting from a poorly executed design was a warning in the guidance section of the MPs. It was only inserted as a rule to the extent that water had to re-stratify above the resource water through density difference. One should expect designers to have some logical capacity in their thinking. u003cbr/u003e Similarly, one expects that Halbwachs would understand that one has to separate re-injectate from the resource water. The separation works by re-injecting above the resource water at a density difference, as stated. This is why it is written up so in the MPs. The overriding need was u003cemu003enot u003c/emu003eto place the re-injectate u003cemu003eabove u003c/emu003ethe Main Gradient, due to much more serious consequences like destroying the Main Gradient. There was therefore no need to calculate the consequences of getting this wrong, writing a paper on the subject and blaming the MPs for making a mistake that it clearly warned against. u003cbr/u003eu003cbr/u003eu003cstrongu003e (C) u003cemu003eComment on p19: “The intake and the discharge in the same 40-50m thick depth range of the URZ may cause short-circuiting”u003c/emu003eu003c/strongu003eu003cbr/u003eu003cbr/u003e To repeat the above point: It may cause short circuiting if the density of the reinjection is not reduced sufficiently to create a sub-layer above the URZ. The control mechanism for densioty control is the depth of the uppermost (or single) separator used. KP1 has a single separator too deep to achieve the required density.u003cbr/u003eu003cbr/u003eTo repeat the above point: It may cause short circuiting if the density of the reinjection is not reduced sufficiently. The control mechanism is the depth of the uppermost (or single) separator used. KP1 has a single separator, which is too deep to achieve the required density.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e (D) Given the suggested 20 years lifetime of Plan A1/A2 this example would involve 34-35 platforms with anchoring, risers, and pipelines distributed over Lake Kivu. This number of plants may be too extensive for commercial exploitation and investments and required spatial distribution over the lake (see also chapter 7 on concessions).u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eThe question is built on a simplistic and incorrect assumption. Clusters of u00225MWeu0022 modules can be spaced out around a single platform. This solution is neither too extensive nor too expensive as implied. As described several comments above, it is a simple engineering decision. Use multiple, dispersed modules around a platform. u003cbr/u003eu003cbr/u003e Kivuxxxx and Symxxxx both used multiple modules, but grouping them too close to achieve the needed effect of minimising negative impact on gradient layers. There are better designs available to fit the requirement, most likely even cheaper than Kivuxxxx's design. They include appropriate anchoring for the modules.u003cbr/u003eu003cbr/u003eIt is a simple engineering decision to use multiple, dispersed modules around a platform. There are designs available to fit this spacing requirement. They are most likely much cheaper than Kivuxxxx's design. u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e (E) Comment on p19: “No context is presented for allowing to change from Plan A1/A2 to Plan B.”u003c/strongu003eu003c/emu003eu003cbr/u003ePlan A1/A2 were conceived at a time that the detailed density calculations to support their operation were uncertain. That density calculation by Chen-Millero was confirmed subsequently. The engineering needs to achieve the combination of A1 and A2 were confirmed. u003cbr/u003eu003cbr/u003ePlan B was inserted as an alternate, potentially simpler plan to be tried treat the URZ and LRZ as a single zone. It required drawing resource water from the bottom of the LRZ and re-injecting degassed water above the top of the URZ, but below the centre-line of the Main Gradient. It proved unnecessary. Furthermore, the calculator proved that Plan B was much more difficult to design for, as it required the top separator to work under partial vacuum. No transition to Plan B is needed.u003cbr/u003eu003cbr/u003eTo continue from the above point: Plan B is problematic to operate and expensive to design, build and operate. One foresaw it as a standby option, but it proved to be of no value. One can demonstrate this in an engineering calculation, performed using the Chen-Millero calculator. It shows that the separator needs to have negative pressure to achieve the required density and restratification. u003cbr/u003eu003cbr/u003e In the panel review document, Plan B is several times referred to being the same as KivuWatt’s design or Wuest’s PR1 concept. Neither is true because they both discharge degassed LRZ water into the PRZ. These options are highly damaging to the Main Gradient and must be banned.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e (F) Comment on p19: “Subsequently, the MPs propose Plan B (Figure 2.8) in which riser water is taken from the LRZ but allowed to be re-injected in the now methane-poor URZ. The MPs define the latter circulation as Gradient Draw-Down Method (GDM) of the URZ-LRZ density gradient or interface, originally at 310m depth. Obviously, Plan B ends if short-circuiting occurs when the URZ-LRZ density gradient sinks below the riser inlet depth and methane concentrations drop to methane-poor URZ level, still leaving some deep volume of methane rich water not easily exploitable.”u003c/strongu003eu003c/emu003eu003cbr/u003eThere seems to be added confusion in the panel review on Plan B's intent. Plan B was introduced to harvest the combined URZ and LRZ as one. This followed if there was a failure to harvest the zones independently by A1/A2. It is not the same as Tietze's Gradient Drawdown Method, which is banned in the MPs. Although the intent of Plan B is repeated in the statement above, it gets mis-read and incorrectly confused with the GDM Method. u003cbr/u003eu003cbr/u003eIf one works with the Chen-Millero model, it can calculate the level of a separator vessel required to achieve a desired density. From a desired depth of water extraction, one can work out the installation depth. If the depth is above surface, i.e. to operate in a partial vacuum, one can see how Plan B becomes very difficult and expensive to implement. KivuWatt sought an easy way out and re-injected the water back into the PRZ. This has turned out to be disastrous for the Main Gradient, which is in the process of being weakened and ultimately will be destroyed by KivuWatt. This is why all the experts warned against KivuWatt’s plan and rejected the ESIA in July 2010.

Is there a clear confirmation that the increase in exploitable methane mass in Lake Kivu is not discernible within the next 50 years?

The papers and data sets from Boehrer (2018) and Schmid 2019 are not yet nearly sufficient to throw out all others. Their method used lacks well-proven validity over the depth range assessed as it was never previously calibrated for the depth or concentration of gas. u003cbr/u003eThe method will require repeated surveys over multi-year intervals in order to establish either that there is a trend, or lack of any trend. u003cbr/u003eFurther cross-referencing is important in order to establish Schmid’s hypothesis and claims of no-growth in the resource. u003cbr/u003eUncertain measurement, including ~6% plus/minus data range uncertainty, along with any of a number of equipment failures in other measurement methods used from 1937 to 2004, could result in similar variances. i.e under-reporting or over-reporting is possible in any of the data series. u003cbr/u003eSimilar measurement and calibration problems, including failure to account for sample leakage and temperature change, may well have compromised other tests. It is therefore way to soon to make or justify the conclusions put forward by Schmid, which have far-reaching consequences if correct.u003cbr/u003eFurther, if accepted, the data suggest that methane is disappearing from the deeper resource zones. It was up to now common cause that the Main Gradient act as an impenetrable barrier to gas diffusion from below to above the gradient. u003cbr/u003eOnly gas extraction or some form of organic consumption of methane could show otherwise. Neither seems likely nor is either proposed to account for a disappearance of methane. One or more set of measurements must be in error for such a thesis to stand, and Schmid is curiously selective on which data he proposes to ignore.u003cbr/u003eThere are several scientific issues to consider, but the key references are: u003cbr/u003e • Every report on the gas concentration surveys from 1937 to 2019, which references are appended to the panel report and the MPs (up to 2004)u003cbr/u003e • The 1st Law of Thermodynamics (i.e. Matter can neither be created nor destroyed).u003cbr/u003eu003cbr/u003eThis finding of Schmid would effectively throw out all work done on Lake Kivu in the past and have all parties having to reset 83 years of past scientific work and measurement, his included. The physics, chemistry, microbiology, limnology, hydrology, geochemistry and other papers on gas extraction written on the subject would need to be withdrawn or re-written to support his hypothesis. u003cbr/u003eu003cbr/u003eThe MPs would need to be re-written to account for a static or declining methane load, and perhaps the carbon dioxide inventory too. The gas extraction methods actually still need to be the same to preserve the lake safety.u003cbr/u003e u003cemu003eOru003c/emu003e, we could check the measurements, past and present for errors.

How was the development of anchorage of KW barge?

