“Whale Deaths” Are Unnatural

Abstract

The past several decades have seen a shift in environmental and risk communication that emphasizes harnessing local knowledge to enhance environmental advocacy. As a result, one would expect local advocacy organizations to manifest this shift. Using Friends of the Nation (FoN; a Ghanaian local advocacy organization) as a case study, this research examines how FoN is constructing offshore oil production risks. The study found that FoN uses “whale deaths” as an exemplar of ecological risks associated with offshore oil production, even though in Ghanaian folk culture coastal communities view whale deaths as signs of bumper fish harvest. The article argues that the disconnect between the dominant frame and local meaning system could be explained in terms of FoN’s policymakers-facing as opposed (or in addition) to community residents-facing engagement approach. Recommendations for environmental advocacy are discussed.

Keywords

framing offshore oil risks environmental NGOs qualitative frame analysis Ghana offshore oil risks communication SARF local knowledge and risks

This case study uses constructionist qualitative frame analysis (D’Angelo, 2002; Gamson & Modigliani, 1989; Pan & Kosicki, 1993) to assess how Friends of the Nation (FoN)—a Ghanaian environmental organization—is framing the risks associated with the West African country’s nascent offshore oil production industry. FoN, based in Takoradi in the Western Region of Ghana, is a local nonprofit that is, among other things, involved in sustainability advocacy pertaining to the extractive industry. Regarding offshore oil production, FoN advocates for environmental accountability and the need to protect local communities from the negative consequences of oil exploration activities (see BBC, 2013; Ghana News Agency, 2016; Soper, 2015; also see fonghana.org). The current research builds on earlier work that found local residents’ perception of the risks associated with offshore oil production are shaped by their cultural, indigenous, and tacit knowledge. Flowing from this, this article highlights the importance of culturally sensitive framing for environmental advocacy. This is achieved through comparing FoN’s message framing strategies to how local residents have been shown to make sense of oil production risks. Thus, the potential benefits of incorporating local communities and knowledge into environmental advocacy are observed.

Background to the Study

Today’s world is characterized by globalization discourses such as the impact of capital flow across the globe, market regulation, ecological stewardship, and climate change (O’Brien & Leichenko, 2000; Robertson & Khondker, 1998). One industry that embodies all four globalization discourses is the fossil fuel industry: It is predominantly self-interested and private, it has legs all over the globe, the dominance of Western corporations is palpable, and it is complicit in global climate change (McMichael, 2013; O’Brien & Leichenko, 2000; Von Werlhof, 2010). Beyond the implications of fossil fuel extraction and use for poor, developing, or third world countries, petroleum production presents both local challenges and opportunities. Thus, the discovery of natural (in this case, petroleum) resources offers such countries the opportunity—albeit illusive—(see Aryee, 2012; Garvin, McGee, Smoyer-Tomic, & Aubynn, 2009) to grow their economies, create jobs, develop their infrastructure, and become energy independent. It also has adverse implications for local communities and environment. One such case study has occurred in the West African country of Ghana.

After many years of prospecting for petroleum resources, Ghana found offshore oil and gas in commercial quantities in 2007. The discovery was met with excitement and expectation that the country’s economic fortunes were about to improve (see BBC, 2007). Despite the optimism that accompanied this discovery, Ghana has a history of poor natural resource management. Resource-rich communities have been displaced and devastated by the harmful environmental, economic, and social impact of mining and lumbering; such communities saw few economic benefits from such resource exploitations (Aryee, 2012; Garvin et al., 2009; Hilson & Yakovleva, 2007; Kumah, 2006). Besides this history, commercial oil production commenced 3 years after discovery—a time span that is considered very fast according to industry standards—before the necessary regulatory frameworks had been established (Civil Society Platform on Oil and Gas—Ghana, 2011). A few years into the oil production, residents in the six coastal districts adjoining the offshore oil region (i.e., Shama, Ahanta West, Jomoro, Nzema East, Ellembelle, and Sekondi-Takoradi) as well as advocacy groups such as FoN became alarmed by the putative consequences of the oil exploration on local communities and marine ecology: astronomical increase in cost of living, perceived decline in fish harvest,¹ inability of locals to secure employment in the sector because they lack the requisite technical skills, increasing number of dead whales being washed ashore, reported cases of conjunctivitis, and the growth of free-floating seaweeds called sargassum (see Ackah-Baidoo, 2013; Ofori-Parku, 2015, forthcoming). Fishing is a major economic activity for residents in the offshore oil production enclave—males go to sea and females sell fresh and smoked fish (Ghana Statistical Services, 2012). The centrality of fishing to these communities underscores the importance of keeping the marine environment pristine to local residents. These residents were hopeful the oil discovery and exploration would lead to jobs and other economic opportunities. However, due to the relatively low level of education (Ghana Statistical Services, 2012) vis-à-vis the skills requirement of the oil industry, it could take many years before this expectation is realized.

Within these expectations and local realities, and given the important advocacy role of nongovernmental organizations (NGOs) in environmental regulation (Doh & Guay, 2006; Heyes, 1997), this case study examines how FoN is framing offshore oil production’s impact on local communities and marine ecology. FoN was selected as a case study of local NGO involvement in sustainability advocacy and decision making because it is active in this space, frequently appearing on television programs and cited in news stories regarding the environmental impact of offshore oil production on marine ecology (e.g., BBC, 2013; Ghana News Agency, 2016; Reporting Oil and Gas, 2015; Soper, 2015; see also fonghana.org). Science and environmental risk communication have seen a shift toward the recognition that local communities and their residents have important indigenous knowledge, which if properly harnessed enhances their participation in (and ownership of) science and environmental policy decisions (Burgess, 2014; Naess 2013). One would therefore expect a local advocacy organization such as FoN to embody this shift the most. By paying attention to which environmental risk issues FoN was highlighting and how these issues are presented, this case study assesses the strengths and weaknesses of FoN’s advocacy strategy.

Literature and Theoretical Framework

This study was underpinned by the concept of framing (D’Angelo, 2002; Entman, 1993; Goffman, 1974) and the social amplification of risk framework (SARF; J. X. Kasperson, Kasperson, Pidgeon, & Slovic, 2003; R. E. Kasperson et al., 1988).

