Environment Performance Indicators
IOPER members have agreed to advance an initiative to investigate the development and implementation of a common set of Environmental Performance Indicators (EPIs) with which to measure key areas of environmental performance for the offshore petroleum industries and regulatory regimes in member counties.
A common set of EPIs would enhance the ability to share and compare information about the environmental performance relevant to the offshore petroleum industry at an international level.
The overarching goal of the initial stage of this project is for IOPER to develop an initial limited set of EPIs that could be used by IOPER members to compare and contrast environmental performance. These EPIs will be developed in consideration of existing schemes in place such as IRF performance measures and the OSPAR and UNEP Global Reporting Initiative.
IOPER members have agreed to take forward a number of work streams on EPIs. Work will be carried out by a multi-national working group chaired by the UK and membership drawn from IOPER member countries. Initial steps for the working group will be foundational and involve reviewing existing EPIs, establishing standardised terminology and considering opportunities and constraints associated with the different regulatory regimes that operate in member countries.
No decision has been made yet regarding implementation of EPIs, however it is possible that some member countries will need to consider amending arrangements for reporting and collection of performance data to ensure the necessary consistency.
A universal data collection template has been drafted for presentation to members at the IOPER mid-year meeting (May 2nd & 6th 2016) and NOPSEMA, UK DECC and US-BSEE are currently trialling 2015 data collection using this template. Once any necessary refinements have been made to the template it is hoped to roll this out to other IOPER members for data collection later in 2016.
An example of the outcomes of an analogous safety-related initiative is reflected in the IRF performance measures project:http://www.irfoffshoresafety.com/country/performance/
Regulating Oil Spill Preparedness and Response
Joint Industry Workshop on Oil Spill Preparedness and Response
In May, 2016 the International Offshore Petroleum Regulators (IOPER) joined forces with the Australian Petroleum Production and Exploration Association (APPEA) to organise and stage a joint regulator/ industry workshop on the oil spill preparedness topic of ‘How Much is Enough?’. The half-day workshop was held in conjunction with the Spillcon conference in Perth, Western Australia. During the well-received workshop industry and government stakeholders working in oil spill preparedness and response discussed national and international perspectives on how much preparedness and response is appropriate in the context of oil spill risks from offshore oil and gas. Topics discussed included the key role of risk assessment in determining response need, the development of tactical response plans, the use of semi-quantitative approaches to measuring capability, and the role that the ALARP principle plays in the Australian context.
The workshop furthered work undertaken by IOPER members to develop a number of internationally-recognised ‘guiding principles’ for regulating oil spill response preparedness in the offshore oil and gas industry. These aim to ensure proper and systematic risk identification and management processes and drive identification, implementation and maintenance of the right spill planning, preparedness and response arrangements. These are described in the Guiding Principles document and its accompanying introduction.
Public Consultation and Decision Making
IOPER members have agreed to explore opportunities and challenges in the area of public consultation and decision making for environment regulatory approaches. This is a key area of environmental management for offshore petroleum industries and regulatory regimes in member counties.
Sharing perspectives on this topic will enhance the ability to compare information about the effectiveness of and return on effort. Surveys of IOPER members on this topic have shown that all jurisdictions have mechanisms in place in legislation to generate appropriate disclosure and opportunities for affected or interested parties to be consulted in the planning and implementation stages of offshore petroleum operations. The means by which informed consultation is provided often vary given the different scope, legal framework and scale of offshore petroleum operations in each jurisdiction.
Further exploration of this topic will focus on the degree to which public consultation mechanisms efficiently and effectively effect and improve environmental outcomes. The initiative may also lead to better understanding where public input and other decision making efficiencies could be achieved.
Members have agreed to further project work to identify areas of highest return and will continue to share experiences and good practices.
Environmental Impact Research Collaboration Opportunities
IOPER members discussed how increasingly complex pressures on the marine environment from petroleum industry activities require regulators to consider what are the priority areas for improving scientific understanding of environmental impacts, how they can be managed and how environmental performance can be measured.
IOPER members have agreed to collaborate on identifying the various ways that each of the different jurisdictions aim to manage or minimise impacts from oil and gas activities and improve understanding in areas of scientific uncertainty regarding environmental impacts, with the aim of identifying where collaboration between the jurisdictions may lead to more cost effective or valuable research outcomes.
Enforcement Tool Research
Regulatory theory suggests that successful regulators have a sophisticated understanding of the nature of the risk that is being regulated, the regulated parties, and the changing regulated environment. In the context of the offshore petroleum industry, the possible research areas include:
- Understanding the regulated companies
- Understanding the capacity and role of the regulator
- Understanding the changing environment
- Understanding the quality and effect of regulation
Practical areas where research might be useful include:
- Enforcement tools
- Information and targeting
Members have agreed to initiate a research project on enforcement tools using a survey and to share a draft of the survey with members for feedback.
General challenges associated with decommissioning include:
- Non-compliance (e.g. if not completed, poses risk to safety and environment).
- Lack of financial solvency, leading to lessees being unable to finance suitable decommissioning.
- Removal of habitat formed around structures during decommissioning.
- Environmental damage caused during the decommissioning activities (such as fish kills associated with explosive removal of platforms).
- Extreme weather events that damage structures and increase the cost of decommissioning.
IOPER members noted that many challenges are common and the issue is addressed differently in each jurisdiction. It was agreed that information on how environmental impacts as a result of removal are considered in respective jurisdictions would be useful to share.
BOEM has prepared a list of scholarly articles on the environmental impacts of decommissioning. These articles were identified using energy and environmental databases with references from peer reviewed journals, industry publications, trade magazines, and workshop proceedings. In all, 38 relevant articles and other sources such as books were identified. A copy of the document is available here.