Hundreds of end-of-life oil rigs in the North Sea are to be decommissioned over the next 30 years. The rules surrounding decommissioning are governed by the OSPAR convention (the mechanism by which 15 governments & the EU cooperate to protect the marine environment of the North-East Atlantic). The UK government, despite being a signatory to the OSPAR convention, has signaled its intention to grant a derogation to Royal Dutch Shell. This would allow the company to partially dismantle three oil rigs in the Brent Spar oil field leaving some of the infrastructure behind on the seabed.
It is not the first time that Shell has sought to jettison decommissioned oil infrastructure in the North Sea. In 1995 Shell proposed sinking the Brent Spar oil storage buoy. At the time KIMO, working alongside Greenpeace, successfully lobbied OSPAR to tighten the rules around decommissioning. As a result, OSPAR banned the practice of leaving oil installations wholly or partly in place. Under exceptional circumstances, national governments could grant a derogation which would allow an operator to leave infrastructure in the North Sea.
The UK government has now signaled its intention to grant a derogation which would allow Shell to leave the bases of the Bravo, Charlie and Delta platforms behind in the North Sea post decommissioning. These platforms were erected in the East Shetland Basin during the 1970s and it is estimated that the derogation would leave infrastructure containing 11,000 tonnes of raw oil and toxins behind on the seabed.
KIMO has always supported the onshore decommissioning of disused offshore installations on the principle of protection of the environment. Whilst we affirm that reuse, recycling or final disposal on land should be the default position, we recognise that there may be exceptional circumstances under which comparative assessment indicates that the potential harm to the marine environment will be greater if some parts of an installation are removed than if they are left in place. In these cases, provided that the responsible parties have taken appropriate mitigation measures, made adequate provision for implementation of robust, ongoing monitoring and assessment of installations left in situ, and for establishing and satisfying legal liabilities, in exceptional circumstances decommissioning at sea may be an environmentally-sound option.
In the case of Shell’s plans for decommissioning of the Brent oilfield installations in the North Sea there appears to be some doubt whether the plans adequately address the long term environmental (and navigational) risks, seeming instead to prioritise the lower costs that may be incurred by leaving parts of the installations in situ.
Germany, Sweden, the Netherlands, Belgium and Luxembourg have all objected to the proposed derogation which will be discussed at a special OSPAR meeting to be held in London on the 18th of October. KIMO welcomes the action of the UK Government in seeking input from national OSPAR and EU stakeholders. We believe that any decision to grant a derogation to Shell should be rescinded until propriety of the plan is established and urge the UK Government to be rigorous in prioritising issues of environmental harm over financial loss. KIMO will be making a formal submission to the OSPAR meeting on the 18th of October. We hope that an agreement can be reached which protects the North Sea and its coastal communities.