If one evaluates the litany of engineering errors by developers to date, including:u003cbr/u003e • In 2006 the first methane extraction pilot plant REC experienced a riser breakage and sank (not correct, it was unseaworthy and sank)u003cbr/u003e • In 2008 the second methane extraction pilot plant REC experienced a structural/stress failure from poor design, was sinking. It was then ordered to be removed before it broke up and sank.u003cbr/u003e • KP1 experienced gas leakage, failing monitoring instruments and a riser that broke off, shutting down the plant for years.u003cbr/u003e • Kivuxxxx experienced problems with gas being over-saturated in wash-water, causing gas bubbling to the surface around the barge.u003cbr/u003e • The Kivuxxxx barge’s anchors began do drift in soft, spongy bottom strata, not allowed for in the anchor design, causing the barge to drift in high wind and current conditions.u003cbr/u003e • Kivuxxxx failing to design according to the MTRs 3 u0026amp; 4, among others, causing problems with the stability and longevity of the Main Gradient layer.u003cbr/u003e Therefore, one can see a persistent trend of bad engineering, whether through incompetence or lack of know-how, but compounded by the impact of refusing to submit to (or a lack of imposing) the oversight of designs by competent experts. These requirements are set out in the 2009 MPs in great detail thus:u003cbr/u003e u0022u003cemu003eMAR1: Before applying for permission to proceed with the construction of gas extraction facilities, concessionaires must be able to thoroughly demonstrate that: u003cbr/u003e a) their plant designs and operational procedures will be in compliance with the provisions of this document; and u003cbr/u003e b) their Environmental Impact Assessments take these provisions into consideration. u003cbr/u003e Should existing facilities become non-compliant with an updated version of this document, the Bilateral Regulatory Authority will notify the operator of the non-compliance and the two parties will negotiate a mutually-agreed plan for bringing the facility into compliance.u003cbr/u003e MAR2: The locations of water intake and re-injection equipment will be approved by the Bilateral Regulatory Authority based on their depth, horizontal separation, and flow volumes.u003cbr/u003e MAR3: Prior to construction, design drawings must be submitted to the Bilateral Regulatory Authority for approval. This information will be kept confidential. Submitted designs must include at least all configurations of: underwater pipes, pumping systems, separators, gas lines, gas treatment facilities, gas buffer storage tanks, water mixing systems, compressors and blowers; power supply systems on off-shore barges; and gas flaring systems. All submerged materials of construction for underwater pipes and anchoring systems must be part of the documentation submitted. u003c/emu003eu003cbr/u003e u003cemu003e Design drawings must include process flow diagrams (PFDs) and piping and instrumentation diagrams (Pu0026amp;IDs) prepared in accordance with ISO 10628. The design will have been subjected to the HAZOP process, and the HAZOP report must be submitted with the design drawings. This information will be kept confidential. The process flow diagrams (PFDs) shall as a minimum include the basic information as per section 4.2.1 plus items a (mass balance for all gases plus water), b, c, and d from section 4.2.2 of ISO 10628, and the Pu0026amp;IDs shall as a minimum contain the basic information as per section 4.3.1 plus items c, d, e, f and g from section 4.3.2.u003c/emu003eu003cbr/u003e u003cemu003eMAR4: Relevant design data that will be reported at the design stage for all single extraction facilities, and that will be made public, include but are not limited to:u003cbr/u003e a) depth of all extraction and re-injection pipe openings;u003cbr/u003e b) design of the extraction and re-injection pipes: diameter, elasticity, heat conductivity, shape of pipe mouth to achieve internal mixing of re-injected water with surrounding water, ejector/diffuser, etc.;u003cbr/u003e c) design flow rates for all water extracted from or re-injected into the lake;u003cbr/u003e d) design flow rates including full mass balance, and expressed in SI Units (t/h or normal m3/h or km3/h etc.) for all gas streams produced during the extraction process;u003cbr/u003e e) the concentrations of methane, carbon dioxide and hydrogen sulphide in said water and gas streams, showing the extraction efficiencies and gas losses;u003cbr/u003e f) detailed and verifiable calculations of expected re-stratification levels for degassed water and for washing water; andu003cbr/u003e g) amounts of sellable power and of all internal power consumption in gas extraction.u003cbr/u003e Any subsequent changes to the above data must be submitted to the Bilateral Regulatory Authority for approval.u003c/emu003eu003cbr/u003e u003cemu003eMAR5: The Bilateral Regulatory Authority has the right of access to gas extraction facilities for inspection at any time, and will provide facility operators with sufficient notice of such inspections. The operator has overall responsibility for safety at the facilities, and thus for granting access. The Bilateral Regulatory Authority personnel will have all necessary safety training as required by the operator for access to the offshore facilities. The operator will provide such training.u003cbr/u003e MAR6: At start-up of a new or modified gas extraction facility, a concessionaire must engage a qualified third party to carry out monitoring in the lake (e.g. salinity and temperature profile measurements) around the point of re-injection. This monitoring will, with sufficient reliability and precision, demonstrate the shape of the plumes of any re-injected water (degassed and washing water). u003c/emu003eu003cbr/u003eu003cemu003eThe purpose is to measure and report, from start-up until sufficient results have been reached, that there are no deviations from re-stratification levels as defined in this document. If necessary, adjustment of density control must take place followed by renewed monitoring until a satisfactory result has been obtained. The third party report will be submitted to the Bilateral Regulatory Authority. u003c/emu003eu003cbr/u003eu003cemu003e MAR7: Operators of gas extraction facilities must report certain operation and monitoring data electronically to, and in a manner and frequency defined by, the Bilateral Regulatory Authority. Operators must be prepared to carry out automatic, online reporting if required by the Bilateral Regulatory Authority. u003c/emu003eu003cbr/u003eu003cemu003eThese data will be made public and used together with other data to develop better scientific understanding of the lake and guidance of extraction concession design, safety and operations. u003c/emu003eu003cbr/u003eu003cemu003eOperator shall ensure that sample points for all major streams are installed, with suitable valving, for taking the necessary samples and for the Regulator’s appointed third party to take samples on request. Facilities shall be designed to allow carrying out tests with injection of tracers (through sample points).u003cbr/u003e Data to be reported include the following parameters:u003cbr/u003e a) Hourly averages of flow rates for all water extracted from and re-injected to the lake, plus the rates of produced gas or electrical power (MW) and cumulative production. Flow meters shall be calibrated once a year and copies of the calibration reports submitted to the Bilateral Regulatory Authority; u003cbr/u003e b) Monthly average values of flow rates for all gas streams produced by the extraction process, including mass balances showing the methane extraction efficiency and the relative carbon dioxide removal rate; andu003cbr/u003e c) Monthly average values of water temperature, conductivity and salinity, as well as concentrations of methane and of carbon dioxide, hydrogen sulphide and nitrogen in said water and gas streams, as well as calculated and/or measured densities of the re-injection water.u003c/emu003eu003cbr/u003e u003cemu003eOther data may be added if concerns for the lake so require.u003cbr/u003e Once a month, a full set of water parameter analyses shall be made in an agreed laboratory on samples of extracted and re-injected water.u003cbr/u003e MAR8: Concessions should be limited to a time frame considered appropriate by the Bilateral Regulatory Authority. In considering an application for the renewal of a concession, the Bilateral Regulatory Authority should consider, among other things: u003cbr/u003e a) the overall gas reservoir management plan for the lake;u003cbr/u003e b) the availability of more efficient and sustainable gas extraction methods; u003cbr/u003e c) the potential need to change the extraction or re-injection depth and/or location; and u003cbr/u003e d) the potential need to change the carbon dioxide removal rate. u003cbr/u003e The Bilateral Regulatory Authority has the right to determine what technical renewal conditions will be required. u003cbr/u003e MAR9: A precondition for permission to start operation of any gas extraction facility is that the Bilateral Competent Authority or its representative has been given the opportunity to inspect all underwater piping and their fittings (as well as the materials they are made of) when assembled onshore but prior to installing these under water. u003c/emu003eu0022u003cbr/u003eu003cbr/u003e Frankly, Nothing More Needs to Be Said. u003cbr/u003e • Kivuxxxx failed on 9/9 MARs u003cbr/u003e • So did REC/Halbwachsu003cbr/u003e • So too did KP1, although it was largely built before the MPs were published.u003cbr/u003eTo correct this: Repeat the same requirements (barring Plan B) in any version of the MPs, only with a stronger BRA and far harsher penalties for transgressions.

u003cbr/u003e u003cstrongu003eUnder what conditions has KivuWatt been licensed?u003c/strongu003e

u003cemu003eu003cstrongu003eFrom the statement on p22 of the panel review: “The set-up of Kivuxxxx is similar to Plan B in the MP, though with re-injection in the Potential Resource Zone (scenario PR1 in (Wüest et al., 2009)). Such a design would not comply with the MP, which calls first for Plan A1/A2 followed by Plan B.”u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003e This statement shows that Kivuxxxx/Antxxxx did not understand (or chose not to apply) Plan B's essential requirements. They modified Plan B by re-injecting into the PRZ. This utterly compromises the intent to protect the Main Gradient. Vaguely similar is not good enough; that’s as close as saying a bus is similar to a car as it has four wheels.u003cbr/u003eu003cbr/u003eThis design element is directly in conflict with one of the more important MTRs in the MPs. Kivuxxxx is unable to comply with many of the 14 MTRs, including the most important. A Kivuxxxx-negotiated concession has stripped the GoR of any control over the mis-use of the resource. The lack of a BRA to enforce the MPs (MTRs and MARs) granted KivuWatt a sense of entitlement and immunity to sanction. u003cbr/u003eu003cbr/u003e Concessional requirements have been abused to an extent illustrated by the lawsuit and arbitration case brought by KivuWatt against the GoR for issuing the 2009 MPs. The basis for the suit was “Change in Law”. This is despite the lack of any substantial difference between the Draft 2008 MPs document and the formally issued 2009 MPs on the MTRs and MARs that KivuWatt has flouted.u003cbr/u003eu003cbr/u003eKivuxxxx’s grievances on the above legal issue seem misplaced. They are trying to attach blame to others for what is a growing litany and engineering and design errors and failures. u003cbr/u003eScientific background is substantiated by the MPs and the body of work that went into its formation. u003cbr/u003eu003cbr/u003eThe few known operational issues are largely anecdotal since Kivuxxxx publishes virtually none of the required data and reportage required under the MARs. For example:u003cbr/u003e • From the initial design data put forward in 2010 as “design information” to support Kivuxxxx’s ESIA application and application for MIGA support, the quality of information, its completeness and its accuracy was laughably inadequate. A few hand sketches, lacking even the basic engineering notation, were put forward for review. u003cbr/u003e • The absence of any design review or compliance review required by the above-copied MARs is a critical non-compliance. u003cbr/u003e • Their design, placed four large separators and their intake and re-injection pipes within a 50 m linear arrangement. It was against the guidance of the MPs.u003cbr/u003e • The report-back to the February 2011 Rubavu stakeholders conference, where the country manager of Kivuxxxx, reported that Kivuxxxx and its engineers “simply did not know how to design a re-injection system for degassed water to comply with the MPs.”u003cbr/u003e• Reportage of incidents, such as the aborted plant start-up in 2014/15. The resulting cloud of bubbles rising up under the platform from over-saturated wash water, was never reported. u003cbr/u003e • Their need to re-design and rebuild the gas washing system to correct the above design defect. Kivuxxx claimed this as a cost due to “change-of-law”, an absurd claim at best and fraudulent at worst.u003cbr/u003e • Kivuxxxx's need to double-up on anchoring systems due to the failure of the original anchors to perform under the lake’s changeable seasonal wind and current conditions. This shows bad design practice.u003cbr/u003e • Most serious of all is the evidence from LKMP monitoring of the lake-wide weakening of the Main Gradient. Monitoring shows alarming evidence of the impact of degassed water re-injection into the PRZ. This contravention alone should require the immediate shut-down of their GEF.u003cbr/u003e • The overuse of resource, due to extremely poor process efficiency, plus the sole use of the resource volume in the band between 310 and 355 m depth, means that Kivuxxxx is accessing well below 50% of the available resource but overusing that band beyond its share. Arguably, Kivuxxxx uses or sequestrates between 3-5 times as much resource as the best available technology for the same net power output.u003cbr/u003e u003cbr/u003eAll the evidence above indicates that the MPs were substantially correct in requiring the technical compliances and administrative compliances. From my review of the MPs, there are many potential additions and one required deletion to the MTRs. The additions are written up in a joint paper written by Hirslund and Morkel, published in Elsevier’s Journal of African Earth Science, January 2020.u003cbr/u003eu003cbr/u003ePerhaps a proper review would have thus dissuaded Kivuxxxx from building this GEF at all. Or it would have at least saved itself from so many embarrassingly incompetent design and engineering errors. u003cbr/u003eThe former would have saved both the countries from expensive wastage of resource, not to mention an increase in the danger levels of the lake. The latter would have saved KivuWatt from tens of millions of dollars of wasted expenditure and years of delayed start-up.u003cbr/u003eu003cbr/u003eAs noted in the panel review document, the BRA was a necessary institution that should have been created to police the many infractions committed by Kivuxxxx. This need is even greater now, as the sense that developers can use political-legal mechanisms to flout the MPs seems to have become the u0022ruling precedentu0022.u003cbr/u003eu003cbr/u003eWe noted that Symxxxx proceeded in virtually the same manner in engineering and design of their proposed GEF. Most of the same design non-compliances were repeated by their engineers. Antares, also did similar poor work on the KivuWatt design. The design changes incorporated only modestly address deficiencies in Kivuxxxx’s GEF design.u003cbr/u003e u003cbr/u003eFortunately, REMA has seen fit to reject the ESIA put forward by Symxxxx/Shema, which has at least one design element that is worse than Kivuxxxx’s, with respect to re-injection.