Framing and Environmental Advocacy

Framing research, as applied to communication texts, deals with how “public discourse about policy issues is constructed and negotiated” (Pan & Kosicki, 1993, p. 70). Although the concept is often applied to news (Entman, 1993), it does not preclude other communication forms and contexts such as for-profit and nonprofit organizations (see Hallahan, 1999; Park & Reber, 2010). Context notwithstanding, frames reveal which issues are covered and how others are ignored. They also reveal the underlying institutional, social, and cultural factors that underpin such frames (Coleman, Hartley, & Kennamer, 2006; Entman, 1993; Watkins, 2001). Despite the preponderance of framing studies, the concept means different things to different researchers (see D’Angelo, 2002; Entman, 1993). This is because framing “suffers somewhat from a tradition of loosely knit explications and operationalizations” (Coleman & Dysart, 2005, p. 6). To Entman (1993), for example, frames are diagnostic, evaluative, make moral judgments, and prescriptive. Applied to policy concerns, frames are viewed as implicit organizing ideas (Gamson & Lasch, 1983) that help us make sense of social phenomena, telling us what policy issues deserve attention, why, and in what ways (D’Angelo, 2002; Entman, 1993; Gamson, 1992; Gamson & Modigliani, 1989). Describing framing research as fractured, Entman (1993) argued that a “common understanding” of frames and framing “might help constitute framing as a [coherent] research paradigm” (p. 56).

While Entman’s case for a unified framework was well-intentioned, framing research arises from different epistemological traditions: cognitive, constructionist, and critical (D’Angelo, 2002). “There is not, nor should there be, a single paradigm of framing research” although working across research traditions is desirable, per D’Angelo (2002, p. 871). To summarize D’Angelo’s three approaches to frame research, the critical perspective views frames as manifesting and reinforcing the dominant opinions and power structures of society (e.g., Watkins, 2001). Cognitivists see frames as emanating from a routinely meaningful process (in the case of news, of journalistic decision making) and in response to the pluralistic demands of information in democratic societies. From a constructionist viewpoint, communicators reflect and add to the “issue culture” of a topic, offering people sense-making filters or “interpretive packages” (D’Angelo, 2002, p. 877) to understand particular issues. Thus, framing, from this approach, means placing issues in a “unique context” [italics added] so certain elements are made accessible to the public (Pan & Kosicki, 1993, p. 57). To constructionists, frames do not merely offer alternative perspectives on issues; they create particular viewpoints within the broader context of public discourse about—and social experience of—issues at stake. Because making sense of the world requires effort, “those tools [i.e., frames] that are developed, spotlighted, and made readily accessible have a higher degree of being used” by others (Gamson & Modigliani, 1989, p. 10). This study is based primarily on a constructionist paradigm of meaning creation and to a lesser extent a critical approach. In line with D’Angelo’s (2002) explanation, the study observes that FoN’s framing of offshore oil risks is a manifestation of the NGO’s priorities, values, interests, and understanding of the issue context.

Identifying Frames in Communication Texts

Communication texts may offer particular or a plurality of frames (Entman, 1993). How then do researchers identify frames in such texts? Similar to the view that there are competing approaches to framing research, the literature is replete with a range of devices or elements used by researchers to identify frames in communication texts (Coleman et al., 2006; D’Angelo, 2002; Entman, 1993; Gamson, 1992; see also D’Angelo, 2002 for a detailed discussion of these devices). According to Entman (1993), for example, frames, whether they perform diagnostic, evaluative, moral, and/or prescriptive functions, are identified through the presence or absence of certain “keywords, stock phrases, stereotyped images, sources of information, and sentences that provide thematically reinforcing clusters of facts or judgments” (p. 52). These frame devices are akin to Gamson’s (1992) idea of interpretive packages. In earlier research, Gamson and colleagues (see Gamson & Lasch, 1983; Gamson & Modigliani, 1989) identified five of such devices: metaphors, exemplars, depictions, catchphrases, and visual images. Thus, to combine Entman and Gamson’s views, while frames perform one or a combination of four “functions,” they can be identified by paying attention to frame devices. Other researchers (e.g., Coleman et al., 2006; Pan & Kosicki, 1993) have also asserted that to identify frames embedded in discourses, one can focus on what the speaker says or claims. To Coleman et al. (2006), since claims are paramount in shaping meaning in communication texts and helping frame public discourse, stakeholders’ language selection and use provides the context for interpreting and discussing issues. This view aligns with Entman’s (1993) last frame device (i.e., sentences that provide thematic clusters facts or judgments).

As observed earlier, these apparently divergent frame identification methods can be unified (Entman, 1993). Responding to the plurality of frame identification techniques in the literature, D’Angelo (2002) admonished framing researchers to use all available “unitizing techniques” found in communication texts to enhance frame analyses (p. 881). In line with this, this research is based on the view that it is possible to identify frames by asking what claims are being made about the nature of a problem, what the causes of the problem are, what moral judgments are made regarding the problem, and what plausible remedies are offered, while also paying attention to keywords, catchphrases, exemplars, and so on that define the problem, identify causes, make moral judgments, and suggest remedial actions in the first place. See Figure 1 for a summary of how different frame identification techniques can be unified.

Figure 1.

Summary of how different frame identification techniques can be unified and used in a single study.

Besides, responding to Entman’s (1993) treatise on how to mend the “fractured” framing paradigm, D’Angelo (2002) observed that even when research findings do not support theories on which they are based, they expand the “hard-core conjectural base” of the theories or frameworks (p. 873). This, according to D’Angelo, is important because by generating divergent results, theoretical models provide new directions for research. Applying this view to Entman’s (1993) and Gamson’s (1992) functional frame elements, one cannot always expect to find all (or only) four frame types—diagnostic, evaluative, moral judgments, and prescriptive—in a given analysis. Another way to deductively apply Entman’s frame elements is that in a given corpus of text, there should be four types of frames, one for each function. Entman’s (1993) original framing article does, however, not support the second interpretation: He observed, “A single sentence may perform more than one of these four framing functions. . . . And a frame in any particular text may not necessarily include all four functions” (p. 52). This assertion suggests two things. The first is manifest: A single frame can perform more than one function. For example, the “cold war” frame that was dominant in foreign affairs news during the cold war era “highlighted certain foreign events—say, civil wars—as problems, identified their source (communist rebels), offered moral judgments (atheistic aggression), and commended particular solutions (U.S. support for the other side)” (Entman, 1993, p. 52). The second point, which flows from the first, is that two separate frames can perform a single function (e.g., diagnose a problem). Therefore, frame analysis, even from a deductive perspective such as using Entman’s functional frame elements, would not necessarily yield only four frame types.

