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Date of publication: October 2018 Updated: October 2019 Requirements for the planning of and consent to UKCS Field Developments
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Page 1: Requirements for the planning of and consent to UKCS Field ... · Requirements for the planning of and consent to UKCS Field Developments . 5. FDP Approval road map 6. The “road

Date of publication: October 2018Updated: October 2019

Requirements for the planning of and consent to UKCS Field Developments

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2 Requirements for the planning of and consent to UKCS Field Developments

1. Introduction 4

Scope and purpose of the document 4

FDP Approval road map 5

Governance 6

Scalability of the process 6

Charging 7

2. MER UK Strategy 8

Stewardship Expectations 9

Ensuringthirdpartyaccesstooffshoreinfrastructure 9

3. Considerationsrelevanttoallnewfielddevelopments 10

Robust Project Delivery (SE-05) 10

Environmental Impact and Health and Safety assessments 10

Decommissioning 11

Unitisation and co-operative development 11

Transboundaryfields 11

Flexible approach to development proposals 11

i. Extended Well Tests 11

ii. Phased developments 11

iii. Satellite tie-back development 12

ConsiderationsofGoodOilfieldPractice 12

Gasutilisation/flaring 12

Measurement of petroleum 12

Financial Criteria 12

4. AssessmentPhaserequirements 13

Concept Select 13

Economic Evaluation 14

Consultation on Supply Chain Action Plan (SCAP) 15

Consultation on Project Execution Plan (PEP) 15

Technology and EOR screening 16

Environmental Statement (ES) preparation 16

Contents

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5. AuthorisationPhaserequirements 17

Economic Evaluation 17

Supply Chain Action Plan 17

Project Execution plan 19

Field Determinations 19

Development Area 19

Unitisation and Unit Operating Agreements (UUOA) 19

Field Operator approval 19

Hostfacilitymodifications 20

Environmental statement consultation 20

DesignNotification 20

Decommissioning security arrangements 21

Consent to the FDP 21

Time frame 21

Content of the FDP 22

Development and Production Consent 22

6. ExecutePhaserequirements 23

Monitor project execution 23

Commissioningflareconsentsissued 24

Pipeline Works Authorisations 24

Safety case accepted by OSDR 24

Divergence from the agreed FDP 24

7. RegulationfollowingFDPauthorisation 25

Required future Consents 25

Reporting 25

Changes of Licensee and/or Field Operator 25

AppendixA:GuidelinesforthecontentofanFDPdocument 26

AppendixB:Rolesandresponsibilities 27

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4 Requirements for the planning of and consent to UKCS Field Developments

1. Introduction

1. The development of, and production from, oilandgasfieldsintheUnitedKingdom’sterritorialwaters and on the United Kingdom ContinentalShelf (‘UKCS’)issubjecttoalicensingregimeoverseen by the Oil and Gas Authority (‘OGA’).Under the model clauses applicable to a seawardproductionlicence,licenseesrequiretheOGA’sconsent to erect or carry out permanent worksfor the purpose of getting or conveying petroleumfrom a licensed area or to get petroleum fromsuch an area. Such consent is referred to asa‘DevelopmentandProductionConsent’.

2. The document submitted in support of anapplication by a licensee for authorisation toproceed with a proposed development is referredto as a Field Development Plan (‘FDP’).TheFDPisthepre-requisitefortheOGA’sdevelopmentand production considerations and should providea description of the technical and economicinformation on which the development is based.

3. When considering whether to consent to anFDP, the OGA will, amongst other things, assesswhether the proposed project accords with theobligations set out in the strategy for enabling theprincipal objective of maximising the economicrecovery of UK petroleum (‘MER UK Strategy’),and whether the development methodsproposedcomplywithgoodoilfieldpractice.

Scopeandpurposeofthedocument

4. This document is intended to assist thoseinvolvedintheplanningofanewfielddevelopment and subsequent consent to anFDPleadingtoproductionoffirsthydrocarbons.The guidance covers the following:

• AnoverviewoftheOGA’sobjectivesand considerations relevant toallnewfielddevelopments

• The Assessment Phase leadingto the Concept Select

• The Authorisation Phase leading to theconsent to a Field Development Plan

• The Execute Phase leading to theproduction of hydrocarbons

• The process for revising a previouslyconsented-to FDP (i.e. an FDPAddendum (‘FDPA’))

5. This guidance is not a substitute for any regulationor law and is not legal advice. It does not havebindinglegaleffect.WheretheOGAdepartsfrom the approach set out in this guidance, theOGA will endeavour to explain this in writing tothe person seeking a decision from the OGA.

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5Requirements for the planning of and consent to UKCS Field Developments

FDPApprovalroadmap

6. The “road map” below sets out the three mainstagesoftheOGA’sfielddevelopmentprocessand the main requirements of each stage.

The OGA encourages the Field Operator,appointed on behalf of the Licensees to undertakethedevelopmentandoperatethefield,toengage with the OGA early and frequently intheplanningofaproposedfielddevelopment,initially to discuss development options and,subsequently, the content of the FDP prior to itssubmission. The OGA will appoint a single pointof contact for all discussions relating to the FDP.

7. TheOGAwillreviewtheFieldOperator’sdevelopment options and subsequently theFDP.Whereissuesareidentified,theOGAwillundertake a detailed examination of the FieldOperator’sdecisionswhichmay,amongstothermatters, include the review of the technicaland economic basis for the development.The Field Operator will be expected toprovidethenecessaryjustificationofsuchplans or amend the FDP as appropriate.

Figure1:NewFieldDevelopmentRoadMap

OGA

BEIS

HSE

ASSESSMENT AUTHORISATION EXECUTE

• Consultation on ProjectExecution Plan

• Consultation on ConceptSelection

• Consultation on SupplyChain Action Plan

• Technology and EOR screening

• Economic Evaluation

Evaluate alternative developmentconcepts

Environmental Statementpreparation

• Project Execution Plan• FDP/FDPA• Field Determination• Unitisation and Unit

Operating Agreements• Field Operator Approval• Economic Evaluation

• SCAP

Fullydefinedevelopmentscopeanddetailedimplementationplans

• Environmental Statement consultation

• Decommissioning security arrangements

Design or Relocation Notification

Safety Case acceptance by OffshoreSafetyDirectiveRegulator (if required)

• Monitor project execution• Commissioning Flare

Consent issued• Pipeline Works

Authorisation

Buildthedevelopment,finalisetheoperatingplan

First Production

OGA agreement to Concept Select

Final FDP

INDUST

RYREQ

UIREM

ENTS

PHASE

OSDR informed ofConcept Select

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6 Requirements for the planning of and consent to UKCS Field Developments

8. AssessmentPhaseleadingtotheConceptSelect

The Field Operator should engage with theOGA early in the Assessment Phase. TheAssessment Phase is an early project phasethat the OGA considers extremely important inthedevelopmentofanewfield.Thisiswheredecisions are expected to be taken by theLicensees on the strategies and project conceptsthat will set out how the Licensees will take thesteps necessary to secure that the maximumvalue of economically recoverable petroleum isrecoveredfromthenewfield(s).Inthisprojectphase, the Licensees should evaluate alternativedevelopment strategies and identify a preferreddevelopment concept. In this guidance the OGArefers to this decision as “Concept Select”.

Once a decision has been made on the developmentconcept, the Field Operator should provide aConcept Select report to the OGA that summarisesthe information and requirements which ledto the proposed development concept. Theconclusion of the Assessment Phase will bethe agreement with the OGA on the ConceptSelect decision. In addition, early engagementwith the OGA on the requirements of theSupply Chain Action Plan should be undertakenprior to the Concept Select decision.

