Rigs-to-Reef: Policy Waters Muddied
UK Government needs to take a lead on forming evidence-based policy on rigs-to-reef decommissioning of oil rigs
RECENT press coverage of the Chief Executive of the Oil and Gas Authority (OGA), Andy Samuel’s evidence to the inquiry into the public cost of decommissioning oil and gas infrastructure at Westminster, prompted me to review the minutes of the session. Alex Chisholm, Permanent Secretary, the Department for Business, Energy and Industrial Strategy (BEIS) and Emily Bourne, Director, Energy Development and Resilience, BEIS, also provided evidence.
I was particularly interested in any evidence addressing repurposing oil and gas architecture as a benefit for the marine ecosystem, so called rigs-to-reefs. The following is a direct lift from the minutes, which you can read in full here.
Q55 Chair: "This question is mainly to Dr Samuel, but also to Emily Bourne. The Scottish Affairs Committee did a report on decommissioning, and raised the question about the best of way of decommissioning to minimise harm to the environment. Do you think that that question is now resolved, Dr Samuel? In all the work that you are doing – benchmarking and so on – can you give us an example of best practice? How widespread is it becoming across the sector?"
Andy Samuel: "From memory, there was quite a lot of conversation in those committees on topics such as rigs-to-reef and the like, which are much more in Emily’s policy area."
Emily Bourne: "This was a question that the Scottish Affairs Committee was interested in. Rigs-to-reef is not something that we currently have a policy on, and the reason for that is that we haven’t had any demands from any operators within the UK to bring forward a rigs-to-reef proposal. We have, as you know, derogations that allow certain parts of an installation to be decommissioned in situ and left in the sea. That is for safety and technical reasons. But we have not had any requirement from someone to leave an installation in place for the purpose of becoming a reef. We would be open to discussing that if people came to us with proposals, but no one has come forward as yet. As you know, we have international requirements that we must meet through the OSPAR treaty."
I found the response from Emily Bourne particularly troubling. It is either very naïve or it is disingenuous. It suggests that the door is open for oil and gas operators to propose repurposing as a benefit for the marine environment. Does she think that any responsible operator would table that? The oil companies will follow marine legislation, legislation that currently leaves no scope for such derogation. So by stating that "we haven’t had any demands from any operators" is hardly surprising, it is also misleading.
Stating that "we haven’t had any demands from any operators" is hardly surprising, it is also misleading.
Furthermore, Bourne states that rigs-to-reefs "is not something that we currently have a policy on". With rigs-to-reefs offering significant cost savings and benefits to the environment, surely this is something BEIS should have a policy on? To infer that there is no policy as there is no demand is unacceptable from my position as a taxpayer. BEIS should be taking a lead here and reviewing the societal, environmental and economic evidence supporting rigs-to-reefs. That evidence should form the basis of the UK’s policy and, if appropriate, be used to renegotiate the associated marine legislation to include the option for repurposing as a benefit to the marine ecosystem.
As a footnote, the evidence session also involved seeking more certainty for decommissioning costs. This seems a bit misguided: the costs are market dictated by the heavy lift and subsea vessel providers together with the well plug and abandon companies. Future rates are highly uncertain which undermine most efforts to improve cost forecasting.
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