Memorandum submitted by Platform.
1. The BP spill in the Gulf of Mexico is but the
latest reminder of the dangers inherent in the extraction of oil
and gas. Much is being made of the technical failures of BP's
operation and the difficulties facing all deepwater operations
and their reliance on the cutting edge of engineering and technological
capability. This memorandum argues, however, that beyond the technical
considerations, deepwater operations, ageing infrastructure, and
frontier oil expansion has not been matched with an appropriate
level of regulation on the part of government, and a lack of overall
rigour and stringency required to protect the UK public and environment.
2. A very narrow definition of "energy security",
with a strong bias towards continued reliance upon fossil fuels,
is increasingly being instrumentalised in both domestic and foreign
energy policy. The push into the oceans, drilling into ever-deeper
waters and increasingly far offshore has been driven and defended
in significant part by governments demanding "energy security".
Sensitivities over "imported oil" and "unreliable
producers" have helped bolster the demands of oil companies
to open up deepwater licence areas in the UK.
3. In the UK, expansion into the deep waters in the
West of Shetland and more remote offshore blocks around the British
Isles are justified along similar grounds as in the US. In January
2010, when Chancellor Alastair Darling announced record tax breaks
for oil and gas companies wishing to exploit the West of Shetland,
he justified it by saying: "The Government recognises the
importance of the UK oil and gas industry to our economy and the
dependable foundation it provides for the UK's energy security."
4. A June 2009 report from the Energy & Climate
Change Committee recommended exploiting deepwater gas resources
off the west of Shetland, having re-affirmed that: "When
determining policy on UK oil and gas, the Government's priority
should be security of supply." This support for expanded
exploration came despite industry bodies admitting that the region
was hampered by a, "hostile marine environment, extreme weather
and the shortage of infrastructure" making projects, "high
risk and technically challenging". The Committee pushed the
government to "take a more active role" that would "not
preclude assistance with funding."
5. In his first week on the job, Chris Huhne, Minister
for Energy and Climate Change, spoke at an industry conference
in Aberdeen where he gave unequivocal support for continued expansion
into the North Sea. "There could be 20 billion barrels of
oil equivalent left to exploit," he said adding, "but
the UK competes against every other basin in the world for investment
and I am committed to make sure that we have a licensing regime
and investment environment that attracts quality companies and
investment to fully exploit the remaining potential. We will work
closely with the industry to ensure that we can achieve just that."
Emphasising the importance of energy security in the new government's
thinking, he stressed: "Energy security, for too long a second
order issue, will be put back at the heart of our national security
strategy. The oil and gas sector should take encouragement from
6. The UK government, led by the Foreign Office,
has also been pursuing an aggressive international diplomacy drive
to increase opportunities for British oil and gas interests in
remote and frontier areas. This is being done in a manner that
is likely to increase reliance on fossil fuel imports, conflict
with climate change goals, and create opportunities for diplomatic
friction with other states while providing little real benefit
to UK citizens. The most recent cabinet report on the UK's National
Energy Security Strategy outlines the government's commitment
to furthering UK oil and gas interests abroad: "Energy reserves
are increasingly found in remote areas and it is therefore essential
that the UK is able to contribute to a system that allows UK companies
to participate safely in the extraction of these fuels and that
provides for secure delivery routes for fuels to the UK."
7. One of the most damning critiques of the Gulf
oil spill was the revelations of the degree of influence that
oil companies held over key arms of the US government including
regulators as well as policy departments. The British government,
led by the Foreign Office with support from various departments,
provides worrying levels of privileged access and support for
the private commercial interests of British oil and gas companies
in matters of state.
8. Foreign Secretary William Hague, recently described
the support of British business as "an existential mission
for the Foreign Office".
The level of diplomatic support afforded to British oil and gas
companies internationally is a little acknowledged form of subsidy
easily amounting to several millions of pounds annually in person
hours, logistical support and consulting services. The diplomatic
support companies like BP and Shell receive, has been instrumental
in them gaining controversial contracts in places like Libya,
Iraq, Azerbaijan and Russia.
