Offshore Activities
Geological and Seismic SurveyDrilling a WellWell TestWorkoverNew Offshore PipelineNew Project or ModificationProductionChemical PermitsOffshore Waste Storage and TransferOil and Chemical SpillsDecommissioningDecommissioning
| Timeline | Requirement / Action |
| What Consents Required for Geological and Seismic Surveys | |
| • | Consent to Survey required for: Seismic survey; high resolution seismic site survey; borehole seismic; shallow drilling; and gravity/magnetic survey. |
| • | Notification of Survey required for: new pipeline or cable route survey; seabed survey not around existing installation or pipeline; all surveys near or in a "relevant site" under the Regulations. |
| • | No Action required for: inspection, repair and maintenance survey; surveys of existing pipelines or installations; pre/post lay environmental survey. |
| Survey Planning & Consents Timeline | |
| 6+ months | Identify if any conditions on seismic survey are detailed in licence conditions. |
| 6+ months | Identify if survey is in an area sensitive to cetaceans and/or near a site designated under the Habitats Directive. Early discussions with JNCC/DESNZ suggested. An EIA and Habitats Regulatory Assessment may be needed. |
| 6+ months | Identify if any important fishing grounds are in the survey area. |
| 6+ months | If necessary, undertake EIA and prepare Environmental Statement (ES). |
| 6+ months | Identify survey window to minimise environmental impacts. |
| 2 months | If applicable, prepare standalone permit submission. |
| 3 months | If applicable, submit Standalone Survey Consent to DESNZ. |
| 1 month | If applicable, submit Notification of Survey. |
| Survey | (Survey work takes place) |
| Key Compliance During Seismic Survey | |
| ✔ | At least 30 minutes before operations, check visually for marine mammals within 500 m of vessel. Hydrophones may also be used in poor visibility. |
| ✔ | If marine mammals are present, delay start until they have moved away. Allow at least 20 minutes after last sighting before starting operations. |
| ✔ | Where equipment allows, build power up slowly from a low energy start, allowing 20 minutes for mammals to move out of range. Start at least 500 m away from seals around platforms. |
| ✔ | Use the lowest practicable power levels throughout the survey. |
| Timeline | Requirement / Action |
| Drilling a Well – Consent Requirements | |
| An Environmental Statement is required for any drilling in near shore or sensitive areas. Drilling associated with a new development is also likely to require an ES. If unsure, discussions should be held with DESNZ or a Drilling Operations Application (DRA) can be used to seek a dispensation. | |
| 12+ months | If required, submit DRA to determine requirement for an Environmental Statement. This step can be skipped if it is clear that an ES is or is not required. |
| 12+ months | Undertake Environmental Impact Assessment (EIA) and prepare ES. |
| 12+ months | Identify if proposed drilling occurs near habitats or protected species under EU Habitats Directive. Additional measures and Habitats Regulatory Assessment may be required. |
| 12+ months | If no asset-wide Oil Pollution Emergency Plan is in place, prepare OPEP. |
| 4 months | If no asset-wide Oil Pollution Emergency Plan is in place, prepare OPEP. |
| 3 months | Prepare Chemical Permit SAT (DRA) and environmental information sections, including any chemical use/discharge associated with well cleanup if applicable. |
| Submission | Submit ES along with Application for Consent (PON16). |
| 2 months | Submit OPEP to DESNZ for approval. |
| 3–5 weeks | If reinjection of cuttings planned offsite, submit application for reinjection under FEPA. |
| 28 days | Submit Chemical Permit SAT (DRA). Ensure chemicals are registered with CEFAS and replace high-risk chemicals where possible. |
| 28 days | Submit PON4 (Consent to Drill Well). |
| 28 days | Make application to DTLR for Consent to Locate for rig (as part of DRA application). |
| 28 days | If Deposit of Stabilisation and Protection Materials required, submit application under EIA Regulations to deposit material on the seabed (as part of DRA application). |
