Guidelines to plan for development and operation of a petroleum deposit (PDO) and plan
for installation and operation of facilities for transport and utilisation of petroleum (PIO).
Issued by the Norwegian Petroleum Directorate 18 May 2000.
CONTENTS
CONTENTS......................................................................................................................................1
Abbreviations .....................................................................................................................................3
1. INTRODUCTION.........................................................................................................................4
1.1 Difference between PDO and PIO...................................................................................................5
1.2 Requirement to submit new or altered plan......................................................................................5
1.3 Procedure in dealing with the PDO and the PIO...............................................................................5
1.4 Reduced time for the administrative process....................................................................................6
PART I ..............................................................................................................................................7
2 GUIDELINES FOR THE DEVELOPMENT PART OF A PDO AND THE INSTALLATION
PART OF A PIO; COMMON PART................................................................................................7
2.1 Introduction ..................................................................................................................................8
2.2 Development concepts ...................................................................................................................8
2.3 Development in stages ...................................................................................................................8
2.4 Tie-in with other fields or facilities .................................................................................................9
2.5 Possibility of tie -ins from other fields .............................................................................................9
2.6 Co-ordination of petroleum activities..............................................................................................9
2.7 Description of facilities and concept evaluation ...............................................................................9
2.8 Costs .......................................................................................................................................... 10
2.9 Organisation and implementation .................................................................................................. 10
2.9.1 Time and activity schedules....................................................................................................... 10
2.9.2 Organisation............................................................................................................................. 11
2.10 Relationship to the fishing industry ............................................................................................. 11
2.11 Operaton and maintenance ......................................................................................................... 11
2.12 Disposal of facilities .................................................................................................................. 11
2.13 Onshore facilities....................................................................................................................... 11
3 IN PARTICULAR ABOUT THE CONTENTS OF THE DEVELOPMENT PART OF A PDO...11
3.1 Description of the production licence............................................................................................ 11
3.2 Production strategy ...................................................................................................................... 12
3.3 Reservoir engineering aspects....................................................................................................... 12
3.3.1 Geological and geophysical evaluation....................................................................................... 12
3.3.2 Reservoir technology ................................................................................................................ 13
3.3.3 Production and reservoir monitoring .......................................................................................... 14
3.4 Technical description of facilities etc. ........................................................................................... 14
3.4.1 Load-bearing structures, topside arrangement and subsea facilities............................................... 14
3.4.2 Overall plan for drilling and well activities ................................................................................. 15
3.4.3 Process and auxiliary facilities ................................................................................................... 15
3.4.4 Metering systems ...................................................................................................................... 15
3.4.5 Regularity ................................................................................................................................ 16
3.4.6 Transportation systems .............................................................................................................. 16
3.5 Economic analyses ...................................................................................................................... 16
1
3.5.1 Assumptions............................................................................................................................. 16
3.5.2 Results..................................................................................................................................... 17
3.5.3 Economic risk evaluations ......................................................................................................... 17
3.5.4 Optimisation of development and operation ................................................................................ 17
3.5.5 Marketing of gas and commercial aspects................................................................................... 18
3.5.6 Gas for injection purposes ......................................................................................................... 18
3.6 Substantial contractual obligations ................................................................................................ 18
4 IN PARTICULAR ABOUT THE CONTENTS OF THE INSTALLATION PART OF A PIO.....18
4.1 Description of the project............................................................................................................. 19
4.2 Possibilities for use of facilities by others...................................................................................... 19
4.3 Technical description of facilities etc. ........................................................................................... 19
4.3.1 Loadbearing structures, subsea installations and system design .................................................... 19
4.3.2 Assumptions............................................................................................................................. 19
4.3.3 Choice of pipeline route and location ......................................................................................... 19
4.3.4 Volumes and composition of the petroleum transported or utilised ............................................... 20
4.3.5 Capacities................................................................................................................................. 20
4.3.6 Metering systems ...................................................................................................................... 20
4.3.7 Regularity ................................................................................................................................ 20
4.4 Economic analyses ...................................................................................................................... 20
4.4.1 Assumptions............................................................................................................................. 21
4.4.2 Results..................................................................................................................................... 21
4.4.3 Economic risk evaluations ......................................................................................................... 21
4.4.4 Optimisation of installation and operation ................................................................................... 22
4.4.5 Tariffs...................................................................................................................................... 22
4.5 Substantial contractual obligations ................................................................................................ 22
5 EXEMPTION FROM THE REQUIREMENT RELATING TO PDO/PIO ..................................22
PART II ..........................................................................................................................................23
6 GUIDELINES RELATING TO THE IMPACT ASSESSMENT PART OF PDO/PIO.................23
6.1 Introduction ................................................................................................................................ 23
6.2 Purpose....................................................................................................................................... 24
6.3 Legal basis .................................................................................................................................. 24
6.4 Process ....................................................................................................................................... 25
6.4.1 When should the work to prepare an impact assessment commence?............................................ 25
6.4.2 Use of regional impact assessments in respect of new field developments..................................... 26
6.4.3 Process for impact assessment programme and impact assessment ............................................... 26
6.4.4. Possibility of exemption from the requirement relating to impact assessment............................... 30
6.5 Contents of impact assessment programme and impact assessment ................................................. 30
6.5.1 Field specific assessments ......................................................................................................... 31
6.5.2 Regional impact assessments..................................................................................................... 34
6.6 Impact assessments in relation to transboundary environmental impact ........................................... 35
6.6.1 Projects in Norway where there is a danger of significant transboundary ...................................... 36
6.7 Other legislation .......................................................................................................................... 36
6.7.1 The planning and building Act................................................................................................... 36
6.7.2 The harbour and fairways Act.................................................................................................... 37
6.7.3 Other potentially relevant legislation .......................................................................................... 37
2
Abbreviations
MPE
MLGRD
NPD
PDO
PIO
IA
FIA
RIA
pa
pr
pba
NGL
The Ministry of Petroleum and Energy
The Ministry of Local Government and Regional Development
The Norwegian Petroleum Directorate
Plan for development and operation
Plan for installation and operation
Impact assessment
Field specific impact assessment
Regional impact assessment
The petroleum Act
The petroleum regulations
The planning and building Act
Natural gas liquids
3
1.
INTRODUCTION
The Ministry of Petroleum and Energy hereby presents new guidelines in respect of Plan for development
and operation of a petroleum deposit (PDO) and Plan for installation and operation of facilities for
transport and utilisation of petroleum (PIO) replacing the existing guidelines for impact assessment and
PDO. These guidelines deal with contents and format of both the development and the installation part
(Part I) and the impact assessment part of the PDO/PIO (Part II).
These guidelines are intended as a supplement to Act 29 November 1996 no. 72 relating to petroleum
activities and regulations to Act relating to petroleum activities laid down by Royal Decree of 27 June
1997. This legislation entered into force on 1 July 1997. Regulations for the amendment of regulations to
Act relating to petroleum activities were adopted by Royal Decree 4 June 1999. The amendments refer to
impact assessments. The intention of the guidelines is to simplify the task of producing a PDO or PIO
complying with the requirements of the authorities for the companies.
It is emphasised that these guidelines are given for guidance only, i.e. the specific contents have to be
adapted to the development situation in question, and that the legislation at all times applicable to
petroleum activities must be complied with. When plans exist for development of a petroleum deposit or
for installation of a facility for transport and utilisation of petroleum, it is therefore recommended that the
developer gets in touch with the Ministry of Petroleum and Energy or the Norwegian Petroleum
Directorate at an early time in order to clarify possible questions in relation to these guidelines and the
specific project. This is particularly important in relation to a PDO or PIO that can be approved by the
Government and where a reply is requested within eight weeks of submitting the plan to the Ministry, cf.
chapter 1.4.
It is pointed out that safety matters are dealt with by the Ministry of Local Government and Regional
Development and the Norwegian Petroleum Directorate according to the provisions of the Petroleum Act
and safety regulations. Requirements to documentation in the area of safety and working environment in
relation to PDO and PIO follow from the safety regulations (regulations 27 June 1997 relating to safety in
the petroleum activities) section 22 with comments and the working environment regulations (regulations
27 November 1992 relating to worker protection and working environment in the petroleum activities),
section 10.
Unless otherwise agreed with the Ministry of Petroleum and Energy, the PDO and the PIO shall be in
the Norwegian language.
4
1.1
Difference between PDO and PIO
A PDO shall be prepared in respect of development of a petroleum deposit. A PIO shall be prepared in
respect of facilities for transport and utilisation of petroleum. A PDO shall also contain information with
regard to transport and facilities for utilisation. The description of facilities for transport and utilisation is
not required to be to the same degree of specification for a PDO as required for a PIO. Pipelines within a
field are to be dealt with in a PDO, and a PIO is not required. In respect of all other pipelines, a PIO shall
as a general rule be drawn up.
A PDO or a PIO shall be drawn up in respect of onshore facilities, which are comprised by the
petroleum Act. In respect of facilities for transport, a PIO shall be drawn up, and in respect of facilities for
production, a PDO shall be drawn up.
As a general rule separate documents shall be drawn up for a PDO and a PIO. If it is considered
expedient, a document containing both a PDO and a PIO may be drawn up. In that case there shall be a
clear division between the different parts, because different approvals and licences on different conditions
are required. If it is desirable to produce both PDO and PIO in a single document, this should be discussed
with the Ministry beforehand.
1.2
Requirement to submit new or altered plan
The Ministry shall be notified of and shall grant approval in respect of any significant deviation or
alteration of the terms and preconditions on whic h a plan has been submitted or approved. The Ministry
may require a new or amended plan to be submitted if significant deviation or alteration of the terms and
assumptions exists.
The licensee shall inform the Ministry of any deviation, except in cases of insignificant deviation. The
Ministry shall decide, based on a concrete evaluation in each separate case, whether a new or amended
plan will be required. In its evaluation the Ministry will, inter alia, attach importance to whether the
alteration entails a significant increase in field investments. In the case of production of a new petroleum
deposit the general rule is that a new PDO will be required.
1.3
Procedure in dealing with the PDO and the PIO
A PDO and a PIO consist as mentioned before of a development part or an installation part and an impact
assessment part. The administrative procedure for and the contents of the impact assessment part are
further described in chapter 6. The contents of the development and installation part are further described
in chapters 2, 3 and 4.
The development or installation part shall be submitted to the Ministry of Petroleum and Energy. The
Ministry of Petroleum and Energy forwards it for consideration by the Ministry of Local Government and
Regional Development and the Norwegian Petroleum Directorate. The Norwegian Petroleum Directorate
and the Ministry of Local Government and Regional Development submit the result of their consideration
to the Ministry according to a specified time schedule depending on how soon the case in question is to be
decided.
