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 Sustainability Strategy Commitments
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UKOOA Sustainability Strategy 2002 - First Report
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3. Protecting the Environment
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3.1 Environmental management
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Commitment No. 37 - Continual improvement and the six guiding principles
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We re-affirm our commitment to continual improvement in our industry's environmental performance and to the six guiding principles (developed with government in 1999) on how continual improvement is best delivered. This over-riding commitment lays the basis for the more specific actions below.
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Box: The UKOOA - UK government guiding principles for the development of future environmental regulation:
- Continual improvement of the industry's offshore environmental performance should be guided as far as practicable by long-term goal setting, considering all emission streams holistically.
- Methods for achieving environmental goals should be flexible, appropriate to the asset life cycle, and promote innovation rather than relying on compliance against prescriptive standards or technologies.
- Sound scientific analysis should be applied to assess environmental risk and impact. However, where there are threats of serious or irreversible damage, lack of full scientific certainty will not be used as a reason for postponing cost-effective measures to prevent environmental degradation.
- In all cases, agreed improvements should recognise the balance between benefit gained and cost incurred, as well as the balance between emission stream trade-offs.
- The process of developing environmental regulations should be transparent and include stakeholder consultation.
- Penalties should apply if environmental laws are broken.
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Progress to date : achievements and difficulties encountered
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The industry remains committed to continual improvement in environmental performance and to the above six principles.
This report shows trends in emission and discharge data over the last five years (1997 - 2001)(See Section 3 introduction). These trends show continual improvement in oil in produced water, small oil spill reporting and large oil spills, SO2, offshore gas flaring and in the more hazardous categories of chemicals. However 2001 figures have shown small upturns in the atmospherics (CO2, NOx, CH4 due to increased energy required for this increasingly mature phase of production), VOCs (due to increased use of shuttle tankers) and in small accidental oil spills (now being addressed through a cross-industry awareness programme).
Over this last year the industry has held a number of discussions centring on the principle of long-term goal setting. This has looked at a number of issues including:
- The scope for the goal setting approach in the context of current regulatory trends which are primarily focussed upon prescriptive measures.
- The practicalities of holistic goal setting between emission streams and the challenge of properly assessing and comparing different types of impact.
- The alternatives for delivery of industry wide goals across the companies involved - including the potential for trading to maximise the economic efficiency of improvements.
The above points have been raised in the Industry-Government Environment Forum, in order to understand better with DTI the potential for the long-term goal setting approach. These discussions are continuing. These debates clearly relate to the industry commitment to develop indicators and to facilitate monitoring of its contribution to sustainable development - progress here is described under Commitment No.59
The principle of "addressing all emission streams" holistically requires the development of a methodology capable of looking at all aspects of sustainable development together - an enormous challenge. This issue has wider benefits beyond the industry itself and UKOOA has been looking into how this might best be taken forward with the support of an independent policy institute - update on this will be available in the coming months.
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Sustainability Strategy Commitments
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