Beruflich Dokumente
Kultur Dokumente
T h e I m p ac ts an d R is k s o f De e p wat e r a n d
A r c ti c Hy d r o c a rb o n De v e l o p me n t
Alberto Serna Martin
March 2012
D eeper a n d C o ld e r: Th e I m p a c t s a n d R i s ks o f D e epwater a nd Arct i c H ydroca rbon Devel opm ent | Ma rch 2 0 12 2
Table of Contents
Executive Summary.......................................................................................................3
Introduction..................................................................................................................5
Global Energy Demand and the Shift Toward Unconventional Oil and Gas........6
Habitat Degradation.......................................................................................................9
Investor Risks................................................................................................................11
Regulatory Risk.............................................................................................................11
Litigation Risk...............................................................................................................13
Reputational Risk.........................................................................................................13
Operational Risk..........................................................................................................14
Best Practices................................................................................................................14
Endnotes.......................................................................................................................21
Hydrocarbon reserves in deepwater basins are vast, particularly in the Gulf of Mexico,
Brazil and West Africa. Arctic reserves are even larger. Unlike oil sands, hydrocarbons
produced in deep and Arctic waters are conventional, however, their extraction requires
the use of unconventional methods that can cause environmental and social impacts and
generate controversy. Moreover, the technological challenges of drilling at sizable depths
and managing extreme weather conditions in the Arctic generate significant operational
risks. Public concern has mounted following several recent safety incidents resulting in
a high number of fatalities on drilling platforms. Company reputation is impacted by
hydrocarbon spills that visibly threaten biodiversity and local economies. The recent
Deepwater Horizon incident caused a global cascade of regulatory reviews, the results
of which will inevitably increase operational costs. Confronted with the possibility of
such a scenario in the fragile and unique Arctic environment, oil companies face further
mistrust and resistance to operations in that region. Unplanned events, such as spills or
injuries, present significant reputational, regulatory and operational risks for individual
companies, their investors, and the oil industry as a whole.
Due to these operational uncertainties, there is still a long way to go to develop and
improve existing best practices. To reduce risk investors should encourage their holdings
to improve transparency, implement process changes, use less toxic products, and
actively manage contractors. Investor risk analysis can be strengthened with company
disclosure on reserves owned in deepwater and Arctic offshore basins. Company risk
mitigation can be accomplished by implementing best practices such as compiling
biodiversity baseline information, enhancing drilling standards that ensure well integrity,
and building sufficient emergency response capacity. Ensuring that contractors adhere
to company standards is also a major factor in both regulatory compliance and risk
avoidance. The industry also has opportunities to develop lower-impact methods and
technologies. Innovation will be the key to long-term success in higher-risk basins.
Responsible investors have an important role to play in decreasing the impacts and
mitigating the risks associated with deepwater and offshore Arctic hydrocarbon
development. Through their numbers and influence investors can engage with oil and
gas producers and encourage innovation, and the adoption and ongoing development
of best practices.
At the same time, responsible investors should view deepwater and offshore Arctic
developments in the context of the broader need to shift our economy away from its
dependence on fossil fuels. Oceanic hydrocarbon development, even with best practices
in place, does nothing to discourage fuel consumption. Therefore, while pushing for best
practices responsible investors should push even harder for investment in renewable
and sustainable forms of energy and for regulatory environments that incentivize such
investment.
Introduction
In December 2011, 53 crew members of the Kolskaya jack up rig died in the Subarctic Siberian waters of the Sea of Okhotsk. A window
was knocked out during a winter storm; flooding and sinking the rig in less than 20 minutes. Preliminary conclusions of the Investigative
Committee of Russia stated that safety violations and towing without consideration of the weather conditions were believed to be the
causes of the disaster.
such an event. of the worst spills in Australian history, leaking 400 barrels a day for more than 10 weeks. An inquiry
by the Australian government found that safety practices at the well were poor, adding that faulty
cementing of the well led to the blowout that caused the spill.