Simultaneously the Ministry initiates the consultation process and circulates the impact assessment for
comments to various bodies and institutions entitled to comment, such as Ministries affected, county
municipalities, municipalities as well as professional and industrial associations, organisations and interest
groups. The impact assessment shall be based on the impact assessment programme which is similarly
subject to a consultation process for comments, cf. chapter 6. Based on the impact assessment, the
development part and/or the installation part together with the comments received from the consultation
process, the Ministry drafts a proposition to the Storting (Parliament) or a Royal Decree which is subject
to a consultation process by circulation to Ministries concerned for their comments. Development projects
with an investment ceiling exceeding a predetermined limit, at present NOK five billion, shall be approved
5
by the Storting (Parliament).
After this consultation process the matter will be submitted by the government either to the Storting
(Parliament) or to the King.
Figure 2 shows an outline of the administrative procedure in relation to a PDO and a PIO. It is
important to note that the process in connection with the impact assessment must commence up to six
months or more in advance of submitting a PDO or a PIO, due to the requirement relating to a
consultation process in connection with the preparation of both an impact assessment programme and the
impact assessment itself, cf. chapter 6.4.
1.4
Reduced time for the administrative process
The Ministry aims at a processing time of eight weeks for development projects that do not have to be
dealt with by the Storting (Parliament). Currently this applies to most projects with an investment ceiling
below five billion NOK. In order for the Ministry to be able to achieve this goal, it is essential that the
developer discusses matters of importance in connection with the development with the authorities in
advance. This applies in particular to production strategy, choice of development concept, health and
environmental aspects and matters in connection with fisheries.
Furthermore it is important that the process connected with the impact assessment should be as good as
completed prior to submission of the development and/or installation part to the Ministry of Petroleum and
Energy. Specifically this means that the impact assessment programme should be submitted to the
Ministry of Petroleum and Energy no later than four to five months prior to submission of the
development or installation part of the PDO or the PIO 1). The impact assessment should be submitted no
6
later than two to three months in advance. This is to allow sufficient time for the consultation process for
comments in respect of the impact assessment programme and the impact assessment.
If the impact assessment has not been submitted to the Ministry sufficiently in advance of the
submission of the development or installation part, a longer time for the administrative process than eight
weeks must be expected. This does not apply to those cases where exemption from the impact assessment
has been granted or where the duty in respect of impact assessment has already been fulfilled, cf. chapter
6.4.4. Figure 3 provides an overview of the administrative procedure with reduced processing time in
respect of a PDO or a PIO.
1) The time for submission of an impact assessment programme and an impact assessment should be
agreed with the Ministry.
PART I
2
GUIDELINES FOR THE DEVELOPMENT PART OF A PDO AND THE INSTALLATION PART
OF A PIO; COMMON PART
7
2.1
Introduction
A PDO or a PIO shall be submitted to the Ministry of Petroleum and Energy when the licensees of a
petroleum deposit have decided to develop the deposit or it has been resolved to build a facility for
transportation or utilisation of petroleum. A PDO and a PIO shall as mentioned before contain an
installation part and an impact assessment part. In the petroleum Act of 1996 and its associated
regulations, certain amendments have been made in relation to PDO and PIO compared with the previous
petroleum Act from 1985 2) , for the purpose of making the administrative procedure more flexible.
As a general rule, a separate PIO shall not be required for facilities for transportation and utilisation of
petroleum within a field. These are dealt with as part of a PDO. A separate PIO shall be prepared for all
other facilities for transportation and utilisation of petroleum.
Development of petroleum deposits shall be approved by the Storting (Parliament), inter alia for
budgeting reasons where the State Direct Financial Interest (SDFI) participates in the production licence.
The Storting (Parliament) has, however, delegated authority to the Government to approve certain
developments. The authority has until now been granted for one year at a time and comprises projects
where the aggregate investments do not exceed a fixed amount.
In general with respect to a PDO or a PIO, the Ministry would emphasise that the reservoir related and
technical solutions must be sufficiently thoroughly prepared, that the financial estimates must be of high
quality and that calculations must have been carried out showing remaining uncertainty and risk.
The plan should also contain an overview of future commercial opportunities, which may provide a
basis for changes in the scope of investment.
This chapter deals with topics that will be common to the development and the installation part of a
PDO and a PIO, whereas the following two chapters deal with specific topics in relation to these parts of
the PDO and the PIO respectively.
It is emphasised that the guidelines do not provide an extensive description of the matters that have to
be taken into consideration in the preparation of the development part or the installation part. This must be
decided specifically for each individual case.
It is pointed out that the term “the development part” is used for both PDO and PIO where there is a
need to distinguish between this part of the plan and the impact assessment part.
2) Act 22 March 1985 no. 11 relating to petroleum activities
2.2
Development concepts
See
The plan shall give a description of the development strategy that has been selected. If at the time of
application it should prove difficult to present only one development concept for all areas, several may be
indicated. The relevant development alternatives should in such case be equally well documented. In
addition, the situations that will entail implementation of each individual development concept, shall be
clearly stated.
If the development comprises facilities onshore, these facilities shall be included in the description of
the development concept. If doubt can be raised as to whether a facility onshore is comprised by the
petroleum Act, the Ministry of Petroleum and Energy should be contacted. Moreover, the need for coordination with regard to impact assessments pursuant to the planning and building Act is emphasised.
The plan should also contain an overview of future commercial opportunities that may entail changes in
the development concept.
2.3
Development in stages
See pa, section 4-2 fourth paragraph, section 4-3 second paragraph and pr section 21 second paragraph
8
litera a.
If the development is planned in two or more development stages, the plan shall to the extent possible
comprise the total development. The authorities may limit the approval to be applicable to individual
stages.
The first stage of a development may have a guiding effect on the further development. This may affect
the total production from the field, as well as the production from other petroleum resources in the area. In
order to be able to evaluate these effects, the PDO and the PIO shall to the extent possible describe the
further stages or alternative stages of the development.
2.4
Tie -in with other fields or facilities
See pa section 4-2, section 4-8 and pr section 21 second paragraph litera a. See also pr section 28 third
paragraph litera b.
If the plan entails use of existing facilities offshore or onshore, a description of these shall as a rule be
presented, including a description of necessary modifications resulting from the tie -in.
The description shall furthermore clarify the physical boundary between own facilities and those of
other parties, and shall also indicate possible factors of uncertainty connected with the tie -in. The
distributio n of responsibility between the parties involved, shall also be stated. The group of licensees who
are owners of the existing facility, has an independent duty towards the authorities in relation to whether
the modifications or alterations will entail a requirement for a new or altered PDO/PIO.
In case the right of ownership and/or the right of use is transferred to another group of owners than the
group behind the application, this should be stated.
2.5
Possibility of tie -ins from other fields
See pr section 21 second paragraph litera l and section 29 second paragraph litera j. See also pa section
4-8
The plan should provide an evaluation of the possibility of future tie-ins with other petroleum deposits in
the area, as well as an analysis of the financial consequences for the field or for the facility if other
licensees are to make use of the facilities.
In this connection, there should be an overview of discoveries and prospects in the area, with particular
emphasis on resource base and maturity. This applies to nearby discoveries and prospects even when they
are not comprised by the production licence.
2.6
Co-ordination of petroleum activities
See pa section 4-7 and pr section 21 second paragraph litera a
If the petroleum deposit extends over more than one block with different licensees, an agreement on joint
activities shall be drawn up. A joint activities agreement shall also be drawn up if there is more than one
petroleum deposit when joint petroleum activities are obviously more efficient.
The authorities attach importance to the principle that a joint activities agreement in respect of the
deposit or deposits should be in place and approved prior to submission of a PDO. Only in exceptional
cases will a PDO be approved without an approved joint activities agreement being in place.
The plan shall refer to the joint activities agreement and shall describe the principal elements of the
agreement. If a joint activities agreement has not been drawn up, the reasons for this should be explained
and a plan for drawing up a joint activities agreement should be described.
2.7
Description of facilities and concept evaluation
See pr section 21 second paragraph literas a and c and section 29 second paragraph literas a and c. See
also pr section 21 last paragraph
9
The various types of facilities that have been under consideration, should be described. This description
should state to which degree of detailed planning the various alternatives have been prepared, as well as
their advantages and disadvantages - also in relation to the environment and soil. Comparable cost
estimates for alternatives should be presented. Life span evaluations should be enclosed, including costs
relating to disposal.
Particular emphasis should be given to what criteria have been decisive with regard to selecting or
rejecting development concepts, and to the evaluation process leading to the selected concept. In this
connection it should in particular be described how technical risk has been evaluated and taken into
account in the ranking order.
In particular it must be stated whether the facility in question is planned to be taken to shore for routine
inspection and maintenance or whether the facility will remain on the offshore field throughout the field’s
life span.
Evaluations that have been made in order to ensure that the concept selected satisfies own and national
environmental goals, should be included.
General drawings should be presented which illustrate the selected concepts and provide a basis for
evaluating the matters me ntioned in these guidelines.
2.8
Costs
See pr section 21 first paragraph and second paragraph litera f and section 29 first paragraph and
second paragraph litera f
Investment costs should be based on “Standard Cost Coding System” 3). Specific profiles for CO 2 fees
should be stated.
Both the reservoir related and the technical basis for cost determination must be prepared thoroughly,
including calculations connected with operational aspects prior to submission of PDO or PIO to the
authorities.
It should be clearly described how the licensee treats uncertainty in cost estimates. Cost estimates shall
be given as expected value. In addition, 10/90 and 90/10 confidence level estimates shall be presented. In
those cases where cost estimates partly or in full are based on a foreign currency, the currency exchange
rates to NOK which have been used, and the pe rcentage of costs that accrue in foreign currency, should be
specified.
The possibilities of future commercial opportunities which may provide a basis for changes in the
scope of investment, should be dealt with.
3) System for allocation of costs prepared jointly by the Norwegian Petroleum Directorate and the
companies Statoil, Saga and Norsk Hydro. The book SCCS “Standard Cost Coding System” may be
obtained by contacting the Norwegian Petroleum Directorate.
2.9
Organisation and implementation
See pr section 21 second paragraph litera d, section 29 second paragraph litera d. See also pa section
10-6 and pr sections 56, 57 and 58
As a general rule, information on the planning, organising and implementation of the development shall be
provided.