By analyzing how FoN frames Ghana’s offshore oil production risks and paying attention to frame devices such as claims, keywords, exemplars, and stock phrases used to diagnose, evaluate, make moral judgments, and prescribe remedies for the risks, this study demonstrates an advocacy organization’s ability to offer interpretative packages (Gamson & Modigliani, 1989) for making sense of the phenomenon. The analysis also highlights how the material interests of the NGO collide with its idealistic interests of ensuring proper ecological management. The ways in which frames reveal the underlying motivations of focal organizations and communicators are discussed below.

Frames and Motivations of the Communicator

The motivations of organizations—idealistic versus material—often find expression in how they frame messages (Price, 2003; Sell & Prakash, 2004). Although NGOs (as opposed to businesses) are often thought of as motivated by normative concerns (Price, 2003), extant research shows that they are motivated by a combination of idealistic and materialistic concerns (see Bakir, 2006; Sell & Prakash, 2004). For example, in their study of business organizations and NGOs, Sell and Prakash (2004) found that NGOs, while motivated by principled, nonmaterial beliefs, are also driven by financial and material interests. In line with this, combining constructionist and critical framing approaches, the study observes whether or not (and how) FoN’s dual motivations manifest in its message framing?

Frames and Environmental Advocacy Strategy

Frames also reveal the institutional, social, and cultural factors that underpin discourses (Coleman et al., 2006; Entman, 1993; Watkins, 2001). Thus, based on frame analysis, one can make inferences about an organization’s strategy: Who is being targeted and to what end? As advocacy tools, frames have also been shown to have important effects on policy. Even when framing studies do not examine these effects, they are inherently based on the assumption that frames have power and exert influence (e.g., D’Angelo, 2002; Entman, 1993; Watkins, 2001). This assumption cuts across cognitive, constructionist, and critical research orientations. Hence, the extent to which important and often contested issues get the attention of both public and private policymakers depends on factors such as the extent to which “media” talk about (as well as frame) those issues and the extent to which public opinion favors those issues (Rogers & Dearing, 2007). Beyond the inherent assumption that frames manifest and exert influence, studies have demonstrated that framing strategies have implications for how publics view issues (e.g., Lakoff, 2010; McCombs, Lopez-Escobar, & Llamas, 2000). When public opinion translates into public pressure, it becomes a powerful catalyst of policy change (Fung & O’Rourke, 2000).

Grassroots mobilization strategies have been shown to be more successful in environmental advocacy than command-and-control, policymakers facing ones (see Bakir, 2006; Fung & O’Rourke, 2000; Konar & Cohen, 1997). For example, Fung and O’Rourke (2000) found that formalized governmental sanctions were not as successful as public pressure was in shaping corporations’ environmental policies: firms adopted “pollution prevention and abatement measures in response to a dynamic range of public pressures rather than to formalized agency standards or governmental sanction” (p. 115). In other words, public mobilization is potentially a more powerful environmental advocacy and regulation mechanism (Konar & Cohen, 1997). Publics tend to have important local knowledge, which if properly harnessed enhances their participation in (and ownership of) environmental policy decisions and actions (Burgess, 2014; J. Mercer, Kelman, Taranis, & Suchet-Pearson, 2010; Naess, 2013). As such, science and environmental risk communication is seeing a shift toward this direction.

Regarding Ghana’s offshore oil industry, local residents’ perceptions of offshore oil production risks are shaped by their indigenous knowledge, lived experiences, and psychological sense of attachment to their locality (see Ofori-Parku, 2015, forthcoming). In these studies, it was found that close to 60% of local residents are willing and likely to participate in street protests against offshore oil activities. For NGOs and advocacy groups such as FoN, these observations point to the strategic importance of understanding and directly engaging the residents and mobilizing them for action. This study does not directly examine the antecedents or effects of FoN’s framing and environmental advocacy. However, since frames are expressions of power and are produced in the “context of complex organizations” (Watkins, 2001, p. 84), analyzing how FoN frames offshore oil production risks also offers insight into the NGO’s exercise of power—its advocacy strategy.

Social Amplification of Risk Framework

The SARF, first proposed by R. E. Kasperson et al. (1988), posits that the dynamic social context of risks plays an important role in whether risks will be amplified or attenuated. SARF shifts the focus of attention from a static description of what risk means for different communities. Instead, it emphasizes an active process that involves how communities (a) share, exchange, construct, information about environmental risk and (b) adjust their perceptions, attitudes, and behaviors accordingly (J. X. Kasperson et al., 2003; Renn, Burns, Kasperson, Kasperson, & Slovic, 1992). Thus, no single factor—psychological, objective hazard levels, or communication—can explain the success or otherwise of risk communication and perceptions. Instead, a combination of historical, social, cultural, psychological, mediated processes, as well as personal experiences and hazardous events, influence how people and institutions perceive and relate to societal risks (J. X. Kasperson et al., 2003). “Amplification” as used in the SARF includes “both intensifying and attenuating signals about risk” (Renn et al., 1992, p. 140). Factors that generate, construct, transmit, amplify, or attenuate risk-related information are referred to as social and individual “amplification stations” (R. E. Kasperson et al., 1988, p. 181). Amplification stations may include formal and informal agents such as NGOs and organized interest groups, news media, business organizations, friendship and familial ties, religious organizations, and local and national governments (J. X. Kasperson et al., 2003; R. E. Kasperson et al., 1988). The SARF has been criticized for privileging a realist conception of risk (as opposed to a constructionist view) and for not being a theory (Rosa, 2003). While these critiques have merit, as proponents of the Framework explain, “The concept of social amplification is not a theory in the classical sense” (Renn et al., 1992, p. 143). It is a framework within which a range of disciplinary, ontological, and epistemological—including constructionist—camps can operate. In this study, FoN is viewed as an amplification station that constructs offshore oil risks.

