The UK government’s Department for Business, Energy & Industrial Strategy (BEIS) has recently issued, in draft, an updated version of its Guidance Notes on the Decommissioning of Offshore Oil and Gas Installations and Pipelines (the “Updated Notes”). The final version is expected in about April this year. In substance the Updated Notes are fundamentally unchanged and have at their heart the UK’s commitment to the OSPAR 98/3 decision, which laid down the guiding principle that all installations and offshore infrastructure should be removed unless a derogation is granted.
What the Updated Notes do seek to achieve is greater clarity regarding the obligations and expectations placed upon operators, marking an important point in the evolution of the decommissioning of the UK’s oil and gas infrastructure.
The information now laid down regarding the decommissioning processes is primarily to be found in Annex H to the Updated Notes, entitled Decommissioning processes and pathways. It sets out three pathways, being:
1. Pathway 1: the full removal of the installation, which pathway applies to all installations under 10,000 tonnes and to all others for which there is no potential for a derogation.
2. Pathway 2: applies in respect of all decommissioning programmes with the potential for an application for an OSPAR derogation.
3. Pathway 3: applies in cases of pipeline decommissioning.
The three pathways are summarised, for the first time, in a flow diagram setting out the required process for each of the pathways. The general requirements for each pathway are then further set out.
The Updated Notes also provide developed guidance on what is required in the Environmental Appraisal and greater clarity around specific requirements and definitions. A key area here concerns the information that an operator must provide to support decommissioning decisions, particularly where it is considering a leave in situ option for pipelines.
Finally, the Updated Notes have been developed so far as post-decommissioning activities are required. These set out a risk-based approach to monitoring and the need for a long term management plan for any infrastructure that will remain in place.
Clearly the Updated Notes are primarily targeted at the operators, being the parties bearing the primary responsibility for decommissioning the assets they have exploited during their productive life. But operators will not be equipped to manage the decommissioning process in isolation and the service company sector will have a crucial role to play in the success of decommissioning oil and gas installations and infrastructure in the UK whether that be in the design, engineering, analysis of options, in the physical decommissioning work itself or in the post-decommissioning monitoring and management. In that sense, the UK government’s decommissioning policies and the Updated Notes will have a bearing on how operators and contractors alike conduct themselves throughout the decommissioning process, so are something that all interested parties need to be aware of.
At the time of going to press, BEIS has just issued a consultation on proposed updates to its Offshore Renewables Decommissioning Guidance for Industry.