Submissions: Published response
What organisation do you represent? - Organisation
Should the property removal obligation be amended to specifically require titleholders to either remove property or make other arrangements that are satisfactory to NOPSEMA? - Q1 - Y/N
No: Why not?
Should the property removal obligation be amended to specifically require titleholders to either remove property or make other arrangements that are satisfactory to NOPSEMA? - Q1 - property removal obligation requirements
NOPSEMA are not the final user. Reef in situ options should be acceptable to the fisheries department.
Should timeframes for property removal be mandated? - Q2 - Y/N
Yes: At what time(s)? Should it be a legislative or non-legislative trigger?
Should timeframes for property removal be mandated? - Q2 - mandating property removal timeframes
yes the should because nothing is being closed out it a timely fashion. It would push operators to get organised faster. Five years after ceasing production is sufficient to P&A and decomm.
Should a new standalone decommissioning obligation be included within the regime? - Q3 - Y/N
Not Answered
Should titleholders be required to inform government of their overarching plans for decommissioning? - Q4 - Y/N
Yes: At what time(s) should this occur? What is the most appropriate method?
Should titleholders be required to inform government of their overarching plans for decommissioning? - Q4 - overarching plans
These should be updated and auditable to ensure operators have made sufficient provisions on their balance sheets for these liabilities!
Should titleholders be required to periodically update government about decommissioning-related information, including an inventory of infrastructure and its status, and a progress report on decommissioning items of infrastructure? - Q5 - Y/N
Yes: What information should be required and when should it be required?
Should titleholders be required to submit ‘close-out’ reporting after decommissioning? - Q6 - Y/N
Yes: What content should be included in the reporting? When should the reporting be required? Should the reporting be made publicly available?
Should current titleholders be made expressly (in the OPGGS Act) liable for the costs of carrying out their decommissioning obligations? - Q7 - Y/N
Yes: Are there any responsibilities that should be excluded?
Should alternative liability arrangements be included in a revised framework, providing government with the ability to pursue previous titleholders in the chain of ownership if the current titleholder is unwilling or unable to decommission? - Q8 - Y/N
Yes: Should this be implemented retrospectively or only prospectively?
Should alternative liability arrangements be included in a revised framework, providing government with the ability to pursue previous titleholders in the chain of ownership if the current titleholder is unwilling or unable to decommission? - Q8 - alternative liability
I believe this is the case already
Should titleholders be released from liability in appropriate circumstances? - Q8 - Y/N
Yes: What are the circumstances that might be appropriate? Which prescribed point(s) might be appropriate? What additional steps should be taken to ensure decommissioning has been undertaken to an acceptable standard?
Should titleholders be released from liability in appropriate circumstances? - Q9 - liability release
Wells P&A'd.
Structures left in situ as artificial reefs
Should titleholders ever be released from liability for infrastructure left in the marine environment? - Q10 - Y/N
Should titleholders ever be released from liability for infrastructure left in the marine environment? - Q10 - liability release infrastructure left
Once the sea dumping permit is issued and the state or federal fisheries department have accepted liability. Marine structures should be thoroughly cleaned and made stable (i.e. grout filled) and augmented to improve their habitat value to commercial and recreational fisherman.
Should government be able to conduct assessments of a titleholder’s capacity to fulfil its obligations at any time? - Q11 - Y/N
Should industry be required to hold and demonstrate sufficient financial security to meet its decommissioning costs? - Q12 - Y/N
Should industry be required to hold and demonstrate sufficient financial security to meet its decommissioning costs? - Q12 - demonstrate financial security
Government is liable for 40-50% of this liability also. this should be recognised throughout the frame work.
Should a former titleholder operating under a remedial direction be subject to all the duties and responsibilities as if it were operating under their previous title? - Q13 - Y/N
No: Should certain duties or responsibilities be excluded or additional duties or responsibilities included?