According to Kasperson and other SARF proponents, two things influence the success of risk communication efforts. The first is the extent to which risk-related amplification stations are trusted (Bakir, 2006; J. X. Kasperson et al., 2003; Poortinga & Pidgeon, 2003; Slovic, 1999). Concerning the trustworthiness of risk amplification stations, in a survey of local residents in Ghana’s offshore oil production region, this researcher found that NGOs, regulatory agencies, and oil production companies are among the least trusted sources of offshore oil risk-related information (see Ofori-Parku, 2015). NGOs were also found to be one of three least favored sources of information about offshore oil production risks. As Kasperson and colleagues assert, trustworthiness does not only influence what people think about risks but also cooperative actions and public participation in political actions to reduce such risks (see Bakir, 2006; J. X. Kasperson et al., 2003; Poortinga & Pidgeon, 2003; Slovic, 1999). In the SARF, the second factor that underpins risk communication successes is information attributes such as volume, whether information or risk is disputed or not (and how), extent of dramatization, stigmatization, and symbolic connotations of risk and communication messages. These attributes influence the risk amplification process and outcome (R. E. Kasperson et al., 1988). Here, stigma refers to negative imagery or “adverse perceptions [and naming] of an activity, person, place, or technology” (Bakir, 2006, p. 70). The information attributes espoused by the SARF are akin to frame “devices” in framing research.

The Current Study

This study builds on earlier work by the author that found that (a) “whale deaths” are not a top-of-mind concern for local residents; (b) local residents’ perceptions of offshore oil production risks are shaped by their indigenous knowledge, lived experiences, and psychological sense of attachment to their locality; and (c) NGOs are neither among the most relied on nor trusted information sources among local residents (see Ofori-Parku, 2015, forthcoming).

From a primarily constructionist perspective, this study examines how the Ghanaian NGO FoN—as oil production risk amplification station—is framing the risks posed by Ghana’s offshore oil activities. The following questions were addressed:

Research Question 1: What meaning structures is FoN constructing through how it frames the ecological risks posed by Ghana’s offshore oil exploration and production? That is, what interpretive packages is FoN offering for making sense of offshore oil risks?

Research Question 2: What stigmatization strategies is FoN employing in how it constructs the offshore oil production risks?

Research Question 3: Based on FoN’s framing of offshore oil production risks, what inferences can be made about its advocacy strategy and motivations?

Research Method

Overview

FoN’s communication texts were analyzed to assess how the local NGO was framing the risks associated with offshore oil production. FoN was selected as a case study of a local NGO’s involvement in sustainability advocacy and decision making because it is one of the active organizations in this space, frequently appearing on and cited in news stories about the environmental impact of offshore oil production on marine ecology and local community (see BBC, 2013; Ghana News Agency, 2016; Reporting Oil and Gas, 2015; Soper, 2015; see also fonghana.org). Drawing on Yin’s (2003, as cited in Coleman & Dysart, 2005) treatise on case study, news releases and all publicly available information on FoN’s website (http://fonghana.org) were retrieved and analyzed. In all, 42 documents/pages were analyzed.

Frame Identification

In line with D’Angelo’s (2002) admonishing that framing researchers should use all available “unitizing techniques” (p. 881), the analysis was based on a combination of three frame identification methods. By focusing on what claims FoN was making (Coleman et al., 2006), using what keywords, exemplars, and catchphrases (Gamson & Lasch, 1983; Gamson & Modigliani, 1989), as well as the function of those claims, keywords, and catchphrases (Entman, 1993; Gamson, 1992; Pan & Kosicki, 2001), the specific aspects of the issue and the ways they were being made salient were identified. Following D’Angelo (2002), the frame categories were based on a hybrid of deductive and inductive approach. Entman’s four frame elements were used as a starting point (see Risse & Van de Steeg, 2003, for example), while allowing for room to identify additional (and even combine) frames imbedded in FoN’s discourse about offshore oil risks.

The four functional frame elements or packages as they apply to this study looked at how FoN was defining and problematizing the offshore oil risks, what diagnoses it was making, what moral judgments it was making, and what causal remedies were being suggested (see Entman, 1993; Gamson, 1992). The first entailed how FoN was articulating the offshore oil production problem. To borrow from Entman, this meant looking at what the oil production company, government, or FoN (i.e., causal agents) were said to be “doing with what cost and benefits” (p. 52). That is, what is the problem or issue (e.g., offshore oil risks manifest in an increasing number of dead whales being washed ashore). From this, it was possible to have more than a single problem definition.

The second frame element implied apportioning blame and responsibility (e.g., who or what is responsible for the whale deaths, the answer to which was a contest between the natural and unnatural). The third element entailed moral claims, evaluations, and arguments in favor of ecological protection and against offshore oil production (e.g., coastal and marine environments are unique systems that must be protected at all times with all the resources that are available). The fourth element simply entailed claims about what was being done or should be done. In sum, these classifications were based on claims that determine a clear thematic pattern that define, diagnoses or attempts to diagnose, make moral evaluations, and offer prescriptions to address the ecological issues associated with the offshore oil production activities.

Framing Categories

Using a combination of inductive and deductive framing approach (e.g., Risse & Van de Steeg, 2003), in line with the interpretive constructionist tradition (Golafshani, 2003), and following an approach used by Coleman and Dysart (2005), all relevant publicly available communication texts were analyzed (i.e., news releases, media texts, and publicly available information on FoN’s website) through a “close reading.” Although counting may be useful, qualitative text analysis—especially within an interpretive, constructionist tradition—does not rest on these techniques (Altheide, 1997). As Risse and Van de Steeg (2003) put it, sometimes, only a hint is enough to invoke particular frames. A constructionist approach to social inquiry is based on the assumption that “symbolic representations are enmeshed in a context of meaning” (Altheide, 1997, p. 659). The goal of the close reading was to obtain an interpretive understanding of FoN’s risk communication text in context, allowing frames to emerge based on claims being made, word choices used, what was being problematized, who was being blamed, moral arguments being made, what prescriptions were being offered, among others (see Coleman et al., 2006; Entman, 1993; Gamson, 1992; Gamson & Lasch, 1983). The frame analysis was done at the argument (or claim) level rather than at the article (or story) level (see Listerman, 2010); claims were used as the unit of analysis. As Entman (1993) observes regarding frames, a single claim can perform more than one function. Following an initial iterative process of frame identification, categories were combined and expanded as was deemed necessary using both the data and the emerging frames (see Eisenhardt, 1989).

