Source: Wikipedia

Eric Faulds, who now manages decommissioning consultancy EFA, managed the aborted disposal of the oil storage buoy in 1995. He told Decom World: “The legal requirements are clearly set out, and you can leave the fittings in place and the rest must be removed. It doesn’t make any scientific sense whatsoever but I just cannot see the legislation changing. Having been through the mill and sensing the feeling around [abandonment in place] I don’t see that the climate has significantly changed to undo that thinking.”

The battle of Brent Spar
The Brent Spar was an oil storage and tanker loading buoy that was made redundant after a pipeline was laid between the Brent fields and Sullom Voe in the Shetlands. Shell then opted to tow it into the Atlantic and sink it in deep water, a decision that was supported by the UK government.
This led Greenpeace, with support from the German government, to organise a global campaign that culminated in a widespread consumer boycott of Shell petrol stations, and pressured the company into reversing its decision. Elements of the platform were eventually turned into a quay extension at the Norwegian port of Mekjarvik.
The outcome of the “battle of Brent Spar” was later reflected in Ospar regulations that made removal and onshore disposal a mandatory requirement when decommissioning steel structures in the North Sea – although companies can apply to derogate from the rules in specific instances.

Rigid regulations
These regulations have been widely criticised within the oil and gas industry.
Brian Twomey, the Managing Director of Reverse Engineering Services, said: “The Ospar region is heavily regulated, but I don’t think it’s the right regulation – it’s too rigid.”
Other regions have taken a much more permissive attitude to abandonment, with the concept of “rigs to reef”, that is cleaning and towing structures to a designated marine conservation area, becoming accepted, particularly in the Gulf of Mexico.
Robert Byrd, Vice President of consulting for TSB Offshore, said: “We’re very positive about rigs to reef and we do everything we can to support it. The case in US waters has been well made and we don’t have any opposition. Even the environmental groups support it.”

The view from the NGOs
In the North Sea area, environmental groups remain as opposed to disposal at sea now as they were in 1995.
Melissa Moore, the senior policy officer with the Marine Conservation Society, said: “Our view is that we should stick with the Ospar requirements. I know that the industry is getting up a bit of a campaign to revisit the Ospar requirements but I think it would end up in a similar NGO campaign.”
“There is an industry-sponsored campaign to get NGOs onside, and certainly ourselves and WWF and others are very concerned about this. We do a big campaign on litter involving about 10,000 people cleaning beaches and we see [disposal at sea] as littering on a massive scale and our supporters wouldn’t be happy if we changed our view,” Moore added.

The chance for change?
The first opportunity to make a cost for a relaxation of the regulations will be the Ospar review conference in 2018, and Moore said the industry will be aiming to open the question of abandonment in place at this conference.
John Paterson, the professor of law at Aberdeen University, told Decom World that although there were “some question marks” over Ospar regulations, they would not be easy to reform.
“If we do see an upwelling of support for the idea that Ospar is a bit narrow-sighted, the question is: how do you change that? They are reviewed every five years, but the wording of the review is that it’s a ratchet: you can review but only with a view to further limiting derogation cases. So my question is, which political actor is going to stick their heads above the parapet and say, post Brent Spa, we ought to widen the number of derogation cases?,” Peterson said.
“The Ospar is overseen by an intergovernmental commission based in Norway and my sense is that unless there were to be a really compelling argument, most governments would think, do we really want to deal with the backlash?,” Peterson added.

Changing the minds of the NGO's
This assessment was shared by Shell in the dossier it compiled in the aftermath of the battle of Brent Spa.
In that, Faulds commented on the original disposal plan: “We had made scrupulous analyses and identified a disposal plan with the least technical risk, lowest exposure of the workforce to accidents, an insignificant impact on the environment and lowest cost. Why couldn’t we carry it out?”
“Was it just because people had been misled by the many inaccurate Greenpeace allegations? It wasn't only that. We realised that our work had followed our normal technical procedure and regulatory compliance, but with limited analysis of potentially wider issues and external sensitivities.”
The conclusion that Shell came to was that it had to do “much more open communicating, and consulting and listening”, and this effectively means that, as Peterson argues, any change of policy will have to be made with the support of environmental NGOs.
Professor Booth, for one, is optimistic that a compromise can be found based on the objective evidence. He said: “What we can do is work to combine our knowledge and work with stakeholders groups, such as conservation NGOs and marine ecologists, to rate decommissioning options on different criteria, such as biodiversity or toxicity. The work we’ve done so far suggest that there might be a surprising similarity of opinion between us and the NGOs, and this way you might get more ownership from the NGOs, who really are receptive to the science.”