| 28 days | If drilling through pay-zone and reservoir hydrocarbon contamination of drill cuttings for overboard discharge expected, apply for Oil Discharge Permit. Permit may also be required if OBM well cleanup is expected or any oil contamination of WBM/SBM cleanup. |
| 1 week | Any radioactive sources will need a Certificate of Registration. |
| Spud Date | |
| Key Compliance During Drilling | |
| ✔ | Ensure compliance with any licence, exemption or consent permit conditions, including commitments made in ES. |
| ✔ | Ensure spill prevention and oil spill response procedures are introduced to rig personnel and appropriate equipment is in place. |
| ✔ | Use only the permitted chemicals and mud system. |
| ✔ | If reinjecting cuttings, ensure alternative legal disposal methods are in place as backup if CRI fails. |
| ✔ | Routinely monitor base fluid use and discharge and sample and analyse cuttings for oil content. Report findings to DESNZ. |
| ✔ | Use technology and other techniques to prevent or reduce discharges of all chemicals. Monitor and report all chemical use via EEMS. |
| ✔ | Ensure compliance with Oil Discharge Permit. Minimise possibility of contaminated fluid discharge. If discharging cuttings overboard, ensure no contamination with oil unless a permit is in place. |
| ✔ | Undertake seabed environmental surveys as required by DESNZ. |
| ✔ | Report any accidental discharge of oil, including OBM or SBM, to DESNZ. |
| ✔ | Report any accidental discharge of chemicals, including drilling muds, to DESNZ. |
| ✔ | Undertake all statutory reporting and EEMS reporting for each activity. |
| ✔ | Ensure renewed permit is in place if the planned well continues beyond expiry date of the initial permit. |
| Rig Compliance (Non-Drilling) | |
| ✔ | Undertake a pre-mobilisation audit of the drilling rig to ensure environmental compliance for drilling and non-drilling operations. |
| ✔ | Machinery space drainage: ensure oil content of discharge meets the 15 ppm standard. Maintain Oil Record Book. |
| ✔ | Diesel engines and generators: maintain record of fuel use. |
| ✔ | No limits on sewage and cooling water discharges. |
| ✘ | No garbage (including plastic) to be disposed of overboard. Only comminuted food waste can be discharged. |
| ✔ | Ensure compliance with waste disposal licences, garbage management plan, and documentation requirements. Reuse or recycling is preferred. |
| ✔ | Ensure compliance with legislation for disposal of drill cuttings, including reinjection, overboard disposal (WBM only), or transfer to shore. |
| Timeline | Requirement / Action |
| Well Test – Consent Requirements | |
| n/a (Well Test) | Determine requirement for an Environmental Statement (ES) by submission of environmental information sections of Master Application Template (MAT).* |
| n/a (Well Test) | If ES is required, undertake Environmental Impact Assessment (EIA) and prepare ES. |
| 9 months (Extended Well Test) | Determine requirement for an Environmental Statement (ES) by submission of environmental information sections of Master Application Template (MAT).* |
| 9 months (Extended Well Test) | If ES is required, undertake Environmental Impact Assessment (EIA) and prepare ES. |
| 4 months | If no asset-wide Oil Pollution Emergency Plan (OPEP) is in place, prepare OPEP. |
| 3 months (Extended Well Test) | Submit ES along with Application for Consent for Test Production (PON16). |
| 2 months | Submit OPEP (if needed) to DESNZ for approval. |
| Well Test | * Drilling Operations Application (DRA) for well test from MODU and Production Operations Application (PRA) for platform or within 500 m of platform. |
| Key Compliance During Well Test | |
| ✔ | Use efficient burners and consider the need for the well test. |
| ✔ | If undertaking extended well test, ensure that the rate of oil production complies with the requirements of the Consent for Test Production. |
| ✔ | If undertaking extended well test, make monthly reports to the regulatory authority detailing the previous month’s test results. Notify the authority on completion and inform them of the production status of the well. |
| ✘ | If flare drop-out occurs during well test operation, cease operations and report oil spill via PON1 to DESNZ. Note: a permit/exemption is no longer required for flare drop-out. |