9. AuthorisationPhaseleadingtotheconsenttoaFieldDevelopmentPlan

The Authorisation Phase of a project iswhere the Concept Select is matured tosecure all relevant Licensee and regulatoryapprovals. The Authorisation Phase shoulddeliveratechnicaldefinitionandaProjectExecution Plan (PEP) to ensure a robustproject is developed with clear scope, costestimate, schedule and commercial terms.

During this Phase, the Field Operator shouldshare an early version of the FDP with the OGA.As the development decisions mature, theFieldOperatorshouldsubmitthefinalisedFDPwhich should include a detailed account of thedevelopment and the principles and objectiveswhich will govern its implementation throughoutthe full lifecycle of the project. The result of thisphase may be a decision by the licensees toinvest in the project (“Final Investment Decision”or “FID”) and consent to the FDP from the OGA.

If the guidance in this document is followed,the FDP prepared towards the end of theAuthorisation Phase will normally require onlyminorrevisionstoreachitsfinalform.

The OGA expects that, where Licensees have followed the process set out in this document, a Development and Production Consent would normally be issued by the OGA within one month ofsubmissionofthefinalFDPdocument.

10. ExecutePhaseleadingtotheproductionofhydrocarbons

The Execute Phase of a project is where theprojectscopedefinedintheFDPandProjectExecution Plan will be implemented by the FieldOperator. At this stage all Licensees who are partyto the development are committed to the projectand a Development and Production Consent hasbeen given to proceed by the OGA. The purposeof the Execute Phase is to carry out all requiredactivities (e.g. well construction, engineering,procurement, construction, commissioning/start-up etc) and to deliver the project objectives safely.

Governance

11. The FDP should represent a single view of theproject by the Licensees, who are jointly andseverally liable for the content and implementationof the FDP. One Licensee is appointed as a FieldOperator to be responsible for the preparation ofthe FDP and to ensure that all necessary consentsand authorisations are obtained, and for theexecution of the project. It is usual for the OGAto conduct discussions with the Field Operatoras the representative of all the Licensees. TheOGA has published guidance1 on how to applyfor OGA approval to become a Field Operator.

Scalabilityoftheprocess

12. Theelementsinthenewfielddevelopmentroadmap and the project phases described aboveareintendedtoguideindustrytoanefficientandtimelyfielddevelopment.Itisrecognisedthatforsmaller projects (for example a subsea tie backinto existing production facilities), some elementsoftheroadmapcanbesimplified,howeverallelements of the approval road map are applicable.

At an early stage, the Field Operator shoulddiscuss with the OGA its requirements for theFDP and the Development and ProductionConsent. The Field Operator should also discusswith the Department for Business, Energy andIndustrial Strategy (BEIS) its requirements foran Environmental Impact Assessment (EIA) andan Environmental Statement (ES) and with theOffshoreSafetyDirectiveRegulator(‘OSDR’)2 itsrequirementsundertheOffshoreSafetyDirective.

1 https://www.ogauthority.co.uk/exploration-production/production/field-operatorship/2 http://www.hse.gov.uk/osdr/index.htm

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7Requirements for the planning of and consent to UKCS Field Developments

Table1:Applicationofguidancebyprojecttypes

Type Overview

NewFieldDevelopment (Greenfield) • This guidance applies

Host Facilities (Brownfield) • This guidance applies

FieldRe-Development • This guidance applies

ExtendedWellTest • Letter to OGA required setting out proposed timeline and objectives• See the OGA website for further information

PhasedDevelopment• This guidance applies• The FDP will cover the initial phase of development

SatelliteTieBack • This guidance applies• FDP can be scaled according to size and complexity

Charging

13. The OGA provides a range of services to licenceholders and charges are made for the reviewof and consent to an FDP (referred to in therelevant regulations as a ‘development andproductionprogramme’),includingconsenttoFDP addenda. Further details of these chargescanbefoundintheOGA’sguidanceonfees.3

3 https://www.ogauthority.co.uk/media/3566/guidance-note-on-ogas-fees-and-charges-regime.pdf

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8 Requirements for the planning of and consent to UKCS Field Developments

14. The MER UK Strategy4 came into force on 18March 2016. Its Central Obligation states that“relevant persons must take the steps necessaryto secure that the maximum value of economicallyrecoverable petroleum is recovered from thestrata beneath UK waters.” The Central Obligationis binding on relevant persons and the OGA.ToassistwithitseffectivedeliverytheMERUK Strategy also sets out several SupportingObligations, Required Actions and Behaviours.These expand on how the Central Obligationapplies in particular circumstances and specifythe actions and behaviours to be adopted byrelevant persons when carrying out activities inthe UKCS. The MER UK Strategy also contains anumber of safeguards; the Central and SupportingObligations, Required Actions and Behavioursshould be read subject to those safeguards.

15. When considering whether to consent toaproposedfielddevelopment,theOGAwill evaluate whether the proposed projectsupports the MER UK Strategy.

16. The OGA will work with Licensees to ensurethat the development option agreed is thatwhich is most likely to secure the maximumvalue of economically recoverable petroleumfrom the strata beneath UK waters.

OGArole

2. MER UK Strategy

4 https://www.ogauthority.co.uk/regulatory-framework/mer-uk-strategy/

The OGA regulates the exploration and development of the UK’s offshore and onshore oil and gas resources and the UK’s carbon storage and gas storage and offloading activities

The OGA has an important role to promote investment in the UKCS, create value in the UK through exports and develop the prosperity of the industry including wider supply chain

Regulate

PromoteInfluence

MERUK

The OGA has a critical role to influence and encourage a culture of greater collaboration on the UKCS, improve commercial behaviours, and help enable a more efficient industry

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9Requirements for the planning of and consent to UKCS Field Developments

StewardshipExpectations

17. In consultation with the industry, the OGA hasdeveloped stewardship expectations5 for FieldOperators and Licensees across the oil andgas lifecycle, including SE-05 (Robust ProjectDelivery). These good practice expectations arealigned with the MER UK Strategy SupportingObligations and are designed to help achieveconsistent stewardship performance.

18. An implementation guide supports eachStewardship Expectation. These providefurther details to assist Field Operators andLicensees in achieving them and includesthe rationale, the expected outcomes anda description of key elements or behavioursrequiredtomeettheOGA’sexpectations.

19. During the Assessment Phase, good practicewill normally require that the information neededto determine the most appropriate developmentoption has been gathered and analysed properly.Thisoptionwillallowallrealisticoptionsforthefieldand area, including the application of Improved OilRecovery (‘IOR’),EnhancedOilRecovery(‘EOR’)techniques, and new or innovative technology, tobe considered properly. Field Operators shouldrefer to the OGA Stewardship ExpectationsSE-02 (Exploration and Appraisal SubsurfaceWork Programme) and SE-03 (Optimum Useof Subsurface Data) for further information.

20. Licenseesareexpectedtobringforwardfielddevelopment proposals in a timely manner,consistent with the relevant StewardshipExpectations referred to above. FDPs shouldbe submitted for consent within the timescales set out in the terms of the licence.