All of the incidents outlined above are indicative of a cascading chain of failure in
offshore drilling operations. These incidents resulted in regulatory reviews of safety,
significant media attention, reputational damage for individual companies as well as
for the entire offshore industry, and financial impacts for both the operating companies
and their insurers. Despite these risks and the low levels of trust for the offshore oil and
gas industry as a whole, companies are pushing into deeper, colder and more dangerous
environments in their pursuit of hydrocarbons.
In this report Sustainalytics outlines the impacts and risks of deepwater and Arctic
offshore hydrocarbon development. Several examples of leading practises are provided
along with an investor initiative and suggestions for shareholder engagement to address
risks with their holdings.
As demand for fossil fuel continues to grow, many conventional sources are being
depleted, and an estimated 87 per cent of known available reserves on the planet today
are under the control of national oil companies (NOCs). 2 Due to this restricted access
to known reserves, many public companies are shifting their operations to higher-
risk areas and to unconventional oil and gas deposits. High-risk regions are generally
characterized by social volatility or environmental sensitivity, while unconventional
deposits are those that either contains heavier or more contaminated oil or gas, or that
occur in less accessible reservoirs or rocks. For unconventional deposits, conventional
extraction methods do not generate profitable returns.
The scale of global unconventional fossil fuel resources is vast. Deepwater and Arctic
oceanic reservoirs can be considered unconventional as they are situated in locations
that are difficult to access. More than half of the oil discovered since 2000 is in deepwater
oilfields, and the production of oil from these reservoirs is expected to grow in the
coming decades. 3 In the case of offshore reserves located north of the Arctic Circle,
undiscovered resources are estimated to be 90 billion barrels of oil, of which 84 per cent
occurs offshore. Moreover, the extensive Arctic continental shelves may constitute the
worlds largest unexplored prospective area for petroleum. 4
Offshore Arctic drilling refers to oil and gas development activities that take place on
the continental shelf above the Arctic Circle or at locations at such high latitudes that
the average daily summer temperature does not rise above 10 degrees Celsius. While
drilling in the Arctic could certainly involve deepwater operations in the future, current
activities are carried out in shallow waters. Operating conditions include potential
exposure to long hours of darkness, pack ice, icebergs and extremely low temperatures.
Thus, companies operating in this region must ensure that vessels are able to withstand
pressure exerted by the ice and potential iceberg collisions.
Natural Gas Liq u id s The deepwater oil and gas development boom started in the late 1990s and accelerated
44
from 2000 onwards as rising oil prices increased the economic feasibility of such
projects. Total global production from deepwater fields rose from less than 200,000
20% barrels a day in 1995 to over five million barrels a day in 2007. The IEA expects that
Billion * by 2035 eight million barrels a day will be produced from deepwater resources. 7, 8
Estimates of recoverable oil located in deepwater and ultra-deepwater lies between 160
Oi l
90
and 300 billion barrels, which is between six and 12 per cent of the 2.5 trillion barrels
of total oil the IEA estimates remains to be produced worldwide. Although much of
13% the development of deepwater fields has occurred in the Gulf of Mexico, deepwater
Billion * discoveries have occurred in various basins around the world, notably in Brazil, West
Africa and South East Asia. 9, 10
Natural Gas
According to a study by the U.S. Geological Survey, the mean total of undiscovered
30% 1,669 conventional oil and gas resources in the Arctic is estimated to be approximately 1,669
trillion cubic feet of natural gas, 90 billion barrels of oil and 44 billion barrels of natural
Trillion * gas liquids of which approximately 84 per cent is expected to occur offshore. 11 This
number represents 30 per cent of the worlds undiscovered conventional natural gas,
13 per cent of the worlds total undiscovered oil resources and about 20 per cent of
% = Percentage of worlds supply the worlds natural gas liquids. 12 Reservoirs are spread among the various Arctic littoral
* = Measured in cubic feet countries: U.S., Canada, Greenland, Norway and the Russian Federation, the latter
Figure 1 holding the vast majority of the undiscovered natural gas. 13 (See figure 1)
5 Arctic
1 Gulf of Mexico
3 4
West Africa Asia
2
Brazil
1 Gulf of Mexico
The Gulf of Mexico is the largest deepwater and ultra-deepwater production area in the world. Total proved hydrocarbon reserves in
2008 amounted 4.21 billion barrels, of which 3.59 billion barrels was crude oil. In 2009, around 32 per cent of the total oil produced
in the Gulf of Mexico came from ultra-deepwater wells, 50 per cent from deepwater and 18 per cent from shallow water production.