2.9.1
Time and activity schedules
A time schedule for the development split into activities will normally be required to be submitted. A
description of the time schedule should be included, showing which activities are time critical, and
whether it is possible to reduce the implementation time.
10
2.9.2
Organisation
The licensee’s management system and philosophy for the implementation of the activities (including
contract philosophy) shall be dealt with.
2.10
Relationship to the fishing industry
Aspects that may be of importance to fisheries as well as any measures planned to be implemented in the
interest of this industry, should be dealt with.
Evaluations carried out in the impact assessment should be used in this connection.
2.11
Operaton and maintenance
Seesection 29 second paragraph litera e
An overall description of operation and maintenance of the facility should be given. It will be natural to
deal with this in relation to the items on regularity mentioned under chapters 3 and 4 of the guidelines.
2.12
Disposal of facilities
See pr section 21 second paragraph litera h and
section 29 second paragraph litera h
The licensee shall describe alternatives for disposal of facilities when the petroleum activities have ceased.
A discussion of different disposal solutions at this stage may be of importance to the choice of materials
and technical solutions. The possibilities for further use after production from the deposit(s) has ceased
should also be included in the description.
2.13
Onshore facilities
See pa sections 4 -2 and 4-3, cf. pa sections 1-4 and 1-6 and pba chapter VII-a
Facilities for production of subsea petroleum deposits and facilities for transportation of petroleum subject
to Norwegian jurisdiction, are comprised by the petroleum Act irrespective of where the activities take
place. Onshore facilities comprised by the petroleum Act, shall have an approved PDO or PIO.
Facilities for utilisation of petroleum onshore are in principle not comprised by the petroleum Act.
Utilisation is defined in the petroleum Act as cooling in order to liquefy gas, refining and petrochemical
activity, production and transmission of electric power and other use of produced petroleum, placing,
operation and use of a facility for the purpose of utilisation.
It is important that the Ministry at an early stage of the planning phase is informed of onshore facilities
which there may be doubt about as to whether they will be comprised by the petroleum Act or not. The
application of the petroleum Act to onshore facilities has in certain cases given rise to difficult
delimitation questions. This applies in particular to facilities where parts of the facilities are clearly
comprised by the petroleum Act, and where certain elements of the installation in isolation may be
regarded as utilisation, which in principle is not comprised by the petroleum Act. The Government has
legal basis to issue supplementary regulations on delimitation in respect of the scope of application of the
petroleum Act. The Ministry must be expected to use this legal basis in the abovementioned cases. Each
individual case will be considered specifically.
3
IN PARTICULAR ABOUT THE CONTENTS OF THE DEVELOPMENT PART OF A PDO
3.1
11
Description of the production licence
The history and present status of the production licence should be briefly described, including present and
previous licensees and the State Direct Financial Interest (SDFI).
3.2
Production strategy
See pa section 4-1, cf. pr section 21 second paragraph litera a. See also proposition to the Odelsting
(ot.prp.) no. 43 (1995-96) p. 41
The production strategy selected for the field shall be described. This includes all short term and long term
plans and measures which affect the rate of production and the total recoverable volumes of petroleum.
The need for and, if applicable, plans relating to further delimitation of the field should be described.
3.3
Reservoir engineering aspects
See pr section 21 second paragraph litera b and section 27
As a rule there shall be a description of geological and reservoir engineering aspects of the petroleum
deposit or of the group or groups of petroleum deposits planned to be developed, together with an
assumed production schedule. The licensee is expected to carry out at thorough examination of the deposit
prior to making a decision for development, and it is consequently expected that it is possible at this time
to submit extensive interpretations and evaluations, both as regards the volumes of pe troleum in place and
as regards alternative methods of production. Assumptions and uncertainties in the interpretation should
be discussed. Furthermore, assessments concerning expected recovery factor and the assumed production
schedule shall be submitted.
3.3.1
Geological and geophysical evaluation
Seismology
Descriptions of seismic surveys should include data basis, interpretation, modelling studies and methods
for depth conversion.
The following illustrations should be enclosed:
- shotpoint map,
- time map,
- depth map,
- velocity map,
- interpretations of seismic sections through the wells.
Geology
Geological surveys should comprise regional geology with tectonic history and sequence stratigraphic
framework, litho-stratigraphy and bio-stratigraphy. There should be a detailed description and mapping of
the deposit, including faults and fracturing which may affect the extent of the reservoir and its production
properties. Model for regional pressure support, if any, should be described.
In order to get an overview of the reservoir properties, it is important to have a description of the
sediments including facies, petrography and diagenesis. Flow barriers, if any, and layers of high
permeability should be described specifically. Thickness maps and cross sectional correlations through the
field should be enclosed.
Evaluation of potential subsidence and sand production should be included.
Petrophysics
The petrophysical documentation should include the following:
- formation parameters (lithology, porosity, permeability, water saturation, cut-off criteria,
12
-
interpretation method),
comparison of laboratory analyses (core measurements and water analyses) with log derived data,
fluid contacts, pressure data,
reservoir zonation,
formation temperature,
method for correcting measured depth to true vertical depth,
porosity maps, net to gross maps, water saturation maps and permeability maps of each reservoir
zone.
Resources in place
The following volume estimates should be documented:
- reservoir rock volume,
- in place hydrocarbons at reservoir conditions,
- in place hydrocarbons at surface conditions.
The volumes should be subdivided according to hydrocarbon types, and also according to the deposits and
reservoir units, which are included in the plan. The method of calculation of the resource estimate should
be stated, and the uncertainties of the calculations should be described and quantified.
3.3.2
Reservoir technology
Data basis
A compilation of relevant data for reservoir studies from all exploration wells and, if applicable, test
development wells, in addition to an assessment of the various reservoir data, should be included.
The following data should be described:
- fluid properties,
- data from production tests,
- data from formation tests/test production.
Reservoir drive-mechanisms and reservoir simulation
Evaluation of various drive-mechanisms and the decision basis for the choice of mechanism, supported by
necessary data basis (core analyses, miscibility studies, simulations etc.), should be stated.
As a rule, drive mechanisms and expected production and injection rates should be documented by
reservoir simulation. Result from sensitivity analyses should be included.
Important input data used in reservoir simulation should be stated. It shall be possible to transfer data
files with input data for simulation to the NPD if the NPD deems it expedient. Uncertainties in connection
with input data and how they affect the calculation of production from the reservoir should be assessed.
Recovery factor and production schedule (production profiles)
The description of estimated recovery and recovery factor should include the following:
- technically recoverable resources with different recovery methods,
- recoverable reserves (commercially recoverable volumes on the assumptions that the plan is based
on).
Anticipated production profiles for oil, gas and condensate/NGL in respect of the entire field and for
separate zones, if applicable different production facilities, should be stated.
In addition to anticipated profiles at least one high and one low estimate should be shown together with
a probability distribution for these.
It should also be shown how the uncertainty both in in-place resources, recovery factor and start-up
time has been taken into account in the preparation of the profiles.
13
Profile of expected water production and profiles, if any, for injection of gas and/or water, split in the
same way as the production profiles, should be included.
Methods for improved recovery
An evaluation of methods for improved recovery in relation to the basic assumptions should be discussed.
A plan for studies of such methods, if any, should also be included.
3.3.3
Production and reservoir monitoring
Rate sensitivity
Planned plateau rate for the field and the maximum rate from individual wells, where any rate sensitivity
of the displacement in the reservoir, coning etc. is taken into account, should be stated.
Production strategy
Information on the considerations leading to the selected well types and the selected number of production
and injection wells should be included. The need for additional well slots and the possible need for
observation wells should be included. The number of wells, the drilling plan and the planned well
positions and perforation intervals forming the basis for the expected production profile, should be stated.
Strategy for choice of production intervals, criteria for recompletion, if any, as well as a programme for
reservoir monitoring shall be stated.
If pre-drilling of development wells is required, a plan for collection of information from these wells,
and for how such information is to be utilised further during the development, should be included.
Possible production strategies should be indicated for zones or parts of the deposit not intended for
production according to the plan submitted, but which may be commercial under different assumptions,
e.g. with regard to volume of resources or oil price.
The effects of capacities for treatment of produced water, gas etc. and of capacities for injection of
water, gas or chemicals, on production schedule and on total production, should be considered.
The main points of any agreements on sales and deliveries of gas should be included, together with an
evaluation of their effect on production from the reservoir.
Fluid chemistry
Information on the composition of the reservoir fluid should be included. The following properties should
be described: corrosivity, scale, wax and asphalt deposition, hydrate formation and emulsion tendencies.
3.4
Technical description of facilities etc.
See pr section 21 second paragraph literas c and e, and section 26
An account of technical solutions applicable to the development, shall be given. Choice of technology in
order to prevent and minimise environmentally harmful discharges and emissions to air and water, shall be
included.
The PDO shall contain a description of the selected type of facility, and the flexibility of the facility
with regard to changes in reserve estimates and production schedule should be discussed. An evaluation of
possible development solutions for additional resources in and in the vicinity of the field should be
included. Technical and cost related effects of including such resources in the pla n or alternatively by
future revision of the plan, should be discussed.
3.4.1
Load-bearing structures, topside arrangement and subsea facilities
The type and life span of load-bearing structures, topside arrangement and subsea facilities shall be
described. Where there is a danger of subsidence in the installation area, there should be a description of
14
what effects this may have on the facilities and what measures will be initiated in order to secure the
facilities.
General drawings should show load-bearing structures and topside arrangement. The topside
arrangement should show the main equipment and the location of the various areas in relation to each
other. The flexibility of the development concept as regards area, weight capacity, marine riser and tie -in
possibilities with view to possible future alterations, should be emphasized.
With regard to subsea developments, general drawings should show the location and the design of the
planned facilities in relation to each other. Flexibility for further connections should be described.
Measures planned to be implemented in order to observe the requirements relating to the interests of the
fishing industry, i.e. installation of protective structure and other cover of pipes and equipment, should
also be described.
Planned maritime operations as well as manned subsea operations in connection with towing out to the
field, installation, operation and maintenance should be described.
3.4.2
Overall plan for drilling and well activities
The PDO shall comprise an overall plan for drilling and well activities. The overall plan should contain
the following:
- purpose and time schedule for the planned drilling and well activities,
- references to relevant controlling documents in respect of the individual activities,
- overview of deviations from statutory requirements and internal procedures/requirements,
- description of drilling and well activities planned to be implemented, with associated use of downhole
equipment, surface equipment and blowout preventers,
- sketch of well with clear indication of barriers in relation to drilling and well activities and technical
solutions in relation to completion and permanent plugging of the well,
- a summary of possible technical and operational problems which may occur during the activities and
identified risk, as well as planned precautionary measures in this connection,
- geological prognoses/information of significance to the activities,
- account of planned use of oil-based drilling fluid, if any,
- plan for disposal of cuttings.