Ensuringthirdpartyaccesstooffshoreinfrastructure

21. Whenreviewingnewfielddevelopmentproposalswhich have implications for future infrastructureutilisation the OGA will evaluate if the proposalssupport the MER UK Strategy, which may includesuch considerations as, but is not limited to:

• Avoiding the unnecessary proliferationof oil and gas pipelines

• Aiding,wherefeasible,futurefielddevelopments, including thoseoutside the licence area

22. Subject to the above, the evacuation route anddestination of petroleum are essentially mattersfor the commercial judgement of the Licensees.Where oil or gas is to be exported to anothercountry by means of a new pipeline, the pipelinewill be subject to the negotiation of appropriateagreements between the governments concerned.

23. AvoluntaryindustryOffshoreInfrastructureCodeof Practice6 seeks to simplify the timely applicationoftheprocessesofseeking,offeringandnegotiatingthirdpartyaccesstooffshorepipelinesand processing facilities and onshore terminalsand ensure that access is easy and fair, with termsofferedonanegotiated,non-discriminatorybasis.

24. The OGA has powers, having considered theinterests of all parties, to impose a solutionto problems with access to pipelines andprocessing facilities and onshore terminals.The OGA has published separate guidanceon disputes over third party access toupstream oil and gas infrastructure7 whichdescribes how these powers are used.

25. The OGA also has powers, if required, to directthe size and or routing of a new pipeline, throughthe Pipeline Works Authorisation process.

5 https://www.ogauthority.co.uk/exploration-production/asset-stewardship/expectations/6 https://oilandgasuk.co.uk/infrastructure-code-of-practice-2.cfm7 https://www.ogauthority.co.uk/regulatory-framework/powers-sanctions-guidance/third-party-access/

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10 Requirements for the planning of and consent to UKCS Field Developments

RobustProjectDelivery(SE-05)

26. Licensees and Field Operators should be familiarwith the Stewardship Expectation implementationguidesrelevanttofielddevelopments,inparticular SE-058 (Robust Project Delivery).

This implementation guide provides directionto promote good project delivery:

• Ensure accountable leadership, aproject delivery organisation andgovernance are in place

• Ensure that an established projectmanagement system is in place and used

• Ensuresufficientfront-endpreparationand benchmarking has been completedprior to project sanction

• Ensure a Project Execution Plan(PEP) is developed and updatedat each phase of the project

The OGA has published a lessons learned report from UKCS oil and gas projects 2011–2016.9

EnvironmentalImpactand HealthandSafetyassessments

27. TheenvironmentalregulationofoffshoreoilandgasactivityistheresponsibilityoftheOffshorePetroleum Regulator for Environment andDecommissioning (‘OPRED’),partoftheUKgovernment’sDepartmentforBusiness,Energyand Industrial Strategy (BEIS). An EnvironmentalStatement (‘ES’)describingtheEnvironmentalImpact Assessment (‘EIA’)isrequiredtobesubmitted to BEIS as part of the FDP authorisationprocess. More information can be found onBEIS’senvironmentallegislationpage.10

28. Safety regulation is the responsibility of theOffshoreSafetyDirectiveRegulator(‘OSDR’),the Health and Safety Executive (‘HSE’)Energy Division and OPRED working togetheras the Competent Authority to implementtherequirementsoftheEUOffshoreSafetyDirective and other statutory provisions on thesafetyofoffshoreoilandgasoperations.

3. Considerations relevant toallnewfielddevelopments

8 https://www.ogauthority.co.uk/media/3828/se-05.pdf9 https://www.ogauthority.co.uk/news-publications/publications/2017/lessons-learned-from-ukcs-oil-and-gas-projects-2011-2016/10 https://www.gov.uk/guidance/oil-and-gas-offshore-environmental-legislation

Organisational

Behaviours

Execution

Project management

Front end loading

PROJECT SUCCESS

Figure2:LessonsLearned–5KeyAreas

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11Requirements for the planning of and consent to UKCS Field Developments

29. OperatorsmustsubmitaDesignNotificationtotheOSDR at an early stage in the design process forfielddevelopmentsinvolvingnewinstallations11. Thedesignnotificationmustbefollowedbysubmissionofasafetycase,fortheOSDR’sacceptance,before the installation can be operated.

30. TheOSDRwillrequireaRelocationNotificationif a production installation, with an existingsafety case, is to be moved to a new location inexternal waters or if a non-production installationis to be converted to a production installation.

31. Licensees are advised to contact the OSDRat an early stage in their developmentplanning, ie during the Assessment Phase.

Decommissioning

32. InaccordancewiththeUK’sinternationalobligations,all installations emplaced on or after 9 February 1999must be designed to be completely removed toshoreforreuse,recyclingorfinaldisposalonland.

Unitisationandco-operativedevelopment

33. Whereafielddeterminationextendsacrossmorethan one licence, the OGA may require Licensees toenter into a Unitisation and Unit Operating Agreement(‘UUOA’)priortosubmittinganFDP.ThisUUOAneedsto be approved by the OGA prior to FDP consent.

Transboundaryfields

34. The development and operation of transboundaryfields12 extending beyond the limits of theUKCS,orfieldswhollyonanothercontinentalshelf which require the development of newtransboundary pipeline infrastructure or wellsand control facilities, will require a formalagreement between the states concerned.

35. The matters to be addressed in any such inter-governmental negotiations are likely to varyfrom project to project. Licensees are advisedto seek early guidance from the OGA during theAssessment Phase for any development proposalthat may have transboundary implications.The authorisation time-scale for transboundaryfieldswilldependonthelevelofagreementneeded between the governments concerned.

36. The OSDR should be engaged at anearly stage to gain understanding ofwhich regulatory regime will apply.

Flexibleapproachtodevelopmentproposals

37. For most offshore fields, it is expected thatLicensees will put forward a plan covering thelifecycle of the development. The OGA recognisesthat there may be valid reasons for more gradualor flexible approaches to some developmentsstemming from geological or engineeringuncertainty, infrastructure constraints or thebenefits of phasing expenditure. The OGA willsupport such approaches where consistent withthe fulfilment of the principal objective of MER UK.The alternatives to full lifecycle developments thatare commonly proposed, and the criteria for theirconsideration by the OGA, are set out below.

i.38.

ExtendedWellTests(EWTs)The OGA may consent to extended periods oftest production from exploration or appraisalwells prior to field development authorisation. AnEWT consent requires an application by theExploratiion or Field Operator to the OGA settingout the timetable and objectives of the test andthe quantities of oil and gas to be produced,saved or flared.

The application should demonstrate that the primary objective of the EWT is to obtain essential field information to improve technical understanding or confidence in the performance of the field to advance towards a development. The EWT should not be prejudicial to ultimate recovery of a future development. EWTs are not an alternative to production under a consented- to FDP. Additional guidance on EWTs can be obtained from the OGA website13.

An EIA is required to be submitted to BEIS to support the EWT application. The Well Operator may request a direction from BEIS confirming that a full ES is not required. Further guidance can be found in the Guidance Notes on the Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (as amended).14

ii. Phaseddevelopments41. Forfieldswhichdonotappeartohavethe

economic potential to sustain further appraisal,or where the best development methodcannot be determined without substantialproduction experience, or to commence earlyproduction, the OGA may accept a proposalforthephaseddevelopmentofafield.Theform of the later phases will be dependent onthe results of the earlier ones. Licensees willbe expected to demonstrate that this phasingis not detrimental to the MER UK Strategy.11 http://www.hse.gov.uk/pubns/books/l154.htm

12 https://www.ogauthority.co.uk/exploration-production/development/transboundary-fields/ 13 https://www.ogauthority.co.uk/media/5476/oga_extended_well_test_guidance.pdf14 https://www.gov.uk/oil-and-gas-offshore-environmental-legislation

39.