Panel Review Statement: u0022Remove the scientific doubts between these conflicting views, record it and publish it.u0022

u003cemu003eu003cstrongu003eFrom the reported conflict on p22: Hirslund (2012) argues that in Lake Kivu chemoclines (constituent or dissolved-gas levels) or isopycnals (density levels) are moving upward by inflows to the deeper parts of the lake. These come from water sources with different salinities (citation from abstract Hirslund, 2012). From these inflows and consequent forced upward movement, Hirslund argues that local gas saturation increases. Thus there is an increase in the probability of gas eruption. Hirslund therefore proposes mitigating actions to limit the rise of chemoclines.u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eSchmid and Wüest (2012) object to these mitigations. While they acknowledge that observed thinning of the chemoclines from below is poorly understood, they hold that sub-aquatic sources maintain the chemoclines at their present levels. u003cbr/u003eu003cbr/u003eHaving been at the periphery of both of these arguments, I was part of a discussion on the merits of each. My initial take was that Schmid u0026amp; Wüest were correct. They argue that the sub-lacustrine inflows would “shave off” tops of any rising chemoclines, keeping their levels constant despite thinning. u003cbr/u003eu003cbr/u003eMoreover, in arguing this matter with Hirslund in favour of the view of Schmid u0026amp; Wüest, Hirslund showed that the top fraction of a chemocline may be subject to this dilution/shaving effect, but that the body of the chemocline was not. DDL can explain the same phenomenon. u003cbr/u003eu003cbr/u003eHe also argued that sub-lacustrine inflows will settle at their own level, determined by the inflow’s density. Measurement from 1975 to 2004 showed that the gradients' centre-line (or peak density change) was indeed migrating upwards. The impact of the moving centre-line is material over the long term mass balance changes. u003cbr/u003eu003cbr/u003eHowever, much of the disagreement hasn't been debated scientifically, but expressed more on a basis of personal animus and pride of authorship. It comes down to protecting one's own thesis rather than doing a simple mass-balance to show that sub-lacustrine inflows will push up gradients.u003cbr/u003eu003cbr/u003eWith the combined effects of double diffusive layering, the sharpening the gradients, data also also shows that the peak of the gradient is perceptibly, and justifiably, rising. I now accept Hirslunds version of the mechanism and result, although less convenient than EAWAG's. It creates lake management problems that will need long-term solutions.u003cbr/u003eu003cbr/u003eTo say that rising chemoclines is a myth and has no impact is wrong. Simple engineering mass balance puts that proposition down. The volume of water under each chemocline is increasing. Operationally, rising chemoclines cause a growing and significant problem later on with extraction of gas. Rising chemoclines accelerate the rising partial pressure of gas where it presently peaks, just under the 260 m and 310 m chemoclines. This rising pressure persists even if, as Schmid 2019 postulates, no new gas is being generated. u003cbr/u003eu003cbr/u003eRising chemoclines will gradually, certainly not drastically, impact the Plan A1/A2 creation of new sub-layers in the URZ and PRZ. This is because with scaled-up production, the sub-layers will thicken faster than the rate of rise of the chemoclines. u003cbr/u003eu003cbr/u003eIn this context, mechanisms for rejecting degassed water to the Biozone need sober debate. Degassed water injected to the Biozone has multiple undesirable impacts on the Biozone ecology that must be measured against the safety impacts of rising partial pressures of gas at the top margins of the URZ and PRZ. But something will have to give over time and the alternatives need more study.u003cbr/u003eu003cbr/u003eExtraction mechanisms proposed by Symbion/Shema do nothing to mitigate the problems of rising partial pressures at the present peak. This peak, at ~265-275 m depth, migrates upwards and grows to be more of a concern. u003cbr/u003eu003cbr/u003eIronically, KivuWatt’s method does slightly mitigate present rising partial pressure peaks at ~265-275 m depth and the 315-325 m as their mass redistribution to the PRZ slows the rate of rise of these 260 m and 310 m chemoclines. It does, however, still accelerate the rise of the 190m chemocline.u003cbr/u003eu003cbr/u003eThe 2009 MPs do not address the issue of rising chemoclines. Once the data and proven or disproven theories and mechanisms are settled, hopefully before another 5-10 years have passed, the matter can be addressed by qualified hydrologists added to the mix of experts.u003cbr/u003eMTRs 3 u0026amp; 4 are affected by the discussion. A question of new MTRs to address the control of the level of key chemoclines must be addressed in concert with MTRs 3 u0026amp; 4. While the LKMP and other researchers can help with providing more data, it is the wider set of expertise that will be equipped to address mitigation measures. u003cbr/u003eu003cbr/u003eThe matter is not one to be settled by Deltares and LKMP as they lack the requisite capabilities.u003cbr/u003e

What arguments were used to prefer Plan A1/A2?