9. The appointment of controversial business leaders
to key government positions is also cause for concern. Shortly
after the new coalition government took office, Lord John Browne
of Madingley was appointed to head the UK government's cost-cutting
and efficiency drives. Browne, former CEO of BP, is under fire
for instituting drastic cost-cutting measures in BP, which have
been slammed by US officials for being partly to blame for major
environmental disasters and accidents that have led to the tragic
deaths and injuries of workers. These include oil spills in the
Alaskan Arctic, the Texas City refinery disaster, and the current
crisis in the Gulf of Mexico.
Lord Browne will also be making recommendations for further appointments
of business leaders into influential positions within government.
10. Former Monument Oil & Gas CEO and Non-Executive
Director of ENI Lasmo, Tim Eggar, has been advising the Chancellor
George Osborne on ways to streamline the tax system in the UK
in order to promote more offshore oil and gas development. Eggar's
report is currently unavailable to the public.
This, despite the fact that the current licensing round has had
a record number of bids since offshore licensing began.
11. Several Permanent Under Secretaries to the Foreign
Office since the early 1990s, have since gone on to take up Director
positions in major oil and gas companies including Shell and BP.
Robert Paterson, a former HSE lead offshore inspector, is now
working for the UK oil lobby group Oil and Gas UK.
12. It is our view that these close links between
the oil and gas industry and the government, undermine public
confidence in the ability to regulate and legislate effectively
at home, and complicate and possibly jeopardise international
relations abroad. It also makes it difficult to institute meaningful
institutional changes required in the face of climate change and
13. Despite recent assurances from the Department
of Energy and Climate Change that the UK offshore regulatory regime
is "fit for purpose", there is a concern that cost-cutting
measures, lack of capacity and resources, a general trend towards
"light-touch regulation", and a desire to swiftly expand
offshore production will lead to insufficient oversight of the
14. In the wake of the Gulf of Mexico disaster, there
has been much condemnation of the failures of the US regulatory
regime. In contrast, the regulatory systems of the UK and Norway
have been held as shining examples of best practice. But greater
scrutiny of the reality of the supposed gold-standard regimes
of these two countries raise critical issues with regards to current
practice and capacity.
15. The 26th licensing round for offshore oil and
gas in the UK Continental Shelf (UKCS) has attracted record bids.
356 bids for blocks in all parts of the UKCS have been made, the
highest ever since bid rounds began. Particular interest has been
in the West of Shetland region - the deepest waters in the UKCS.
The record interest will require regulatory oversight over the
new exploration programmes, appraisal well drilling, sub-sea infrastructure
development, pipeline management, spill response and production
and transport apparatus.
16. Regulators from the Health and Safety Executive
(HSE) will also be required to inspect the 293 offshore platforms
currently in operation, thousands of kilometres of pipeline and
sub-sea infrastructure, and related facilities.
There are 115 inspectors employed by the HSE to supervise all
this activity as well as provide health and safety guidance for
the approximately 20,000 workers in the offshore industry.
The concern is that there is insufficient capacity in the HSE
to adequately monitor, regulate and enforce offshore oil and gas
operations in the UKCS at a rigorous enough level.
17. Concerns are also being expressed with regards
to the changing culture and attitude to regulation at the HSE.
Academics at Liverpool University and Liverpool John Moores University,
have recently completed a study into health and safety regulation
of business. They found that in the last ten years: "The
number of inspections made of business premises have fallen by
69% and investigations of health and safety incidents have declined
by 68%. The study also found a 48% reduction in prosecutions of
companies who have breached HSE regulations over the same period.
One of the report's authors, Dr David Whyte, observed that: "The
collapse in inspection, investigation and enforcement has dramatically
reduced the chances of businesses being detected and prosecuted
for committing safety offences. Most serious injuries now are
not even investigated."
Health and Safety
18. The UK Government does not monitor abandoned
or suspended wells in the UK Continental Shelf. As many as several
hundred abandoned and suspended wells may have slow leaks, fractures,
corrosion and other worrying characteristics that could prove
disastrous for the region if they continue to be left unmonitored.