Research Question 2 inquired about the stigmatization strategies (J. X. Kasperson et al., 2003; R. E. Kasperson et al., 1988) used in FoN’s risk communication. To address this, a purely inductive, grounded theory approach—without a priori categories (Charmaz & Belgrave, 2002)—was used. Following the lead of Bakir (2006), stigmatization strategies were analyzed by identifying negative imagery, keywords, metaphors, adjectives, and so on, that were used to characterize the negative effects as well as people’s reaction to and perception of Ghana’s offshore oil production. Keywords that convey negative imagery were generated from FoN’s communication text using an emic (i.e., staying close to the data) approach (Kottak, 2006). Following a technique recommended by Eisenhardt (1989), the data and the emerging categories were utilized to assign etic (i.e., researcher determined) labels (Kottak, 2006).

Reliability

As Golafshani (2003) observed, “The quality of a study in each paradigm should be judged on its own paradigms’ terms” (p. 601). Therefore, the positivist criteria for validity and reliability do no directly apply here. Instead the trustworthiness, transferability, or credibility (Glaser & Straus, 1967; Golafshani, 2003) of the analysis was enhanced in two ways: First, “close reading” of text and categorization continued until data saturation was attained (i.e., no new findings were emerging; Morse, 2004). Second, taking a lead from Golafshani (2003), the analysis uses direct quotes to illustrate how key frames were embedded in the discourse about offshore oil production risks.

Media and communication researchers have long explained how frames serve as schema for selecting and making sense of social phenomena. Hence, by examining the “implicit organizing ideas” or frames (Gamson, 1992, p. 3) in these news releases, website, and communication texts, this study learned how FoN, as a case study of NGOs, is helping individuals and collective social actors (especially policy and industry actors) make sense of the socioecological impacts of Ghana’s offshore petroleum activities.

Results

Framing Offshore Oil Production Risks

Research Question 1 asked, “What meaning structures is FoN cultivating through its framing of the risks posed by Ghana’s offshore oil exploration and production?” The following six frames emerged: “the rate of whale deaths is unnatural,” “FoN and other civil society organizations (CSOs) are ensuring environmental accountability,” “petroleum revenue needs to be properly managed,” “someone needs to be blamed,” “morality,” and “policy actions need to be taken.” (See Figure 2 for a summary of how the frames found in this study relate to the conceptual categories that underpinned their identification.)

Figure 2.

Relationship between functional frame elements and six frames identified in FoN’s risk communication texts.

“Rate of Whale Deaths Is Unnatural” Frame

This frame problematized offshore oil production risks based on whale deaths. It emphasized that there are increasing numbers of dead whales being washed ashore along Ghana’s west coast. And it diagnosed the problem as resulting from an unnatural cause: offshore oil production activities. Examples of this frame include the following: “This is the fifth whale that washed ashore in the same week” and “This is the 17th occurrence [of whale deaths] since 2009, and the sixth within one month.” As would be seen from the other five frames discussed below, the “whale deaths” frame represents a form of meta-frame (Saugmann, n.d.) for FoN’s discourse about environmental risks associated with Ghana’s offshore oil production.

“Role of FoN in Environmental Accountability” Frame

This frame is self-reflexive. It developed in response to the problem definition in the preceding frame identified here. In this frame, FoN made claims about its role in ensuring environmental stewardship, accountability, and public awareness of and participation in environmental decisions. This frame includes justification for why FoN documented every whale death: “The intention [for cataloguing the whale deaths] is to draw the attention of the public to these unfortunate happenings and to advocate for research into the actual cause of death of the marine mammals” (FoN, 2013b). The-role-of-FoN frame also elucidated the NGO’s efforts to ensure that other sources of risk communication such as the Environmental Protection Agency (EPA), Fisheries Commission, Ministry of Environment and Science perform their duty of safeguarding the integrity of ecological resources and human life. For example, in a news release commending government for finally setting up a committee to investigate whale deaths, FoN talked about its engagement and interactions with the Committee:

Friends of the Nation was able to provide information on the death of marine mammals so far, and outlined possible causes, such as collision with vessels, pollution of the sea, seismic exploration conducted by petroleum companies, or net entanglement. (FoN, 2014, p. 1)

In another statement, FoN detailed that “the socio-environmental NGO Friends of the Nation (FoN) mobilized the community to hold a traditional ritual for the whale.” The frame is also used to problematize other risk regulation institutions’ inactions. For example, FoN claimed in a webpage story that it had, on several occasions, expressed concern about the rampant dying of whales, but regulatory agencies such as the Fisheries Commission and EPA had not responded to those concerns (FoN, 2013a). A fourth example of this frame type emphasized FoN’s advocacy successes. In a February 12, 2014, news release, FoN explicitly touted its influence on policymakers. It stated that “extensive campaigns by NGOs in the Western Region” had resulted in the President of the Republic of Ghana setting up a committee to investigate the death of whales.

“Petroleum Revenue Management” Frame

This was the only frame that did not focus on an environmental issue. It was cast as both a remedy for corruption and a blueprint for responsible financial management. Hinged on the Petroleum Revenue Management Act of 2011, this frame emphasized (a) the importance of the Act, (b) the need to apply petroleum revenues to a long-term national development plan, and (c) the importance of additional public financial management oversight mechanisms such as the Extractive Industries Transparency Initiative. This frame also underscored the need for civil society groups and other individuals to exercise their democratic rights as citizens to “participate in decisions around the management and spending priorities of petroleum revenues” (Communiqué, 2013, p. 1).

“Blame” Frame

This frame aligns with the second element of Entman’s (1993) functional framing element. It develops in response to the “whale deaths are unnatural” frame. This classification is based on keywords, phrases, and claims that determine a clear thematic pattern that diagnoses the cause of ecological problems such as the surge in the number of dead whales being washed ashore the west coast of Ghana. Although none of FoN’s communication texts referred to hard evidence, it attributed the problem to the offshore oil exploration and activities, stating that the whale deaths are “an indication that something wrong is happening in the marine environment” (FoN, 2013b).