The overall plan for drilling and well activities shall be submitted as a separate document enclosure with
the PDO.
3.4.3
Process and auxiliary facilities
A flow chart for the process indicating capacities and describing the arrangement of principal areas should
be included.
The following should also be described:
-
basic principles and criteria for choice of arrangement and main components,
flexibility in relation to expected changes in operational conditions, and future use.
Possibilities for future process changes with a view to unforeseen reservoir behaviour, as well as
possibilities for receiving a well stream from satellite fields, should be described.
3.4.4
Metering systems
For the fiscal metering systems the plan should contain the following information:
15
-
measuring principle,
quantification of expected measuring uncertainty,
cost/benefit evaluation of the selected solution.
This will replace the requirement relating to licence for design of the metering system and licence for
delivery from the place of manufacture in regulations relating to fiscal measurement of oil and gas, and
regulations relating to measurement of fuel and flare gas for calculation of CO2 tax.
3.4.5
Regularity
The plan should indicate the expected regularity for the entire facility and for central main components.
Sensitivity with regard to possible changes of a technical or commercial nature should be dealt with.
3.4.6
Transportation systems
See pa section 4-2 second paragraph, cf. pr section 21 second paragraph litera i
When the development includes facilities for transportation or utilisation of petroleum the PDO shall
contain information also on this aspect. The plan should in this connection contain an evaluation of the
relevant landing methods and locations. Even if a PIO is to be submitted, facilities for transportation or
utilisation shall be described also in the PDO.
The description of the transportation system should give an account of the criteria used in the choice of
technical solutions. This may be
- volume and composition of the hydrocarbons to be transported,
- corrosivity evaluation over the planned life span of the system,
- capacity increase possibilities,
- connection points,
- regularity,
- overtrawl properties.
General drawings showing the total transportation system, including any connection points, should
accompany the description.
The sensitivity of the transportation system with regard to possible changes of a technical or
commercial nature, should be dealt with.
Priority rules for the transport of oil/gas by various users should be described.
If, at the same time as the PDO is submitted, a PIO is also submitted which describes the transportation
solution for the development, details on this may be included in the PIO.
3.5
Economic analyses
See pr section 21 second paragraph litera f
A description of all relevant economic aspects related to the development and an evaluation of
uncertainties, shall be given.
Profitability calculations before and after tax shall be carried out, and the basic assumptions for the
calculations shall be specified. To the extent possible, all variables should be according to statistical
expectation.
3.5.1
Assumptions
All assumptions on which the economic calculations in the PDO are based, are to be documented in order
to make it possible to reproduce the calculations. This entails, inter alia, that the different variables
contained in the calculation to the extent necessary are presented in a time related distribution. Central
16
variables are:
- prices and price trends of products sold,
- currency exchange rates,
- inflation,
- requirements in relation to return,
- oil, gas, condensate and NGL sales (volumes),
- gas purchases,
- income from tariffs,
- investments,
- all operating costs, inclu ding tariffs for transportation and processing of petroleum as well as other
services, CO2 tax etc.,
- all essential conditions for tax calculations, including assumptions on financing,
- final disposal,
- any credits in relation to income, expenses, taxes etc. included in the calculations.
In the event that different licensees should have significantly different basis for decisions, e.g. different
price trend expectations, the plan may contain comments on this.
All amounts are to be given in fixed NOK rates, or, if applicable, in another currency where this is
relevant.
Simultaneously with submission of the PDO, an update of the petroleum related data submitted in
connection with reporting to the Revised National Budget, is requested.
3.5.2
Results
Profitability calculations should be presented before and after tax
Profitability should be expressed in terms of net present value on the basis of the authorities’
requirements to return at any time in force.4) The CO 2 tax sha ll also be included in pre-tax calculations.
Net present value before tax of income (if applicable per product/service), investments and operating
costs should be shown separately. In the operating costs, tariffs and CO2 tax should be separated from
other operating costs.
In addition to net present value, break-even price and internal rate of return shall be calculated before
and after tax. Break-even price is the oil price (together with associated gas, NGL and condensate price)
that makes the net present value of the development, based on the selected requirements in relation to
return, equal to zero.
4) It is recommended to contact the Ministry of Petroleum and Energy in order to clarify what
requirements are to be used in relation to return
3.5.3
Economic risk evaluations
It shall be clearly shown how the licensee has handled uncertainties in the project, e.g. with regard to
dimensioning and flexibility.
The total economic risk and the most important uncertainty factors should be described and quantified,
as seen both from the licensee’s point of view and from the point of view of what is economically
beneficial to society. Methods and basic assumptions used in dealing with uncertainties, must be
described.
3.5.4
Optimisation of development and operation
A presentation of the project economics should include analyses demonstrating that optimal solutions have
17
been chosen with regard to
- development concepts,
- production strategy,
- solutions for transportation of oil and gas,
- flexibility, i.e. possibilities for making adjustments to altered assumptions.
Altered assumptions include changes in petroleum prices, changes in resource estimates and additional
resources in the vicinity.
3.5.5
Marketing of gas and commercial aspects
See pr section 21 second paragraph litera j
The planned solution for marketing of gas shall appear from the plan. Furthermore, an account of the
status for the gas marketing solution recommended, how the production of the field is intended to be
incorporated in gas delivery agreements and the economic framework for marketing of gas from the field
should be included.
Furthermore, information on agreements relating to sale of gas and to transport of petroleum which
have been entered into or which are planned to be entered into, as well as hire of facilities, if any, should
be given. The importance of the agreements to profitability and production should be dealt with.
3.5.6
Gas for injection purposes
If imported gas is to be used for gas injection in order to optimise production, the purchase of gas should
be described and agreements on gas deliveries which have been entered into, should be documented.
3.6
Substantial contractual obligations
See
Substantial contractual obligations must not be undertaken, nor construction work be started, until the
PDO has been approved, unless by consent from the Ministry. This means that the licensee must submit an
application to the Ministry stating the reasons for why it is necessary to undertake substantial contractual
obligations or commence construction work before the PDO has been approved.
When the administrative procedure of the authorities is to be limited to eight weeks after submission,
the Ministry will adopt a restrictive practice with regard to granting consent to undertake contractual
obligations or commence construction work before the plan has been approved by the authorities. The
need for such consents is expected to be less when the time allowed for the administrative procedure of
the authorities is reduced.
In cases where the administrative procedure of the authorities is expected to take longer, e.g. if the case
is to appear before the Storting (Parliament), the Ministry will consider the disadvantages with regard to
economy and progress which the project in the opinion of the licensees will be subjected to as a result of
the administrative procedure of the authorities. In order to achieve consent to undertake contractual
obligations or commence construction work, it must be demonstrated to the Ministry that the
disadvantages connected with a delay are substantial, and it must be established that the actions will not be
able to incur an adverse effect on the quality assurance of the project costs.
Undertaking of contractual obligations and commencement of construction work will take place at the
applicant’s own risk even if the Ministry has granted consent to entry into the agreement. The licensees
must allow for the possibility that the PDO submitted may not be approved or may be altered during the
approval process.
4
IN PARTICULAR ABOUT THE CONTENTS OF THE INSTALLATION PART OF A PIO
18
See pa section 4-3 and pr sections 28 and 29.
4.1
Description of the project
The history and present status of the project should be briefly described, including participants and
distribution of shares.
4.2
Possibilities for use of facilities by others
See pr section 29 second paragraph litera j. See also pa section 4-8
The plan should account for the possibilities that the facilities may have for transportation and processing
of production from other fields.
It should be documented that technical solutions, tariff structure, rules regarding ownership and
agreement framework in general (including voting rules) are designed to ensure the best possible
utilisation of infrastructure from the point of view of what is economically most beneficial to society. The
plan should give an account of technical and legal matters of importance to the use by third parties of the
facilities descirbed in the PIO, and, if applicable, of the owners’ individual right to make use of spare
capacity.
The plan should give details on ownership and resource estimates for central fields in the area.
Reference is also made to chapter 2.6 in the common part relating to co-ordination of petroleum
activities.
4.3
Technical description of facilities etc.
See pr section 29 second paragraph literas c and e and section 26
A general description shall be given of facilities and equipment planned to be installed for transport and
utilisation of petroleum, and the choice of technology to prevent and minimise environmentally harmful
emissions and discharges to air and water. A description of the facilities and their functions, the
underlying principles of the development concept evaluations and the reasons for the choice of solution is
expected.
4.3.1
Loadbearing structures, subsea installations and system design
Loadbearing structures and subsea installations should be described with regard to type and foundation.
General drawings should show the location of various equipment components on the facilities, and in
particular the location of all critical equipment.
Importance should be attached to giving an assessment of the flexibility of the development concept as
regards area, strength, design etc. The possibilities for future modifications, if rele vant, should be
described.
4.3.2
Assumptions
The assumptions on which the engineering is based should be accounted for, including
- life span,
- choice of materials,
- corrosion protection,
- operation and maintenance philosophy,
- regularity.
4.3.3
Choice of pipeline route and location
19
See
Aspects in connection with pipeline routes should be accounted for, with reference to surveys of pipeline
routes which have been carried out or planned. Information on other planned activities in the pipeline
route area must be given.
Location of facility and pipeline route should be indicated on a map with co-ordinates on a suitable
scale. If applicable, alternative routes should also be indicated.
Relevant landing locations for the transport system shall be discussed.
Pipelines on the seabed inside the territorial border require licence according to the harbours and
fairways Act.
4.3.4
Volumes and composition of the petroleum transported or utilised
The plan should, to the extent possible, describe which fields, mapped discoveries and undrilled prospects
the facilities are meant to service. Resource volumes with uncertainty evaluation and production profiles
should be stated.
Anticipated need for transport and peak delivery period should be described.
Information on the composition of hydrocarbons should be included where such data are known.
4.3.5
Capacities
The plan should account for the volumes and the composition of hydrocarbons which the facility is
designed for. This applies to the input flow into the system as well as to the end products. The plan should
state the expected composition of the end products from the fractionating plant.
The possibilities for increased capacity, altered product composition and limitations, if any, should be
indicated.
4.3.6
Metering systems
In respect of the fiscal metering systems, the plan should contain the following information:
- principle of measurement,
- quantification of expected measuring uncertainty,
- cost/benefit evaluation of the selected solution.