Active companies in the region include Anadarko, Apache, BP, BHP Billiton, Chevron, Eni, and Royal Dutch Shell.
Brazil
2 Recent large deepwater discoveries in Brazil have the potential to double the country s reserves. In 2011, the country s oil reserves
amounted to 12.85 billion barrels, of which 80 per cent is located in deepwater reservoirs in the Campos and Santos basins. Active
companies include BG Group, Chevron, Petrobras, Repsol, Royal Dutch Shell, Sinopec, and Total.
3 West Africa
In the last 15 years, Angola has become the second largest oil producer in Africa after Nigeria. The country has proven reserves of
approximately nine billion barrels and it has managed to produce almost two billion barrels per day. Of the 40 offshore oil concessions
in Angola, 27 are deepwater or ultra-deepwater in the Kuito, Girassol, Belize and Tomboco fields. Active companies include BP, Chevron,
CNOOC, Exxon, Sinopec, Sonangol, and Total.
4 Asia
In recent years there has been an increase in deepwater activities as Asian oil companies have signed large agreements with European
oil majors, such as the 2008 deal to explore the deepwater Gumusut field in Malaysia (signed by: Shell, ConocoPhillips, Murphy Oil
and Petronas Carigali); or the 2011 upstream partnership between Reliance Industries and BP to explore and produce offshore oil,
including ongoing deepwater projects in the Krishna-Godavari basin. Chinese companies are also developing deepwater rigs, such as
the CNOOC981, that will allow deepwater exploration and production from the Peal River Mouth Basin and the Qiong Dong Nan Basin
in the South China Sea.
5 Arctic
The Arctic remains the largest unexplored oil and gas reservoir on Earth. There have been an increased number of continental shelf
exploration licenses awarded and new licensing rounds in the Arctic littoral countries (U.S., Canada, Greenland, Iceland, Norway, and
Russia) in the last 10 years. Notably, in October 2011, the Obama administration upheld 500 leases issued in the Alaskan Chukchi Sea
after several environmental groups challenged the sale of the leases in court. Gazprom expects to start oil production in the Russian
Pechora Sea shelf from Prirazlomnoye field in 2012.
Habitat Degradation
PHYSICAL DISTURBANCE
Marine animal life can be negatively affected by various stages of deepwater and
Arctic oil development. Air guns, used during seismic surveys of potential oilfields,
vent pressurized air into the water producing noise up to 259 decibels. Studies have
shown that as a result of these acoustic disturbances some animal species can suffer
hearing loss, stress, and a change in behavioural patterns due to their hampered ability
to communicate. 15, 16 While the effects of air guns on shallow water species can be easier
to ascertain, the effects on species inhabiting the deepwater are difficult to determine
due to limited knowledge of their baseline behaviour.