In this frame, FoN interpreted and constructed the apparent surge in the number of whale deaths as an outcome of sea pollution; seismic activities due to deep sea oil exploration; noise pollution, which might have disoriented the whales causing them to fall in harm’s way; net entanglements; and sea vessels colliding with the sea mammals. Only one phenomenon is to blame: offshore petroleum production, led by Tullow Oil and its partners. This frame suggests that the EPA, Fisheries Commission, and other state regulatory agencies are accomplices in the disruption in the natural course of things. Sometimes, this attribution was couched in terms of rhetorical questions such as the following:

Are the deaths of the whales caused by a possible pollution of the water? Or is the water polluted to the extent that small fishes that represent nutrition in the food chain for marine mammals are dying? Are the whales being hit by vessels deep in the sea and die because of the collision? Are the whales disoriented due to noises caused by oil and gas exploitation activities and therefore swim to shallow waters where they die? (FoN, 2013c, pp. 1-2)

Interestingly, rather than appealing to science-based evidence, FoN mostly attributed these causal diagnoses to local residents’ perceptions, such that citizens in the coastal areas were increasingly² linking unfortunate events—whale deaths, growth of sea weeds, and so on—to the offshore oil and gas; therefore, it is plausible something is going on. In one instance, however, FoN appealed to the authority of EPA to attain some form of validation for its claim that the offshore oil activities are responsible for the increasing whale deaths along Ghana’s coast. It used a quote from an EPA team leader (also a professor of aquatic science), who after a visit to collect samples from a dead whale stated that “the whale could have been hit by a vessel because its vertebrae were broken and it was also suffering from internal bleeding” (FoN, 2013d).

“(Im)Morality” Frame

This frame ranged from a focus on regulators and institutions’ lack of responsiveness and stewardship, environmental sustainability as a moral imperative that must be absolutely upheld, and negative human consequences of the whale deaths. This frame had three subframes.³ The first was a “lack of responsiveness” subframe, which critiqued the EPA’s lack of responsiveness and accountability as immoral. It viewed the practice where the EPA and Fisheries Commission dismissed the possibility of potential impact of offshore petroleum activities on the washing ashore of dead whales as unacceptable. The second framing illustrates the moral imperative subframe: “The coastal and marine environments are unique systems that must be protected at all times with all the resources that are available” [italics added] (FoN, 2013b). Another statement that exemplifies this frame is this:

The bio-diversity conversation is [ . . . of] utmost importance to ensure balance in the ecosystem’s functions and services. The washing ashore of dead mammals should be a major concern not only for coastal communities, but for all of us. (FoN, 2013c, p. 2)

The third subframe framed the surge in the number of dead whales as a moral issue. This frame draws a direct link between an environmental challenge (i.e., offshore oil production) and a human one: effects on the health, economic, social, and psychological well-being of local communities. Thus, the fact that whales are dying was framed as an issue of social justice. This morality subframe manifests in the following statement:

[Coastal communities] are left helpless to deal with the pungent smell emerging from the dead mammals as well dealing [sic] with the decomposing bodies. . . . The environmental and health risk associated with this phenomenon is profound. Not only is this event affecting the communities psychologically. They have to live with the anxiety of not knowing what is causing the whales to die raising the question if their fish may be contaminated and therefore threatening [sic] their natural livelihood. (FoN, 2013a)

“Policy Actions” Frame

In basic terms, this frame asserts that there is a dire need for policymakers and institutions to “learn from best practices” and “take steps to protect” the coastal and marine ecosystem (FoN, 2013b, p. 1). These causal remedies were directed primarily stakeholders such as the EPA, Fisheries Commission, and Tullow Oil and its partners. Some of these policy recommendations include organizing “thorough investigations” into why the whales are dying, revising oil and gas operation guidelines, and requiring that all offshore seismic explorations include at a minimum a preliminary environmental assessment. Other policy suggestions include the need to urgently enforce existing laws such as the Fisheries Act; ensure that all oil companies conduct fisheries impact assessments as legally required; and make public whatever findings are reached regarding the whale deaths. As can be seen from the aforementioned examples, FoN often framed and justified its policy recommendations in terms of law, need for scientific certainty (which would be attained through “thorough investigation”), the democratic principle of the public’s right to know, and transparency.

“Stigma” in FoN’s Communication Texts

Research Question 2 asked, “What stigmatization and dramatization strategies does FoN employ in communicating offshore oil production risks?” In this study, stigma in FoN’s environmental risk communication refers to words, metaphors, adjectives, and so on, used to characterize the negative effects as well as people’s adverse reactions to and perception of Ghana’s offshore oil production risks. The study found elements of stigma such as “unfortunate events,” used to describe the washing ashore of marine mammals; “shock among locals,” referring to the effect of whale deaths on residents of coastal communities; and rising fears and uncertainty among fishermen and local residents. Other stigmatization techniques include increased fears about the inadequacy of responses to any accidental pollution event, increasing public resentment, public confusion, psychological discomfort and anxiety due to the uncertainty surrounding the oil production risks, and pungent smell (referring to the sea mammal carcasses). The offshore oil production activities were stigmatized at two levels: issue level (focusing on environmental and health risks) and the public level (focusing on the nature of public reactions and concerns). Interestingly, it was the latter type of stigma that featured most prominently in FoN’s communication texts.

Discussion

Using a local environmental NGO, FON, as an example of risk amplification station (J. X. Kasperson et al., 2003), this study applied the concept of framing to assess how the advocacy organization is framing and attempting to help other stakeholders perceive and attend to Ghana’s offshore oil production risks. Four observations are made about FoN’s framing of offshore oil production risks and about framing in general.

Limits and Prospects of FoN’s Environmental Risk Communication

First, the current study identified six implicit organizing ideas (Gamson, 1992) in FoN’s risk communication and advocacy text: “the rate of whale deaths is unnatural,” “FoN and other Civil Society Organizations (CSOs) are ensuring environmental accountability,” “petroleum revenue needs to be properly managed,” “someone (i.e., Tullow, EPA, and Fisheries Commission) needs to be blamed,” “offshore oil risks are immoral,” and “policy actions need to be taken.” Although the six frames relate to Gamson’s (1992) and Entman’s (1993) functional elements of frames as defining problems, diagnosing causes, making moral judgments, and suggesting causal remedies, they cannot be mapped on to the functional frame elements in a one-to-one manner. This is not surprising because although Entman (1993) identified four frame elements, he also asserted that a single frame might include more than one or all of these functions. In this study, therefore, the “role of FoN” frame straddles Entman’s first and fourth frame elements—except that rather than offer a causal remedy, it makes a claim about what is being done by FoN. Similarly, the “rate of whale deaths is unnatural” frame bridges Entman’s problem definition and diagnosis functional elements.

As D’Angelo (2002) asserts, even when research findings do not fully support theories on which they were based, such occurrences expand the “hard-core conjectural base” of the theory (p. 873). This study found that some frames, while they may not neatly align with one of four frame elements (Entman, 1993) or packages (Gamson, 1992), develop naturally in opposition to other frames. For example, the “role of FoN” develops in reaction to the increased “rate of whale death,” regulatory agencies’ “lack of responsiveness,” and because of the “immoral” nature of the ecological, health, and psychological consequences of offshore oil production. Likewise, the “blame” frame develops in opposition to the “rate of whale deaths” and in consonance with “the “morality” frame.