19. The HSE does not currently monitor what happens
to such wells in UK waters. At the time of this submission there
have been 10,972 wells drilled in UK waters since the 1960s.
Several thousand of these have been "abandoned" by the
companies. According to a number of studies of abandoned wells
in the United States, it has been found that a high percentage
of wells can rupture and leak over time due to poor cement work,
erosion/corrosion, and subtle shifts in geology.
A recent six-kilometre oil slick in the Danish North Sea has baffled
agents from the Environmental Protection Agency in Denmark, leading
some to suggest that the source of the oil slick could be a leaking
Freedom of information requests to the HSE have revealed that
the UK offshore regulator does not monitor abandoned wells in
the UKCS, and recommended that: "The best source for this
information is most probably going to be the individual licensees."
20. The Department for Energy and Climate Change
(DECC) does maintain a database of existing wells, however it
has no monitoring role over abandoned wells.
The lack of oversight of abandoned and suspended wells is cause
for serious alarm. Some US studies have indicated that onshore
well failure rates were projected to be as high as 17%, and warned
that offshore wells may likely have a higher failure rate due
to the harsher conditions.
If a similar rate were applicable to the offshore wells in the
UKCS, several hundred abandoned wells may be slowly leaking and
poisoning the local environment and wildlife. A major leak is
21. Leaks may also go undetected due to the way hydrocarbons
interact with the cold waters of the North Sea. A study by Det
Norske Veritas (DNV) - an industry consultancy -
found that subsea plumes would likely form in the thermoclimes
of the North Sea waters and travel great distances before any
oil might appear on the surface.
The study also raised concerns about the length of time deepwater
operations might require to drill a relief well. One of the aspects
of the Gulf of Mexico spill that is under investigation is the
procedure used to cement the well. If a high-pressure or repressurised
abandoned well in UK waters were to rupture, it could cause a
major environmental and economic disaster for the region.
22. An industry study of blowouts in the deepwaters
of the Gulf of Mexico and North Sea suggests that the potential
failure rate for blowout preventers (BOPs) in these environments
can be as high as 45%. A widely reported study by Det Norske Veritas,
commissioned by drilling contractor Transocean - the company that
owned and operated the ill-fated Deepwater Horizon rig - examined
11 cases where rig managers operating in deepwater areas had to
activate a blowout preventer as a final failsafe due to loss of
well control. Blowout preventers are the last line of defence
in the event of an unstable build-up of pressure in a well. They
usually contain several redundant mechanisms designed to seal
the well in order to prevent hydrocarbons escaping up the well
and potentially igniting on the platform as happened in the Deepwater
Horizon explosion. Out of the 11 cases where a BOP was triggered,
only six actually succeeded in preventing a blowout. The researchers
concluded that as a result of their findings, the industry failure
rate for blowout preventers in deepwater areas was a staggering
23. Industry groups insist blowouts are very rare.
However, given that drilling engineers use a variety of methods
to maintain well pressure and prevent so-called "kicks"
of pressure escaping up the well, even a moderate number of blowouts
should be cause for alarm. In most cases, their occurrence signifies
that there was in fact a dramatic cascade of concurrent failures
in the well operation. Blowouts are not as rare as many would
like to believe. Overall, there have been a total of 237 blowouts
in the Gulf of Mexico and North Sea recorded in the period between
1 January 1980 and 1 January 2008 and 573 recorded worldwide.
24. A recent spate of serious incidents in the North
Sea underline the inherent risks in all oil and gas extraction
projects, and the seeming inability of the industry to demonstrate
global excellence in health and safety standards despite the numerous
painful lessons of the past. A recent incident in the Norwegian
North Sea at Statoil's Gulffaks C platform gives pause for concern.