This will replace the requirement relating to licence for design of the metering system and licence for
delivery from the place of manufacture in regulations relating to fiscal measurement of oil and gas and
regulations relating to measurement of fuel and flare gas for calculation of CO2 tax.
4.3.7
Regularity
The plan should indicate the regularity expected for the entire system and for central main components.
The sensitivity of the transportation system with regard to possible changes of a technical or
commercial nature should be dealt with. Priority rules for the transport of oil/gas by various users should
be described.
4.4
Economic analyses
See pr section 29 second paragraph litera f
A description shall be given of all relevant economic aspects in relation to the facility and an evaluation of
uncertainties.
Profitability calculations before and after tax are to be carried out, and the basic assumptions for these
calculations shall be specified. To the extent possible, all variables should be according to statistical
20
expectation.
4.4.1
Assumptions
All assumptions on which the economic calculations in the PDO are based, are to be documented in order
to make it possible to reproduce the calculations. This entails, inter alia, that the different variables
contained in the calculation, to the extent necessary are presented in a time related distribution. Central
variables are
- prices and price trends of products sold,
- currency exchange rates,
- inflation,
- requirements in relation to return,
- product sales (volumes),
- gas purchases,
- income from tariffs,
- flow profiles,
- investments,
- all operating costs, including tariffs for processing and transportation of petroleum as well as other
services, CO2 tax etc.,
- all essential conditions for tax calculations, including assumptions on financing,
- final disposal,
- any credits in relation to income, expenses, taxes etc. included in the calculations.
All amounts are to be given in fixed NOK rates, or, if applicable, in another currency where this is
relevant.
In the event that various licensees should have significantly different basis for decisions, e.g. different
price expectations, the plan may contain comments on this.
Simultaneously with submission of the PIO an update of the petroleum related data submitted in
connection with reporting to the Revised National Budget, is requested.
4.4.2
Results
Profitability calculations shall be presented before and after tax
Profitability is to be expressed in terms of net present value on the basis of the authorities’ requirements
to return at any time in force.5) The CO2 tax shall also be included in pre-tax calculations.
Net present value before tax of income (if applicable per product/service), investments and operating
costs should be shown separately. In the operating costs, tariffs and CO2 tax should be separated from
other operating costs.
In addition to net present value, break-even tariff and internal rate of return shall be calculated, before
and after tax. Break-even tariff is the tariff that makes the net present value of the development, based on
the selected requirements in relation to return, equal to zero.
5) It is recommended to contact the Ministry of Petroleum and Energy in order to clarify what
requirements are to be used in relation to return.
4.4.3
Economic risk evaluations
It should be clearly shown how uncertainties in the project have been handled, e.g. with regard to
dimensioning and flexibility.
The total economic risk and the most important uncertainty factors should be described and quantified,
as seen from the point of view of both the owner and the user of the facilities, and from the point of view
21
of what is economically beneficial to society. Methods and basic assumptions used in dealing with
uncertainties, must be described.
4.4.4
Optimisation of installation and operation
A presentation of the project economics should include analyses demonstrating that optimal solutions have
been chosen with regard to
- development concept,
- flexibility, i.e. possibilities for making adjustments to altered prices and capacity requirements.
4.4.5
Tariffs
See pa section 4-8 second paragraph and pr section section 28 third paragraph litera a
The plan shall describe the agreement framework and the tariff calculation principles for the volumes
intended to be transported and/or processed, as well as tariff calculation principles in respect of possible
volumes in addition to this.
4.5
Substantial contractual obligations
According to the petroleum Act, there are essentially no limitations in relation to entering into substantial
contractual obligations or commence construction work in connection with installation and operation of
facilities for transport and utilisation of petroleum. It is, however, important to note that the undertaking of
contractual obligations or commencement of construction work will take place at the applicant’s own risk
as long as licence for installation and operation has not been granted by the Ministry. It is also important
to note that it is a requirement that a licence has been granted before installation of pipelines or facilities
may be commenced.
5
EXEMPTION FROM THE REQUIREMENT RELATING TO PDO/PIO
See pa section 4-2 sixth paragraph, cf. section 4-3 second paragraph
In certain cases there has been provided an opening for granting exemption from approval from the
authorities of a PDO and PIO. In order to be granted exemption, the licensees must submit an application
to the Ministry. Licensees are recommended to contact the Ministry as early as possible to determine
whether it is relevant to apply for exemption. In cases where doubt may be raised as to whether there is
basis for an application for exemption, it will in most cases be more efficient to prepare a PDO or a PIO.
It should be noted that in order to be granted complete exemption from the requirement relating to
submission of a PDO and PIO, there are also certain criteria in relation to requirement for an impact
assessment which must be complied with, see chapter 6.
Exemption from the requirement relating to PDO will primarily be relevant in case of development of
small deposits which may be reached from existing facilities on fields with an approved plan for
development and operation. Elements of particular importance in considering an application for exemption
from the authorities’ approval, are
?
the deposit is near, e.g. above or below a deposit which already has an approved plan for development
and operation,
?
the entire deposit can be drilled and produced from facilities which are comprised by an approved
plan for development and operation,
22
?
the deposit is located within an area subject to requirement for a licence. Where there is basis for coordination between different licensees, the necessary agreement must be in place,
?
modification of facilities must not result in increased risk to people, the environment or to property
and financial interests,
?
a satisfactory solution for marketing of gas is in place.
The list is not complete.
It is pointed out that the Ministry will normally require a PDO or a PIO in respect of facilities where
third party use is planned or may be an option.
The application must substantiate that there is basis for exemption. It is important that the authorities at
an early stage acquire knowledge about the technical and economic evaluations of the applicants in order
to secure the best possible basis for a decision. Furthermore, in the case of modifications to facilities,
various consents must be obtained (inter alia according to section 15 of the safety regulatons). A deposit
which is developed in this way, will normally be comprised as a part of the existing field without
receiving its own name.
PART II
6
GUIDELINES RELATING TO THE IMPACT ASSESSMENT PART OF PDO/PIO
6.1
Introduction
The Ministry of Petroleum and Energy is responsible for submitting impact assessment (IA) when new
areas are opened. With regard to development, operation and disposal of facilities, it is the licensees, in
practice the operator, who is responsible for preparing and submitting an impact assessment. These
guidelines are meant to contribute to clarifying the purpose of the assessment, procedures and
requirements to contents and in addition discuss the role of bodies involved in the assessment process and
the administrative procedure.
A central feature of the impact assessment process over the last few years has been an increasing
interest in the regional effects of a development. This increased regional emphasis is, together with a wish
to improve the efficiency of the process shared by the companies as well as the parties entitled to submit
comments in the consultation process, the explanation why regional impact assessments have been
produced. In addit ion there has been an increased emphasis on impact assessments within the EU, cf.
Council Directive 97/11/EC amending Directive 85/337/EEC on the assessment of the effects of certain
public and private projects on the environment, cf. chapter 6.3.
These guidelines therefore also describe contents and process relating to regional impact assessments
and the interrelationship between field specific (FIA) and regional (RIA) impact assessments. With regard
to RIA, experience to now has shown that in most cases it is sensible to prepare topical 6) regional
assessments, since the choice of a geographical area for assessment of the consequences of various
discharges and emissions etc. will vary a great deal depending on the topic in question.
The guidelines are organised as follows:
? purpose,
? legal basis,
? the assessment process and administrative procedure,
? contents and format of assessment programme and impact assessment.
It is emphasised that the directions given here are only guidelines7). The specific contents must be
23
adapted to the development situation in question, and it will be seen as a natural procedure for the
developer to do this in consultation with the Ministry of Petroleum and Energy.
6) Topics may for example be area occupied, discharge of produced water and discharge of nitrogen
oxides.
7) Cf. chapter 1 Introduction
6.2
Purpose
The purpose of the provisions relating to impact assessments, is to clarify the effects of a development or a
facility on the environme nt, including monuments of cultural heritage and the cultural environment,
natural resources and on society at large. Impact assessments are to ensure that these effects are taken into
account during the planning of a development or a facility, and when decision is to be made as to whether
and on what conditions approval of a PDO or licence for installation and operation is to be granted. The
provisions are to secure a good decision basis for the authorities.
The impact assessment process is an open process designed to ensure that parties who have an opinion
relating to the development and/or the facility in question, shall have a right and an opportunity to express
their opinion. This is important for several reasons. The process ensures, inter alia, that the authorities are
made aware of possible other consequences and alternatives than those presented by the entrepreneur. This
applies both to the evaluation of consequences caused by the activities and to what remedial measures will
be necessary to carry out.
The consultation process of circulating the impact assessments for comments is consequently an
important part of the PDO/PIO process, because it contributes to the promotion of the optimal solutions
from the point of view of what is most beneficial to society.
The parties entitled to comment must be given the opportunity to assess the operator’s description of
the effects which the development and/or the facility may have. The FIA shall consequently, together with
possible relevant regional assessments,
? describe the plans relating to the field development and/or the facility and the effects they may have
on the environment, on natural resources and on society,
? discuss the principal positive and negative consequences envisaged,
? discuss remedial measures and suggest any necessary follow -up studies and monitoring programmes.
If the licensees in an area wish to prepare an RIA, or if they are required to do so pursuant to section 42 third paragraph of the petroleum Act, the purpose of this is to obtain a better overview of regional
effects and to enable a simplification of the process connected with impact assessments relating to
individual developments. Together, the RIA and FIA must satisfy the impact assessment requirement of
the applicable legislation.
6.3
Legal basis
See pa sections 4-2 and 4-3, cf. pr sections 20, 22, 22a, 22b, 22c and 29. See also the planning and
building Act of 14 June 1985 no. 77 chapter VII a concerning impact assessments
Act 29 November 1996 no. 72 relating to petroleum activities contains provisions relating to impact
assessments as a part of the decision basis in connection with the opening of new areas for petroleum
activities, in connection with development and operation of petroleum deposits and when the petroleum
activities have ceased. The Ministry of Petroleum and Energy is responsible for assessing the
consequences in connection with the opening of new areas. In the case of development, and when the
petroleum activities have ceased, it is the licensees, in practice the operator, who is responsible to carry
out the impact assessment. Regulations to Act relating to petroleum activities, laid down by Royal Decree
27 June 1997, further regulate the contents of an impact assessment. In the case of onshore developments,
the planning and building Act of 14 June 1985 no. 77 will also be applicable. Regulations relating to
24
impact assessments in respect of measures covered by the scope of application of the planning and
building Act are to be found in chapter VII-a of the Act and in regulations relating to impact assessments
of 21 May 1999 no. 502.