| Timeline | Requirement / Action |
| Workover – Consent Requirements | |
| 4–5 months | Apply for a Certificate of Registration if any radioactive sources are to be used. |
| 28 days | Apply for an Oil Discharge Permit for oily discharges. |
| 28 days | Submit a Well Intervention Operations Application (WIA) for any chemicals to be used or discharged, including any consideration of OBM well clean up if applicable. |
| Workover | Note: WIA can also now be an annual permit for ongoing platform well interventions and workovers. |
| Key Compliance During Workover | |
| ✔ | Ensure monitoring of oil in water content of any discharge takes place. |
| ✔ | If oil is detected in discharge, report total quantity of oil and water discharged during operation to DESNZ. |
| ✘ | Cease operation if free oil is seen on the sea surface and report as an oil spill via PON1. |
| ✔ | Ensure a renewed permit is in place if the planned workover operation continues beyond expiry of the initial permit. |
| Timeline | Requirement / Action |
| Approval for New Pipeline – Consent Requirements | |
| > 12 months (depends on size of development) | Determine requirement for an Environmental Statement (ES). ES is mandatory for pipelines >40 km length and 800 mm diameter. Smaller pipelines may still require ES if part of a wider development. |
| > 12 months | Undertake Environmental Impact Assessment (EIA) and prepare ES. |
| > 12 months | Undertake informal consultation with statutory consultees, DESNZ, JNCC, and MS/CEFAS. |
| > 12 months | Undertake early consultation with fishing interests. |
| > 12 months | Identify if development is near habitats or protected species under the EU Habitats Directive. Additional measures and a Habitats Regulatory Assessment may be required. |
| > 12 months | Prepare environmental information (and possibly chemical permit application) section of PLA. |
| n/a / 4–5 months | Prepare environmental information (and possibly chemical permit application) section of PLA. |
| 4 months | Submit Pipeline Works Authorisation, which includes application for Consent to Locate and Consent to Deposit Materials for pipeline stabilisation. |
| 4 months | Submit ES along with Pipeline Works Authorisation. |
| 28 days | Prepare and submit application for PLA for any chemicals to be used and discharged during pipeline commissioning. |
| Pipeline Construction | (Construction and commissioning phase begins.) |
| Key Compliance During Pipelay | |
| ✔ | Ensure all commitments made in ES submitted to DESNZ are met in detailed design and implementation of pipeline installation and operation. |
| ✔ | Ensure pipelay and other vessels have UK Oil Pollution Prevention Certificate (UKOPP) or IOPP. Ensure appropriate Garbage Management Plans are in place. |
| ✔ | Remove any deposited stabilisation material if required by the regulator due to obstruction or hazard to other sea users. |
| ✔ | Monitor and record use and discharge of all chemicals. Report quantities via EEMS. |
| ✔ | Monitor and record all waste generated. Maintain records and meet disposal requirements for non-hazardous and hazardous waste. |
| Timeline | Requirement / Action |
| Approval for New Project or Major Modification – Consent Requirements | |
| > 12 months | Determine requirement for an Environmental Statement (ES) by submission of Production Operations Application (PRA). An ES is mandatory for all new fields and for new or increased production of over 500 tonnes of oil or 500,000 m³ gas per day. |
| > 12 months | Undertake informal consultation with statutory consultees, DESNZ, JNCC, and MS/CEFAS. |
| > 12 months | Identify if development occurs near habitats or protected species under EU Habitats Directive. Additional measures and a Habitats Regulatory Assessment may be required. |
| n/a | Undertake Environmental Impact Assessment (EIA) and prepare ES. |
| 6 months | Apply in writing to DESNZ for Consent to Locate for fixed installation. |
| n/a | Prepare environmental information section of PRA. |
| n/a / 4 months | Submit Production Operations Application (PRA) along with Application for Consent (PON16). |
| 3 months | Submit ES along with Application for Consent (PON16). |