40.

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12 Requirements for the planning of and consent to UKCS Field Developments

42. Licensees must submit an FDP for the initial phaseof the project. The submission can be scaledin accordance with the phased nature of theproposed development plan and should include:

• the more likely forms of subsequent phases

• the criteria which will need to be met to moveto development of the subsequent phases

• the time frame proposed for furtherappraisal or development.

iii. Satellitetie-backdevelopment43. Incaseswhereasatellitefielddevelopmentisto

betiedbacktoexistinghostfacilitieswithdifferentownership, it is important that the Field Operatorof the satellite development and the operator ofthe host facility collaborate to ensure an agreedplanforanynecessarymodificationtothehostfacility and associated safety case management.

44. The OGA will require a letter of supportfrom the host facility operator, onbehalf of all its co-venturers.

ConsiderationsofGoodOilfieldPractice

45. The licence model clauses require that theLicensee(s) shall execute all operationsin or in connection with the licensed areain a proper and workmanlike manner inaccordance with methods and practicecustomarilyusedingoodoilfieldpractice.

46. TheOGAconsidersthatgoodoilfieldpracticerelates largely to technical matters withinthe disciplines of geology and reservoirengineering, petroleum engineering andfacilities engineering and to the impact ofthe development on the environment.

47. Practices that are harmful to future oil or gasrecoveryincludingthewastefulflaringofgas,orwhichconflictwiththeinterestsofotherpotential users of the licensed area, should beavoidedatallstagesoffielddevelopment.

48. Licensees should ensure that they follow goodoilfieldpracticewhenproposingplansforthedevelopmentandmanagementofafield.

Gasutilisation/flaring49. Fornewfielddevelopments,theOGA

expectsthatwhere,overthelifeofthefield,the value of the produced gas is higherthan the costs of bringing it to the market,Licensees will make provision to do so.

The Licensees should consider carefully alloptions for gas handling. These may includeits processing and transportation to shore, useas fuel, as a means for improving oil recovery,for sale to another development, conversionto other fuels (including electricity), injectionfordisposal,or,asalastresort,flaring.

50. In considering which option should be selected,the OGA will, amongst other things, considertheexpectedoverallcostsandbenefittotheUK (in accordance with the provisions of theMER UK Strategy), which may not alwaysreflectthecommercialpositionsofindividualLicensees. The OGA encourages bothinfrastructure owners and users to adopt theprinciplesoftheindustry’svoluntaryOffshoreInfrastructure Code of Practice when examiningthe options for transporting gas to market.

51. Wheregasistobedisposedofbyflaring,adetailed technical and economic assessmentshould be provided to the OGA to justifytheselectionofthisoption.TheLicensees’full consideration should be given in thedesign of the facility to providing for lesswasteful alternatives should the economicor technical circumstances change.

Measurementofpetroleum52. Licensees are required under the licence

model clauses to measure petroleumusing methods customarily used in goodoilfieldpracticeandapprovedbytheOGA.Petroleum Operations Notice (PON) 615 setsout the procedure that Licensees shouldfollowtogaintheOGA’sapprovaloftheirmethods for petroleum measurement.

Financial Criteria

53. The OGA has issued guidance16onfinancialcriteria for Licensees. The measures describedintheOGA’sfinancialguidancesetouthowtheOGA will assess whether the Licensees havethefinancialviabilityandcapacitytoundertakethe commitments set out in the proposed FDP.

15 https://www.ogauthority.co.uk/exploration-production/petroleum-operations-notices/pon-6/ 16 https://www.ogauthority.co.uk/licensing-consents/licensing-system/licensee-criteria/

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13Requirements for the planning of and consent to UKCS Field Developments

Figure3:AssessmentPhase

54.

ConceptSelect

56. The OGA attaches great importance to theAssessment Phase and the Concept Select asit is at this stage the Licensees will be makingdecisions that are likely to have the mostsignificantimplicationsfortheirMERUKStrategyobligations.Inaddition,aFieldOperator’sprojectplanningprocessgenerallybenefitsifintermediate decisions can be made on the projectbeforefinalcommitmentismadetotheFDP.

4. Assessment Phaserequirements

Indu

stry

OGA

OSD

R

AssessmentPhase

InformOGA ofprojectinitiation

OGAreviewConceptSelect

ReportdraftSCAP andPEPEconomicEvaluation

Appointsinglepointcontact

BEISEnvironmentalStatementPrep

OGAmeet regularlywith Operator regarding

projectupdates

Agree to ConceptSelect

Evaluate Development Concept(s)

DraftSCAPDraftPEP

ConceptSelect Report

EconomicEvaluation

Move to Authorisation

Phase

During the Assessment Phase Licensees should providetheOGAwithsufficientopportunityand informationtogainanunderstandingofthefield and its conceptual development. The conclusion of the Assessment Phase will be the agreement with the OGA on the Concept Select decision including the considerations set out below.

In addition, the OGA should be informed about certain relevant meetings between joint venture partners in accordance with the OGA’s statutory notice17 on meetings issued pursuant to the OGA’s powers under the Energy Act 2016. right to attend such meetings as well as be provided with a written summary.

Such meetings include Operational Committee meetings (‘OCM’) and Technical Committee meetings (‘TCM’) for specified assets or major project review meetings for projects with capital costs of over £300 million. The OGA has the

55.

17https://www.ogauthority.co.uk/media/4220/meetings-statutory-notice-2017.pdf

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14 Requirements for the planning of and consent to UKCS Field Developments

57. The OGA requires to be consulted on thedevelopment plan options so that aspectsrequiring detailed consideration by theOGA can be identified. Such considerationshould include economic evaluation of thedevelopment options, with the requirements foroperators outlined further below.18

58. The Field Operator should prepare and submit tothe OGA a Concept Select report once thedevelopment plan option hasbeen selected.

59. Once the Field Operator has provided the OGAwith the Concept Select report, includingsufficient opportunity and information to gain anunderstanding of the field and its conceptualdevelopment, the OGA will review the report andnotify the Field Operator of any aspects of thedevelopment which are not aligned with the MERUK Strategy or any other issues to be addressed.If any such issues are identified the OGA will seekto agree a programmeof work or review, intended to lead to theirresolution within an agreed timetable.

60. Agreement with the OGA on the Concept Selectwill ensure the OGA’s support moving forwardwith the Authorisation Phase. However, theOGA's confirmation that it has no objection to theConcept Select does not necessarily mean thatthe final version of the submitted FDP will beconsented to. Similarly, such confirmation shouldnot be taken to imply any agreement, consent orauthorisation from OPRED, OSDR or any otherGovernment agency.

EconomicEvaluation61. The OGA considers the economics of field

and incremental developments as part of theassessment of FDPs/FDPAs. It is therefore essentialthat the Field Operator includesdetails of the project economics – includingthe various development options being considered– within the Concept Select report and submits datato the OGA in the Standard Economics Template19

(SET) format.

62. Where the development plan for a new field orincremental development has a significant impact onan already consented-to field(s), relevant data for theaffected field(s) should also be provided to capturethe impact of the developmenton the principal objective of MER UK.