The sections of the petroleum regulations relating to impact assessments were amended by Royal
Decree of 4 June 1999. The amendment regulations entered into force on the same date. The amendments
are implemented in order to approximate Norwegian legislation to the EU Council Directive 97/11/EC
amending Council Directive 85/337/EEC on the assessment of the effects of certain public and private
projects on the environment, and to implement the obligations according to the convention on impact
assessments relating to measures that may have transboundary environmental impact (the Espoo
convention) 8)
The impact assessment is an integral part of a PDO and a PIO and constitutes the basis for the decision
on approval of a PDO and the granting of a licence for installation and operation. The impact assessment
process must consequently be terminated, and the assessment requirement under the act and regulations
must be complied with, before a PDO can be approved or a licence to install and to operate facilities can
be granted.
8) Cf. proposition to the Storting (Parliament) no. 113 (1991-1992) on consent to ratification of a
convention of 25 February 1991 on impact assessments in relation to activities with potentially
transboundary environmental impact.
6.4
Process
6.4.1
When should the work to prepare an impact assessment commence?
6.4.1.1 Field specific impact assessments (FIA)
See pr section 22 et seq.
In many cases the natural time to commence the work of preparing an impact assessment will be when a
deposit through drilling, testing and, if applicable, appraisal wells, has been deemed to be commercially
interesting for development.
Representatives of the licensees should at this point in time contact the Ministry of Petroleum and
Energy to discuss the impact assessment for the deposit in question, so that the subsequent work can be
organised in the best possible way.
6.4.1.2 Regional impact assessments (RIA)
See pa section 4-2 third paragraph, cf. pr section 22a second and third paragraphs
A RIA will in particular be relevant where there are several developments planned within the same area.
Through an RIA, economies of scale can be achieved which may facilitate the work of preparing field
specific assessments. It will also provide a better total picture of the effects on the environment in the area.
The authorities may, when there are particular reasons to warrant it, require an RIA to be prepared.
Generally, the licensees themselves will choose to prepare an RIA. Any independent regional impact
assessments which the developer wishes to use in field developments, should be prepared enough for the
approval process in respect of the impact assessments to be completed before they are intended to be used
as documentation in connection with an FIA for the first time. This means that they ought to have been
through the consultation process for comments, and also that any need for improvements has been
complied with before the FIA programme is circulated for consultation (cf. 6.4.3.2). Nevertheless, the
completion of an RIA, or the lack of updating of certain elements thereof, will not impede the
administrative process in connection with an FIA. This, however, requires that all relevant aspects be
covered in the FIA.
25
It is important that the developer enters into dialogue with the Ministry of Petroleum and Energy about
these matters at an early stage.
6.4.2
Use of regional impact assessments in respect of new field developments
6.4.2.1 Existing regional impact assessments
It is the intention of the Ministry that regional impact assessments shall be used as documentation in
future developments. The Ministry will not, however, require regional impact assessments to be updated
every time they are used as documentation for a development. On the other hand, it would be natural to
consider updating when the assumptions on which the assessment is based have become materially
altered, e.g. if new large developments which have not been taken into account are carried out, or if for
other reasons it is deemed that the impact assessments are outdated. It will nevertheless make sense that
the impact assessments are updated in relation to other updating, which may be carried out as part of an
FIA.
For the Ministry, it is essential that the duty to carry out impact assessment in accordance with
applicable acts and regulations in connection with a development, be complied with. This may be done
either through a field specific impact assessment or a combination of an FIA and an RIA. It will be up to
the companies themselves to decide how this assessment duty can be most expediently complied with.
It must be made clear in the impact assessment programme for a development what type of information
may be intended, if any, to be covered by regional impact assessments or through an updating of relevant
regional impact assessments.
6.4.2.2 New regional impact assessments.
If regional impact assessments which are under preparation, are intended to be used in a new
development, this must also be reflected in the FIA programme. The Ministry would emphasise that the
developer must allow for the approval of the FIA being dependant on the completion of and the
consultation process in relation to the regional impact assessment.
6.4.3
Process for impact assessment programme and impact assessment
The work connected with an impact assessment may be divided into two phases, the assessment phase and
the decision phase. Figure 4 outlines the process.
6.4.3.1 Field specific impact assessments
Impact assessment programme
See pr section 22. See also section 29 fourth paragraph.
The operator starts the process by preparation of a proposed impact assessment programme. This
programme shall describe the development and its anticipated effects on the environment, including
monuments of cultural heritage and the cultural environment, possible transboundary environmental
impact, effects on natural resources, fisheries and on society at large. It shall be prepared based on
available knowledge and shall account for any need for new assessments and documentation. The purpose
of an impact assessment programme is to provide information and a signal of what is planned to be
developed, where and how, to the authorities and to other parties entitled to submit comments. The impact
assessment programme shall also provide opportunity for the authorities and the other parties entitled to
submit comments to influence what will be required to be included in the assessment. The impact
assessment programme determines what issues are to be discussed in the impact assessment and forms the
basis for the impact assessment carried out by the developer.
Consultation process for comments - impact assessment programme
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See pr section 22 second paragraph.
The Ministry of Petroleum and Energy shall circulate the impact assessment programme to concerned
authorities, professional and industrial organisations and interest groups, for their comments. This
consultation process is an important part of the process in connection with the impact assessment
programme. The parties entitled to submit comments shall be given the opportunity to assess the
operator’s description of the effects that the development may have, point out potential conflicts and
possible alternatives. The parties entitled to submit comments, should in this way contribute to
clarification of which issues that should be dealt with in the impact assessment.
The deadline for submitting comments shall be determined by the Ministry and will as a rule be twelve
weeks, but this period may be reduced. The length of this period will depend on size, complexity and
extent of possible consequences to the environment, to society and other industries, and to what extent
these effects have been assessed earlier.
When regional impact assessments are used as support for an FIA programme, they will also constitute
part of the consultation process of the FIA. If the parties entitled to submit comments consider it necessary
to have relevant regional assessments updated, this must be specified in the comments submitted in
relation to the FIA programme.
If regional impact assessments that are used are not enclosed with the FIA programme, it must be
clearly stated where the parties entitled to submit comments may get hold of the assessments in question.
Determination of the impact assessment programme
See pr section 22 second paragraph.
The Ministry of Petroleum and Energy determines the impact assessment programme based on the
licensees’ proposed impact assessment programme, comments received from the consultation process and
possible reply comments to these from the developer. In practice, the Ministry will often request a meeting
with the licensee in order to go through the comments received from this process and clarify how they will
be taken into account in the impact assessment. The Ministry may require the impact assessment
programme to be altered in line with comments received from the consultation process and also that other
issues shall be addressed. The Ministry shall, furthermore see to it that the impact assessment programme
is in compliance with the requirements laid down in the applicable legislation as to the contents of an
impact assessment programme.
The determination of an FIA programme takes place by a letter to the operator from the Ministry of
Petroleum and Energy. If an impact assessment programme is required to be produced, which must also
comply with the requirements of the PBA, the impact assessment programme shall be submitted to the
Ministry of the Environment 9) before the Ministry of Petroleum and Energy can approve the programme.
The Ministry of the Environment must submit comments no later than two weeks after having received the
necessary case information.
9) It is the Ministry of Petroleum and Energy who submits the impact assessment programme to the
Ministry of the Environment.
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Consultation process relating to the impact assessment
See pr section 22 a fourth paragraph
The impact assessment is prepared by the licensees, usually the operator, in accordance with the
applicable legislation. The Ministry of Petroleum and Energy will circulate the impact assessment
according to the list of parties entitled to submit comments, and will at the same time announce in the
Norwegian Gazette that this has been done. During this consultation process it is important to evaluate
whether the effects of the development have been adequately considered in relation to the impact
assessment programme that has been determined. The deadlines for reply are determined by the Ministry
of Petroleum and Energy and will as a general rule be twelve weeks, in exceptional cases shorter. As for
the programme, the deadline for reply will depend on the nature of the development. This means that the
entire process from submission of the programme until the impact assessment has been approved, may
take more than six months. It is important that the operator allows for this in his planning.
When the impact assessment duty has been complied with - possible requirements with regard to
additional assessment or supplementary information
See pr section 22 a fifth paragraph
Based on the impact assessment and the comments received to the assessment through the consultation
process, the Ministry of Petroleum and Energy will decide whether the impact assessment duty has been
complied with. When the operator’s impact assessment duty is considered by the Ministry to be complied
with, the Ministry will notify the licensee thereof in writing. The letter will also be sent to those who have
submitted comments and to the Ministry of the Environment.
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If, during the process of consultation, information emerges which indicates that there are significant
deficiencies in the implementation of the impact assessment programme, or if the parties entitled to submit
comments have pointed out new issues of significant importance in relation to the decision on approval,
the Ministry may require additional information or supplementary assessments before the impact
assessment duty is considered to be complied with. Additional assessments beyond the determined impact
assessment programme shall as a rule not be required.
Additional and supplementary assessments shall as a rule be circulated for consultation to the parties
that have submitted comments in connection with the impact assessment consultation process. The impact
assessment duty is not considered to be complied with until any required additional assessments or
supplementary information have been circula ted and processed. The deadline for comments will normally
be significantly shorter than that which applies to the consultation process in respect of the impact
assessment itself.
Approval of the development
See pa section 4-2, cf. pr section 20 fourth paragraph
The comments received from the consultation process in respect of the impact assessment, will constitute
part of the decision base for the authorities’ approval of a PDO or a PIO. The development is described in
a proposition to the Storting (Parliament) (when the matter has to appear before the Storting) or in a Royal
Decree (when the matter is decided by the Government). When the development has been approved by the
Storting (Parliament) and/or the Government, the reasons for the decision to approve or not approve the
PDO/PIO shall be made public. In practice this is normally done by sending a letter to the parties who
have submitted comments in the consultation process.
6.4.3.2 Regional impact assessments
Consultation process - impact assessment programme
The period allowed for submitting comments is determined by the Ministry and will, as for an FIA, as a
general rule be twelve weeks. In the case of programme for regional assessments, stipulating a shorter
period than twelve weeks will require very good reasons. This is due both to the fact that such
programmes will normally be geographically more extensive than programs for field specific
developments, and because a regional impact assessment will be used in connection with several
developments and consequently will have greater importance and a longer life than the field specific
impact assessments.
Determination of the impact assessment programme
The Ministry of Petroleum and Energy then determines the impact assessment programme based on the
licensees’ proposed impact assessment programme, comments received from the consultation process and
comments in reply to these from the licensees, if any. The RIA programme is determined by letter from
the Ministry of Petroleum and Energy to the licensees.
