Shell submitted two decommissioning programs (DPs) in a single document to the Department for Business, Energy and Industrial Strategy (BEIS) for review in February. The 60-day public consultation ended on Monday.
Environmental groups, including WWF, Greenpeace UK, the Marine Conservation Society, Friends of the Earth Scotland, KIMO, Whale and Dolphin Conservation, the Scottish Wildlife Trust, and RSPB Scotland issued a joint consultation response, rejecting the decommissioning plans, citing “insufficient information” and a failure to adhere to clear internationally agreed criteria and procedures.
The concrete legs of the platforms raise questions
The concrete legs on three of the four platforms and Shell’s proposal to leave them in place rather than removing them are being questioned. According to OSPAR Commission, there are very clear criteria and procedures for operators to follow in carrying out decommissioning procedures.
Environmentalists do not believe the OSPAR rules have been fully adhered to, in this case, writing in their response: “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.”
The BBC reports that Greenpeace UK chief scientist Dr. Doug Parr said: “The plans in their current form don’t allow international law to be upheld because it’s not possible for regulators to really understand what the proposition is.”
Dr. Parr adds, “We don’t think they have explored options fully, we don’t think they have justified the options we want to carry through and we think they should go back and properly do their homework.”
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.”
Since 1998, the dumping, and leaving wholly or partly in place, of disused offshore installations is prohibited within certain sea areas, and in particular, the North Sea, under OSPAR Decision 98/3, unless permission is given based on specific conditions. Shell is hoping the OSPAR Commission will allow them to leave the concrete legs, which weigh about 300,000 tons apiece, in place.
A Shell spokesman said: “Shell welcomes the feedback, which has been received from stakeholders and members of the public during the 60-day public consultation period for the Brent field. The consultation concludes today and, over the coming weeks, we will continue to review and respond to the comments received.”
Now, it is up to government ministers to decide to accept or reject Shell’s decommissioning plans. A spokeswoman for the BEIS said: “Any decommissioning plan will be carefully considered by the government, taking into account environmental, safety and cost implications, the impact on other users of the sea and a public consultation.”