63. MER UK is achieved when a developmentmaximises the net present value (NPV) ofeconomically recoverable petroleum from the UKCS,taking into account the effect on recovery from otherfields and the impact on infrastructure. This isirrespective of the division of realised value betweenthe Licensees and the Exchequer. In ranking optionsin terms of their impact on MER UK, the OGA willfocus on pre-tax NPVs calculated using anappropriate discount rate (currently, 10 per centreal). The OGA does not consider that unavoidablecosts such as capital repayment and the costs offinancing are true costs of production and theyshould, therefore, not be considered in pre-tax cashflows or the definition of the economic limit forcessation of production.

64. Where the leasing of an asset is being considered,Licensees should work with the potential lessor(s) toreach a contractual agreement which willget as close to the theoretical economic limitas practicable, considering the need of theLicensees to manage the risk of the project.The OGA is willing to work closely with theField Operator to identify these risks and encouragethe development of appropriate contractualframeworks which can take account of informationgained during production.

18This is to enable OPRED to highlight any issues that may need to be addressed in the ES, and for HSE to highlight any issues that may need to be addressed for the Safety Case19https://www.ogauthority.co.uk/exploration-production/development/field-development-plans/

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15Requirements for the planning of and consent to UKCS Field Developments

ConsultationonSupplyChainActionPlan(SCAP)

65. In 2018, the OGA introduced new measuresto ensure Field Operators work appropriately withthe supply chain and derive maximum value fromproject activity. The purpose of a SCAP19 is toassist operators in demonstrating their contractstrategies and concepts are comprehensive andwell-positioned to deliver ‘best value’ inaccordance with their FDP.

66. The OGA expects all projects requiring an FDP todevelop a SCAP. In the Assessment Phase, theField Operator should prepare a draft SCAP priorto Concept Select and share with the OGA forinformal review and discussion. This should be atan early stage of the project, in advance of anyproject specific contract award.

67. Following the OGA’s initial review, any incompleteor unsatisfactory SCAPs will be returned withcomments/clarifications to be addressed. TheField Operator can amend the SCAP during thelater Authorisation Phase following feedback fromthe OGA or the Field Operator’s internal review.The SCAP is non-prescriptive with no template,therefore simple guidance notes are set out in theSCAP criteria and expectations.

68. There is also an expectation that Field Operatorswill extend the SCAP commitment to first tiercontractors where individual contracts specific tothe project exceed a value of £25 million.

69. It is anticipated that SCAPs will be developed asan ongoing process in tandem withthe field development planning.

ConsultationonProjectExecutionPlan(PEP)

70. The Field Operator should prepare a PEP forall stages of the project. In the AssessmentPhase, the PEP should be developed inparallel to the FDP and should be recompiledand updated at each stage of the project.

71. The PEP should include sections comprising:

• Schedule

• Project organisation

• Contracting strategy (reference the SupplyChain Action Plan)

• Cost estimate

• Risk and opportunity management

72. Further guidance can be found in StewardshipExpectation SE-05 (Robust Project Delivery).20

19 https://www.ogauthority.co.uk/news-publications/publications/2017/supply-chain-action-plans-guidance/20 https://www.ogauthority.co.uk/media/3828/se-05.pdf

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16 Requirements for the planning of and consent to UKCS Field Developments

TechnologyandEORscreening

73. Field Operators should demonstrate that bothexisting and new and emerging technologieshave been considered for deployment totheir optimum effect to maximise the valueof economically recoverable petroleumfrom the field development through its fulllifecycle. Field Operators should refer to theOGA’s Technology Strategy and StewardshipExpectation SE-08 (Technology Plan).21

74. Depending on their relevance toeach project/development, the OGAexpects the Field Operator to:

• Undertake early engagement with theOGA (at the start of the AssessmentPhase) on technology deploymentprior to submission of FDPs

• Conduct Improved Oil Recovery (‘IOR’) andEnhanced Oil Recovery (‘EOR’) screening (asnecessary), including the development of anynecessary technologies

• Refer to the OGA’s EOR Strategy22

75. In the Assessment Phase for all oil or condensatereservoir developments, the potential forapplication of improved recovery processesbeyond conventional methods should beevaluated. A summary of all the recoveryprocesses considered and the reasons forthe final choice is required in the concept selectreport. Field Operators are requiredto justify if EOR processes are not beingused or are not planned to be utilised.

76. Where a development demonstrates economicpotential for EOR, Licensees should set out theirfirm plans to implement this. Where definiteconclusions cannot be reached, a programme foraddressing the outstanding issues duringproduction should be given in the FDP and forensuring that both wells and production facilitiesare EOR-ready or can be readily made so.

77. A summary of applicable technologies consideredshould be included in the Concept Select report.Appropriatetechnologyshouldbeidentifiedat the Concept Select stage and discussed inthe Concept Select report. The report shouldidentify what technologies were considered andthe reason for being proposed or discountedshouldbeprovided.Thelikelybenefitsthesetechnologies could potentially provide to thedevelopment should be stated as well as anyrisks associated with their deployment. Reasonsforthefinaltechnologysolutionshouldbeincluded in the report. Technologies shouldcover the full life cycle of the development.

EnvironmentalStatement(ES)preparation78. An Environmental Statement (‘ES’) describing

the Environmental Impact Assessment(EIA) is required to be submitted to BEIS aspart of the FDP authorisation process.The Environmental Impact Assessmentprocess should begin in the AssessmentPhase before Concept Select and the choiceof development concept must be made givingfull weight to any environmental concerns.

79. See BEIS guidance23 for further information onthe preparation and submission of an ES. Thetimescale for the approval of anES may vary from project to project.

21 https://www.ogauthority.co.uk/exploration-production/asset-stewardship/expectations/22 https://www.ogauthority.co.uk/exploration-production/development/enhanced-oil-recovery/23 https://www.gov.uk/guidance/oil-and-gas-offshore-environmental-legislation

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17Requirements for the planning of and consent to UKCS Field Developments

Figure4:AuthorisationPhase

80. During the Authorisation Phase the Licenseesare required to undertake a number of activitiesin support of their application to obtain consentfrom the OGA to install facilities and producehydrocarbons.

81. At the end of the Authorisation Phase the FieldOperator, on behalf of the Licensees, shouldsubmit an application via the UK Energy Portalfor the necessary consents to be issued.24 Theissuing by the OGA of a Development andProduction Consent for the proposeddevelopment via the UK Energy Portal indicatesthe completion of the Authorisation Phase.

EconomicEvaluation

82. Towards the end of the Authorisation Phase, theFieldOperatorshouldsubmitfinaldetailsoftheproject economics in the SET format to account foranysignificantchangestotheEconomicEvaluationprovided at the earlier Assessment Phase. TheField Operator should provide this informationfor the chosen development concept prior tointernal approval of the project by Licensees.

SupplyChainActionPlan

83. In the Authorisation Phase, the Field OperatorshouldsubmititsfinalSCAP.Itisrecommendedthat the SCAP be submitted to the OGAprior to internal approval of the developmentby the Field Operator and the Licensees.