On 21 May 2010, an "unstable well event" led to a dangerous
level of pressure build-up. This pressure led to the failure of
one of the valves of the well's blowout preventer. All 90 rig
workers were forced to evacuate and the event was categorised
as "critical". The remaining valve managed to withstand
the escaping pressure and the operations have been shut down for
two months. The well itself has now been plugged, and one of the
senior Statoil staff described the conditions of the well as a
"high pressure zone in the Shetland/Lista formation"
suggesting that other well operations in the region may also encounter
problems with the high pressure hydrocarbon deposits present.
This would be the eighth incident in Norway that had "large
scale potential" to cause a major disaster since the beginning
25. Shortly after the Gullfaks C shutdown, a major
gas leak discovered at the massive Troll fields in the North Sea
would also lead to a major shutdown and reduction of gas flows
to the UK as a result. This would be second time this year that
production would be stopped due to a major gas leak.
Blowouts and gas leaks have been at the root cause of many of
the world's worst accidents involving offshore platforms. The
infamous Piper Alpha explosion in 1988, which resulted in the
deaths of 167 workers, was the result of such a leak.
26. Nearly half of all offshore installations in
the UKCS are operating beyond their original design life. While
the Health and Safety Executive has been proactive in working
with industry to address the unique challenges of maintaining
ageing infrastructure and ensuring best practice, there nevertheless
remain concerns about the continued reliance on decades-old technology
and infrastructure. Of the 289 installations active in the UKCS,
93 are older than 30 years old - 43 of those have been in active
service for over 40 years, all in the Southern North Sea region
close to the Scottish coastline.
The typical design life of a platform is between 20 - 25 years.
That would suggest that nearly half of all installations are operating
beyond their expected design life.
27. A 2008 report by Norwegian industry researchers
SINTEF expressed serious concerns over the ability for companies
and regulators to cope with ageing installations in the North
Sea due to a lack of knowledge and experience, absence of coherent
standards and procedures, and lack of sufficient regulatory capacity
to provide more frequent and comprehensive regulatory scrutiny.
The group called for a root-and-branch assessment of ageing platforms
and a robust assessment of their extensibility.
28. While improvements have been made, the overall
record of industry in the North Sea since the Piper Alpha explosion
in 1988 is still patchy and bears greater scrutiny. After the
Piper Alpha incident and resultant Cullen Inquiry into the industry,
there has been a presumption that the UK regulatory regime had
become one of the strictest and best performing in the world.
However, the record to date has been disappointing in many respects.
29. There has been a marked increase in the number
of "Notice of Improvement" issued by the Health and
Safety Executive to offshore platform operators in the past year.
In that time period, BP has been served with 14 notices - seven
for its West of Shetland operation in Schiehallion alone, just
18 months after a fire required the evacuation of staff there.
In the past few years, serious concerns have been raised about
the safety culture of companies operating in the North Sea.
30. In 2003, the cost-cutting measures of Shell were
alleged to be responsible for the death of two workers and the
near explosion from a gas leak at the Brent Bravo platform in
the East of Shetland region. "Shell's negligence came close
to destroying the platform that day and killing another 105 souls
who were on board," remarked Jake Molloy from the Oil Industry
Liaison Committee/Rail, Maritime and Transport union.
Despite the negative publicity and record fine of £900,000,
the company's safety record has consistently been among the worst
in the industry as it has continued to insist on deep cost-cutting
31. According to industry journal Upstream Online
in 2008, Shell had been "by far the worst performer"
having received 6 out of a total of 18 legal notices issued by
the HSE over a two-and-a-half year period.
The article revealed that Shell had received more notices than
any other operator working in the UK North Sea. A Financial
Times investigation in the same year found that, globally,
Shell had the highest worker death rate than any other Western
A recent investigation by The Press and Journal, found
that between 2006 and 2008 the HSE was involved in 1,042 incidents
offshore. Among these were 841 "dangerous occurrences"
and 192 accidents.
According to Carlo von Bernem, marine biologist and expert on
oil pollution and coastal zone management at the German Institute
for Coastal Research: "It is a wonder that an oil spill of
the dimensions of the present one in the Gulf of Mexico has not
32. The "normal" operation of offshore
platforms and their attendant infrastructure - including pipelines
and tanker traffic, as well as the relatively high frequency of
unintended hydrocarbon releases - has resulted in the equivalent
of a slow Gulf of Mexico-sized leak in the last two decades.