These frames, overall, elucidate FoN’s efforts to ensure that the EPA, Tullow Oil, and the Ministry of Environment and Science attend to their responsibilities of safeguarding the integrity of ecological resources and human life, which it views as being threatened by the oil production activities. These frames appear to be policymakers-facing (as opposed to public/community facing). Interestingly, rather than appealing to science-based evidence, FoN attributes its causal diagnoses to local residents’ experiences and reactions. In democratic societies, where the public sphere tends to be “battlegrounds where participants vie for advantage” (R. E. Kasperson et al., 1988, p. 184), FoN’s attribution of causal diagnosis to local residents can be seen as a strategy to raise the specter of Ghana’s offshore petroleum production risks, thereby amplify the issue. This strategy sought to galvanize policy and political interests via creating a perception of high public concern or attributing claims to local communities and residents—a potentially powerful policy advocacy strategy. Bakir (2006) made a similar assertion when he observed that CSOs try to influence public policy in two ways: shape public perception of risks and/or shape policymakers’ perception of public opinion. Furthermore, none of FoN’s communication texts explicitly mentioned the precautionary principle, which “gives the benefit of doubt to planetary and societal welfare rather than to potentially hazardous human [economic] activities” such as oil exploration (Bakir, 2006, p. 83). However, since FoN hardly provided empirical bases (beyond public concern) for the claim that the petroleum production is responsible for ecological problems such as increased whale deaths, the precautionary principle can be said to be at play here.

Second, in line with the view that advocacy organizations’ motivations find expression in how they frame issues (Price, 2003; Sell & Prakash, 2004), the current analysis suggests that FoN is motivated by idealistic as well as material considerations. For example, while the frames generally demonstrate the organization’s commitment to values such as equity, ecological welfare, and human wellbeing, its “FoN is ensuring environmental accountability” frame extensively spotlights its advocacy efforts and successes. The latter frame is important for battling competing voices in the public sphere. But one cannot rule out the fundraising or developmental potential and/or intent of this frame. Since NGOs in the developing world heavily rely on external funding for their programs and activities (C. Mercer, 2002), it is reasonable to argue that this frame may also be geared toward creating goodwill, legitimizing its efforts, and seeking a stamp of approval from current and potential partners—including donors.

Third, a careful look at the six frames identified in this study indicates that apart from the “petroleum revenue” frame, a meta-frame that connects the other four is “whale deaths.” “Meta-frame” is used in this study to describe the common narrative that runs through all other frames in FoN’s communication texts. It refers to what Saugmann (n.d.) describes as the frame that “rules them all.” In FoN’s risk communication text, the “whales are dying” central organizing idea “rules” all the other frames: It is an issue (i.e., problem) that exemplifies the ecological harm resulting from offshore oil production (i.e., causal diagnosis) and poor environmental management and improper regulation (i.e., diagnosis and moral judgment). The ecological harm—exemplified by the whale deaths—poses dire consequences for the environment and human health of local residents (i.e., moral judgment), for which reasons policymakers and oil companies need to be more responsive, responsible, and investigate more vigorously, as well as err on the side of caution (i.e., causal remedy).

Despite FoN’s use of the “whale deaths” meta-frame to construct offshore oil production risks, a previous study found “whale deaths” to be one of the issues local residents were least concerned about regarding Ghana’s offshore oil production (see Ofori-Parku, 2015). Although message framing is important for environmental advocacy (McCombs et al., 2000), the effectiveness of frames is affected by their ability to reinforce particular corresponding local knowledge and worldviews (D’Angelo, 2002; Goffman, 1974; Lakoff, 2010). However, FoN’s use of “whale deaths” to construct offshore oil risks runs contrary to indigenous ways of making sense of whale deaths (Flavio, 2015; Ofori-Parku, 2015, forthcoming). As observed in earlier studies, the washing ashore of dead whales is largely viewed by local residents of Ghana’s coastal communities as an omen of imminent bumper fish harvest (see also Daily Graphic, 2010; Flavio, 2015). The cultural significance of whale deaths is not limited to Ghanaian culture; similar beliefs exist in Japanese culture (see Kalland, 1999; Mallarach & Papayannis, 2006). In the Ghanaian context, therefore, while the rate at which whales were dying is of concern to some residents (Flavio, 2015), this is not a dominant position. From this, it is apparent that FoN’s “whale deaths” meta-frame is in conflict with the prevailing traditional meaning systems in the oil enclave—a plausible limit to the NGO’s ability to shape public perceptions of the ecological risks posed by the offshore oil production activities. Stated differently, although FoN’s objective is to educate and create awareness about natural resources health and empower target communities to assert their basic rights (FoN, 2015), its message framing does not harness the local knowledge of the communities it seeks “empower.”

A fourth observation about FoN’s advocacy on offshore oil production risks goes beyond its message framing: it touches on the NGO’s overall approach to environmental advocacy. It is observed that FoN’s advocacy strategy as seen in how it frames offshore oil production risks could offer insights into the NGO’s inability to successfully reach, engage, and build trust with local communities—thereby enhance public participation as was I found in a 2015 study. This observation however comes with two caveats: One, the current work is an interpretive study, and therefore a direct effect cannot be specified. However, this claim is plausible considering that other researchers have observed how important it is for frames to align with people’s meaning systems (e.g., D’Angelo, 2002; Goffman, 1974; Lakoff, 2010) and the effectiveness of public-facing environmental advocacy strategies (see Fung & O’Rourke, 2000; Konar & Cohen, 1997). Two, since FoN’s public communication is also carried out via news media (Yamoah, 2014, personal communication), even if local residents get exposed to such communication, they are likely to cite news media as their risk information sources. But this is not the entire story.