5. Authorisation Phaserequirements

24 https://www.ogauthority.co.uk/licensing-consents/consents/production-consents/

OSD

RIn

dust

ryOGA

ConceptselectedFieldOperatorAppointed

(byLicensees)

Regularupdates withOperator

Prepare:SCAPPEP

UUOA(ifrequired)ES

DecomSecurityArrangementDN(ifrequired)

Review and scoreSCAPReviewPEPReviewSETApproveField

OperatorIssueProposed

FieldDetermination

DraftFDPHost Facility Addendum (ifrequired)

ReviewFDPReview Financial

ViabilityandCapacity

DevelopmentandProduction

consent issued

FIDSubmitFinalFDP

Move to ExecutePhase

AuthorisePhase

BEISReviewEnvironmentalStatement(ES)BEISReviewDecomSecurityArrangements(DSA)

HSEDesignNotification(DN)

ES,DSAandDNReviewcomplete

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18 Requirements for the planning of and consent to UKCS Field Developments

25 https://oilandgasuk.co.uk/supplychaincodeofpractice.cfm 26 https://www.ecitb.org.uk/Project-Management/Collaboration/Project-Collaboration-Toolkit

84. The SCAP submission should focus on thefollowing criteria as per the OGA guidance:

• Engagement – early and continuedengagement with the supply chain regardingthe specifics of the project, aimed at improvingproject performance. This may extend toevidence of adoption of current industry toolkits such as those outlined in the Oil & Gas UKSupply Chain Code of Practice (SCCoP),25

ECITB Project Collaboration Toolkit26 and theOGA Project Pathfinder Portal.

• Trust – demonstration of trust andempowerment throughout the projectlife cycle – clearly identifying functionalrequirements and subsequently supporting thesupply chain to deliver to their contractualcommitments without bespoke, restrictive orclient-specific requirements.

• Innovation – encouragement and fair evaluationfor the proposed use of alternative/newproducts, processesand/or contracting methodologies.

• Quality – demonstration that historicalperformance, quality, employment practice andsupplier culture is appropriately valued.

85. OncethefinalSCAPissubmittedanassessment process will be undertaken by theOGA. Where all four of the above criteria aredeemed to be acceptable, the SCAP wouldusually be endorsed with no further action.

In cases where one or more of the elements aredeemed to be classed as below expectations,the OGA will seek improvement. In caseswhereimprovementscannotbeachieved,finalendorsement will be withheld pending discussionbetween the Field Operator and the OGA.

86. There is no prescriptive format for a SCAPdocument or on how to prepare the requiredsupporting evidence. It is preferred thatthe SCAP should be submitted as a singledocument where possible and, to aidconsistent assessment, SCAPs should includeas a minimum the following sections:

• Executive summary

• Company overview and contracting policy

• Project overview

• Evidence of engagement, trust,innovation and quality

Engagement

Innovation

Trust

Quality

Figure5:EvaluationCriteria

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19Requirements for the planning of and consent to UKCS Field Developments

ProjectExecutionPlan

87. The Field Operator should provide theOGA with an updated PEP covering theAuthorisation Phase and prepare a PEP forthe Execute Phase of the project, consistentwith Stewardship Expectation SE-05 (RobustProject Delivery) Implementation Guide.

FieldDeterminations

88. TheOilTaxationAct1975statesthatallfieldsmustbe “determined” by a boundary drawn aroundthem. A Field Determination27 will enable theLicensees with an interest in the licenced blocksinwhichthefieldissituatedandLicenseesintheadjacent blocks to understand what constitutesthefieldforbothdevelopmentandtaxpurposes.Thisisundertakenintwostages;first,theOGAwill issue a proposed Field Determination at anearly stage in the Authorisation Phase, utilisingthe geological information that is available to it atthattime.Second,thefinalFieldDeterminationwill be issued when the FDP is consented to.

DevelopmentArea

89. TheFDPmustrelatetoadefinedarea.Inmanycases such area will coincide with the FieldDetermination. However, the Field Operator, onbehalf of the Licensees, may propose that theFDPcoversanarea(the‘DevelopmentArea’)thatdiffersfromtheFieldDetermination.Forexample, where the Field Determination is notunitised the Development Area would usuallyextendonlytothatpartofthefieldcoveredbythe FDP (see below). Another example wheredevelopment well trajectories are outside theDetermination. Another example is a phaseddevelopment, where the Development Area maybelimitedtothatpartofthefieldaddressedinthedetailedfirstphaseproposals.TheDevelopmentArea may be extended with subsequent phases.The Development Area will be agreed with theOGA and documented in the FDP.

UnitisationandUnitOperatingAgreements(UUOA)

90. Commercial and technical disputes mayarise about the optimum development planwhenanFDPisproposedforafieldwherethe Field Determination extends into anarea covered by an adjacent licence.

InsuchcasestheOGAneedstobesatisfiedthatthe ultimate economic recovery of petroleum is maximised and that unnecessary competitive drillingisavoided.Themostefficientwaytosatisfy these requirements, and avoid any possible delay in the consenting process, is for the Licensees to agree with their adjacent Licensees, and propose to the OGA, a unitised development or other commercial arrangement thatfacilitatesafielddevelopment.

91. Where such agreement is not reached ortheproposedfielddevelopmentdoesnotdemonstrably satisfy these requirements,the OGA will wish to understand thecircumstances and give all parties adequateopportunity to make representations.

92. The OGA has powers under the licence modelclauses to require a Field to be worked anddeveloped as a unit between Licensees.The grounds for the use of this power arethat the OGA considers it is in the nationalinterest in order to secure the maximumultimate recovery of petroleum and in orderto avoid unnecessary competitive drilling.

93. If, in any intended development, thereis a likelihood of claims or disagreementbetween adjacent licence groups relatedtothefield’sextent,theOGAshouldbe consulted at an early stage.

94. If a UUOA is put in place by Licensees, thiswill need to be submitted to the OGA forapproval at the same time as the FDP.

95. If the Licensees choose not to enter into aUUOA and propose an alternative commercialarrangement,itmaybeappropriatetodefinetwo or more Development Areas within theFieldDeterminationtodocumentdifferentownershipsinthedifferentpartsofthefield– this should be discussed with the OGAat an early stage in the FDP process.

FieldOperatorapproval

96. Prior to the seeking FDP consent, Licenseesare required to appoint a Field Operator, whichrequires approval by the OGA. The OGA haspublished guidance on that process.28

27 https://www.ogauthority.co.uk/exploration-production/development/field-determinations/ 28 https://www.ogauthority.co.uk/exploration-production/production/field-Operatorship/

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20 Requirements for the planning of and consent to UKCS Field Developments

Hostfacilitymodifications

97. Incaseswhereasatellitefielddevelopmentisto be tied back to existing host facilities it isimportant that the Field Operator of the satellitedevelopment and the operator of the host facilitywork together to ensure an agreed plan for anynecessarymodificationtothehostfacility.

98. The OGA will require a letter of supportfrom the operator of the host facility,endorsed by all co-venturers. The lettershould cover the following points:

• A statement supporting the developmentofthesatellitefield(s)overthehostfacilityand committing the host facility to providethe necessary processing services

• Astatementconfirmingtheintentto execute the required commercialarrangements (Construction and Tie-InAgreement, Transportation, Processingand Operating Services Agreement, etc)

• A summary of the major new equipment/modificationsproposedtobecarriedout on the host facility to supportdevelopment of the satellite

• An assessment of the impact ofthenewsatellitefieldproductionon existing production.

99. Wheretheproposedmodificationsaresubstantialthe OGA may require the operator of the hostfacilitytosubmitanapplicationfortheOGA’sconsenttosuchmodifications,supportedbya document describing the new equipment/modificationsproposedtobecarriedoutonthe host facility to support development ofthe satellite. This application and supportingdocument should be submitted to the OGA atthesametimeasthefinalFDPforthesatellitefield.IftherespectiveFieldOperatorsofthehost facility and the satellite development preferan alternative approach to documenting theproposedhostmodificationsthenthisshouldbe discussed with the OGA at an early stage,especially if the host facility is leased ratherthan owned by the host Field Operator.

