Environment Report 2015

page 53

In 2015, Oil & Gas UK worked closely with IOGP, DECC and the Department for Environment, Food & Rural Affairs

on this issue, successfully securing a revision of the BAT AELs. This included developing evidence that compared the

cost of implementing the BREF with the forecast air quality benefits. This cost-benefit analysis demonstrated that

the expenditure associated with compliance with the BREF significantly outweighed the forecast environmental

and societal benefits. It is believed that approximately two turbines on one installation will be exposed at the

revised emission limit for NO

by the time the new AELs come into force. Oil & Gas UK continues to work with

DECC to understand its interpretation of the relevant text within the BREF as well as its plans for implementation.

The proposed BAT DLN, meanwhile, is only effective at reducing emissions when the load on the turbine is high.

The load usage of turbines on offshore platforms is highly variable and, for safety reasons, a redundant extra

load capacity is maintained. Therefore, significant reductions in emissions using DLN are not achievable in most

operating circumstances.

Similarly, Oil & Gas UK worked with IOGP and DECC to put forward the industry’s position on the proposed

Medium Combustion Plant Directive. The Directive included Emissions Limit Values (ELVs) for NO

and CO that

were unachievable for the UKCS due to the operational reasons highlighted above. The proposed ELVs had the

potential to force early decommissioning of numerous installations on the UKCS. At the time of writing, it appears

that the final text of the Directive is likely to include an exemption for offshore platforms.

Increasing Standardisation

Standardisation of approaches across industry improves efficiency. Oil & Gas UK has been working with its

members to increase standardisation in environmental management including:

•

Generating seabed survey strategies that aim to encourage standardisation while gaining greater

understanding of the effect oil and gas activity has on the seabed. A standardised approach will also promote

sharing of data and survey platforms.

•

Working in co-operation with regulators on new guidance and requirements to improve consistency, such as

the Energy Saving Opportunity Scheme guidance, the oil spill modelling for OPEPs and improvements to the

classification of accidental releases.

•

Working with the regulators on standardising and simplifying approaches to chemical permitting to reduce the

administrative burden of the process.

•

Publication of industry guidelines that aim to improve knowledge and promote consistent approaches. These

include fisheries liaison guidelines, comparative assessment in decommissioning programme guidelines and a

suite of eight oil spill response implementation guides in the oil spill response toolkit

These guidelines are available to download at