33. The steady waste from offshore oil and gas operations
is routinely, and legally, dumped into the surrounding waters
after some processing. The result is that in the whole of the
North Sea, an estimated 10,000 tonnes of waste hydrocarbons is
released into the water each year according to marine pollution
expert Christian Bussau.
A further 10,000 tonnes is estimated to be illegally dumped by
tanker traffic in the region. The combined effect of hundreds
of platforms, tanker traffic, pipelines and well leaks, makes
the North Sea "one of the most contaminated maritime areas
of the world," according to Bussau.
The slow multiple-sourced leak of this magnitude poses a major
threat to marine ecosystems and wildlife such as fish stocks and
the livelihoods that depend on them, as well as impacts on tourism
and other local economic impacts. Over a 25 year period the amount
of pollution would be roughly equivalent to the Gulf of Mexico
spill in volume.
34. As operations move into new areas and deeper
waters, concerns mount that threatened ecosystems and marine habitats
for endangered species will be severely impacted. Last year, for
example, the British Geological Survey found previously unknown
pristine deepwater coral reefs in the waters around the Rockall
Basin - an area recently opened up for bidding by prospective
companies in the 26th Seaward Licensing Round of the UK.
35. The number of non-permissible hydrocarbon releases
into UK waters has seen a sharp increase on previous years. Compared
with the year before, the number of minor and "significant"
hydrocarbon releases into the sea in 2009-10 has increased by
20%, and major incidents have doubled.
A total of 182 spills have been reported in the period, up from
157 the year before. This despite the fact that the industry together
with the HSE has committed to making 10% reductions in hydrocarbon
releases year on year. The trend of increasing spills is likely
to increase, as according to the HSE, the majority of hydrocarbon
releases happen at facilities older than 20 years old, of which
more than 50% of existing platforms fall under that category.
36. The controversial drilling programme currently
underway in the Falkland Islands is directly supported by British
government agencies and staff. The current exploration campaign
taking place in the Falkland Islands, including several deepwater
areas, has already uncovered one significant oil discovery and
prompted much speculation about a major new oil province opening
up in the South Atlantic. The sheer remoteness of the location,
and the fractious history of the region give pause for concern
about the potential impacts of any major development of offshore
oil and gas in the region. The UK government claims to take a
hands-off role with regards to the internal affairs of the Falkland
Islands government, but the reality is that British government
provides critical support to exploration companies and has had
a direct hand in developing the territory's offshore licensing
37. Foreign Office officials, keen to stress the
right to self-determination of the Falkland Islands, nonetheless
acknowledge that every stage of the offshore licensing round in
the Falklands Islands has had "ultimate sign-off by the Foreign
It is estimated that over 30 members of staff and senior government
officials across departments including the Department for Energy
and Climate Change (DECC), and the Ministry of Defence (MoD) are
regularly involved in discussions, consultations, policy development
and planning about energy strategy in the Falkland Islands.
At the time of this writing, Foreign Secretary William Hague has
been personally briefed on the Falkand Islands oil exploration
progress several times since taking office.
38. There are serious safety, political and environmental
concerns about the drilling programme underway in the Falkland
Islands. FCO officials have stressed that the Falklands explorations
programme is "constantly reviewed in order to ensure that
it is up to UK standards".
But analysis of the environmental impact statements of the companies
currently drilling in the remote waters raises serious concerns,
particularly in light of the BP spill in the Gulf of Mexico. Environmental
impact assessments carried out by UK-based consultancy RPS Energy
for four of the five companies planning to drill in the Falkland
Islands, has played down the risks of a blowout as "extremely
rare" and suggests that risks of an oil spill reaching the
shores of the Falkland Islands are "negligible".
As a result, the company has advised against the need for any
shore-based oil spill response measures to be put in place arguing
that they are "impractical and unwarranted".
