The NPD has contributed sub-report No. 10 "Environmental Technology", together with facts and other data to subcontractors upon request. The NPD's main comments on ULB are generally related to HES (Health, Environment and Safety) and to issues relating to resource management. The NPD has the following comments concerning the impact assessment:
Choice of scenarios
The NPD's resource report shows that about 36% of the total undiscovered resources on the Norwegian shelf are expected to lie in the Lofoten-Barents Sea area. The undiscovered resources in this area are estimated at a total of 1215 million Sm3 o.e., divided between 485 million Sm3 o.e. liquids and 730 millions Sm3 o.e. gas. We must develop these resources if we are to achieve the long-term development scenario, which is stated as a goal in Storting White Paper No. 38. This is because 62% of the difference between the decline scenario and the long-term development scenario lies in the total undiscovered resources on the Norwegian shelf.
The scenario document defines a certain number of fictitious fields in the Barents Sea and Lofoten area. There are three different scenarios reflecting a high, medium and low level of activity.
A high activity level is defined as 10 fields; 6 oil fields and 4 gas fields. In all of the scenarios, both the location and type of field have been deliberately defined to create the greatest possible potential conflict between the activity and environmental considerations. The NPD is of the opinion that both statistics and expectations based on more than 23 years of exploration, 62 wildcat wells, studies and other mapping activities show that it is most likely that we will find gas.
Based on what is known today, the type and volume of hydrocarbons we expect to find in the area, and where we expect to find these resources, the NPD regards the described high activity level scenario as being highly unlikely.
The NPD believes that a medium activity level is more realistic. Therefore, the impact assessment should be based on this scenario.
The time perspectives for discovering and developing the fields included in the high activity level are unrealistic in relation to what is common in the North Sea and the Norwegian Sea, according to the NPD's view.
It is largely the scenarios related to a high level of activity that are emphasized in the report's description of potential consequences. These scenarios are extremely conservative as regards conflicts between activity and environmental considerations. The NPD believes that it is important that this emerge more clearly.
Risk of discharges
The NPD is of the opinion that confidence in and understanding of the risk perspective in the ULB report are important factors in creating a balanced joint platform among all of the parties involved in the present decision process.
The risk concept is defined as a result of probabilities and consequences. In a ULB context, it is of particular interest that the risk concept expresses the likelihood of an undesirable incident harming the external environment, with particular focus on the most vulnerable resources that could be affected.
The NPD has the following comments concerning presentation of environmental risk in the ULB report:
The analysis of the environmental consequences in the event of a spill are based on worst-case scenarios.
The report should express more clearly what risk analyses can and cannot be used for. A risk analysis is not used to predict future accidents. No activity is without risk - there is always a chance that something will happen.
However, accidents are not fated. They are caused, and can thus be prevented.
Risk analyses are used to understand what could happen, why it can happen, and what the consequences could be. Statistics are often used in this context, i.e. historical data, for the purpose of learning from the mistakes of others.
The results of risk analyses are used to assign resources to the correct areas so that what in theory could happen (and has happened in other places) never actually happens. In other words, a risk analysis is used to learn from the mistakes of others. Using statistics that illustrate the probability of this happening again to predict the future would be to assume that we were not able to learn anything from history, or to develop new technology and thus find solutions which make us better at what we do.
Therefore, a risk analysis is not meant to be used to predict future accidents. All phases of the petroleum activities are becoming safer as we gradually acquire more knowledge, experience and better technological solutions. This will therefore be a continuous process.
Climate, great distances and lack of infrastructure are also factors that will demand special attention in the area covered by the impact assessment, as compared with other parts of the Norwegian shelf.
The regulatory requirements for winterization (both technical and operational) will apply. Necessary logistics during normal operations and in emergency response situations will be more demanding and cost-intensive.
The scenario documents presents spills and transport based on a high/ambitious plateau production (e.g about 25 percent resource withdrawal/year for Nordland VI). These assumptions are then used as a flat rate for the entire analysis period.
This means that estimates for e.g. tank transport throughout the field's lifetime are far too high. (For example, for the Nordland VI area, this gives transport of 170 million Sm3 o.e. from a field with recoverable resources of 50 million Sm3 o.e.).
The conclusions and the assessments that are given with regard to risk do not necessarily apply to activities north of about 74.5 degrees north. No assessments have been made of what happens in connection with oil spills north of Bjornoya Island.
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