Decommissioning the UKCS: increasing flexibility of approach through proportionate regulation and evidence based practice.

Brooks, Richard

Abstract

The purpose of this research is to investigate how industry and government can strategically align to improve efficiency and gain environmental benefit from the challenge of decommissioning redundant offshore oil and gas infrastructure, through an alternative evidence-based practice and proportionate regulatory approach. Despite nearly thirty years of periodic decommissioning activity, the regulatory drivers and programme design dynamics continue to be politically driven and not evidence based (Penner, 2001, Bellamy and Wilkinson, 2001 and Pulsipher and Daniel, 2000). Projects are not deliverable as originally agreed in the approved programmes ( BEIS close out reports) and do not maximise the potential benefits to the marine environment of the North Sea ( Jorgensen 2013, Van Der Stap et al, Macreadie et al 2011, Love et al, 2003, and Soldal et al, 2002). Much of the knowledge and experience gained over the past thirty years has not been recorded or archived in any form that would benefit future programmes, and approved decommissioning programmes continue to be audited historically rather than in real time. All stakeholders have a genuine interest and an opportunity to benefit from a regulatory approach that is both evidence-based and proportionate by design. An adopted mixed-methods approach - combining quantitative, qualitative and case study approaches - was used to investigate the current regulatory framework and the resulting decommissioning methods that are employed to achieve compliance. The development and impact of the current decommissioning framework was investigated from both the published literature and the research participants' perspectives. The emerging recommendations for change are based on evidence from this research. This research adds to the body of knowledge on three fronts: theoretical, methodological and practical. Gaps between theoretical compliance demands and deliverability are identified, several evidence-based recommendations are made and an alternative, more flexible framework is proposed. The audit methodology and audit template are significant contributions to practice. The research concludes with key recommendations. The primary recommendation is that the United Kingdom government should implement a fundamental review of the current regulatory framework for offshore decommissioning and consider the evidence base for proposing changes to OSPAR Decision 98/3. The supporting recommendations are: that the derogation limit of 10,000 tonnes should be removed and each project should be assessed on an individual case basis; the UK should initiate the introduction of a "rigs to reefs" programme on the UKCS through a broad stakeholder consultation; the current baseline of a clear seabed, one-size-fits-all approach is not sustainable and a more flexible, proportionate approach should be adopted; specific changes are proposed to the current regulatory framework to increase its proportionality; the audit process needs to be strengthened and focus on invasive audits to increase stakeholder confidence; guidelines provided to industry need to be revised; and the regulator in partnership with industry should develop a decommissioning knowledge bank at the heart of a knowledge transfer system. Taken together, the research and the resulting recommendations have generated a conceptual framework combining strategic, evidence-based decommissioning options with proportionate regulatory practices. This provides both policy makers and industry with a developmental envelope for an alternative framework for future decommissioning in the UK and further afield.

Citation

BROOKS, R. 2018. Decommissioning the UKCS: increasing flexibility of approach through proportionate regulation and evidence based practice. Robert Gordon University, DBA thesis. Hosted on OpenAIR [online]. Available from: https://doi.org/10.48526/rgu-wt-1677784

• Thesis Type: Thesis
• Deposit Date: May 31, 2022
• Publicly Available Date: May 31, 2022
• DOI: https://doi.org/10.48526/rgu-wt-1677784
• Keywords: Offshore decommissioning; Decommissioning in the oil and gas industry; Oil and gas industry; Energy policy; North Sea; United Kingdom
• Public URL: https://rgu-repository.worktribe.com/output/1677784
• Award Date: Oct 31, 2018