Deepwater installations often encounter large fish, marine mammals, and giant
cephalopods, whose habitats are disturbed or destroyed by the presence of drilling
equipment and underwater hydrocarbon transport infrastructure. Moreover, offshore
development in the Arctic has the potential to negatively impact the habitats of mammal
species considered vulnerable and near threatened, including polar bears and some
whale species, as well as the routes travelled by migratory animals such as the humpback
whale. 17
Shoreline ecosystems provide the mainland with natural protection against hurricanes
and storms. Hydrocarbon transport to refining and consumption centres can cause
shoreline erosion and damage to coastal wetlands, coral reefs, and mangroves. In the
Gulf of Mexico, Louisianas shorelines have lost approximately 3,000 km due to human
activities including the construction of more than 12,000 km of pipelines to transport
hydrocarbons onshore. 18 Increased activity in deepwater development regions like Brazil
and West Africa can exacerbate shoreline change in these areas.
PLANNED DISCHARGES
During any drilling operation, waste is produced and requires disposal. Proximity to land
determines the viability of onshore disposal. Deepwater and Arctic operations typically
discharge drilling fluids, cuttings, produced water, and domestic waste to the sea and
the subsurface. Produced water often contains polycyclic aromatic hydrocarbons (PAHs)
along and other hazardous substances such as heavy metals. Concentrations of PAHs
in produced water are toxic and can negatively impact local ecosystems. In 2008, on
average, an offshore installation drilling in the North Sea discharged 1,681,916 cubic
meters of produced water into the ocean. 19 Since more than 200 deepwater wells
reached production status in 2011, hundreds of millions of litres of produced water are
discharged into the oceans every year.
Depending on the composition of the drilling fluids, synthetic oil and chemical
components containing traces of heavy metals, such as lead, can be discharged into the
sea. Deepwater projects require much larger volumes of drilling mud than shallow water
projects. Although several technologies exist to handle drilling fluids with contaminated
cuttings, companies often release fluids into the sea. Also, while some jurisdictions, like
the North Sea and the Gulf of Mexico, prohibit the discharge of synthetic-based mud,
West Africa, South America, and the Far East allow controlled discharges if cuttings meet
certain toxicity criteria. 20
According to a report by the World Wildlife Foundation, the Arctic offers the highest
level of ecological sensitivity and the lowest level of capacity to cleanup after an oil
spill. The efficiency of standard industry oil spill response strategies such as mechanical
containment and recovery, in situ burning, and dispersant application can be questioned.
Again, due to the remoteness of the location and local conditions, such as ice cover, low
temperatures, reduced visibility or complete darkness, high winds, and extreme storms,
spill response activities can be delayed. 22 In cold conditions, oil is less susceptible to
bacterial degradation and evaporation, especially when trapped under ice. Conversely,
some operators claim that the low oil evaporation rates in the Arctic could result in a
more effective cleanup as more of the oil could be disposed of via in situ burning, and that
the ice may act as a natural barrier between the oil and the marine environment below.
The majority of the activities carried out on offshore platforms, including most of the high
risk activities, are performed by contractors on the payroll of oilfield service companies.
From drilling, cementing, circulating mud, and running geophysics, all the way down to
the cooks, contractors are essential for rig operation. In fact contractors far outnumber
the oil and gas company representatives on a rig. According to a study carried out by the
Offshore Division of the Health and Safety Executive analysing the underlying causes of
the offshore accidents, contractors accounted for 62 per cent of injured parties. 26
Investor Risks
Regulatory Risk
The negative attention deepwater and Arctic drilling has received as result of recent
offshore catastrophes has had implications on regulatory frameworks. Various
jurisdictions have begun to review, or have already tightened, environmental and safety
requirements for the issuance of drilling permits (see text box 1 on page 12). Following
the Deepwater Horizon incident, the U.S. imposed a six-month moratorium on deepwater
projects, and issued new rules to address major safety gaps identified by investigations
into the incident (see text box 2 on page 12). 27 Companies whose operations were
halted had to resubmit safety plans in order to receive approvals to resume operations.
In the aftermath of the Deepwater Horizon incident, Arctic developments have also
experienced slowdowns partly due to the regulatory review sparked by the Gulf of
Mexico spill. Royal Dutch Shells plan to start exploration drilling in the Beaufort Sea in
2010 has experienced a longer permitting timeframe that has delayed operations for at
least two years.