u003cemu003eThis is a short question that requires a detailed and wide-ranging answer to many issues, including: u003c/emu003eu003cbr/u003e (A) Halbwachs’ studies deserve the following response summary that we share in our evaluation - Reference is made to non-unanimity in the MPs expert group on the optimal extraction of methane.u003cbr/u003e A 5:1 majority was acceptable in the circumstances, particularly as Tietze did agree several times during detailed debates. He had agreed with our convincing technical arguments, data and models, only to renege days or weeks later. It was a regular pattern he exhibited over three years. In particular, throughout the 2009 finalisation of the MPs, Tietze agreed with the draft until the last day. u003cbr/u003eu003cbr/u003eThe rationale for the Expert Group rejecting the dissent of Tietze was overwhelming. His and Halbwachs' views were rejected for good, reasoned arguments on the stability breakdown that would eventuate. They both argued for a method that would have destroyed the future stability of the lake by breaking up the important density structure. u003cbr/u003eA major safety problem reoccurs well after the completion of 50 years of gas harvesting. That is u003cemu003eif u003c/emu003egas content is regenerated after the initial gas harvest (as argued in this panel review). Their (Halbwachs and Tietze's) harvest approach would have destroyed the existing density structure, resulting in a mixed layer taking up the entire lake. This results in a single density layer, like Lake Tanganyika.u003cbr/u003eu003cbr/u003eHalbwachs issued his paper on the eve of the 2011 Gisenyi conference of stakeholders. The Expert Group nominated Morkel and Hirslund, at the request of Rwanda’s Minister of State for Energy – Dr Albert Butare, to prepare a reply to Halbwachs. The response, repeated here in full and unedited, was provided to him on 18 February 2011: u003cbr/u003eu003cbr/u003eu003cemu003e u0022To all Stakeholders in Lake Kivu Gas Extraction,u003cbr/u003e Re: Comments by Prof Halbwachs on Management Prescriptions (MPs) and in particular Plan A1, A2 and B Methodsu003c/emu003eu003cbr/u003eu003cemu003eu003cbr/u003e Dear Colleagues,u003cbr/u003e As members of the International Expert Group we wish to respond to all parties addressed by the above correspondence, issued to most workshop attendees very shortly before it commenced. As such, we comment on the Halbwachs’ note and its attached YLec report from September 2009. Being addressed as late as it was, to almost all attendees, these were delivered as an “ambush” tactic to gain attention without allowing an opportunity of a timely rebuttal by the experts.u003cbr/u003e Nevertheless, we are obliged to properly consider the merits or otherwise of any communication on the MP’s, and to provide all those addressed with a sober evaluation and response. Both the Management Prescriptions and the conference have channels in place for the hearing of objections to the contents of the MP’s, neither of which was used by Prof Halbwachs. It is therefore principally to allay any concerns that could have been raised in the minds of other delegates that we reply as below. u003c/emu003eu003cbr/u003eu003cbr/u003e u003cemu003eThe MPs have been conceived as Society's tool to prevent future cataclysmic eruptions of the lake while extracting the gas. They are the only known tool to prevent this, and this is why the issue of adherence to the MPs is of exceptional importance. The comments by Prof Halbwachs do not qualify as sufficient reason to change this situation, as described below. If we were to follow these ideas of Prof Halbwachs, we would instead increase the certainty of many future eruptions of the lake. u003cbr/u003eu003cbr/u003e u0022Pour tous ceux qui s’occupent de l'extraction du gaz du lac Kivu,u003cbr/u003e Note sur les commentaires par le professeur Halbwachs sur les prescriptions de gestion (les PG) de lac Kivu, et notamment les méthodes Plan A1, A2 et B u003c/emu003eu003cbr/u003eu003cemu003eu003cbr/u003e Chers collègues,u003cbr/u003e Comme membres du Groupe international d'experts nous souhaitons répondre à toutes les parties intéressées par la correspondance ci-dessus, délivrée aux participants de l'atelier à Gisenyi juste avant qu'il ne commence. En tant que tel, nous ne commentons que la note du Prof. Halbwachs et sa pièce jointe de Septembre 2009, s'adressant si tard à la totalité des participants de l'atelier, l’intention claire a été d‘attirer l'attention des participants d’un côté et de l’autre de ne pas laisser la possibilité d'un échange et surtout d’une réponse par les experts avant que l'atelier ne commence.u003c/emu003eu003cbr/u003eu003cemu003eu003cbr/u003e Néanmoins, nous sommes obligés de prendre dûment en compte le bien-fondé ou non de toute communication sur les PG, et à fournir à toutes questions qui ont été adressées, une évaluation et une réponse mesurées. Pour les PG ainsi que pour la conférence des moyens ont été mis en place pour permettre d’adresser les questions et objections sur le contenu des PG, ceux-ci n’ayant malheureusement pas été utilisés par le Professeur Halbwachs. Il nous semble donc absolument nécessaire d’apaiser les inquiétudes qui pourraient naître dans l'esprit des différents délégués et c'est justement dans ce but que nous répondons ci-dessous.u003c/emu003eu003cbr/u003eu003cemu003eu003cbr/u003e Les PG ont été conçus comme l'outil de la Société servant à prévenir de futures éruptions cataclysmiques du lac lors de l'extraction du gaz. Les PG sont les seuls outils connus pour éviter cela, et c'est pourquoi la question de l'adhésion aux PG est d'une importance capitale. Les commentaires du professeur Halbwachs ne changent en rien cette situation comme décrit ci-dessous. Si par hasard ces idées du Prof. Halbwachs étaient suivies, cela conduirait presque à une certitude de futures éruptions gazeuses du lac. u003c/emu003eu003cbr/u003eu003cbr/u003eu003cemu003eu0022u003cstrongu003eBackground Issuesu003c/strongu003eu003c/emu003eu003cbr/u003eu003cemu003eOn the matter of their being included as part of the creation of the MPs, Prof Halbwachs and Dr Klaus Tietze are long-standing members of the Lake Kivu scientific community whose views are well circulated in publications. There are many parallels and commonalities in their viewpoints and opinions and, as such, one of the two was invited to be represented on the formative Expert Group in March 2007.u003c/emu003eu003cbr/u003eu003cemu003eu003cbr/u003eThe broader scientific, consulting engineering, environmental and extractive technology community was similarly to be included in the group to make it properly qualified and representative. In addition, the group’s appointed members bring with them a broad set of additional skills which have markedly benefited the discussion and development of the MP’s. As such the group was properly and reasonably constituted and was not unduly biased in favour of or against any one particular set of opinions.u003c/emu003eu003cbr/u003eu003cemu003eu003cbr/u003eFurther, in succeeding stages of the development of the Management Prescriptions, between October 2007 in Kastanienbaum and May 2009 where the final draft was prepared, open sessions of the experts were held and successive drafts issued for public comment. The opportunity to attend the May 2009 session was not taken up by Prof Halbwachs and comments on the draft MP’s were refused to be submitted on the “misguided” document on the grounds that he “knew better”. In the final issue of the MPs Dr Tietze was given a right to note his concerns over some elements of the MP’s and to reserve the right to prepare further research on his position and revert with proposed changes with justifications. To date none have been received for consideration.u003cbr/u003eThe MP’s were issued as final in June 2009, and presented to the two governments in July 2009. After receiving copies of widely circulated negative comments on the MP’s, the Minister of State for Energy of Rwanda and the Deputy Minister of Hydrocarbons of the DRC both wrote to Prof Halbwachs to warn him against continued vilification of the MP’s and its authors through the press, including the writing of similar e-mails to the broader community. He was advised to deal with such matters through the relevant authorities, as appointed, and not in the public media.u003c/emu003eu003cbr/u003eu003cbr/u003eu003cstrongu003eu003cemu003eSpecific Objectionsu003c/emu003eu003c/strongu003eu003cbr/u003eu003cemu003eOn the water re-injection method used after degassing, the YLec consultant’s competencies in fluid dynamics referred to are relevant to the argument on the predicted results of the extraction and re-injection piping and methods, but less relevant to the general safety of the lake. The public safety consideration always supersedes the economic priorities of either country, or any developers, in the order of precedence established in the guiding principles.u003cbr/u003eIn the development of the Plan A1, A2 and Plan B as described in the MPs, these more detailed methods were instituted precisely because of the loss of gas recovery potential through dilution of the resource zones. It was well understood that dilution, caused by re-injection water distributing throughout the two mixed resource zones (URZ and LRZ), would render as much as 40-50% of the methane unrecoverable. Much of the research and discussion that preceded inclusion of these detailed extraction methods centred on their practicality and the relative improvement of gas recovery compared to the dilution method.u003c/emu003eu003cbr/u003eu003cbr/u003eu003cstrongu003eu003cemu003eHydraulic Evaluation of MP’su003c/emu003eu003c/strongu003eu003cbr/u003eu003cemu003eIn Copenhagen in both May 2008 and May 2009, two hydraulics specialists were mobilised by COWI to assist with evaluations. Before, during and after these sessions they advised on the 3-D impact of flows deriving from a variety of configurations of re-injection piping and the impact on flow regimes from the design of nozzles. These experts enjoy at least the same reputation as Yves Lecoffre of YLec, more especially in their hydrology experience of large unconfined bodies of water such as lakes rather than in piping systems.u003cbr/u003eThese independent experts were called in to comment on and verify or dispute the opinions of persons in the expert group. Several of the Expert Group members have experience in the hydraulics of water bodies and flows. They had proposed certain configurations designed to vertically segregate the re-injected water from the underlying resource water in each zone. Detailed simulations were performed by these supplementary experts, based on the flow, density, and other data including the configurations of re-injection piping. Their results were used to determine the resultant shapes of plumes and re-injected water lenses in the lake, especially on the ratio of lens spread to thickness.u003cbr/u003eWhere water of the precise density of the lower half of the relevant gradient layer was re-injected through a correct nozzle configuration, the re-injection lens was shown to stratify very widely, with a limited vertical penetration. With the correct parameters and designs, simulations showed lateral transport of 10 km or more being achieved with a vertical lens thickness of no more than a few metres, a ratio of the order of a thousand times. This spreading potential and segregation of the re-injected water is the basis of both Plan A1 and Plan A2 configurations.u003c/emu003eu003cbr/u003eu003cbr/u003eu003cstrongu003eu003cemu003eAssumptions as Basis of Objectionsu003c/emu003eu003c/strongu003eu003cbr/u003eu003cemu003eThe fundamental assumptions given to or used by YLec, gives rise to a serious bias in the results of their analysis. There are nine parameters that need to be well understood in a 3-D simulation, of which too few are mentioned in the analysis provided. Some are assumptions are made correctly, some incorrectly to the extent of being misleading, and too many are not even considered:u003cbr/u003e• The potential influence of the currents, even if for a transient condition, is discussed;u003cbr/u003e• YLec’s shape, configuration and flow parameters of re-injection nozzles are unlike any considered by the experts, and they do affect the analysis markedly;u003cbr/u003e• The assumption of re-injection density being the same as the mixed zone average density leads to the worst case result of zone dilution. Instead, this density should be assumed to being lower than the mixed zone, some 10 % lower than the difference between the mixed zone and the centre-line of the gradient above. This density is made possible by removal of the majority of the CO2 content of the resource water;u003cbr/u003e• Other parameters such as lens shape, the use of diffusers, selective withdrawal designs, flow rate, double-diffusivity effect on vertical and horizontal mixing should also be properly considered.u003cbr/u003eWith the third point above, where the average density of the mixed-zone is assumed by Halbwachs to be the re-injection density, any resultant YLec simulation is not on a comparable basis with the Expert Group’s simulations. This assumption is wrong and designed to produce a misleading result.u003c/emu003eu003cbr/u003eu003cbr/u003eu003cstrongu003eu003cemu003eConclusions Drawnu003c/emu003eu003c/strongu003eu003cbr/u003eu003cemu003eThe statement by Prof Halbwachs that his conclusions are final is rejected. The inherent bias, in both assumptions and modelling methodology, renders the work unacceptable as a basis for such conclusions or for recommending a change to the MP’s. Specifically:u003cbr/u003eThe re-injected water can form a distinct lens, even becoming a distinct layer that forms above the mixed zone of the individual URZ or LRZ layers. During the conference, the simple example given of a cocktail that a barman can make with multiple coloured layers shows the alleged “impossibility” to be false. It’s a matter of skill and precision being demonstrated with fluids of very similar density.u003cbr/u003eThat the dilution of a resource zone leads to a reduced extraction plant’s effectiveness is well understood. The extraction plans in the MP’s were drawn up precisely in order to minimise and delay this effect and then to be able to respond to the eventual drop in effectiveness of Plan A1 after some 20 years by switching to Plan B.u003cbr/u003eGiven all the above, Prof Halbwachs’ conclusion that the description of the technology described in the MP’s as being “totally unrealistic” and “impossible to control” is (in itself) misleading, unfounded and without merit.u003c/emu003eu003cbr/u003eu003cemu003eThe issue of operating to Plan A1 and A2 will remain a concern for the designers and operators of gas extraction facilities, but the effort is necessary to maximise their commercial benefit from their respective concessions while preserving the density gradient layers.u003c/emu003eu003cbr/u003eu003cemu003eu003cbr/u003eu003cstrongu003eExpert Conclusionsu003c/strongu003eu003cbr/u003eThe clear, but unstated, inference from the Halbwachs report’s conclusions is that the MP’s should be based on the original legacy extraction method where the entire Resource Zone is displaced into the Intermediate Zone after degassing. This was the extraction method long-supported by Dr Tietze as well. However, this method unavoidably leads to weakening and, after 50 years methane harvesting, to the destruction of the key stability structures that have evolved to protect the lake for the past 1000 years from self-destruction.u003cbr/u003eA detailed set of quantitative evaluations and simulations of this methodology was analysed by EAWAG in 2007, with comparisons checked against the new proposed alternatives. The simulations of time-based variations to all parameters established the complex and long-term changes to the lake structure, and the dangers and effects of the total mixing of the lake’s zones. These included:u003cbr/u003e• The total loss after 50 years of protective density gradient layers that are essential to keep the future gas production retained safely, deep in the bottom half of the lake;u003cbr/u003e• The virtual certainty that after 50 years, the new gas accumulating will lift to just under the Biozone and will eventually result in frequent smaller eruptions of the lake;u003cbr/u003e• The injection of gas-bearing water of high gas partial pressure just below the Biozone which will, in time, increase the gas eruption risk with saturation levels up to 100%;u003cbr/u003e• The lifting of high nutrient concentrations to just below the Biozone will lead to significant impact on the biozone, including possible eutrophication. In the worst case this eutrophication leads to a dead lake unable to support sustainable fish life and can lead to seasonal releases of methane and hydrogen sulphide, in addition to carbon dioxide, from the surface as oxygen periodically depletes;u003cbr/u003e• The danger of the lake becoming a no-go zone for any surface vessels in the future is contemplated due to outbursts of gas originating just below the biozone. Frequent gas releases could lead to the shores of the lake becoming uninhabitable in the long term.u003cbr/u003eAfter considerable debate in the Expert Group on the need to consider the long-term after the 50-year harvest window, it was clear that the top two principles (Public Safety and Environmental Protection) would be considerably at risk from then onwards. It is quite obvious too that the social benefit from the lake, the third principle, would also be severely compromised for future generations.u003c/emu003eu003cbr/u003eu003cemu003eIt was therefore a clear and irrefutable decision by the experts that the Zone Mixing approach to lake harvesting had to be rejected completely in favour of the newer lake stability approach. The sacrifice of a small percentage of potential harvest in the medium-term (50 years) is not a high price to pay in the circumstances. These two divergent extraction methods are also completely incompatible so there is no room for accommodating both side-by-side on the lake at greater than experimental scale, as the chosen method relies on the stability and positional integrity of the density gradient layers to operate and perform.u003cbr/u003eWe are not opposed to further hydrological and hydraulic evaluation and testing of the proposed extraction methods in the MP’s, and in fact encourage it. We would however insist on the proper use of both verifiable assumptions and models to ensure that a correct result is obtained.u003cbr/u003eYours sincerely,u003cbr/u003eDr Finn Hirslund P Engu003cbr/u003ePhilip Morkel Pr Eng.u0022u003c/emu003eu003cbr/u003eu003cbr/u003eOur opinion expressed in the above letter remains substantially unaltered since 2011. No response or rebuttal to the above letter was received by the Expert Group nor arose until the process of this panel review commenced in 2019. The Halbwachs paper has been unaltered in the intervening years to cater for faulty assumptions made then.u003cbr/u003eConsistent with the opinion in the letter above, in response to Halbwachs contentions, no updates or corrected versions of his paper are published, to our knowledge. One assumes that correcting flawed assumptions and applying generally acceptable modelling techniques may have deflated the desired impact of the Halbwachs paper.u003cbr/u003eThat said, if after nine years there has been no apparent advance by Halbwachs on improving the paper. The 2019/2020 re-issue of it to this review panel should equally questioned for validity of assumptions. So too the veracity of the results as a basis to argue against Plan A1/A2.u003cbr/u003e

