Striking a Balance Index

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3.1 Environmental Management Progress to date: achievements and difficulties encountered Improved environmental performance through technology development Most UK offshore installations were designed and built well before technology to improve environmental performance was available (see case study below). As technology has advanced, new equipment has been retro-fitted to older installations wherever possible and incorporated in new developments at the design stage. One of the best of the many examples of improved environmental performance through technology development is the reduction of oil discharged in produced water. When oil is produced, some water comes with it. Separation and cleaning processes remove most, but not all, of the oil from the produced water which is then discharged, under licence, into the sea. Advances in technology have enabled a reduction in the average content of oil in water from over 32 parts per million (ppm) in 1989 to 22 ppm in 1999. UKOOA produced its first environmental research and development database in 1999 and this has been made available to Government and environmental groups to disseminate information on work being done in this area. Engaging with government, environmental groups and other stakeholders While the UK offshore oil and gas industry has always complied with the law, the case of the Brent Spar in 1995 brought about a fundamental change in communications strategies. Compliance alone was insufficient; stakeholder engagement was recognised as an imperative in major environmental issues. Since then, UKOOA and its member companies have worked with NGOs to build communications links and facilitate dialogue. Today, regular tripartite meetings take place involving industry, NGOs and government. Environmental Impact Assessments For several years, it has been common practice for companies to carry out environmental impact assessments for internal reporting purposes. In 1998, however, legislation resulting from a European Union directive was introduced, requiring consideration to be given to the need for formal environmental impact assessments for certain new development activities. These environmental statements are subject to public consultation. The imminent implementation offshore of the Habitats Directive will extend the scope of the existing legislation to the full range of existing operations and will specifically address particular species or habitats where industrial activity might have an adverse impact. Case Study One In 1999 the UK government and UKOOA agreed that the following guiding principles should govern the development of future environmental regulation: Continual improvement of the industry's offshore environmental performance should be guided as far as practicable by long-term goal setting, considering all emission streams holistically. Methods for achieving environmental goals should be flexible, appropriate to the asset life cycle, and promote innovation rather than relying on compliance against prescriptive standards or technologies. Sound scientific analysis should be applied to assess environmental risk and impact. However, where there are threats of serious or irreversible damage, lack of full scientific certainty will not be used as a reason for postponing cost-effective measures to prevent environmental degradation. In all cases, agreed improvements should recognise the balance between benefit gained and cost incurred, as well as the balance between emission stream trade-offs. The process of developing environmental regulations should be transparent and include stakeholder consultation. Penalties should apply if environmental laws are broken. Sustainable Development Action Plan Continual environmental improvement and the six guiding principles We re-affirm our commitment to continual improvement in our industry's environmental performance and to the six guiding principles (developed with government in 1999) on how continual improvement is best delivered. This over-riding commitment lays the foundation for the more specific actions below (see Case Study One). Industry-wide adoption of Environmental Management Systems (EMS) We have set a target that 90% of ukcs oil and gas production will be covered by an independently verified ems by end 2001, and all by end 2002. given the range of emss available, we do not intend to adopt any particular accreditation system, but we will ensure in every case that the management system adopted matches the criteria set by international environmental management systems, such as iso 14001. if necessary, we will set up a workshop in 2001 to help those starting this process. Biodiversity and Environmentally Sensitive Areas Oil and gas reserves are sometimes found in areas of particular environmental sensitivity and it may be concluded that some discoveries cannot be developed. Where development can be carried out in an environmentally responsible way, government and UKOOA operational guidelines are followed. Our industry is committed to developing and improving the technologies and processes to ensure that environmentally responsible exploration and production continue. UKOOA has provided its members with guidance on working in sensitive areas for some years. It has co-operated with the Government in establishing the new Environmental Assessment regime and in extending application of the EU Habitats Directive ahead of other users of the sea. The industry has carried out extensive environmental surveys in sensitive areas. For example, it has assisted local authorities to draw up protection plans for the north Scottish coast, Orkney, Shetland and the Western Isles. Industry surveys are recognised as a major source of information about the marine environment generally and sensitive areas in particular. We are committed to two actions in recognition of the importance of environmentally sensitive areas: We will meet non-governmental and academic stakeholders to understand and, where possible, assist their research needs, so that surveys carried out meet our joint data requirements. A workshop will be held with stakeholders during 2001 to determine research priorities. We will maximise access to reliable industry research data pertinent to environmentally sensitive areas. Case Study Two EMS The impact of industrial activity on the environment is under increasing scrutiny as public concern grows about waste, pollution, use of resources and risks to the natural world. There is a demand for transparency, accountability and reassurance that industry is genuinely seeking to improve environmental performance. Responsible companies understand this and accept the challenge of integrating good environmental management with efficient business performance. An Environmental Management System (EMS) provides a disciplined framework for the planning, implementation and monitoring of activities aimed at good environmental performance. An effective EMS sets environmental policy, objectives and targets; defines roles and responsibilities; has procedures to monitor and measure activities that have environmental impact; and has senior management review performance and effectiveness. Each operating company in the UKCS must produce an EMS for each installation as a condition of its operating licence. International standards for environmental management systems have been established, such as ISO 14001, and many companies have chosen to seek this kind of accreditation which requires independent verification against a rigorous set of criteria. Sharing best practice, ensuring guideline compliance We will develop a formal framework for sharing best practice within the industry (prioritisation of areas, definition of roles and responsibilities, clarification of implementation media) by mid 2001. We intend to agree a cross-industry action plan by end of 2001. We have introduced new reporting arrangements so that the ukooa council is aware of cases of non-compliance with any ukooa guideline and the reasons for it. UKOOA companies will put the necessary controls in place to ensure that contractor companies also comply with guidelines and address past problem areas (for example, compliance with seismic guidelines) Workforce environmental awareness and training We will develop a framework in 2001 to identify and address environmental awareness and training needs, ensuring all employees achieve a basic understanding of environmental issues. We will involve contractors in this process, which will be implemented across the industry between 2001 and 2003. Case Study Three BAT and BPEO These well-established terms stand for best Available Technique and Best Practicable Environmental Option. BAT is defined in the Integrated Pollution Prevention and Control (IPPC) Directive of the European Union, now enacted in the UK, and takes into account benefit or does the least damage to the environment, in the long as well as the short term. Both are accepted measures in the industry for assessing costs versus benefits of any particular activity with potential environmental impact.