100. The OSDR may also require the InstallationOperator of the host facility to submitaDesignNotificationformodificationstothehostfacility’sSafetyCase.

Environmentalstatementconsultation

101. The OGA cannot issue a Development andProduction Consent for an FDP until the EIA processfor the development has been completed.

102. UndertheOffshorePetroleumProductionandPipe-lines (Environmental Impact Assessmentand other Miscellaneous Provisions) (Amendment)Regulations 2017, the Field Operator shouldsubmit a notice of their intention to apply fora Development and Production Consent andto submit a supporting ES. This notice shouldbe submitted to the OGA (copied to BEIS) atthe same time as the ES is submitted to BEIS,usually after the Concept Select decision. AllESs are subject to a period of consultationduring which time any person or body with aninterest in the proposed development may maketheir views known to the Secretary of State forBEIS. Licensees should bear in mind that theconsideration of an ES generally takes severalmonthsandcantakesignificantlylongerthanthisif substantial representations are made by anyof the consultees or members of the public, or ifinsufficientinformationispresentedwithintheES.

103. Once BEIS are content with the informationprovided and that there are no environmentalobjections to the issue of consent for the project,BEIS will issue a letter to the developer advisingthemtothateffectandwillalsonotifytheOGAof the conclusions of the ES review process,and advise the OGA of any environmentalconditions that must be incorporated intoany consent issued for the project.

DesignNotification

104. Where appropriate, the OSDR needs tohave completed its review of the Design orRelocation Notification before the OGA issues aDevelopment and Production Consent.

105. Design Notifications (or Relocation Notificationswhere applicable) need to be submittedby the Installation Operator to the OSDRat an early stage of the design process.The Installation Operator should ensure theOSDR has sufficient time to complete theirreview of the Notification prior to the formalsubmission of a FDP. The OSDR guidelines29

state that the OSDR require three monthsto complete its review of the notification.

106. The Field Operator should advise the OGAof the outcome of the Design or RelocationNotification review, and any necessarysteps needed to implement the OSDR’srecommendations, prior to Development andProduction Consent.

107. The OGA will inform the OSDR when it issues aDevelopment and Production Consent.

29 http://www.hse.gov.uk/pubns/books/l154.htm pages 44 to 46

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21Requirements for the planning of and consent to UKCS Field Developments

Decommissioningsecurityarrangements

108. BEIS Offshore Decommissioning Unit (ODU) needtobesatisfiedthatappropriatefinancialsecurityarrangements for decommissioning are in place.30

ConsenttotheFDP

109. The development will normally be consentedto (pursuant to the applicable modelclauses and/or EIA regulations) once theOGA is satisfied of the following:

• the FDP meets the Licensee’sobligation to deliver MER UK

• the EIA process has beencompleted successfully

• OSDR have completed their review ofthe Design or Relocation Notification

• a Supply Chain Action Plan hasbeen agreed by OGA

• a proposed Field Determination has been issued

• where appropriate, a Unitisation and UnitOperating Agreement has been put in place

• each Licensee has committed funding sufficientfor their share of the development costs31

• the OGA has approved a FieldOperator for the development32

• Where appropriate, the host facilityOperator and coventurers have confirmed theirsupport for the development

• BEIS Offshore Decommissioning Unit aresatisfied that appropriate decommissioningfinancial security arrangements are in place (seeODU guidance notes33 for more information)

110. In the event the Licensees disagree amongthemselves on whether an FDP can besanctioned, the OGA will wish to discussthe proposed FDP with any Licensee whohas not voted to support the project tounderstand their reasons for not doing so.Licensees should note their obligations underthe MER UK Strategy to allow others toseek to maximise the value of economicallyrecoverable petroleum from their licences.

The OGA may be prepared to consent to theFDP if the necessary pass mark has beenobtained under a formal vote called under theprovisions of a Joint Operating Agreement orUUOA or if the Licensees have entered into aSole Risk agreement. Licensees should notethat any FDP submission that is not supportedby all the Licensees is likely to take longer toachieve a Development and Production Consentthan a proposal that is supported unanimously.

Timeframe111. Provided that the process described in this

guidance has been fully implemented, theOGA will usually aim to complete its reviewofthefinalsubmittedFDPwithinonemonth.The early review by the OGA of draft sectionsof the FDP, SCAP and PEP as these becomeavailable will help achieve this aim.

30 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/704675/ Offshore_Oil_and_Gas_Decommissioning_Guidance_Notes_May_2018.pdf31 https://www.ogauthority.co.uk/media/4186/revfinancialguidancev5.pdf32 https://www.ogauthority.co.uk/exploration-production/production/field-Operatorship/33 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/704675/ Offshore_Oil_and_Gas_Decommissioning_Guidance_Notes_May_2018.pdf34 https://www.ogauthority.co.uk/media/3828/se-05.pdf

It is also expected that Project Execution Plan is in place which supports the objectives in the FDP and SE05 Robust Project Delivery expectation.34

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22 Requirements for the planning of and consent to UKCS Field Developments

ContentoftheFDP

111. The FDP should provide a summary of the Licensees’ understanding of the field although more information must be provided if required by the OGA. A suggested structure for the FDP is set out in separate OGA guidance.35

112. The content of the FDP should be agreed with the OGA and will depend on the complexityof the field, the degree of interaction prior to the submission and the issues identified.

113. The FDP will provide a clear explanation ofthe commitments that the Licensees are making (in terms of facilities, number of wells, provision for IOR/EOR, provision for third party access hydrocarbon export routes etc.) to bring forward a sound development, rather than a detailed technical description of the subsurface reservoir or required infrastructure.

114. The actual form of the development and the basis for field management should be described and sufficient detail will be required to permit development and production performance tobe measured.

115. The FDP document should be submitted formally by uploading a digital copy (preferably pdf) as an attachment to the UK Energy Portal application for Development and Production Consent.36

DevelopmentandProductionConsent

116. The issuing by the OGA of a Developmentand Production Consent for the proposeddevelopment via the UK Energy Portalindicates the completion of the AuthorisationPhase. The Development and ProductionConsent will cover both the construction ofthe facilities and other infrastructure, and theproductionofhydrocarbonsfromthefield.

117. The OGA will generally issue ProductionConsents for as long a duration as possible,consistent with the duration of relevant licences,and the technical and investment uncertaintiesassociated with future production. The durationof the initial period of agreed production willusuallyreflectthedegreeofunderstandingofthefield:themoreuncertaintheperformance,the shorter the duration. Subject to theuncertainties involved, the OGA would anticipateadurationofbetweenfiveyearsandlifeoffield.For phased developments, the Developmentand Production Consent will normally befor the duration of the relevant phase.

The OGA may attach conditions to the Consentrequiring the Field Operator to review thedevelopment plan with the OGA if performancefallsoutsideconsentedproductionprofilesorifthefieldisfoundtodifferfromtheassumptionsmade in the FDP to such an extent that there is arisk of a loss of economic reserves. BEIS OPREDmay also require the OGA to insert conditionsin the Development and Production ConsentwhereBEIS’sapprovaloftheESisconditional.

118. Forallfieldsbothupperandlowerlimitsto production levels will be included in theProduction Consent. These will usually bebased on the maximum and minimum casesas stated in the FDP. Licensees shouldhowever note that the OGA cannot issue aProduction Consent at levels that exceedthe maximum production given in the ES.