| Project Approval | Also see summary tables for Production Consents and New Pipeline if appropriate. |
| Key Compliance | |
| ✔ | Ensure all commitments made within ES submitted to DESNZ are met in detailed design and implementation of the project or modification. |
| ✔ | Ensure all production or other consents are met (see Production Consents). |
| Timeline | Requirement / Action |
| Production – Consent Requirements | |
| - | Ensure approval in place for New Project or Major Modification. |
| - | Ozone depleting substances and fluorinated GHGs. Ensure halon use meets strict controls, especially in firefighting systems and refrigerants. |
| 6 months | Prepare PPC Application for any new combustion plant exceeding 50 MW(th) or if substantial change to existing plant. Submit EU ETS registration and allocation application to DESNZ. |
| 5 months | Undertake risk assessments and prepare Production Operations Application (PRA). Ensure chemicals are CEFAS-registered and replace high-risk ones where possible. |
| 4 months | If radioactive sources are to be used, submit application for Certificate of Registration to SEPA/EA. |
| 4 months | If no asset-wide Oil Pollution Emergency Plan (OPEP) is in place, prepare one. |
| 3 months | Submit PPC Application. |
| 3 months | Submit Chemical Permit Application (PRA). |
| 2 months | Submit application for Consent to Flare to DESNZ. |
| 2 months | Submit application for Consent to Vent to DESNZ. |
| 2 months | Submit OPEP to DESNZ for approval. |
| 28 days | Submit Application for Oil Discharge Permit for produced water discharge (and other oil to sea e.g. drainage). Application required even if PWRI planned. |
| 28 days | Include in Oil Discharge Permit any produced sand and LSA discharge if oil contamination expected. |
| 28 days | Ensure installation has a valid Garbage Management Plan in place. |
| 28 days | If new production facility, ensure a valid UK Oil Pollution Prevention Certificate (UKOPP) is held for oily machinery space drainage. |
| First Oil | (Operations commence.) |
| Key Compliance During Production | |
| ✔ | Ensure oil content and total volume of produced water discharge meets Oil Discharge Permit requirements. |
| ✔ | Undertake routine sampling and analysis of produced water with monthly reporting. |
| ✔ | Undertake routine sampling and analysis of produced sand with quarterly reporting. |
| ✔ | Machinery space drainage: ensure oil content of discharge meets 15 ppm standard. Record and keep Oil Record Book entries for 3 years. |
| ✔ | Combustion plant: monitor and report emissions as required by permit. Report via EEMS. |
| ✔ | Record quantities of crude oil stored, loaded, and offloaded. Calculate VOC emissions and report annually. Follow guidance for VOC reduction. |
| ✔ | Ensure flaring and venting volumes comply with consents. Report via EEMS and notify DESNZ of any compliance failures. |
| ✔ | Ensure EU ETS reporting and annual verification of emissions and improvements. |
| ✔ | Use technology to prevent/reduce chemical discharges. Monitor and report via EEMS. |
| ✔ | Report any accidental oil discharge to sea to HM Coastguard and DESNZ using PON1. |
| ✔ | Report any accidental chemical discharge to DESNZ using PON1. |
| ✔ | Keep OPEP up to date and undertake routine response training and exercises. |
| ✔ | No current limits on sewage and cooling water discharges. |
| ✘ | No garbage (including plastics) to be disposed of overboard. Only comminuted food waste may be discharged. |
| ✔ | Ensure Garbage Management Plan is in place. |
| ✔ | Maintain records of waste types and quantities. Report as required. Ensure correct documentation for transfer of waste (including special and hazardous waste) to shore. |
| Timeline | Requirement / Action |
| Use of Chemicals – Consent Requirements | |
| - | Under the Offshore Chemical Regulations 2002, all chemicals (including drilling muds) require a consent to discharge. Chemicals must be registered with CEFAS and selected through a risk-based approach. Different Master Application Templates (MATs) apply for drilling, pipelines, platforms, decommissioning, and workovers. |
| 4 months | Identify chemical requirements and ensure all chemicals are registered with CEFAS (i.e. full HOCNF data set available). |