39. Without sufficient support infrastructure in
place in the Falkland Islands, oil spill response crews and equipment
would have to be imported. In the event of a major spill, the
company suggested that airplanes can be flown in from the UK mainland
in order to spray chemical dispersants. Only two support vessels
are available to assist in any major response. A secondary rig
could take as long as three months to reach the Falklands from
the UK in order to begin drilling a relief well. The BP oil spill
response operation is currently deploying thousands of vessels
and has brought in two rigs from nearby locations to assist in
relief well drilling. In the remote context of the Falklands,
any extra support apparatus would take a significant length of
time (it took approximately three months for the drilling rig
Ocean Guardian to reach the Falkland Islands from Scotland) to
mobilise, causing potential delays to any response operation.
40. The contingency plan also includes a provision
to use the controversial dispersant Corexit 9500 manufactured
by American company Nalco.
Use of Corexit is restricted in the UK, after failure of the rocky
shore tests required for its approval,
and there remain concerns over the overall effects on shore-based
animals and wildlife as well as the general toxicity of the product
and its effects particularly on fish and marine mammals.
Two million gallons of the product has been used in cleanup operations
in the Gulf of Mexico despite a public outcry and major concerns
by lead scientists.
41. There are also concerns about the financial and
insurance safeguards in place in the event of a major accident.
To date, all the companies involved in the drilling programme
are AIM-listed small-to-medium capitalisation companies. A Gulf
of Mexico-type disaster could bankrupt such smaller companies,
leaving the UK taxpayer liable for the costs of the cleanup and
any compensation claims. After the Gulf of Mexico spill, the DECC
announced it would review the indemnity and insurance requirements
for operators in the UK Continental Shelf, but this would not
include the Falkland Islands, and is unlikely to come into force
in the current year.
42. BP, Shell and their competitors have identified
the deep sea floor as a key exploration area for current and future
efforts to replace their reserves. At the same time, civil servants
and politicians who formulate and implement energy policy in both
the UK and US describe the exploitation of offshore oil and gas
as a solution within the frame of "energy security".
This perception of overlapping interests has defined much of UK
and US foreign and domestic energy policy, and led to mutual support
in colonising the oceans for fossil fuel extraction. Actors from
both the corporate and public sectors have been outspoken in promoting
the urgent need to explore the outer reaches of the continental
43. British and American state support through various
government departments and agencies has helped ensure that oil
companies have both formal and informal regulatory, fiscal, diplomatic
and social "licences to operate" in the deep waters
off the US, Brazil, Angola, Azerbaijan and elsewhere. The oil
majors have developed the technology and hired the contractors
to build rigs that will drill and pump thousands of feet down
through water and rock. Yet no-one has adequately created the
means to deal with the situation when the engineering breaks and
the house of cards collapses.
44. The Gulf of Mexico disaster shows that government
policy driven by the current dominant "energy security"
discourse fails to deliver "security" on many levels.
And while we can expect certain ripples from the unfolding crisis
in the Gulf to impact the industry as a whole, the long view from
insiders suggests that continued expansion into ever more riskier
environments is widely seen as an inevitability. However, that
is predicated on the assumption that the "energy security"
paradigm retains its primacy in decision-makers minds and public
attitudes. Recent events may throw that assumption into question.
45. In light of the crisis unfolding in the Gulf
of Mexico the United States, Canada, and Norway have imposed various
restrictions on new offshore drilling. A recent speech by EU Energy
Commissioner Günther Oettinger advocated a Europe-wide moratorium
arguing that, "any authority in the world (not only in the
US or in Europe) would be advised to implement a precautionary
The UK has so far resisted instituting a freeze on new drilling
permits, arguing that its regulatory regime and safety record
is "fit for purpose".
46. But even a cursory glance at: the health and
safety record of the industry in the North Sea; the increasingly
ageing infrastructure; the increases in hydrocarbon releases;
the lack of regulatory monitoring of abandoned wells; the data
demonstrating major concerns over the reliability of failsafe
mechanisms; the expansion into new deepwater areas; and the increased
workload on the regulators in an era of cost-cutting and "light-touch
regulation" are all sufficient reason to suspend new permits
and institute a root-and-branch review of the industry and the
regulatory regime. In particular, any expansion into deepwater
offshore, both domestically and in British Territories such as
the Falkand Islands, must be put on indefinite hold.