Investors in companies holding deepwater and Arctic projects will see that, as a result of
tougher regulations and increased oversight, it will take more time to produce first oil. If
production takes longer, the development and operational costs of projects increase and
revenues are delayed. Companies with strong environmental and social management
practices should obtain permits more efficiently, have lower compliance costs and
experience fewer delays. Furthermore, these companies also lower the risk of a costly
non-compliance incident.
While more stringent regulations may increase costs or cause production delays, they
also help ensure higher safety standards and practice. In doing so, regulatory changes
play a critical role in managing risk and helping to avoid disastrous and costly events. As
a result, raising standards aids in the protection of the industrys reputation as a whole.
Canada: In December 2011, the Canadian National Energy Board (NEB) concluded a review of the safety and environmental
requirements for offshore drilling in Canadian Arctic waters. The process included consultation with interested parties such as
non-governmental organizations, local communities, other regulators and the oil industry. The NEB states that companies must
demonstrate that they would be able to complete a relief well and cap a blowout in the same season. Companies can get an
exemption to this requirement if they show they have alternative methods for quickly killing a blowout.
Source: National Energy Board of Canada
United Kingdom: One of the priorities for 2012 of the offshore division (OSD) of the U.K. Health and Safety Executive is to
conduct a revision of the U.K.s offshore oil and gas regulatory approach, touching upon health and safety and oil spill response
aspects.
Source: Health and Safety Executive
Greenland: With no producing wells in the country, the first offshore drilling legislation was introduced in 2010. In 2011, the
Ministry for Industrial and Natural Resources announced that it was setting higher requirements in Arctic waters. The new
requirements include ice handling programs and an exceptional two rig policy that demands companies install two drilling rigs
for every well. The purpose of the second rig is to reduce the time needed to mobilize a rig to drill an emergency relief well.
Source: NANOQ
China: In September 2010, the government began three weeks of additional safety checks to all offshore installations in the
wake of an oil spill at a Bohai Bay platform run by ConocoPhillips. In November 2011, it was reported that a revision of joint
offshore hydrocarbon development may be undertaken by the Ministry of Land and Resources. Current regulation lacks clarity
with regards to the obligations and responsibilities of companies and regulators during unplanned events.
Source: Reuters News
The International Maritime Organization, a UN body tasked with protecting the marine environment from pollution from ships, has set
up a working group to address pollution from platforms. If the working group succeeds, oil companies will witness the start of the first
international agreement ever dealing with offshore hydrocarbon development.
Box 1
New U.S. Environmental and Safety Rules Prompted by the Deepwater Horizon
As a direct consequence of the Deepwater Horizon tragedy, the U.S. Minerals Management Service was restructured to separate the
energy development functions from the safety and environmental enforcement function. Two new organizations emerged in October
2011: the Bureau of Ocean Energy Management (BOEM) and the Bureau of Safety and Environmental Enforcement (BSEE). The BSEE
developed and implemented two rules aimed at raising operations standards for companies operating in the U.S. outer continental shelf:
A Drilling Safety Rule set new standards for well design and well control equipment. Voluntary well design practices, recommended
by the American Petroleum Institute (API) became mandatory and third-party inspections and certifications are necessary for
every stage of the drilling process. In terms of well control equipment, an engineer must certify that blowout preventers meet
new standards for testing and maintenance, and are capable of severing the drill pipe under anticipated well pressure.
A Workforce Safety Rule requires companies operating offshore to develop and maintain a safety and environmental management
system (SEMS) making 13 previously voluntary health and safety elements mandatory. Companies are also required to provide
documentation that describes all elements of the SEMS program. Procedures such as emergency evacuation plans and oil spill
contingency plans must now be in place and validated by drills or records and documentation.