Since frames are expressions of power and produced in the “context of complex organizations” (Watkins, 2001, p. 84), analyzing how FoN frames offshore oil production risks offer insights into the organization’s advocacy strategy—how it is exercising its power. Like many civil society organizations, as opposed to decentralized mass movements, FoN’s strategy is top-heavy. Its frames and over all advocacy approach appears orientated toward ostensibly influencing corporate and policy elites—directly. Although FoN identifies its mission as providing services to communities and advocacy groups, it’s approach favors directly engaging policy elites (i.e., policy engagement) over directly engaging with and mobilizing the public/ community (i.e., public engagement). Although FoN states that its advocacy efforts are guided “by a rights-based, ecosystem-based and participatory” philosophy (FoN, 2015), its communication flow seems asymmetrical, ebbing away from the grassroots and toward policy elites. This is directly in conflict with its objectives to “educate and create awareness about natural resources health” and “empower target communities in asserting their basic rights” (FoN, 2015).

Summary and Conclusion

In line with the literature on frame analysis (e.g., Coleman et al., 2006; D’Angelo, 2002; Entman, 1993; Watkins, 2001), this study demonstrates that framing research can reveal institutional, social, and cultural factors that underpin discourses and serve as the basis for making inferences about how an organization (or communicator) is exercising its power—its strategy. The research offers insights into how an NGO (at least attempt to) constructs and amplifies an environmental risk concern. First, building on an earlier work done by the researcher (see Ofori-Parku, 2015, forthcoming), this article found a strong disconnect between the dominant frame used by FoN and the local meaning system that local residents use to make sense of oil production risks. This disconnect can be explained in terms of FoN’s policymakers-facing as opposed to community-facing advocacy strategy. The study shows that FoN uses a predominantly policymakers-oriented framing strategy (built around the meta-frame that offshore oil production is a danger to marine ecology).

The foregoing discussion raises the question of whether NGOs working in environmental advocacy and decision-making are best served by seeking to engage and mobilize the general public or directly influence policymakers and corporate actors (or both). Based on the analysis of FoN’s risk communication texts vis-à-vis an earlier work, which found that local residents neither trust nor rely on NGOs as a source of information about offshore oil production risks (Ofori-Parku, 2015), this article problematizes the advocacy organization’s focus on directly influencing policymakers rather than—or in addition to—community/public mobilization. FoN’s approach means little contact with local residents, leading to the focus on frames (i.e., whale deaths are unnatural) that do not necessarily align with local residents’ existing meaning systems and local knowledge (see Ofori-Parku, 2015). The effectiveness of frames is impacted by their ability to reinforce particular corresponding existing worldviews (D’Angelo, 2002; Goffman, 1974; Lakoff, 2010). Thus, FoN’s efforts to demand ecological accountability is noble. However, by focusing less on the local context and what residents care about, FoN complicates its ability to build community partnerships and alliances with local communities—all of which are necessary for successful environmental policy advocacy.

A plausible explanation for FoN’s policymakers-facing approach could be that it did not intend to influence the local community or reflect them because, perhaps, the local community has little power. Instead, FoN may be seeking to influence other publics such as policymakers and corporate leaders. This could very well be the case. However, this view does no fully align with FoN’s own expressed objectives: to educate and create awareness about natural resources health and empower target communities in asserting their basic rights (FoN, 2015). Furthermore, regarding how much power the local community has, as a growing body of literature suggests (e.g., Bakir, 2006; Burgess, 2014; Fung & O’Rourke, 2000; Konar & Cohen, 1997; Morgenstern & Sessions, 1988; Slovic, 1999) community mobilization and public-facing strategies lead to pressure, and are more effective in shaping environmental policy than command-and-control approaches. And, as was found in an earlier study (Ofori-Parku, 2015), more than half of residents in Ghana’s offshore oil enclave reported they are likely and willing to participate in street protests against offshore oil activities. This affirms the mobilization potential of these local residents.

Limitations and Future Studies

Being a qualitative, constructionist case study, this research comes with the limitations of this approach. Although the results could be applied to other contexts and cases, the study focuses on the particular rather than the universal (Golafshani, 2003). Besides, despite that the study makes some propositions about FoN’s advocacy strategy, assessing the success of its advocacy would require more than an analysis of how the NGO frames offshore oil production risks. Subsequent studies would benefit from further exploring this. Since Ghana’s oil production industry is in a nascent stage, studying NGOs’ advocacy strategies over time could yield interesting insights.

Recommendations

For NGOs and advocacy groups such as FoN, the results, coupled with evidence that grassroots mobilization strategies are more potent than command-and-control, policymakers-facing ones (see Fung & O’Rourke, 2000; Konar & Cohen, 1997) underscore the strategic importance of understanding and directly engaging with local residents and mobilizing them for action (even if the ultimate goal is to influence policymakers and corporate actors).

This study also recommends that NGOs and other advocacy groups frame offshore oil risks in terms that are in sync with indigenous knowledge and meaning systems. And, again, this would require a public engagement approach. Also, given evidence (e.g., Burgess, 2014; Fung & O’Rourke, 2000; Konar & Cohen, 1997; Morgenstern & Sessions, 1988) that public perception when accompanied by public pressure are powerful influences on policy decisions—more than the direct influence of NGOs and regulatory agencies—a community mobilization and public engagement strategy would be more effective in shaping public policy regarding ecological management in Ghana’s offshore oil industry. Thus, a direct public communication, local mobilization, and engagement strategy (preferably in concert with direct engagement with policy elites) that is culturally relevant is recommended. In all, rather than viewing public-facing and policymakers-facing environmental advocacy strategy as opposites, this research observes the importance of a two-pronged approach, which directly engages with policy elites while fully engaging with local communities, understanding their local knowledge, and integrating such knowledge into all communication efforts.

Footnotes

Acknowledgements

I am grateful to Dr. Susanna Hornig Priest, Dr. Cynthia-Lou Coleman, and the anonymous reviewers for their insightful comments on an earlier version of this article. And thanks to Dr. Kim B. Sheehan, Dr. H. Leslie Steeves, and Dr. Paul Slovic for their help with the larger project that this research was part of.

Declaration of Conflicting Interests

The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.

Funding

The author(s) disclosed receipt of the following financial support for the research, authorship, and/or publication of this article: This research was funded by the generous support from the Oregon-University System Sasakawa Young Leaders Fellowship Fund, University of Oregon School of Journalism and Communication’s Lorry I. Lokey Fellowship, and the University of Oregon’s Public Impact Award.

Notes

Author Biography

Sylvester Senyo Ofori-Parku is an assistant professor in the Department of Advertising and Public Relations at The University of Alabama. His research examines communication public participation in environmental decisions, sociocultural cognition pertaining to environmental/health risks, corporate sustainability, and consumer behavior relating to “green” brands and products.

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