| 4 months | Ensure chemicals selected are registered with CEFAS and those of high environmental risk are replaced where possible. |
| 4 months | Undertake risk assessment and CHARM modelling for chemicals not on the OSPAR PLONOR list. Substitute any high-risk chemicals. |
| 4 months | Prepare the appropriate Master Application Template (MAT). Environmental information is required for all applications, even if an ES has not been submitted. |
| 28 days | Submit the appropriate MAT to DESNZ. |
| Chemical Use or Discharge | (Covers the application and approval process for chemical use.) |
| Key Compliance | |
| ✔ | Use technology and other techniques to prevent or reduce chemical discharges. |
| ✔ | Provide justification for all chemicals flagged for substitution. Encourage suppliers to identify alternatives. |
| ✔ | Monitor and record use and discharge of all chemicals. Report quantities via EEMS. |
| ✔ | Report any chemical spills to DESNZ using PON1. |
| ✔ | Submit annual substitution spreadsheets identifying all priority action or candidate substitution chemicals used and/or discharged during the year. |
| Timeline | Requirement / Action |
| Offshore Waste Storage and Transfer – Consent Requirements | |
| Before Waste Generation | Ensure Garbage Management Plan and appropriate procedures are in place. |
| Before Waste Generation | Ensure any Certificate of Authorisation for Accumulation and Disposal of Radioactive Waste is in place (if required). A separate certificate may be required for overboard disposal of LSA liquid waste. |
| Before Waste Generation | If necessary, ensure registration with SEPA/EA for recycling of packaging waste and that recovery obligations are met. |
| Before Waste Generation | If installing a shipboard incinerator for garbage, ensure it complies with Regulation 16 Annex VI of MARPOL. |
| Before Waste Transfer | Ensure Transfer Notes for any Controlled Waste transfer to shore are completed. |
| Before Waste Transfer | Ensure Consignment Notes for Special/Hazardous Waste are completed. Waste must be correctly marked and labelled for onshore requirements and IMDG Code compliance. |
| Before Waste Transfer | Ensure correct Transportation Records are completed for any Radioactive Waste. |
| Key Compliance for Offshore Waste Storage | |
| ✔ | Ensure waste is correctly segregated to support recycling/reuse and transport to shore. |
| ✔ | Ensure appropriate authorisations and placards are displayed. |
| ✘ | No overboard disposal of garbage. Waste must be contained and secured to prevent loss overboard. |
| ✔ | Encourage waste minimisation and recycling/reuse/recovery as far as possible. |
| ✔ | Ensure all Transfer Notes and Consignment Notes are retained as required. |
| Event / Timeline | Requirement / Action |
| Oil and Chemical Spills – Contingency Planning and Reporting | |
| 2 – 4 months before operation | Ensure an Oil Pollution Emergency Plan (OPEP) is in place. Currently no statutory requirement for chemical spill planning, but this may be included in the OPEP. |
| 2 – 4 months before operation | Ensure any vessel has an appropriate Ship Oil Pollution Emergency Plan (SOPEP) in place. |
| In event of spill | Report any oil spill or accidental chemical spill immediately to DESNZ and HM Coastguard using PON1. Additional external reporting is required for oil spills. All spills must also be reported internally. |
| In event of spill | If there is an excursion to a chemical permit, do not report on PON1. Instead, report to DESNZ within at least 2 days of the incident. Best practice is to submit a variation to the permit before an excursion occurs and ensure out-of-hours contacts are available. |
| In event of spill | Mobilise appropriate response measures as set out in the OPEP. |
| Key Ongoing Compliance | |
| ✔ | Ensure appropriate spill prevention and response measures are in place. |
| ✔ | Undertake regular oil and chemical spill response exercises as detailed in the OPEP. |
| ✔ | Ensure all personnel are trained in spill prevention, reporting, and response measures. |
| Timeline / Event | Requirement / Action |
| Decommissioning – Consent Requirements | |
| 3–5 years | Hold preliminary meeting with BEIS regarding the Decommissioning Programme. Schedule events and review options for pipelines and installations. |