What arguments were used to prefer Plan A1/A2? (Continued)

u003cemu003e(B) Comment on p25: “Re-injection in the (same) zone of extracted water creates dilution and should be prohibited, notably for Plan A1.”u003c/emu003eu003cbr/u003eu003cbr/u003eThis view was known at the time of the 2009 issue and had been discussed. Halbwachs failed to acknowledge that this hypothesis applied only to reinjection of degassed water at the same density of the resource zone (URZ).u003cbr/u003eBut the stated requirement in the MPs was to reinject at density less than the URZ zone's density. The difference must be sufficient to form a new sub-layer in the u0022kneeu0022 of the density profile. The density difference must be enough to remain separate from the URZ zone.u003cbr/u003eThe detailed proceedings of discussions at the 2008 conference of the Expert Group were not published to provide as a reference. Parties to the conference, include several hydrology experts from COWI, with whom options were discussed. They include respondents to these questions. The collective opinion, after interrogation, was that the idea of re-injection to form a new sub-layer of the URZ or LRZ was accepted. The MPs were written accordingly. Dr Finn Hirslund must still have access to the same experts and can confirm the evaluation.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(C) Comment on p25: “A minimum efficiency in first stage separation should be imposed (75-80% is suggested.)” and “A maximum fraction of methane in re-injected water should be imposed (less than 20% is proposed)” and “A risk analysis of the evolution of a gaseous explosion is needed.” And “Thorough hydrodynamic simulations of the consequences of re-injection by an expert company are required (see below)”.u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eThis imposition of these suggestion is not necessary or justifiable as a rule. Experts drafting the MPs were clear in saying that the process of extraction and gas scrubbing is a u0022black boxu0022. The black box is the domain of the developer. However, all inputs and outputs from the u0022black boxu0022 are regulated, including their depths within the lake. It should stay that way otherwise the potential for innovation and design flexibility are lost.u003cbr/u003eWhat if there were ten separation stages? Would one stage have to do 80% of the work? That is silly and it is not the domain of the regulator to specify internal elements of the design. The regulator must, however, be convinced that the design is practical, adequately pilot-tested or full-scale demonstrated to allow it to be permitted.u003cbr/u003eThe origins of these highlighted statements is not known, but they display a poor understanding of chemical engineering process design. The suggestions must be discarded as they make no sense and have no applicability to the broader options of plant design.u003cbr/u003eu003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(D) Comment on p25: “The pie-shaped sub-division of the lake into concessions each having access to the deepest part of Lake Kivu located north-east of Idjwi Island is hardly feasible near the end (in time and depth) of exploitation. For access to the deepest parts gas-pipe lines should cross the lake to Rwandese or DRC shores with access to high-voltage electricity pylons respecting terrain and owners; a single concession should take over at the end.”u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eThe pie-shape was the only way to give each concession access to the deepest water in each country. It is thus able to produce until the end of the concessions’ lifetime with the illustrated arrangement.u003cbr/u003eSafety and fairness of concession allocations were behind this choice. This alternative presented is unhelpful and barely comprehensible. The author of this suggestion is unknown, but he/she would be better served by withdrawing this statement.u003cbr/u003eThere is no place for these “narrow interest, no context or self-serving” forms of comment or inclusion in the MPs. This is not in the domain of a regulator.u003cbr/u003eWe must assume that a developer hires a competent engineer and that engineer can design to conform with regulated boundary conditions. They must perform engineering according to industry standards and with the necessary HAZOP or HAZID actions at the appropriate time. If any regulation should be applied to GEFs, it is this paragraph’s italicized sentence!u003cbr/u003eFurther, these ideas apply to the type of legacy design which is inherently unable to operate within the bounds of the MPs. So these have no relevance to the discussion.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(E) Halbwachs’ study and more items on your p25 from the YLec Consultants paper have been quoted here with questions raised. They question items such as “The exploitable minimum…”, “A diffuser set-up…”, “Short-circuiting…”, “Single available study on gas lift…” etc.u003c/strongu003eu003c/emu003eu003cbr/u003eu003cbr/u003eConsistent with the overall opinion in the above letter response, here are some specifics that show the opinions not to useful, applicable, true etc. For example:u003cbr/u003eThis 5 mol methane per m3 limit is highly dependent on the design efficiency of plant alternatives. It's certainly true of designs for Kivuwatt, KP1 and probably Halbwachs. It is not true for multi-stage alternatives, which can operate where single-separator designs are unable to do so.u003cbr/u003eu003cbr/u003eThis diffuser set-up has been argued above already. The assumption made by Halbwachs and YLec are the same, that the density of reinjected water is the same as the zone. The MTR specifically calls for sufficient density difference to remain a separate sub-zone of the URZ. The problem is thus preventable and the conclusion unsupportable.u003cbr/u003eThe argument, once again, only applies to the inherent weakness of designs. Examples include (1) single-separator designs, and (2) a failure to use the available controls of density. These ensure that densities are sufficiently different to remain unmixed in the URZ. The balance of this argument falls away as the base assumption is wrong.u003cbr/u003eThe argument was simple and clear. The fundamental and best protection of the lake against eruption is to retain the current density structure. This must be retained forever, if possible, even if that requires long-term intervention to keep it stable. By re-injecting deep water into shallow water, the main gradient layer (chemocline) will weaken and then disappear. It may then take centuries to re-establish the stability structure and the safety it ensures.u003cbr/u003eu003cbr/u003eIf there is a theory that this will create a stable and static new Main Gradient, it is wishful thinking at best. Due to the stronger sub-lacustrine inflows above the current Main Gradient, this gradient will migrate upwards and disappear faster than before. The 190 m gradient is too high to retain much pressure (~19 bar vs ~26 bar) and therefore less gas storage.u003cbr/u003eu003cbr/u003eAs the gradient weakens, gas can migrate through it and will sharply increase gas partial pressure below the 190 m gradient. All benefits of stability will be rapidly lost. The lake will be a more dangerous place before the first harvest period of 50 years is complete. This theory is dangerous. KivuWatt is practicing this now at a smaller scale. It is already showing evidence of weakening the main gradient and compromising lake safety.u003cbr/u003eu003cbr/u003eThis Fig. 3.2 graphic has a fundamental weakness. It is an equilibrium-state calculation, not based on a dynamic state. Let me put this simply: If you open a beer and leave it so for 24 hours, most of the CO2 gas will have escaped. But it only approaches equilibrium 24 hours later. But the residence time in an extraction system is 2-3 minutes, over which time a far smaller fraction of a beer's CO2 will escape. u003cbr/u003eu003cbr/u003eDynamic curves are very different. Likewise even the green curve, %CH4 recovered, is over-ambitious. 100% recovery is reached at much shallower depth in a dynamic system. It won't get there with 2-3 minutes residence time. The curves are probably 50% over-stated. Halbwachs apparently lacks the data to show a dynamic curve. After all, his theory in 2003 was that it's impossible to extract gas with a separator deeper than 20m. His own test-work failed to collect the relevant data. Hydragas is able to extract and separate gas at 65 m depth by contrast.u003cbr/u003eu003cbr/u003eIf the review panel has no objections to Halbwachs’ proposal, it has much to learn on this critical subject. This statement shows a worryingly low level of subject appreciation and knowledge. It cannot identify glaring and proven problems with Halbwachs' proposal. Considering KivuWatt's dangerous application of it, it is time to get some help. It's really time to u0022go back to schoolu0022 to learn not to make such dangerous statements.u003cbr/u003eu003cbr/u003eThe statement “Plan A1/A2 and Plan B require conditions of the hydrodynamic stability of Lake Kivu” is an example. It's confused and out of touch. It is simplistic and uninformed, akin to one made in 2007 by Dr Tietze. His view was that u0022The only good lake is a dead lake. Take the gas out quickly and completely in 50 years. Then we are done.u0022 u003cbr/u003eHis view was dissected thoroughly and rejected for its many flaws by the Experts in 2007-2009. Fundamental to our rejections was that the world still needs to be safe well after 50 years. The lake will be there, biogenesis will be there (despite Schmid's revelation that methane is fossil). People will be around the lake and they will be placed in mortal danger. The danger arises mainly by elimination of the best natural protection against gas eruptions. That protection is the density structure. It must be kept as-is.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003eOn the statement “We conclude on (Halbwachs, 2011a,b,c ; Guillaume, 2009) as follows. u003c/strongu003eu003c/emu003eThe definition and function of concessions is of major concern. The reduced performance of gas-lift driven flow-rate in risers is not explicitly referred to in the MPs but of concern for determining the end of-exploration.”u003cbr/u003eu003cbr/u003eNothing stated above establishes any such rationale for your concern. Despite his theory of di-phasic flow, Halbwachs’ ability to create high-performing gas-lift is lagging the leaders. This u003cemu003eitalicisedu003c/emu003e statement in the panel review shows a concerning bias. It provides little justification that stands up to inspection. u003cbr/u003eu003cbr/u003eThere seemingly exists an implicit distrust of the prior work Expert Group members. This is despite not having tested the arguments against Halbwachs' paper. These are now provided. Two eminent COWI hydrologists did simulations and made presentations to the Experts in Copenhagen. They established that a stable re-injection lens could form in the given conditions. It would be a couple of metres deep and up to 20 km wide. u003cbr/u003eu003cbr/u003eIt is concerning again too that Halbwachs never sought to correct or update his paper for this panel review. It is nine years after it was issued and largely built on false assumptions. But he threw it again into the mix in a hope of not being found out for flawed assumptions. I suggest you set up a proper debate on the subject. It's preferable to listening to one side only and pronouncing the above conclusion.u003cbr/u003eThe Expert Group never issued published, formal working papers from its proceedings. Much of the work was consolidated by Hirslund in a 400-page treatise, shared among some members. This is still not published. u003cbr/u003eu003cbr/u003eHalbwachs publicised his 2011 study to refute the MPs. But he made invalid assumptions in the paper as the basis of his argument. As a result, his paper is only true for a case mixing equal density discharges into the URZ. For the Plan A1 and supporting MTRs it is invalid.u003cbr/u003eThe Expert Group spent almost two years, from 2007-09, dissecting Halbwachs and Tietze's theories. They found them to be grossly flawed sometimes. So it is time-consuming to have to debunk them all over again. A major underlying flaw is their shared prediliction to destroy the lake's density structure. This key structure is still widely acknowledged as the best natural protection against a lake eruption.u003cbr/u003eHirslund has published a number of papers to describe his work and findings on Lake Kivu since 2009. I have taken the time to study them. Although few are in my field of expertise, they are a valuable source of insights into behaviours of Lake Kivu. One paper, jointly authored with me, is now published in Elsevier’s Journal of African Earth Science, January 2020.u003cbr/u003eu003cbr/u003ehttps://www.sciencedirect.com/science/article/pii/S1464343X19303279. In this paper there is in-depth investigation of issues and ideas put forward by other authors in the field since 2009. There are also new ideas and findings on improving the safety of extraction.u003cbr/u003eu003cbr/u003eu003cemu003eu003cstrongu003e(F) Comment on p28 (KivuWatt 2015-present): “However, to some degree the strategy followed by KivuWatt does comply with the MPs in the aspect of depth of re-injection and the diffuser designs which agree with the primary intention of the MPs.”u003c/strongu003eu003c/emu003eu003cbr/u003e14 MTRs have vital requirements, serious requirements and good practice requirements. KiwuWatt is compliant with some less serious needs and non-compliant with the more serious.u003cbr/u003eBut the MTRs are not a smorgasbord. They are mandatory, all 14 of them. Complying u0022to some degreeu0022 is not adequate. One good diffuser design does not excuse half a dozen non-compliances in other areas.u003cbr/u003eIf anything, more MTRs are needed to tighten up KivuWatt's further bad practices on a poorly engineered plant. Lawsuits initiated by KivuWatt are a political-legal argument against complying with the 2009 MPs. But these MPs were written six years before KivuWatt commissioned their platform.u003cbr/u003eu003cbr/u003eTheir lawsuit claims a u0022change-in-lawu0022. KivuWatt reportedly preferred a u0022bootlegu0022 2008 early draft copy of the MPs, that a government official provided. But KivuWatt had been present, represented by their project technical director and ContourGlobal counsel in Copenhagen in 2009. Examination of the claims made in the lawsuit indicate that virtually all related to their poor engineering, rather than any change in law.u003cbr/u003eIt may be legal practice to argue that prior law is u0022grandfatheredu0022 when it is updated. But this argument must be refuted when used to excuse placing millions of lives at greater risk. However, in this case there was no prior law. u003cbr/u003eu003cbr/u003eNeither engineering nor construction were even started by time the MPs were first formally issued in June 2009. The relevant elements of the 2008 and 2009 MPs do not differ.u003cbr/u003eu003cbr/u003eShould there be any access to view the proceeds of the KivuWatt vs GoR, there would be documentary evidence. Evidence both on behalf of the proponent and the defendant can be found there.