35 https://www.ogauthority.co.uk/media/3837/fdp-guidance.pdf36 https://itportal.ogauthority.co.uk/eng/fox/oga/OGA_LOGIN/login/

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23Requirements for the planning of and consent to UKCS Field Developments

Figure6:ExecutePhase

119. TheprojectscopeasdefinedbytheFDPand PEP will be implemented during theExecute Phase of the project. At this stage,the Licensees have committed to proceedwith the development and the OGA has issueda Development and Production Consent.The purpose of this phase is for the FieldOperator to execute all required activities (e.g.well construction, engineering, procurement,construction, commissioning/start-up etcand to safely deliver the project objectives.

The end of Execute Phase will be regarded asproductionoffirsthydrocarbons.TheOGA’sexpectations during this phase are set out below.

Monitorprojectexecution

120. The FDP and PEP will include a projectschedule including major decision points andmilestones as well as permitting requirements.As part of the PEP the Field Operator shouldalso discuss and agree an engagement planwith the OGA. During the Execute Phase,progress against the project schedule shouldbe monitored and deviations from the plannedschedule should be reported to the OGA.

6. Execute Phase requirements

Others

Indu

stry

OGA

ExecutePhase

Review HSE Safety Case Safety Case accepted

Projectexecution

commencesasPEP

Prepare:PWA

Flare ConsentPetroleumMeasurements

Safety Case

Ready for First

Hydrocarbons

First ProductionofHydrocarbons

MonitorProjectExecution as

SE-05

ApprovePetroleumMeasurementproposalFlare Consent Issued

PWA

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24 Requirements for the planning of and consent to UKCS Field Developments

Commissioningflareconsentsissued

121. During the commissioning of production facilities,theOGAwillissueflaringconsentswhichwillusually be restricted in duration to between oneandthreemonthsandwillbeforafixedquantityof gas based on an auditable programme.37

Once commissioning is complete and stableoperating conditions have been achieved the FieldOperator may apply for longer durations for theflaringconsentsubjecttoanagreedcumulativemaximum for the duration of the consent.

PipelineWorksAuthorisations

122. Pipeline Works Authorisations38 (‘PWA’) willnot usually be issued until after the FDP has been consented. The OGA has published separate guidance on the PWA process.

123. A Pipeline Works Authorisation or variation should be in place before any pipeline or pipeline system construction or modification works begins. Before submitting an application, the OGA recommend that, the prospective owner informally consults both the OGA and the HSE at the earliest possible opportunity, to discuss the proposed scheme and the regulatory requirements.

124. Where there are no objections, it takes approximately four to six months from receipt ofa satisfactory application to issuing the PWA.In the case of pipelines in respect of which an environmental statement is required under the Offshore Petroleum Production and Pipelines(Assessment of Environmental Effects) Regulations 1999 (as amended), the procedure may take longer. Field Operators must therefore submit applications at least four to six months before construction begins.

SafetycaseacceptedbyOSDR

125. Please refer to the OSDR websitefor further information.

DivergencefromtheagreedFDP

126. Once an FDP has been consented to it isexpected that the development will proceed inaccordance with the Consented FDP and thePEP. The Licensee should inform the OGA of anydeviations to the plan as they become evident.

127. If the Licensees wish to deviate from the agreedFDP they may be required to submit a FieldDevelopmentPlanAddendum(‘FDPA’).

128. It is possible that a change to the consented FDPmayrequireanEIAundertheOffshorePetroleumProduction and Pipe-lines (Assessment ofEnvironmentalEffects)Regulations1999(as amended). The Field Operator shouldcontact OPRED for further information.

37 https://www.ogauthority.co.uk/licensing-consents/consents/flaring-and-venting/38 https://www.ogauthority.co.uk/licensing-consents/consents/pipeline-works-authorisations/

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25Requirements for the planning of and consent to UKCS Field Developments

RequiredfutureConsents

DevelopmentandProductionConsent129. If Licensees wish to continue production beyond

the duration of the initial consent they may applyfor an extension to the production consentvia the UK Energy Portal.39Iffieldproductionperformance is expected to fall outside theupperorlowerlimitsspecifiedintheProductionConsent, the Field Operator may apply via theportal for a revision to these levels. A request toincrease the maximum production in the FDPConsent may also require the Field Operator toapply to BEIS OPRED via the PETS system40 fortheir environmental permits to be revised.

Flaring and venting consent130. Once commissioning is complete and stable

operating conditions have been achievedthedurationoftheflaringconsentwillbeincreased and will be subject to an agreedcumulative maximum for the period. TheOGA has published detailed guidance.41 42

PipelineWorksAuthorisation131. If the Operator wishes to install new

pipelinesorvarytheoriginalspecificationofa pipeline, a Pipeline Works Authorisation orVariation may be required.43

CessationorsuspensionofProduction132. If Licensees wish to cease production

permanently, or if production is to be suspendedfromafieldforanextendedperiod,theOperatorshould contact the OGA to discuss whatnotifications/authorisationsmayberequired.44

RetentionandReporting

133. Licensees have a number of obligations forretention and reporting of data and informationforfielddevelopments.Pleaserefertothe OGAwebsite for additional information.45

ChangesofLicenseeand/orFieldOperator

134. Re-assignmentofaLicensee’sequityinterest46 or changes of Field Operatorfollowing FDP consent require the approvalof the OGA.47 A Change of Control of aLicenseeshouldbenotifiedtotheOGA.48

7. Regulation followingFDP Consent

39 https://www.ogauthority.co.uk/licensing-consents/consents/production-consents/40 https://www.ogauthority.co.uk/site-tools/energy-portal-guidance/#wons-2 41 https://www.ogauthority.co.uk/licensing-consents/consents/flaring-and-venting/42 https://www.ogauthority.co.uk/media/5014/flaring-and-venting-policy-position-website.pdf 43 https://www.ogauthority.co.uk/licensing-consents/consents/pipeline-works-authorisations/ 44 https://www.ogauthority.co.uk/exploration-production/production/cessation-of-production/ 45 https://www.ogauthority.co.uk/exploration-production/asset-stewardship/surveys/46 https://www.ogauthority.co.uk/licensing-consents/licensing-system/licence-assignments/ 47 https://www.ogauthority.co.uk/exploration-production/production/field-Operatorship/48 https://www.ogauthority.co.uk/licensing-consents/licensing-system/change-of-control/

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26 Requirements for the planning of and consent to UKCS Field Developments

Guidance on the preparation and content of offshore oil and gas field developmentplanscan be found on the OGA web site.49

Appendix A: Guidelines for the content of an FDP document

49 https://www.ogauthority.co.uk/media/3837/fdp-guidance.pdf

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27Requirements for the planning of and consent to UKCS Field Developments

Table2:Applicationofguidancebyprojecttypes

WHO ROLES&RESPONSIBILITY

LICENSEES

• Endorse FDP• FID/Confirmcommitmenttofunding• Finalise UUOA (if required)• Appoint a Field Operator• Appoint Installation Operator (if required)

FIELDOPERATOR• Produce FDP on behalf of Licensees• Responsible for engagement with the OGA• Engage with BEIS

INSTALLATIONOPERATOR • Engage with HSE

OGA

• Agreement to Concept Select• Issue Field Determination• Approve Field Operator• Consent to FDP• Issue PWA• Issue Flare Consent• Approve petroleum measurement systems

BEIS

• Review Environmental Impact Assessment• Agree the Environmental Statement• Issue Environmental Permits• Agree Decommissioning Security Arrangements

HSE• ReviewtheDesignNotification• Accept Safety Case

Appendix B: Roles and responsibilities

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