Litigation Risk
Generally, litigation risk relates to the effects of pollution and the subsequent
compensation claims filed by affected parties, who might also seek to receive punitive
damages after an unplanned event. In December 2010, BP took a pre-tax charge of USD
40.9 billion in order to fund claims, cleanups, and damages from the Deepwater Horizon
incident. As oil spills can have a large material impact on companies, there is also a risk
of litigation from a companys own shareholders. After the Deepwater Horizon incident
several groups of shareholders filed lawsuits against BP claiming that the company
misled them about its commitment to safety and operational integrity.
Liability is a deterrent to spills. Currently, the operators hold the liability, however,
the contractors physically perform the work and thus control a portion of the risk. In
the case of the Deepwater Horizon, the U.S. Coast Guard named some contractors as
potentially responsible parties, thus complicating traditional liability lines. Furthermore,
BP began an aggressive legal campaign to recover some costs from its contractors. Post-
Deepwater Horizon, the traditional distribution of risks and benefits between operators
and contractors is being challenged.
Stakeholders who oppose projects may also use legal tactics such as lobbying regulators,
challenging permits, or obtaining court injunctions, to delay or derail projects. Since 2010,
environmental groups and local Inupiat communities have been legally challenging air
permits issued by the U.S Environmental Protection Agency to Royal Dutch Shells drilling
vessel. Shells plans to start drilling during the Arctic summer of 2012 may experience
another delay if these appeals succeed. Operators that have strong relationships with
their stakeholders may benefit from reduced resistance to permitting and fewer lawsuits.
Reputational Risk
The powerful images of oil spills, worker fatalities, and the effects of climate change in
the Arctic can induce strong emotion among the general public and can expose companies
involved in deepwater and Arctic operations to significant negative media attention.
Negative reputational impacts related to operations in sensitive environments are an
issue that both companies and the industry as a whole have been facing for decades.
Exposure to reputational damage increases as non-governmental organizations (NGOs)
and local communities organize themselves in more sophisticated ways. Visual NGO
campaigns outlining the potential environmental effects of an Arctic oil spill provide
a significant amount of negative media attention that can lead to further distrust of
the offshore industry and an increase in opposition to drilling projects. In the 1990s
Royal Dutch Shell was subject to a boycott in Europe after it announced plans to sink
the Brent Spar storage installation in the North Sea. Some BP gas filling stations in the
southern U.S. were boycotted by consumers after the Deepwater Horizon sank resulting
in a temporary loss of business opportunities and reduced revenues.
Operational Risk
Operating in deepwater and Arctic environments is generally more complicated than
operating in shallow water. The depth of deepwater drilling translates into extremely
low temperatures and high pressures. Drilling risers and other equipment are built with
thicker walls and higher grade materials to handle the additional stress. However, there
is no one-size-fits-all technology that guarantees safe operations. For example, Brazilian
deepwater basins require well integrity techniques designed to adjust for shifting sand
that falls back into the well, while Gulf of Mexico operations need to be designed to
withstand severe storms and hurricanes.
In the Arctic, the most obvious operational challenge is ice. Ice movement is subject to
wind and water currents. Ice conditions can also vary significantly season-to-season,
or year-to-year, within an area. Thus, fixed platforms must be designed to withstand
the pressure exerted by ice. Drilling activities and support vessels can be delayed by
approaching icebergs or the more difficult to detect ice growlers.
Blowouts are often caused by well integrity issues related to poor cementing jobs or loss
of drilling mud pressure. The deeper the well, the more cement and drilling mud is used,
increasing the likelihood of well integrity failure. Furthermore, because of the isolated
nature of deepwater rigs, blowouts and subsequent spills tend to take longer to contain
compared to the same scenario in shallow waters or on land. In terms of emergency
planning, the last line of defence for an uncontrolled offshore spill is to drill a relief well.
The relief rig is relatively easy to acquire in the Gulf of Mexico with hundreds of rigs
operating in the area. However, in the remote Arctic, that relief well rig may take several
months just to reach the site, prior to beginning the drilling process.