Should a former titleholder be permitted to submit risk management plans? - Q14 - Y/N
Should a former titleholder be permitted to submit risk management plans? - Q14 - former titleholder risk mgmt plans
Should a ‘person’ (or another entity other than a former titleholder) be permitted to submit risk management plans? - Q15 - Y/N
Should a new category of title be established to enable a former titleholder to have a current title under which to undertake relevant decommissioning and remediation activities with relevant regulatory approvals? - Q16 - Y/N
Should NOPSEMA and the Minister be permitted to issue remedial directions to all former titleholders?
- Q17 - Y/N
Is there additional research (and/or development) being undertaken relevant to decommissioning that government should be aware of? - Q18 - Y/N
Is there additional research (and/or development) being undertaken relevant to decommissioning that government should be aware of? - Q18 - research current
Exmouth Artificial Reef is the only project underway currently.
We are funding research by NERA and RecFishWest into the stuctures' productivity and social economic value.
Operators perspective (BHP):
https://www.youtube.com/watch?v=CESWkR1q7r8&t=2s
NERA summary:
https://www.nera.org.au/Projects/ExmouthIntegratedArtificialReef
RecfishWest
https://www.youtube.com/watch?v=hgfmveywreE
First Survey
https://www.youtube.com/watch?v=mhtx1fCA5Fw&t=4s
Please note the Subcon have built over 15 engineered reefs in Australia to support recreational fishing operations. We have installed 4 steel jackets standing 12 m tall and weighing up to 90Te each for this express purpose. THere are 4 more funded for installation in NSW in 2019. Their productivity is proven beyond doubt. The science should be focussed now on just how productive these engineered ecosystems can be. We have a real opportunityt o create a win win by enabling operators to save 30% and changing the narrative from "rigs to reefs" which is just another term for "sea dumping" into a conversation aout augmentation and "marine habitat creation". We've enabled operators to not pull out productive ecosystems by enabling them to put more in!
Also check out:
The Artificial Reef Network
https://www.facebook.com/groups/433078633769225/
And this California team
http://www.carereefs.org/news/news-articles/
Is there additional research that should be undertaken on decommissioning, and in particular on environmental standards? - Q19 - Y/N
Yes: What areas should be researched? Should government be involved? Which entities should be involved and what should their roles be?
Is there additional research that should be undertaken on decommissioning, and in particular on environmental standards? - Q19 - research future
The science is comprehensive on reefs.
There should be science completed on encapsulating NORMS by grout filling pipelines left in situ and on the impact of leaving PolyUrethan clad cables on the seafloor.
Should more be done to encourage industry collaboration to help ensure that options for the continued use of offshore petroleum infrastructure in Commonwealth waters are explored prior to its decommissioning? - Q20 - Y/N
Yes: What are the current barriers to collaboration? What is suggested to break these down? Who should be responsible for this? Should government be involved? If so, how?
Should more be done to encourage industry collaboration to help ensure that options for the continued use of offshore petroleum infrastructure in Commonwealth waters are explored prior to its decommissioning? - 20
Operators dont want to set a precedent on what needs to be done to leave sturtcures in situ.
NOPSEMA is saying "give us a compelling case as to why you shouldnt pull these out and we'll consider it".
Its a stand off!
Meanwhile commercial and recreational fisherman are askign for more complex habitat to be placed on the sea floor and the fisheries departments of NSW, Queensland, NT and WA are paying large sums of money to build artificial reefs made form steel jackets that look remarkably like oil and gas platforms!
https://youtu.be/MahYUfW9kIM
Is there interest and merit in creating an Australian offshore petroleum decommissioning industry? - Q21 - Y/N
No: Why not?
Is there interest and merit in creating an Australian offshore petroleum decommissioning industry? - Q21 - Aus decomm industry
Its not significant. We just need to get on with it.
Are there other issues relating to decommissioning that are not covered in this discussion paper and you think it is appropriate for government to be involved in?
- Q22 - Y/N
Yes: What are they? What is the suggested government involvement?
Are there other issues relating to decommissioning that are not covered in this discussion paper and you think it is appropriate for government to be involved in?
- Q22 - other decomm issues
The ability to transfer the title by reefing in situ should eb clarified between departments. A fund should be established similar to california and florida to capture some of the savings for reef conservation and marine science.
Unique ID