Consultation process - impact assessment
The impact assessment is prepared by the licensees in accordance with the impact assessment programme.
The Ministry of Petroleum and Energy will circulate the impact assessment according to the list of parties
entitled to submit comments, and will at the same time announce in the Norwegian Gazette that this has
been done. During this consultation process of the impact assessment it is important to evaluate whether
the effects of the development have been ade quately considered in relation to the impact assessment
programme that has been determined. The deadlines for reply are determined by the Ministry of Petroleum
and Energy and will as a general rule be twelve weeks. As for the programme, the deadline for reply will
depend on the extent of the impact assessment.
29
Administrative procedure in relation to the impact assessment
A regional impact assessment will not in the same way as a field specific one constitute a part of a
development. In the case of a regional impact assessment, there must consequently be prepared an
attachment where comments received from the consultation process and the licensees’ comments to these
are presented. The licensee is responsible for preparation of this attachment, but it must be carried out in
dialogue with the Ministry.
The regional impact assessment will together with this attachment be dealt with by the Ministry in a
separate letter where the Ministry decides whether the RIA with attachment may be used in connection
with future field specific impact assessments.
6.4.4.
Possibility of exemption from the requirement relating to impact assessment
See pa section 4-2 sixth paragraph, cf. pr section 22b and section 29 fourth paragraph, cf. section 22b
6.4.4.1 Exemption
In exceptional cases the licensee may apply for exemption from the requirement to submit an impact
assessment. The criteria to be able to apply for exemption from the requirement relating to impact
assessment in connection with a PDO, are that the development will not entail production of more than
4000 barrels of crude oil per day and/or more than 500 000 m3 of natural gas per day, and that the
development otherwise is not expected to have significant effects on other industries or the environment.
The criteria to be able to apply for exemption from the impact assessment requirement in connection with
a PIO, are that a facility for transport or utilisation of petroleum does not entail a pipeline with a greater
diameter than 800 mm and a length exceeding 40 km, and that there otherwise are not expected to be
significant effects on other industries or the environment.
The licensee may, in addition to this, in specific cases also apply for exemption from the impact
assessment duty, even if the development or the facility for transport or utilisation of petroleum exceeds
the threshold values stipulated in the regulatory legislation. The EFTA Surveillance Authority shall
however be notified of the reasons for the exemption before exemption can be granted. As a consequence
of the stringent criteria (which follow from the imple mentation of Council Directive 97/11/EC amending
Directive 85/337/EEC on the assessment of the effects of certain public and private projects on the
environment) the Ministry assumes that the provision relating to exemption will not be of any great
practic al importance.
6.4.4.2 The impact assessment duty has already been complied with
If the impact assessment duty has already been complied with, a new impact assessment will obviously
not be required. If the operator feels there is no need for an FIA, this must be substantiated to the Ministry.
In practice, this will mean a letter explaining why existing impact assessments, if applicable in
combination with a regional impact assessment, are adequate for the project in question. It is important
that the letter to the Ministry contains sufficient information for the Ministry to be able to evaluate the
abovesaid aspects. It is furthermore important for the operator to be in contact with the Ministry in order
to clarify relevant issues during preparation of the letter.
The Ministry of Petroleum and Energy decides on the basis of an application for exemption, or a letter
from the licensee seeking to establish that the development is already sufficiently assessed with regard to
impact, whether an FIA is to be required or not. The decision will be made after consideration of whether
the development satisfies the requirements to exemption from impact assessments, or whether it has been
established that the anticipated effects have already been satisfactorily dealt wit h.
If the Ministry deems that it is not necessary to carry out an impact assessment, the application will be
approved and the administrative process will be terminated at this point.
6.5
Contents of impact assessment programme and impact assessment
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6.5.1
Field specific assessments
6.5.1.1. Impact assessment programme
See pr section 22
When a specific impact assessment is required in connection with a development, an impact assessment
programme shall be prepared.
It is important that the impact assessment programme in a clear and straightforward way provides an
overview to the parties entitled to submit comments of the planned project, to what extent existing
regional background studies will be used and planned new assessments.
In some cases, one or more of the elements to be included in the impact assessment may already have
been covered in other assessments, or planned to be covered in assessments under preparation. It is
regarded as positive if, for example, regional impact assessments are used in new field developments. This
will reduce the workload both for the developer and for the parties entitled to submit comments.
Below is a suggested outline of structure and contents of the impact assessment programme. Chapters
3, 4 and 6 should describe to what extent possible existing or new independent regional impact
assessments are intended to be used as documentation. If existing regional assessments are intended to be
used it must be demonstrated that these assessments to a sufficient degree have allowed for the effects of
the development. The consultation process in relation to the programme will be the appropriate time for
the parties participating in the process to submit their comments with regard to a possible need to update
the relevant regional assessments.
0.
1.
2.
3.
4.
5.
6.
Summary
Introduction
Plans for development and operation
Environmental impact and remedial measures
Impact on fisheries as a result of activities occupying an area
Impact on society
Planned assessments
Chapter 1
This chapter would appropriately contain an account of the purpose of the impact assessment programme
and the requirements relating to impact assessment contained in the legislation. Process, administrative
procedure and time schedule should also be dealt with. The time schedule should be cleared in advance
with the Ministry of Petroleum and Energy.
Chapter 2
The impact assessment programme shall briefly describe the licensees, the history of the licence,
resources, production plans, alternative development solutions which have been under consideration,
health, working environment and safety, economy and ending the activities.
Chapter 3
There shall be a provisional description here of the planned contents of the FIA with regard to
environmental issues and impact on the environment. The effects of discharges and emissions and
consequences seen in relation to national goals and objectives, must be included. There shall be a
description of possible known monuments of cultural heritage in the area and whether such relics have
been discovered through the work which has been carried out. How the effects of regular and acute
discharges and emissio ns on animal life and vegetation in the sea and coastal areas, as well as on
monuments of cultural heritage and the cultural environment, are intended to be addressed, should be
included. The same applies to the probability of acute discharges and emissions.
31
In addition, there must be an overview of which remedial measures to limit discharges and emissions to
water and air are intended to be considered together with a preliminary evaluation of these measures.
Among remedial measures, the developer shall in accordance with decision by the Storting (Parliament)
22 February 1996 and recommendation (innst.s.no. 114 (1995-96), submit an evaluation both of the
consequences of electrifying the facility rather than using gas turbines, and of re-injecting CO2 from
turbines and, if applicable, from produced gas when the CO 2 content exceeds the sales specifications.
Furthermore, the adopted objective that in relation to new discoveries with independent development
concepts environmentally harmful discharges to the sea shall as a general rule not be permitted, shall
constitute basis for the remedial measures under consideration (cf. report to the Storting (Parliament) no.
58 (1996-97). Expected content of chemicals etc. in produced water shall, to the extent possible, be stated.
Whether or not existing impact assessments in relation to remedial measures may be used, or if there is
need for new assessments, should be discussed with the Ministry of Petroleum and Energy at an early
phase
Possible transboundary environmental impact shall also be dealt with, i.e. possible significant
environmental effects on other countries than Norway. Expected discharges from ships in connection with
the activities, should be estimated.
Chapter 4
This chapter should provide a provisional description of the area that will be occupied as a result of the
development, and what is to be described in the FIA in relation to this.
Chapter 5
This chapter shall give a provisional account of the planned contents of the FIA with regard to impact on
the society. This should comprise planned operation and base services, the provision of goods and services
and expected employment locally, regionally and nationally.
Chapter 6
This chapter should contain a brief survey of what issues are intended to be dealt with through new
assessments - and how these will be carried out and reported in the impact assessment. It may also be
appropriate to indicate a (preliminary) list of contents for the impact assessment.
The impact assessment programme shall serve as information to the authorities and as basis for the
consultation process. It should be made as short and concise as possible, and should normally not exceed
30 A4 pages of text (excluding attachments). It should be written in easily accessible Norwegian language.
Draft of an impact assessment programme and the summary shall be forwarded to the Ministry of
Petroleum and Energy in 40 copies. The Ministry will then circulate the programme to the list of parties
entitled to submit comments and will stipulate a deadline for reply. The deadline for reply is as a general
rule twelve weeks, but it may in exceptional cases be shorter.
6.5.1.2 Field specific impact assessment
The impact assessment may be presented prior to submission of the development part of PDO or the
installation part of PIO to the authorities, but must at the latest be presented concurrently with these. The
impact assessment shall be based on the issues defined in the impact assessment programme.
Relationship with regional impact assessments
For the authorities and other parties entitled to submit comments, the main point is that field specific
impact assessments together with other relevant documentation, such as approved regional assessments on
various issues, in combination cover the requirements applicable to impact assessments in connection with
new developments.
Because of the independent approval process which the regional impact assessment are subjected to
(see above) the general rule is that when these are used by the developer in field developments, and are
32
therefore included in the FIA process, then both the regional impact assessments and the attachments
thereto shall be available in the consultation process in connection with an FIA programme, cf. chapter
6.4.3.2.
Extent
The extent of an FIA will depend on, inter alia, to what extent other independent documentation, e.g.
regional impact assessments, are used to document consequences, size of the development, possible effect
on particularly environmentally sensitive areas etc. See also chapter 6.4.4. concerning exemption from
FIA.
Structure of contents
The proposed structure of contents for an FIA is very close to that suggested for the impact assessment
programme.
Preface
0. Summary
1. Introduction
2. Plans for development and operation
3. Summary of comments received from the consultation process
4. Environmental impact and remedial measures
5. Impact on fisheries as a result of activities occupying an area
6. Impact on society
7. Summary of remedial measures and follow-up investigations and monitoring
8. Technical devices comprised by a PIO, if any
9. Preparedness
The preface shall give a short description of why the impact assessment has been prepared and who is
behind it.
The summary and the conclusion of maximum five pages shall summarise the main points of the impact
assessment and present the most important conclusions and recommendations.
Chapter 1 should deal with the purpose of the impact assessment and briefly comment on the legislation
requirements in relation to the impact assessment. Process, administrative procedure and time schedule
should be dealt with. In addition there shall be a list of other permits and licences than approved PDO/
PIO required from the authorities in connection with the project.
Chapter 2 should briefly describe the licensees, the history of the production licence, resources,
production plans, development concept, including production regularity, health, working environment and
safety, economy and ending the activities.
Chapter 3 should provide a summary of comments received during the consultation process in relation to
the FIA programme together with an evaluation of these and, if applicable, reference to where in the
impact assessment the various matters are dealt with.
