UK Deepwater Drilling-Implications of the Gulf of Mexico Oil Spill - Energy and Climate Change Contents

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."[16]

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."[17]

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."[18] 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 that."[19]

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."[20]


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".[21] 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.[22] 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.[23] This, despite the fact that the current licensing round has had a record number of bids since offshore licensing began.[24]

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.[25] 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 peak oil.


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 industry.

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.[26] 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.[27] 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.[28] 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."[29]

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.[30] 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.[31] 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 abandoned well.[32] 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."[33]

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.[34] 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.[35] 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 also possible.

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.[36] 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 45%.[37]

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.[38]

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.[39] This would be the eighth incident in Norway that had "large scale potential" to cause a major disaster since the beginning of 2010.[40]

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.[41] 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.[42] The typical design life of a platform is between 20 - 25 years.[43] That would suggest that nearly half of all installations are operating beyond their expected design life.[44]

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.[45] The group called for a root-and-branch assessment of ageing platforms and a robust assessment of their extensibility.[46]


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.[47] 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 measures.

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.[48] 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 oil company.[49] 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.[50] 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 occurred here."[51]


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.[52] 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.[53] 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.[54]

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.[55] 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.[56]


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 round.

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 Secretary".[57] 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.[58] 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.[59]

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".[60] 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".[61] 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.[62] Use of Corexit is restricted in the UK, after failure of the rocky shore tests required for its approval,[63] 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.[64] 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.[65]


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 shelves.

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 approach."[66] 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 other countries.

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.

September 2010

16   Alastair Darling, "Tax boost for West of Shetland gas fields", HM Treasury, Press Release, 27 January 2010.  Back

17   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

18   Chris Huhne, "Huhne Backs Aberdeen's Energy Industries (Press Release)", DECC Press Release, 20 May 2010. Back

19   IbidBack

20   Cabinet Office, "UK National Security Strategy: Report on Progress 2010", 18 March 2010. Back

21   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

22   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

23   Robin Pagnamenta, "Business Big Shot: Tim Eggar, former Energy Minister", The Times, 18 February 2010.  Back

24   Department for Energy and Climate Change, "Energy Minister gives go-ahead to new North Sea development", DECC Press Release, 28 June 2010.  Back

25   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

26   DECC, "Existing UKCS installations", July 2010.  Back

27   Oil & Gas UK, "Background Information", Oil & Gas UK Knowledge Store,  

28   Prof Steve Tombs and Dr David Whyte, "Regulatory Surrender: death, injury and the non-enforcement of law", Liverpool University, 13 July 2010. Back

29   IbidBack

30   IbidBack

31   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

32   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

33   Freedom of Information request to Health and Safety Executive Reference No. VBRY-876DPY, 8 July 2010. Back

34   DECC, "Well Data",

A Freedom of Information request regarding DECC management of abandoned wells is still pending at the time of this writing.  Back

35   Jeff Donn and Mitch Weiss, "Gulf awash in 27,000 abandoned wells", Associated Press, 6 July 2010.  Back

36   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 Conference. Back

37   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

38   SINTEF Offshore Blowout Database, Back

39   Acting head of Gullfaks drilling and well operations, Rune Gaaso, as quoted in "Gullfaks C production resumes", Upstream Online, 14 July 2010.  Back

40   Wojciech Moskwa and Gwladys Fouche, "Statoil evacuates North Sea platform due 'unstable' well", Reuters, 21 May 2010.  Back

41   Angela Henshell, "Gas Leak Halts Production at Norway Troll A Field", Dow Jones Newswires, 29 June 2010. Back

42   DECC, "Existing UKCS Installations", July 2010.  Back

43   Alexander Stacey, "HSE Research Initiatives on Ageing Offshore Installations in the UK", The International Committee on Regulatory Authority Research and Development (ICRARD). Back

44   IbidBack

45   "Aging oil platforms focus minds in Norway", Scandinavian Oil & Gas Magazine, 26 November 2008. Back

46   IbidBack

47   Jake Molloy, "The High Price of Cost Cutting (again)", OILC, 

48   Chris Hopson, "Under fire: Shell is feeling the heat over its Brent Bravo safety record", Upstream Online, 14 March 2008.  Back

49   Ed Crooks, "Shell deaths higher than other western groups", Financial Times, 30 November 2008. Back

50   Stephen Christie, "Alarm over hundreds of offshore incidents", The Press and Journal, 9 February 2009. 

51   Julio Godoy, "Oil Spill Will Devastate the North Sea Warn Experts", IPS, 14 May 2010. Back

52   IbidBack

53   IbidBack

54   British Geological Survey, "New discovery of deep-water coral reefs in UK waters", BGS, July 2009.  Back

55   Health and Safety Executive, "All Offshore Hydrocarbon Releases", Database, HSE, Accessed 20 July 2010.  Back

56   Alan Thompson, "Analysis of offshore hydrocarbon releases 2001 - 2008". Back

57   Interview with FCO representatives Victor Clarke and Kathryn Hogg, 14 July 2010. Back

58   IbidBack

59   IbidBack

60   IbidBack

61   J Perry/RPS Energy/Desire Petroleum plc, "Environmental Impact Assessment for Offshore Drilling The Falkland Islands to Desire Petroleum plc", November 2005.  Back

62   IbidBack

63   Marine Management Organisation, "Oil spill treatment products approved for use in the United Kingdom", MMO, 18 May 2010. Back

64   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

65   DECC, "UK increases North Sea rig inspections", DECC Press Release PN10/067, 8 June 2010.  Back

66   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

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