How would this in your view affect the current set of MPs or current operational practises?u003cbr/u003e(please specify the current number of the MPs that would possibly be affected)

It appears that the review panel scoured the earth for every negative sentiment, or every aggrieved proponent of debunked theories. This applies whether they were dealt with in the past or not. The same arguments are presented, without having addressed identified errors, false assumptions and unsubstantiated data. These prompted a previous debunking of the findings, conclusions and hypotheses in their work.u003cbr/u003eu003cbr/u003eCuriously too, the work of KivuWatt has been presented here as a u0022good exampleu0022. In fact it has been more characterised by engineering and design flaws and lack of compliance. It demonstrates outright avoidance of compliance with technical and administrative rules. This lack of oversight provides clear evidence of no real knowledge and insight by the review panel. There is seemingly a willingness to believe anyone with a grievance.u003cbr/u003eu003cbr/u003eAs a result, there seems to be scarce constructive value emanating from this panel review. It is assembled with a suspicious mind-set, with most of the suspicion directed at the established experts and little directed at their critics.u003cbr/u003eu003cbr/u003eThis panel document did not identify the one MTR that was actually flawed. We acknowledge that MTR 5 on Plan B was flawed in its construct. But the panel document has falsely identified problems with other MTRs. These u0022issuesu0022 have not been established with any validity.

Why are conclusions offered in 3.1.5 on a series of contentions statements?

On p29 is a summary of Conclusions is offered in the panel report. Most of these are somewhat contentious and unproven, including:u003cbr/u003eu003cbr/u003eu003ccodeu003eu003cemu003eu003cstrongu003e3.1.5 Our conclusions on previous discussions on the MPs. Before we continue presenting our review, we summarize as follows the existing recommendations and amendments about the MPs. 1. The concerns and proposals presented by Halbwachs (2011a,b,c) and (Guillaume, 2009) are explicitly related to the methane extraction procedures of the MPs and point to voids in the MPs definition of concessions.u003c/strongu003eu003c/emu003eu003c/codeu003eu003cbr/u003eDealt with before in 2011 and can be rejected again and again for the same reasons. The detailed letter of 2009 to Halbwachs stands, unanswered to date.u003cbr/u003eu003cbr/u003eu003ccodeu003eu003cemu003eu003cstrongu003e2. At least the part of Halbwachs’ proposal to re-inject de-gassed URZ water into the PRZ (Table 3.1) deserves closer attention.u003c/strongu003eu003c/emu003eu003c/codeu003eu003cbr/u003eThis is dangerous, not improving on retrospectively approving KivuWatt's bad engineering and failure to conform to the MPs. It deserves closer attention again to justify its rejection and continued banning.u003cbr/u003eu003cbr/u003eu003ccodeu003eu003cemu003eu003cstrongu003e3. The discussion by Tedesco et al. and Nayar invites risk assessment for cases where methane extraction is relevant or significant.u003c/strongu003eu003c/emu003eu003c/codeu003eu003cbr/u003eThe opposite was true. MTRs in the MPs were made more difficult to comply with in order to prioritise safety of methane recovery. The principles in order were (1) people safety, (2) environmental safety, (3) community benefit and finally (4) developer benefits. We did not deviate and that is why KivuWatt, Halbwachs and Tietze all found the MPs difficult to comply with when issued. Their objections followed.u003cbr/u003eu003cbr/u003eu003ccodeu003eu003cemu003eu003cstrongu003e4. The methane extraction by KivuWatt since 2015 can serve as probe for the practical applicability of the MPs rules and guidelines for safety, inspection, on-site and nearfield monitoring, concession demarcation, legal instruments etc.u003c/strongu003eu003c/emu003eu003c/codeu003eu003cbr/u003eKivuWatt’s practice, both before and since the 2105 start-up, demonstrates gross errors in engineering. They show failure to comply with the MPs. They adopt their own interpretations of the MPs – neither grounded in the letter or intent of the MTRs and MARs.u003cbr/u003eKivuWatt failed to consult or take heed of the advice of experts. They didn't even to attempt to understand the mandatory requirements for design. It is not a probe for practical applicability. Theirs is a lesson on how not to engineer, design, build and operate a gas extraction facility.u003cbr/u003eIt could, however, be a lesson on how to stress-test the rules. They provide a check on authorities’ ability to verify and monitor circumvention of compliance.u003cbr/u003eu003cbr/u003eu003ccodeu003eu003cstrongu003eu003cemu003e5. Despite the exhibited knowledge of many aspects of Lake Kivu and methane extraction, we may appreciate Hirslund’s arguments more if his papers where u003c/emu003eu003c/strongu003eu003c/codeu003eu003cemu003eu003cstrongu003e(sic)u003c/strongu003eu003c/emu003eu003ccodeu003eu003cstrongu003eu003cemu003e more concise and his papers discuss the observations of, and with e.g. Ross and Sommer of EAWAG.u003c/emu003eu003c/strongu003eu003c/codeu003eu003cbr/u003eThis statement is rich. The MPs are criticised for being too concise to explain the reasons behind all the Plan A1/A2 etc. When the rationale is presented by Hirslund in detail, his papers need to be more concise. Damned if you do, damned if you don’t.u003cbr/u003eThere is virtually no material in this section of the panel review that seems to come close to being a valid basis for overturning any of the content of the MPs. The exercise seems to have been completed by calling up all aggrieved parties to do their best to undermine a respectable body of work by any means possible.