Chapter 4 shall give an account of the effects that the development may have on environmental matters,
including preventive and remedial measures. Any subsequent development stages, tie -ins with other fields
and shore facilities and, if relevant, co-ordination of petroleum activities shall be described. Furthermore,
account shall be given of
?
alternative development concepts which have been considered,
33
?
?
?
?
?
?
choice of development concept and production strategy,
what criteria have been used as basis for choice of development concept and production strategy,
discharges and emissions to sea, air and soil,
possible material assets and monuments of cultural heritage which may be affected as a result of he
development,
the consequences of the technical solutions chosen,
how environment criteria and impact on the environment have been taken into account in the
technical solutions that have been chosen.
Possible environmental consequences to animal life and vegetation in the sea and coastal areas shall also
be described, including regular and/or acute emissions and discharges from the activities. Significant
transboundary environmental impact, if any, shall also be dealt with, i.e. possible significant
environmental effects on other countries than Norway. If these matters are documented in existing or new
independent regional impact assessments, reference shall be given and it must also be established that
these impact assessments have sufficiently allowed for the volume of discharges and emissions expected
in connection with the activities. Anticipated chemical content etc. in produced water shall, to the extent
possible, be indicated.
In dealing with each individual type of discharge or emission, remedial measures must also be dealt
with. In case monuments of cultural heritage have been discovered, remedial measures shall be presented.
It is important that even measures which have been decided not to be implemented, are discussed. The
reasons why it has been decided not to recommend implementation, on the basis of environmental,
economic, technical or reservoir related considerations, must be stated. The degree of documentation in
relation to these elements can profitably be discussed with the Ministry of Petroleum and Energy at an
early stage of the process. In considering the remedial measures in question, the Ministry will base its
evaluation on the principle that environmental measures that are reasonable in a cost/-benefit analysis of
costs versus reduced volumes of emission/discharge, are to be implemented in order to meet the
environment requirements at any time applicable.
This chapter should also contain an estimate of expected discharges from ships in connection with the
activities.
Chapter 5 shall give a description of the area occupied and the associated effects on the fishing industry.
If documentation has been provided in attached regional impact assessments, reference shall be given.
Chapter 6 shall give an account of effects on business related aspects. This should comprise planned
operation and base services, the provision of goods and services and expected employment locally,
regionally and nationally.
Chapter 7 shall give a summary of remedial measures and follow-up examinations and environment
monitoring.
Chapter 8 shall give an evaluation of facilities for transport or utilisation which are comprised by the PIO.
See chapter 3.3.6.
Chapter 9 shall give an assessment of technical measures for preparedness.
In attachment to the impact assessment there should be lists of existing or new approved regional
background assessments, other assessments carried out and other relevant basis material. Attachment to
the assessment should also include a plan indicating how possible follow-up examinations and monitoring
programmes are to be carried out.
6.5.2
34
Regional impact assessments
When there is reason to assume that there will be new developments carried out in an area on the
continental shelf, the Ministry of Petroleum and Energy takes a positive view in relation to preparation of
regional impact assessments of the effects of various emissions/discharges, occupation of areas and to
society in general as a result of the present and anticipated future activities inside the relevant
geographical area. The Ministry of Petroleum and Energy may also require the licensee to produce
regional impact assessments if particular reasons warrant it.
The purpose of establishing such approved regional impact assessments is that they, as long as
methodology and assumptions are relevant, may be used as documentation in connection with new
developments in the area. Such assessments will consequently contribute to ensuring that both the FIA
document and the procedure in dealing with it is simplified since part of the need for documentation in
relation to the developments already exists.
A joint impact assessment for several specific developments could be appropriate for certain
fields/areas. This will in particular be the case in respect of small fields/areas with the same deve lopment
operator and several developments at approximately the same time. It will not, however, be natural to
regard such an assessment as a regional impact assessment, but more as a collective FIA for several
developments.
The geographical delimitation of a regional impact assessment will vary very much from one case to
another. With regard to discharges to sea, there is an expressed wish that the regional division is made in
accordance with the defined environment monitoring regions on the continental shelf. These will not
necessarily correspond with an optimal division with the view to look at regional effects from emissions to
air. The infrastructure within an area can also make such division unsuitable.
Since suitable geographic area with the view to assess the consequences of various discharges and
emissions etc. will vary strongly from topic to topic, it will in most cases make sense to prepare a
topical10) regional impact assessment. This will provide the best basis for an evaluation of the
consequences since one can optimise a geographic area based on what is most relevant in relation to each
topic.
The consequences/effects that can be suitably dealt with through an independent regional assessment,
are, for example,
?
?
?
?
?
regional consequences for the natural environment and resources as a result of emissions to air,
including NOx and nmVOC,
regional consequences for the natural environment and resources as a result of planned discharges to
the sea, including oil and chemicals,
consequences for the natural environment and resources as a result of acute oil spills,
consequences for the fisheries as a result of the total area occupied by the activities,
impact on society as a result of the activities in an extended area, to the extent it is desirable.
There should in each individual case be a dialogue between the company, the Ministry of Petroleum and
Energy and the parties entitled to submit comments in order to reach agreement on an appropriate
delimitation. It may vary considerably with the various assessments topics.
10) Topics may for instance be area occupied, discharges of produced water and discharges of nitrogen
oxides.
6.6
Impact assessments in relation to transboundary environmental impact
See
The regulation relating to transboundary pollution is derived from the obligations Norway has according
to convention of 25 February 1991 relating to impact assessments of activities that may have
35
transboundary environmental impact (the Espoo Convention). Sweden, Finland, Denmark and Great
Britain have also ratified the convention, which entered into force 10 September 1997. In addition,
Council Directive 97/11/EC amending Directive 85/337/EEC on the assessment of the effects of certain
public and private projects on the environment, contains regulations on transboundary pollution. In short,
the regulations state that countries that may be affected by other countries’ activities which may have
significant environmental impact, have a right to information about the project and its possible significant
environmental effects. In addition, the affected country and its citizens have a right to participate on an
equal footing with the citizens of the country of origin itself in the national impact assessment process.
Consequently, the various countries also have an obligation to have regulations relating to impact
assessments on a national level.
6.6.1
Projects in Norway where there is a danger of significant transboundary
In the impact assessment programme, the licensee shall give an account of possible transboundary
environmental effects.
If the Ministry of Petroleum and Energy deems that there is a considerable danger of significant
transboundary environmental impact, the impact assessment programme containing information on the
project, shall be submitted to the authorities of the country in question (point of contact). The Ministry of
Petroleum and Energy does this at the same time as the Ministry of the Environment is informed. The
Ministry of Petroleum and Energy also ensures that the countries in question that wish to take part in the
impact assessment process, get a genuine opportunity to do so, and to participate on an equal footing with
the national parties entitled to submit comments in the impact assessment process. The same rules in
relation to process of consultation and letter of approval that apply to impact assessment, will also be
applicable to these. The Ministry of the Environment and other relevant authorities are kept up to date by
the Ministry of Petroleum and Energy.
Since the Ministry is under obligation to notify other states, the operator will have to allow somewhat
longer time for the consultation process in connection with the impact assessment programme in such
cases. The Ministry must first of all decide whether notification is necessary, and, subsequently, the
adjacent country must have a reasonable period of time to decide whether they are going to participate in
the impact assessment process or not.
6.7
Other legislation
Certain developments may be comprised by other legislation which also requires impact assessments. The
petroleum Act does not exempt from the impact assessment duty pursuant to other legislation. In such
cases it will as a general rule not be necessary to produce several assessments, but the procedure and
requirements to contents may vary in relation to different legal frameworks. The relationship to other
legislation should be clarified with the Ministry well in advance of the time when the PDO/PIO is planned
to be submitted. The planning and building Act with associated regulations is the legislation that the
licensees in practice will encounter most often in relation to impact assessments. It is therefore briefly
commented on below.
The Ministry of Petroleum and Energy will co-ordinate the process in relation to other min istries
involved, so that the licensees as far as possible only shall have one single body to relate to with regard to
impact assessments.
Safety matters are dealt with in the normal way by the Ministry of Local Government and Regional
Development and the Norwegian Petroleum Directorate according to the provisions of the petroleum Act
and safety regulations.
6.7.1
The planning and building Act
When a facility is placed onshore or offshore inside the base line, the planning and building Act is
36
applicable. Offshore pipelines transporting petroleum inside the base line, are not comprised by the
planning and building Act. Chapter VII-a of the Act contains requirements relating to impact assessments.
Further details on the statutory framework are to be found in T-1/97 and T-1173, which are general
guidelines on the impact assessment process according to the planning and building Act, and which may
be obtained by contacting the Norwegian Pollution Control Authority.
The Ministry of Petroleum and Energy is the responsible authority with regard to developments and
facilities related to the petroleum activities. The licensees shall relate to the Ministry of Petroleum and
Energy also in cases comprised only by the planning and building Act and not the petroleum Act. Projects
are listed in regulations to the planning and building Act appendix I and II.
The administrative process is largely the same as that which applies to the petroleum Act. It is worth
noting that the impact assessment process shall be completed before decisions on planning permission etc.
are made according to the planning and building Act, or permission to commence work is granted
according to specific acts.
The licensee should allow some extra time since the impact assessment programme is to be presented
to the Ministry of the Environment prior to being determined by the Ministry of Petroleum and Energy.
The Ministry of the Environment has two weeks in which to submit their comments, if any, from the time
when they have received all relevant information in the case. The impact assessment is forwarded to the
Ministry of Petroleum and Energy who initiates the process of public consultation and simultaneously
submits it to public inspection in the municipality where the facility is to be established. According to the
planning and building Act, a public meeting is also required in relation to the project. When the impact
assessment process is completed, a final document shall be prepared in which all comments received from
the consultation process are discussed and assessed. The final document is then sent to all those who have
submitted comments in the process. The practice the Ministry has adopted, has been for the licensee
himself to prepare a draft for a final document, which the Ministry of Petroleum and Energy then
discusses with the licensee in question and thereby approves.
6.7.2
The harbour and fairways Act
Laying of pipelines and other petroleum activities in Norwegian territorial sea which may be of
importance to shipping and safety at sea, will require licences, if applicable order to submit an assessment
according to the provisions of the harbour and fairways Act (Act 8 June 1984 no. 51 relating to harbours
and fairways etc.).
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?
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6.7.3
Other potentially relevant legislation
Act 19 June 1970 no. 63 relating to conservation of nature
Act 4 February 1977 no. 4 relating to worker protection an d working environment etc.
Act June 1978 no. 50 relating to cultural heritage
Act 13 March 1981 no. 6 relating to protection against pollution and relating to waste
37