| 3 years | Describe and quantify materials on the structure, including chemical inventory. Identify possible decommissioning options and disposal routes. |
| 3 years | Undertake comparative environmental assessment of decommissioning options. |
| 3 years | Identify if the project is in a designated habitat area and assess potential impacts. Consult with JNCC. |
| 3 years | If planning to leave pipeline in situ, undertake a study on exposure and environmental impacts. |
| 3 years | If applying for derogation, prepare a Derogation Case. |
| 3 years | Prepare 1st draft of Decommissioning Programme. |
| 24 months | Submit 1st draft of Decommissioning Programme. BEIS consults Government Departments including MS/CEFAS, DETR, SEPA/EA, JNCC, and HSE. |
| 21 months | Receive BEIS feedback on 1st draft. (If applying for derogation, process may take longer.) |
| 18 months | Submit 2nd draft of Decommissioning Programme. BEIS re-consults with relevant Government Departments. |
| 18 months | Operator circulates proposals to statutory consultees and publishes in press/online. Statutory consultees have 30 days to comment. |
| 18 months | Consider need for baseline environmental survey if no prior data exists. |
| 16 months | Receive BEIS feedback on 2nd draft of Decommissioning Programme. |
| 12 months | Submit final draft of Decommissioning Programme, including consultation outcomes. |
| 12 months | Submit application for an Oil Discharge Permit (if oily discharges expected). |
| 12 months | Submit application for Disposal of Material under FEPA (if seabed deposits anticipated). |
| 12 months | Consult SEPA/EA for waste disposal licences. |
| 4–6 months | Receive written approval of the Decommissioning Programme from BEIS. |
| 4 months | Submit Decommissioning Operations Application (DCA) for chemicals to be used or discharged. |
| 6 weeks | Provide Notice of Change of Status of pipeline/installation to the UK Hydrographic Office. |
| Decommissioning | Also see Well Abandonment requirements if applicable. |
| Key Compliance Post Decommissioning | |
| ✔ | Where pipelines or installations are left in place, submit locational data and surveyed depths to the Hydrographic Office. Install and maintain navigational aids for any remains above sea surface. |
| ✔ | Segregate hazardous (e.g. oily waste, asbestos, chemicals) and non-hazardous wastes. Keep records of hazardous waste and consignment notes. |
| ✔ | Comply with all waste disposal licences and transfer documentation. Reuse or recycling is preferred. |
| ✔ | Undertake an independent debris clearance verification survey. |
| ✔ | Conduct post-decommissioning seabed sampling survey for hydrocarbons, heavy metals, and contaminants. Survey strategy agreed with BEIS. |
| ✔ | Submit copies of all debris clearance and survey reports to BEIS. |
| Timeline / Event | Requirement / Action |
| Well Suspension or Abandonment – Consent Requirements | |
| As early as possible | If explosives are required, consult JNCC/DESNZ early to consider habitats and species issues under the Habitats Regulations. |
| As soon as need is known | Submit summary of chemical use/discharge to DESNZ via a Well Intervention Application, even if already covered in a Drilling Operations or Decommissioning Operations Application. |
| As soon as need is known | If any deliberate oil release is planned, obtain an Oil Discharge Permit. This must be included in the Well Intervention Application and will trigger permit issue. |
| As soon as need is known | In exceptional cases, a FEPA licence may be required for seabed deposits (e.g. rock dumping over wellhead). Submit details in the Well Intervention Application. |
| Well Suspension or Abandonment | General category for the above actions. |
| Key Compliance | |
| ✔ | Ensure compliance with all licence, exemption, or consent conditions. |
| ✔ | Apply technology and techniques to prevent or reduce chemical discharges. |
| ✔ | Monitor and record all chemical use and discharges. Report quantities to the UKOOA EEMS Coordinator. |
| ✔ | Report chemical spills to DESNZ using PON1. |
| ✔ | Report oil sheens or spills to HM Coastguard and DESNZ using PON1. |