Equipment selection for deepwater and Arctic operations requires an immense amount
of technical consideration. Due to the specialized equipment and risk profile of the
activities, average day rates for deepwater and Arctic projects vary from around USD
250,000 to USD 415,000 per utilization day. 28 Therefore, temporary stoppages or delays
due to operational failures, even if not critical, can represent high and unwelcomed
expenses for the company.
Best Pr actices
There are general operational best practices that oil and gas companies and their
servicing companies can employ to address the risks inherent to deepwater and Arctic
operations. While some best practices have been identified by evaluating what went
wrong in past incidents, other practices are based more on a precautionary approach
and the need to establish baseline data. Although not an exhaustive list, below are some
examples of leading practices for deepwater and Arctic operations.
Process Changes:
Activities to Decrease Impact on Biodiversity
A greater understanding of deep marine life is needed in order to inform oil and
gas production best practices. Early partnerships between science-based research
organizations and oil and gas exploration companies can produce scientific data useful
for both groups. Companies operating in deepwater and the Arctic can aid in the
development of best practices by building a baseline data set that can be used to inform
mitigation strategies and avoid negative impact. For example, by monitoring local whale
behaviour drilling operations can be scheduled to avoid migration and calving periods.
Gathering baseline biodiversity data is important in deepwater and Arctic regions as
such data is lacking in comparison to warm water continental shelf regions.
Companies can implement strategies for reducing physical impacts such as reducing
underwater sound disturbances. For example, soft starting is recognized as a best
practice for seismic testing. The procedure begins by producing a low level of noise that
is gradually increased. The gradual increase allows marine mammals and fish to move
away from the testing areas and avoid exposure to high-volume sound. Companies can
also replace air guns with marine vibrators, which produce much lower pressure and
sound. Although it has a lower impact, marine vibrator technology is not yet as reliable
as traditional seismic technology.
Leading Practice Example: BPs ENHANCED DRILLING STANDARDS IN THE GULF OF MEXICO
In the aftermath of the Deepwater Horizon incident, BP announced a set of voluntary performance
standards that go beyond U.S. regulatory requirements and will be implemented by the company
for its operations in the Gulf of Mexico. Under the new drilling standards BP commits to:
Require contractors to use BOPs equipped with no fewer than two blind shear rams and a
casing shear ram on all drilling rigs under contract to BP for deepwater service;
Third-party verification in testing and maintenance of BOPs, in accordance with manufacturer
recommendations and industry recommended practice; and
Laboratory testing of cement slurries used in wells and disclosure of tests to the regulators
Although the enhanced standards go beyond regulatory requirements in the U.S., BP is not
requiring all of its worldwide drilling rigs to conform to this leading practice.
Oil spill containment also presents business opportunities for companies. Helix Energy Solutions
Corp. has designed a fast response system (HFRS) for future spills that has been cited as the spill
response system of record for six new drilling permits issued in the Gulf of Mexico.
MWCC and the HFRS are examples of leading practices, however, both are only available in the
Gulf of Mexico and other high risk deepwater and Arctic regions remain underserviced.
accordance with the operators standards. As a best practice, prior to drilling, operators
and contractors should prepare a bridging document that outlines how the contractors
safety and environmental standards can link with the oil and gas companys standards.
Such documents are prepared on a well-by-well basis, are tailored to specific local
conditions, and outline chains of command during an emergency.
Months after the Deepwater Horizon incident, a Ceres-led coalition of 62 global investors
with USD 2.5 trillion in assets under management sent letters to the CEOs of 28 major
energy companies engaged in deepwater drilling and 26 insurers. The letters requested
further disclosure of the companies risk oversight measures for deepwater drilling. 33
Current engagement should follow the same track of improved disclosure with a
particular focus on reserve disclosure and best practices. In order to better understand
their level of exposure to unconventional oil and gas, investors should request that
companies disclose a breakdown of higher risk reserves including deepwater and Arctic.