FAQs about Lake Kivu's Dangers

Including Questions Asked by the Review Panel of Past Experts

Why is it known as a Killer Lake? What are Lake Kivu’s Dangers?

Lake Kivu’s dangers come from gases, mainly CO₂, CH4 and H₂S. They accumulate due to biogenesis in deep water up to the 485 m lake floor. Gas in solution after hundreds of years is trending closer to saturation. This is contributing to Lake Kivu’s dangers. Lake saturation means the carrying capacity of dissolved gas is fully loaded. Any over-accumulation threatens an imminent limnic eruption.
The dissolved gas volume is almost as large as the 500 cubic km of the lake itself. This will mostly release like a giant geyser in less than a day. In Lake Kivu’s case this can be catastrophic to all life forms in the lake environment, where millions of people live today near the shores.

Is Lake Kivu the Only Killer Lake?

No. An eruption, occurring at Lake Nyos in Cameroon in 1986, caused 1746 casualties. Another happended in Lake Monoun. As Lake Kivu is 10,000 times larger, millions of deaths follow if we do not prevent it.
So Lake Kivu’s dangers relate to its huge inventory of gas. The consequences can be over 1000 times larger. A dense cloud of gas will fill the valley to a depth of 100 m or more. Anyone caught inside the cloud will be asphyxiated by the lack of oxygen. Or, more quickly, they can be poisoned by the released hydrogen sulphide content of 2000 ppm.,

Can an Eruption of the Lake be Prevented?

Yes. Natural Lake Kivu’s dangers come from processes that create the biogas (methane) and co-products carbon dioxide and hydrogen sulphide have operated for thousands of years. It’s a near perfect environment for this to happen. So it’s not just about stopping gas generation, but about reversing any more accumulation to reduce the danger.
The “trigger” gas is methane as it’s much less soluble. Its 25 times higher partial pressure than CO₂ increases the eruption potential disproportionately. If one harvests methane, one can prevent an eruption. But the key to harvesting gas and preventing an eruption lies in how it’s done. It must be in compliance with the rules. Doing extraction the wrong way can bring on a disaster even more quickly.

Is there a Right and Wrong Way to Harvest Methane?

We now know that there are several wrong ways, and perhaps only one right way. The difference lies in two main areas. (1) Is enough of the methane removed from the lake in the extraction process? (2) Does the process destroy or preserve the natural safety mechanism of the lake? That is what keeps Lake Kivu’s dangers from gas contained in deep water.
We need to do the right thing. Harvesting methane for commercial reasons to make the lake safe, in a way ensures continued safety. The alternate to commercial production would cost billions and would never get funded.

When Will a Lake Eruption Happen and is it Predictable?

One can calculate when the lake would be certain to erupt simply, by following the trends. But the trend is changeable. We can even reverse the trend by our actions. Changes in nature can also vary the trend. Nature governs new gas formation; i.e. how fast or slow is like growing a crop.
Algal growth in the shallow waters depends on nutrients and oxygen. Wind and rain govern oxygen levels, with seasonal variation. But little-used agricultural fertilizers partly govern nutrient levels. Even more impactful is gas extraction bringing up deep water. Deep water is N and P-rich, depositing it in the Biozone above 60m. Therefore algal growth rates can double or more.

What happens with the Carbon Dioxide when you Harvest Gas?

There is five times more volume of CO₂ in the lake than methane. About four times as much comes into the raw gas from older, simpler extraction methods. More advanced extraction techniques produce less. But in both cases we must water-wash the gas to remove CO₂.
The whole balance is important. It’s not only important to retain CO₂ deep in the lake, where it is safest, but it has a role in driving the extraction process. CO₂ washed out of the produced gas into shallow water would be better to return to depth instead.

What does Lake Kivu do for Climate Change? Is it a big Problem?

It can be a huge problem, but it has the potential to become a giant climate benefit. The big gas emission problem seems inevitable. The lake saturation is trending to cause a huge eruption in about 50 -70 years. An eruption can release as much GHG as the United States in a year, anywhere between 2-6 gigatons of carbon, on any single day.

How then can we benefit? It is prevention of what is otherwise going to happen, but with some great side benefits. Those benefits include providing cheaper, cleaner, carbon-negative energy to the region.

When can an eruption happen?

As it stands Lake Kivu’s dangers of an eruption seem destined to see it happen in plus/minus 60 years. But the known occurrences, but unpredictably-timed potential for a new volcano or a seismic rift can pre-empt that scenario by decades. This scenario can trigger a major lake eruption any time from now. In one of the most active volcanic and seismic areas on the planet, this is an ever-present risk. However, the longer such an incident delays, the more severe an eruption could be as the gas inventory builds.

Is Climate Change the Main Reason to do the Projects?

Over time, the reason for and importance of developing Lake Kivu has changed. At first it was about filling an urgent need for power.

Recently it has become more focused on reversing climate change.
But overshadowing all of that, and potentially far more newsworthy, will be the humanitarian impact of a lake eruption. Millions of people could lose there lives on that same day. If caught in a toxic cloud in the dead of night. People would be defenceless.

With the best of safety alarms, with sirens warning people to get to high ground above the gas cloud. Many people will not make it. Prevention is far better than any cure.

Where can one learn more detail about the lake?

Lake Kivu’s dangers have become a special case in academia, dating back to the 1930s. It would not surprise us if more PhDs and Masters degrees were awarded on this body of water than nearly every other one. It is a unique lake with uncommon characteristics. You will find many papers in the EAWAG faculty, in Kastanienbaum on Lake Lucerne in Switzerland.

Blog posts on this site describe and refer to more papers.
The expertise comes from academia, consulting and the engineering world. They contributed to the large body of knowledge and to the drafting of the rules for use of Lake Kivu. Eawag provided experts on the lake itself to the pro-bono Expert Group.

A recent paper was published in Elsevier’s Science Direct, written by two members from COWI and Hydragas. Both are long-standing members of the Expert Advisory Group for Lake Kivu Development. It was published in January 2020. It speaks in great detail about Lake Kivu’s dangers and the solutions.

What are the Rewards for Developing the Gas Extraction Solution?

For the long lead time to developing a solution to Lake Kivu’s problems, that is a tough one. This is the province of scientists in the pursuit of knowledge, the publishing of one’s theory or invention. It can’t be for quick money. Most involved here earn little.

Now that’s where latecomers may have the advantage. They don’t have to spend millions of their own funds to pursue the ideas. In fact they can experiment with solutions or volunteer as an expert. Further, they clearly don’t have to commit the proverbial 10,000 hours to become an expert. Nor must they do the work to become the owner of a valid solution. They can wait, see who has it right, do some due diligence and then perhaps invest there in a fantastic opportunity. Lake Kivu’s dangers should not only be known by then, but their mitigation should be embedded in the solution

Can you put a value on the Value of Lake Kivu’s Development?

The best solution that comes out for the extraction process is, however, incredibly valuable. Beyond bragging rights of resolving one of the world’s intractable problems, there are huge potential commercial rewards. Any company that gets to that position is therefore a candidate biotech unicorn.

The best solution can extract up to $60 billion in revenues from the lake, with >80% FCF and high returns. Efficiency of extraction and recovery of available gas are vital in turning a non-profit into a super profits earner. This comes through smart and world-leading technology.

Does that value include Carbon Credits?

No. At this time there are evolving methodologies for claiming carbon credits. First is the simple replacement of diesel with clean fuel, that counts for about 7.5 Mtpa carbon. The alternative biogas emits 1.19 Mtpa.

Secondly, but much more significant is the prevention of an eruption that would emit 1.9 Gigatons in a one-off event. This is if calculated at 28 tons CO₂ per ton methane. The range is 25 to 87 t/t. Calculated at 87 t/t, the one-time carbon emission is 5.9 gigatons in a day. That number is close to the USA’s annual emissions of 6.9 gigatons in 2014. The value of these carbon emissions averted is huge. At just $30/ton, the value ranges from $60 – 175 Billion. The government of Canada has in 2020 published a rate of CAD150/ton.

How does a VC respond to information requested and provided on their initial enquiry questionnaire? We know the answer is never “yes”, but how is it done?

Hi Philip, Thanks a lot for reaching out and for your interest in InActive Impact Investments! I have taken a look at the information you submitted through our application form as well as your website. From your website, it looks like you have developed a new technology to extract dissolved methane from water to generate energy. While we appreciate that energy generated from methane results in less GHG emissions than diesel generators, it does not fit with our investment thesis of investing in renewable energy sources, so we are not a fit for an investment in Hydragas. We wish you and your team all the best.

Best regards, Sophie

Hello Sophie,

Thank you so much for your considered reply. I get it. See the word methane and evil is assured. It’s a comforting mantra. Rather read no further than that “m” word and keep your hands clean.

But, though saying it will change nothing for you, this methane is biogenic. It is there in vast quantities and grows 1-2% per year from naturally digesting algae. It is not sequestered forever in the lake’s gas trap, so it has to be removed carefully before it erupts, to be removed with the least impact. That’s what we do.

The “moral” alternative is to leave it alone and allow it to erupt direct to atmosphere with 25 times the impact than the CO2 emitted from combusting it. Five times that volume of CO2 is released in the eruption, simultaneously. That limnic eruption could happen any day in the next 60 years, although the danger increases with time. Let’s also set aside any guilt that the eruption of this methane is a cataclysmic one day event, potentially to be the biggest natural humanitarian disaster of human history. It kills 2-4 million people that same day and emits one third of total annual emissions from the US per year, or 2 gigatons.

