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Environmental groups yesterday (Monday 10 April) rejected plans put forward by oil and gas giant Shell to decommission four of the company’s North Sea oil and gas platforms, citing “insufficient information” and a failure to adhere to clear internationally agreed criteria and procedures. [1]

Along with some other potentially polluting wastes, Shell had proposed leaving the giant legs of some of its four Brent field platforms on the seabed when it completes decommissioning work. [2]

A joint submission from eight environmental and conservation organisations to the consultation, which closed yesterday, said:

• It has not been possible to come to a view on the decommissioning proposal due to insufficient information provided by Shell.
• The material presented cannot be clearly cross referenced to OSPAR 98/3 requirements for each of the major components and pollutants for which Shell seeks derogation.
• There is a lack of quantitative analysis based on hard data, a significant reliance on subjective, qualitative judgments and opinions by experts, including Shell’s own engineers, which has led to some options being excluded from further consideration.
• There is also a lack of quantification of the uncertainties in many of the estimates made, which was also highlighted by the Independent Review Group. [3]

The groups recommended that Shell be requested to provide further specific information in order to be able to adequately assess the proposals.

WWF Scotland director Lang Banks said:

“Despite over 3,000 pages of documentation, it has not been possible to come to a view on Shell’s decommissioning proposal due to insufficient information being provided by the company across several key areas.

“The internationally agreed OSPAR rules set out very clear criteria and procedures for operators to follow in carrying out such assessments, but we do not believe they have not been fully adhered to in this case. [4]

“The material presented cannot be clearly cross referenced to the OSPAR requirements meaning we cannot assess whether or not there is a solid case for the derogations sought by Shell.

“We are therefore left with no choice but to reject Shell’s plans in their current state and have asked for key further information in order to adequately assess their proposals.

“Given the enormous size of the rigs and the iconic nature of the Brent field, its decommissioning is being watched closely, both here and globally, and it should therefore be aiming to set the highest possible benchmarks for the rest of the industry to follow.

“If done right, it could open the door for this country to lead a new multi-billion pound, global decommissioning industry that could create thousands of jobs as we continue our transition away from fossil fuels.” [5]

Notes to Editors

[1] A full copy of the joint consultation response by WWF, Greenpeace UK, the Marine Conservation Society, Friends of the Earth Scotland, KIMO, Whale and Dolphin Conservation, the Scottish Wildlife Trust, and RSPB Scotland is available https://www.wwf.org.uk/sites/default/files/2017-04/Reply%20to%20Brent%2…

The Summary of their response said:

“Unfortunately it has not been possible to come to a view on the decommissioning proposal due to insufficient information provided by Shell. OSPAR 98/3 sets out very clear criteria and procedures for operators, requiring derogations to this decision, to follow in carrying out such assessments, which have not been adhered to. The material presented can not be clearly cross referenced to OSPAR 98/3 requirements and means we cannot assess whether or not there is a solid case with full legal, technical, environmental and economic justification, aligned specifically against the requirements of OSPAR 98/3, for each of the major components and pollutants for which Shell seeks derogation.

Related to this and generally there is a lack of quantitative analysis based on hard data, a significant reliance on subjective, qualitative judgments and opinions by experts, including Shell’s own engineers. There is also a lack of quantification of the uncertainties in many of the estimates made, which was also highlighted by the Independent Review Group.

In view of this we recommend that Shell be requested to provide the following in order for interested parties to be able to adequately assess the proposals: a table setting out Shell’s response in full to each specific requirement of 98/3 (Appendix 1), for ALL potential reuse, recycle and disposal options (not just those that were pre-shortlisted internally by Shell), which are based on independent assessments and clearly identify and quantify all inherent uncertainties as required by 98/3. This information should be circulated to all interested parties to allow any further consideration of the proposals.”

[2] A 60-day public consultation into Shell’s decommissioning plans was launched by the UK Department for Business, Energy and Industrial Strategy in February.

UK Department for Business, Energy and Industrial Strategy consultations:

https://www.gov.uk/guidance/oil-and-gas-decommissioning-of-offshore-installations-and-pipelines

Shell submits plans to decommission Brent field

http://www.shell.co.uk/sustainability/decommissioning/brent-field-decommissioning/brent-field-news-and-media/shell-submits-recommendations-for-retiring-brent-field.html

[3] Shell Brent Decommissioning Project: Independent Review Group Final Report

http://www.shell.co.uk/sustainability/decommissioning/brent-field-decommissioning/brent-field-decommissioning-programme/_jcr_content/par/tabbedcontent/tab_1385449832/textimage.stream/1487694847829/b5aeed967c2da19ff716bc3366894eedc2e1898a0d894e2583047230e6ae344a/brent-irg-final-report-feb-2017.pdf

[4] Since 1998 the dumping, and leaving wholly or partly in place, of disused offshore installations is prohibited within certain sea areas, under OSPAR Decision 98/3 on the Disposal of Disused Offshore Installations. Under certain circumstances companies can seek permission to leave some installations in place.

http://www.ospar.org/work-areas/oic/installations

[5] Industry analysts Wood Mackenzie have estimated that at least 140 fields will cease production over the next 5 years, with a total of £55 billion (real terms) to be spent on decommissioning the UK Continental Shelf.

For more info, see: https://www.woodmac.com/analysis/mission-decommission-the-north-sea

[6] Shell Brent decommissioning website:

http://www.shell.co.uk/sustainability/decommissioning/brent-field-decommissioning.html

Shell’s media contacts are available here: http://www.shell.com/media/contact-media-relations.html