47. The role of the Foreign Office and other arms
of government must also be held to account. British foreign policy
should be every much subject to public debate and challenge as
any other aspect of government, not myopically fixated on promoting
narrow commercial interests. The degree of direct and indirect
support afforded to British oil and gas corporations at the highest
levels of office, cast doubts on the government's commitment to
transparency, democracy and accountability, and the UK's reputation
as a responsible global citizen and leader on climate change suffers
as a whole when companies like BP cause such untold damage in
48. A broader critique of "energy security"
discourse is also sorely needed. The instrumentalisation of a
very narrow definition of energy security lies at the heart of
domestic and foreign policy. Its use and misuse in advancing a
course of perpetual reliance and dependency on offshore drilling
and fossil fuels as a whole, flies in the face of the urgent need
to address the root causes of climate change and a just and meaningful
transition to a fossil-fuel free economy that does not adversely
impact workers and the economy.
49. The work that the Committee on Energy and Climate
Change in this regard is therefore critical. We look forward to
providing further evidence in person and thank you all for the
opportunity to address these issues.
16 Alastair Darling, "Tax boost for West of Shetland
gas fields", HM Treasury, Press Release, 27 January 2010.
House of Commons Energy and Climate Change Committee, "UK
Offshore Oil and Gas: First report of session 2008-2009",
Vol 1, 17 June 2009. Back
Chris Huhne, "Huhne Backs Aberdeen's Energy Industries (Press
Release)", DECC Press Release, 20 May 2010. Back
Cabinet Office, "UK National Security Strategy: Report on
Progress 2010", 18 March 2010. Back
Foreign Secretary William Hague as quoted in: George Parker, James
Blitz and Alex Barker, "Hague vows to defend embassy network",
Financial Times, 13 July 2010. Back
See for example: "The Report of the BP U.S. Refineries Independent
Safety Review Panel", which concluded that with regards to
the Texas City refinery disaster in 2005: "The Panel believes,
however, that the company did not always ensure that adequate
resources were effectively allocated to support or sustain a high
level of process safety." Back
Robin Pagnamenta, "Business Big Shot: Tim Eggar, former Energy
Minister", The Times, 18 February 2010. Back
Department for Energy and Climate Change, "Energy Minister
gives go-ahead to new North Sea development", DECC Press
Release, 28 June 2010. Back
Sir Anthony Acland (Permanent Under-Secretary of State, Foreign
& Commonwealth Office, 1982-86; Ambassador to USA 1986-91;
Non-Executive Director of Shell 1991-99), Baron Kerr of Kinlochard
(PUS, FCO, 1997-2002; Non-Executive Director, Shell, 2002 to date;
currently Deputy Chairman), Lord Wright of Richmond (PUS, FCO,
1986-1991; Non-Executive Director BP 1996-2001); and Sir John
Coles (PUS, FCO, 1994-1997; Non-Executive Director BG plc 1998-2008). Back
DECC, "Existing UKCS installations", July 2010. Back
Oil & Gas UK, "Background Information", Oil &
Gas UK Knowledge Store,
Prof Steve Tombs and Dr David Whyte, "Regulatory Surrender:
death, injury and the non-enforcement of law", Liverpool
University, 13 July 2010. Back
US Government Accountability Office, "Offshore Oil and Gas
Resources: Interior Can Improve Its Management of Lease Abandonment",
GAO, RCED-94-82, 11 May 1994. Back
Anthea Pitt, "New spill in Danish North Sea", Upstream
Online, 23 June 2010. Followed by Freedom of Information requests
to the Danish Environment Ministry MIM - Miljøministeriets