Environmental and social impacts and their associated risks can, to a significant degree,
While the practices outlined above are important and should be encouraged, it should
be noted that they do nothing to address or mitigate the contribution of fossil fuel
consumption specifically oil and natural gas to climate change. In fact, a positive
feedback cycle exists in that, as more oil and gas is extracted from Arctic environments,
the associated increase in carbon dioxide decreases the amount of Arctic ice. More ice-
free days translate into easier drilling conditions and the production of even more Arctic
oil and gas. Therefore, while pushing for impact mitigation in the deepwater and Arctic
oil and gas industry, responsible investors should also push for investment in renewable
energy and for regulatory environments that incentivize such investments.
Endnotes
1
World Energy Outlook 2010 (Paris: International Energy Agency, 2010).
2
National oil companies (NOC) are companies that are fully or majority owned by a national government. NOCs do not completely impede the access of
publicly traded companies to these resources; however, foreign companies are subject to operating restrictions which often include partnerships with NOCs
and technology transfer requirements.
3
World Energy Outlook 2010.
4
Peter H. Stauffer, ed., Circum-Arctic Resource Appraisal: Estimates of Undiscovered Oil and Gas North of the Arctic Circle, U.S. Geological Survey, 2008,
http://pubs.usgs.gov/fs/2008/3049/fs2008-3049.pdf.
5
On October 1, 2011, the U.S. Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE), formerly the Minerals Management Service
(MMS), was replaced by the Bureau of Ocean Energy Management (BOEM) and the Bureau of Safety and Environmental Enforcement (BSEE) as part of a major
reorganization. BOEM is responsible for managing environmentally and economically responsible development of the U.S.s offshore resources. Its functions
include offshore leasing, resource evaluation, review and administration of oil and gas exploration and development plans, renewable energy development,
National Environmental Policy Act (NEPA) analysis, and environmental studies. BSEE is responsible for safety and environmental oversight of offshore oil and
gas operations, including permitting and inspections of offshore oil and gas operations. Its functions include the development and enforcement of safety and
environmental regulations, permitting offshore exploration, development and production, inspections, offshore regulatory programs, oil spill response and
training, and environmental compliance programs.
6
World Energy Outlook 2010.
7
Ibid.
8
Ibid.
9
Ibid.
10
Ibid.
11
Stauffer, Circum-Arctic Resource Appraisal: Estimates of Undiscovered Oil and Gas North of the Arctic Circle.
12
Arctic Oil and Natural Gas Potential, U.S. Energy Information Administration, accessed December 6 2011, http://www.eia.gov/oiaf/analysispaper/arctic/
index.html#aongr.
13
Donald L. Gautier, et al., Assessment of Undiscovered Oil and Gas in the Arctic, Science, 324, no. 5931, (2009): 1175-1179.
14
MMS GOADS and Offshore Methane Emissions: Lessons Learned from the Natural Gas STAR Program, U.S. Environmental Protection Agency, published May
6, 2008, http://www.epa.gov/gasstar/documents/workshops/2008-tech-transfer/neworleans3.pdf.
15
Ocean Noise: Turn it down: A Report on Ocean Noise Pollution, International Fund for Animal Welfare, published June 2008, http://www.ifaw.org /sites/
default/files/Ocean%20Noise%20Pollution%20Report.pdf.
16
Marine Mammals and Noise: A Sound Approach to Research And Management, Marine Mammal Commission, published March 2007, http://mmc.gov/
reports/workshop/pdf/fullsoundreport.pdf.
17
Red List, The IUCN Red List of Threatened Species, accessed December 2, 2011, http://www.iucnredlist.org /.
18
About Coastal Erosion: What are the causes? Parishes Against Coastal Erosion, http://www.paceonline.org /erosion_det.php?poErosion_ID=3.
19
About Coastal Erosion: What are the causes? Parishes Against Coastal Erosion, http://www.paceonline.org /erosion_det.php?poErosion_ID=3.
20
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