I get it that DAC, for example, sounds very noble. It’s most unfortunate that it is >50 times more expensive to lock up a ton of carbon that way. It’s also inconvenient that the mass and energy balance questions its carbon negativity. Its clean power consumption to make DAC carbon neutral means that this power use is diverted from other users. Fortunately it’s replaceable with non-renewables for the others.

Even our pilot plant, cheaper than CE’s DAC pilot in Squamish that will sequester one ton/year, does 160,000 tons per year of carbon emissions reduction. Our full project will remove more carbon than DAC plans to remove, in the next 20-30 years, about 1 gigaton.

Our full project will also be able to supply a downstream project with cheap CO2 feedstock, enough for example to convert to 1 million tons per year of low-cost protein powder. This is in a region where the population, exceeding 500 million in 2030, is protein deficient.

Anyway, I’ve taken enough of your time. We wish you all the best in your mission. Please feel assured that you’ve at least saved the planet from some methane combustion by boldly saying no.

Regards, Philip

Questions asked by reviewers of a proposal to join the Innovative Growth Forum

Application Feedback from the NREL-IGF Application by five reviewers. It could be that they skimmed over the application, but perhaps the questions were not asked at all. What do you think?

Review #1: There are other technologies that could compete with these technologies, specially non CO2 emitters, such as solar PV. Methane, although is extracted from the lake, it would emit CO2. How competitive is the technology compared with natural gas.

Response: The project presented is not a CO2 emitter. It is a negative emitter to the tune of 40 millions tons carbon a year in generating 600 MW. The power generation using gas engines or CCGT has the option of improving these negative emissions by another 4% by dissolving all the exhaust CO2 back into the lake, if that process is accepted by the environmental authorities for the lake ESIA.

Further, the whole point of this project is to prevent the lake’s gas content building up to saturation, causing an eruption emitting 2 gigatons of carbon in a day. A billion solar panels do not contribute to that problem’s resolution. i.e. Not doing this project is a huge problem, requiring this solution.

Finally, this biogas used is far cheaper than any source of natural gas delivered to the region, as the closest source is thousands of km away. No gas pipelines any closer than that. This is remote Africa.

Review #2: I’m not sure this is a renewable energy company?

While the team has a novel method for extracting bio-methane I’d have concerns around leaks and emissions from combustion.

Given the resource depth it seems as though the methane is sequestered and this project will bring it to the atmosphere.

To the extent the team is also going to need to build the power facilities there is additional financing risk on the company on top of a $23mm capex demonstration plant. And at roughly ($23mm + $12mm) per 5 MW (~$7/watt) I’d wonder how the plant would be cost effective.

Response: If you’re not sure, then ask. This is renewable energy because the lake is a natural digester, not even man-made, using the Acetate Process to convert dead algae to CH4 and CO2 in anaerobic conditions. That’s by definition RNG – renewable natural gas! It’s the biggest biogas digester on the planet. Please look it up for reference.

Leaks and emissions from combustion may be symptomatic of gas pipelines operating at pressure, but this is a low pressure system operating short, new, HDPE pipelines at 5 bar, or 5% the pressure of typical large gas pipeline systems. I have built a number of HDPE gas pipelines and experienced two leaks in 25 years, both quickly repaired. Leaks will be very evident from the submerged gas pipeline on the lake, with a visible stram of bubbles. Repairs take a few hours.

The resource is deep, so it is at high pressure with increasing partial pressure over time. Gas is temporarily sequestered, until gas reaches saturation. Once saturated, or even earlier if disturbed by an energetic volcanic event, the total gas load of the lake can erupt. This would release gigatons of carbon in a day. So keeping gas “sequestered” creates more risk of a far worse problem than using the gas in a controlled manner. This degassing pays for the essential, but otherwise very expensive and higher emitting degassing of the lake with no revenue. That approach is silly.

Your economic analysis makes a flawed assumption. It is that the cost of gas production, distribution and power generation are all to be included in your calculation. Only the 33% cost of the power plant belongs in that calculation of generation cost, as the balance of capital cost goes to the fuel supply cost. It’s a common mistake. Unlike the Sahara Desert and the many arid areas of Africa, solar power competes with the high-density and dominantly agrarian population for land. Covering the landscape with solar panels will spark serious conflict with landowners.

Review #3: For speaking to your technology in the future please include detail on how it functions. – It was a little unclear how this project will be carbon negative and not simply a natural gas extraction play.

Is there imminent risk of gas leaking out from underneath the lake? How likely is this and within what timeline? If this gas is going to be leaking into the atmosphere then it makes sense to capture and use it, however, if this is not certain then the justification of pursuing this project is diminished from the view of investors with an ESG focus.

The expertise of the core team in this area is impressive, but seems like there will need to be more members brought on to help bring this project to life. Please consider adding a hiring plan for the next 3-24 months.

IP expiration concerns will be on the minds of anyone considering investment in Hydragas. Would recommend providing expanded detail on how
patents on the core technology will be extended.

Response: In the form provided by IGF, 1000 characters does not give us sufficient space for the explanation you seek. This is a unique and complex project, unlike solar and wind power which everyone gets. But it was provided and referenced in the attachments. It will be carbon-negative as it prevents an otherwise inevitable eruption of 2 gigatons of carbon. “Prevention is better than a cure!”, as your mother may have told you. Check Response #2 for it not being “fossil” natural gas, it’s RNG.

There is no gas underneath the lake, it is all dissolved in the lake, in the water. You made an error of assumption here and the balance of your argument therefore does not follow. So what part of avoiding the loss of 2-3 million lives and 2 gigatons of carbon emissions in one day is not of interest for ESG? Are these lives and gigatons not worthy because they are in Africa? However, an outburst from the water of the lake is explained in the documentation. The explanation is simple physics. Once the total partial pressure of gas reaches saturation, it erupts in what is called a limnic eruption.

Since the company has received no external funding yet, we have no payroll funded to keep our planned 20-person team on salary. Most of our team is on standby, working other jobs while we raise funds. A hiring plan can be added easily, but the on-payroll numbers were requested, not plans.

The plan for extension of patent coverage is developed, based on updated processes and improvements in mechanical design. In the meantime, most of the core information is kept secret and has not been copied or reverse engineered to date.

Review #4: From the attached presentation, I have a hard time separating the
technology from specific project opportunity.

It seems a lot of risk lies on getting the permit/rights to develop this specific project, and furthermore to get a firm offtake agreement in place on all capacity installed.

Is there a pipeline besides this specific lake, or does the commercial roadmap stop there?

What is the risk of developing a project that borders between three African countries?

Response: The technology was purposely developed for this specific need, hence the close correlation of technology and specific opportunity. But, having developed it, it became clear that multiple other needs were out there and the same concept design could be applied. These vary from methane seeps from submerged Arctic permafrost to Australian CSG (coal-seam gas) for which concept designs are complete. We haven’t the funds to pursue all in parallel, let alone this urgent need yet.

The risk of permitting is well know to the founder as he co-wrote the rules under which gas extraction is permitted, along with five other experts from academia. The offtake agreement on offer in the PPA is simple. It is a take-or-pay agreement at a given price. It could hardly be simpler or firmer. The agreement will be MIGA-backed like all previous offtake agreements.

There is presently no gas pipeline within 2000 miles of this lake, perhaps further in Cameroon or Nigeria. A project concept for gas distribution around the two countries has been prepared for discussion with governments. It has been discussed with the IFC/World Bank as an important solution for both countries to halt and reverse deforestation.It’s one of many follow-on projects to be developed.

The project is on a lake through which the border runs north-south. Both countries will be developing their 50% share of the resource in parallel, with the outline of how the resource is shared already legislated in both countries. The risk has been substantially mitigated by agreements on the development and the rules to be followed. This founder developed the resource-sharing and concessioning concept for both governments as part of drafting the rules.

Review #5: Very bold and important idea. Assuming technology for gas harvesting and separation is valid and works, why also build the power plants? Power generation is commoditized. You should be able to get higher returns just being a gas producer.

Team looks a bit thin for all the work that needs to be done.

Have you sought project financing from the IFC or World Bank?

Seems like a really valuable project that the international financing community should support. Not a VC play. Project finance.

The lake and the gas in it is owned by the DRC and Rwandan governments. Concessions are to be granted to produce power. The obligation of concession-holders is to produce the gas and generate the power according to the rules (the MPs). We have discussed with the Minister of Energy in Rwanda to do as you suggest, produce the gas and allow the government to lease out the rights to generate power.

Power is commoditized globally, except that there is no local, capable generation utility that can step in. Having two parties complicates the issue commercially as one failure leads to another. Several poorly engineered gas production projects have failed or are failing. With two parties, both can blame each other for delays and failures and may sue the government, who also has to act as a referee. Do we need that? Do they? This is a developing world situation, not North America

The team is not on payroll yet, but largely identified as most have previously worked on the project. See Response #3.

It’s the other way around with the IFC and World Bank. Hydragas was approached by the World Bank and IFC as their best adjudicated provider of gas extraction capability. We signed an MoU. However, by their own rules we have to develop the project demo to provide “proof-of-performance” before thay can step in with 75% of the funding, as offered. The IFC’s first proposed development funder failed to raise funding and so we’re doing that instead.

We agree on not being a VC play. Other avenues are being pursued.

Review #6: The application is nicely organized. The company articulates a clear vision to displace diesel generators, which would create significant savings and reduce greenhouse gas emissions. The company provided helpful information on costs, status of the technology, IRR, and customer engagement. I am wondering how replicable the technology is water other than Lake Kivu.

I also think there are risks in lack of customer diversification – the company really needs the utility partnerships to succeed.

I am also not sure if the company appreciates the competition that is coming from very cheap renewables in Africa

The technology was purpose-designed for this project, as detailed in Response #4. Two diverse alternate opportunities were identified and conceptually developed. They are 20 times and thousands of times larger than this one, in Australia and the coastal zone of the Arctic Ocean. We plan to get to them.

The customer diversification is a political reality. In the past the customers have had few options and has not chosen well, in terms of granting concessions. It’s difficult to for them make selections in this very novel field of science and engineering. They now have a need and an option to correct that with us offering a far better outcome for them. They get up to five times more power out at a similar unit cost.

Very cheap renewables exist in Africa, mostly a long way away from this lake and not grid connected to this region in quantity yet. The displacement of expensive power will first have to address 4000-5000 MW of diesel rental power in the EAPP, with tariffs more than double what we offer.