Informationscenter on 24 June 2010, and Danish Energy Agency -
Energistyrelsen 12 July 2010 (pending). Back
Freedom of Information request to Health and Safety Executive
Reference No. VBRY-876DPY, 8 July 2010. Back
DECC, "Well Data", https://www.og.decc.gov.uk/pls/wons/wdep0100.qryWell
A Freedom of Information request regarding
DECC management of abandoned wells is still pending at the time
of this writing. Back
Jeff Donn and Mitch Weiss, "Gulf awash in 27,000 abandoned
wells", Associated Press, 6 July 2010. Back
Jesse Uzzell and Aage Bjørn Andersen "A Response Plan
For Deep Sea Blowouts In The North Sea: Monitoring The Subsea
Plume", Det Norske Veritas AS, #110, International Oil Spill
David Barstow, Laura Dodd, James Glanz, Stephanie Saul and Ian
Urbina, "Regulators Failed to Address Risks in Oil Rig Fail-Safe
Device", New York Times, 20 June 2010. Back
SINTEF Offshore Blowout Database, http://www.exprosoft.com/products/pdf/BlowoutDatabaseWeb.pdf Back
Acting head of Gullfaks drilling and well operations, Rune Gaaso,
as quoted in "Gullfaks C production resumes", Upstream
Online, 14 July 2010. Back
Wojciech Moskwa and Gwladys Fouche, "Statoil evacuates North
Sea platform due 'unstable' well", Reuters, 21 May
Angela Henshell, "Gas Leak Halts Production at Norway Troll
A Field", Dow Jones Newswires, 29 June 2010. Back
DECC, "Existing UKCS Installations", July 2010. Back
Alexander Stacey, "HSE Research Initiatives on Ageing Offshore
Installations in the UK", The International Committee on
Regulatory Authority Research and Development (ICRARD). http://www.icrard.org/templates/Page____464.aspx Back
"Aging oil platforms focus minds in Norway", Scandinavian
Oil & Gas Magazine, 26 November 2008. Back
Jake Molloy, "The High Price of Cost Cutting (again)",
Chris Hopson, "Under fire: Shell is feeling the heat over
its Brent Bravo safety record", Upstream Online, 14
March 2008. Back
Ed Crooks, "Shell deaths higher than other western groups",
Financial Times, 30 November 2008. Back
Stephen Christie, "Alarm over hundreds of offshore incidents",
The Press and Journal, 9 February 2009.
Julio Godoy, "Oil Spill Will Devastate the North Sea Warn
Experts", IPS, 14 May 2010. Back
British Geological Survey, "New discovery of deep-water coral
reefs in UK waters", BGS, July 2009. Back
Health and Safety Executive, "All Offshore Hydrocarbon Releases",
Database, HSE, Accessed 20 July 2010. Back
Alan Thompson, "Analysis of offshore hydrocarbon releases
2001 - 2008". Back
Interview with FCO representatives Victor Clarke and Kathryn Hogg,
14 July 2010. Back
J Perry/RPS Energy/Desire Petroleum plc, "Environmental Impact
Assessment for Offshore Drilling The Falkland Islands to Desire
Petroleum plc", November 2005. Back
Marine Management Organisation, "Oil spill treatment products
approved for use in the United Kingdom", MMO, 18 May 2010. Back
See for example: Andrew Rogersona and Jacques Berger, "The
toxicity of the dispersant Corexit 9527 and oil-dispersant mixtures
to ciliate protozoa" Department of Zoology, University of
Toronto, 24 November 1980. Concluded that: "Chemically dispersed
oil was more toxic than either the dispersant or crude oil alone."
And US Environmental Protection Agency Office of Research and
Development, "Analysis of Eight Oil Spill Dispersants Using
In Vitro Tests for Endocrine and Other Biological Activity",
30 June 2010 where Corexit ranks among the most cytotoxic of the
eight dispersants in the study. Back
DECC, "UK increases North Sea rig inspections", DECC
Press Release PN10/067, 8 June 2010. Back
Günther Oettinger EU Commissioner for Energy, "Oil exploration
and extraction - risks, liability and regulation" at the
European Parliament Plenary Session Strasbourg, 7 July 2010. Back