Country
Assessment
Almost all flaring and venting and emissions from the oil and gas industry are from Saudi Aramco, the Saudi Arabia Basic Industries Corporation (SABIC), and other public companies.
As noted earlier in the case study, the MGS is a large system that gathers associated gas and delivers it to various end-users via a pipeline network of more than 4,000 km. As of early 2023, 7 gas processing plants, 2 natural gas liquid units, and 50 gas-oil separation plants complemented the network. The MGS midstream infrastructure, developed primarily by Saudi Aramco since the 1970s, ensures the utilization of associated gas for power generation, industrial activities, and other end uses. The Royal Commission oversees the downstream operations hosted by industrial cities; regulations, standards, and investments are coordinated across upstream, midstream, and downstream as well as across Aramco, Royal Commission, and other government entities.
The OGA Flaring and Venting Guidance, 2021, requires that flaring and venting be reduced to the lowest possible level under the circumstances, mirroring the previous criteria of a technically and economically justified minimum for safe and efficient commissioning and operations. The new guidance also requires that existing facilities engage in zero routine flaring and venting by 2030 and that all new developments be based on zero routine flaring and venting. Earlier guidance stated that the OGA would not examine in detail applications for consents with flare levels less than 40 tonnes (1.6 million cubic feet [mmcf]) a day or vent levels less than 4 tonnes a day from a single facility during production. According to the new guidance, the OGA will consider in detail all consent requests regardless of quantity. In response to assisting the government with its net-zero emissions target, including zero routine flaring by or before 2030, the primary industry association, Offshore Energies UK (name was changed from Oil & Gas UK in February 2022), released decarbonization targets, which the OGA incorporated in its tracking of flaring and venting. The current industry methane intensity commitment is 0.25 percent by 2025, with an ambition to reduce it to 0.20 percent (North Sea Transition Deal 2021). The Net Zero Stewardship Expectation 11 states that “zero routine flaring and venting and the use of the lowest-GHG-emission fuels should be the base case for power generation and GHG emissions targets.”
The OGA issues consents for flaring and venting under the Energy Act, 2016 . Environmental regulation of the oil and gas industry, including compliance with flaring and venting consents, remains with OPRED for offshore operations and the Environment Agency for onshore operations. The Scottish Environment Protection Agency; Natural Resources Wales; the Northern Ireland Environment Agency within the Department of Agriculture, Environment and Rural Affairs; and the Environment Agency regulate GHG emissions from flaring at onshore oil and gas facilities. Each agency manages and monitors the GHG permits and emissions plans of industrial facilities and aviation covered under the UK ETS in its jurisdiction. The Health and Safety Executive remains the safety regulator and takes the lead on offshore gas leaks.
The Energy Act, 2016 , amended the Energy Act, 1976 . Under its Section 12A, approval for flaring or venting is not required if it is necessary to reduce or avoid the risk of personal injury, the risk could not reasonably have been foreseen in time to reduce or avoid it other than by flaring or venting, or it was not reasonably practicable to obtain consent in the time available.
Under Section 12A of the amended Energy Act, 1976 , consent from the OGA is required to flare or vent gas from upstream oil or gas and processing facilities. Operators must apply for these consents via the UK Energy Portal. The OGA used to provide separate guidance with regard to applications for flaring or venting consents during commissioning and production. The OGA Flaring and Venting Guidance, 2021 , replaced these two guidance documents, but most requirements for authorization of flaring and venting remained the same. The procedure for commissioning new facilities is summarized as follows: The OGA issues flaring or venting consents valid for about one month (up to three months) during the commissioning of new facilities. The amount of gas flared and vented is fixed and subject to an auditable program and should be at the lowest level possible for safe and efficient commissioning. Consents are not issued until the OGA is satisfied that the gas-processing plant is ready to receive gas (construction complete, fully tested). If the gas-processing plant cannot handle all gas within two weeks of first oil, the OGA may limit production. Supporting documentation should be submitted to the OGA six months before the expected start-up. A formal written application should be made about two weeks before first oil. The procedure for production is as follows: Consents for flaring or venting during production operations are issued after commissioning of the gas-processing plant is completed. Consents are annual, and leftover allowances cannot be carried forward. The operator must submit a new application every year (usually in October). One objective of the OGA is to use these applications to develop a realistic forecast against which to track performance. The OGA may issue consents of shorter duration if, for example, the level of flaring or venting raises concerns or more investigation or data are necessary. Flare (vent) consents are for a field, which may have multiple installations that flare (vent). Composite or group consents can be issued for several fields tied to common facilities when equity partners are the same or operators of fields and common facilities submit their agreement for a group consent. A new field connecting to an existing facility may obtain a new consent or may be added to the existing consent via a new application. Possible breaches must be reported to the OGA promptly, and a technical case must be made if a revision is required. Commissioning consent documentation may differ depending on the facility size and complexity. At a minimum it should include the following: a brief overview of the field and associated main facilities a detailed description of the plant commissioning philosophy and procedure, including gas export line commissioning, should it be applicable the commissioning schedule a summary of the main flaring and venting assumptions and GHG profiles under different commissioning strategies forecasts of daily and total quantities of gas flared or vented sketches and figures containing a high-level field layout, process flow diagram, and systems for gas compression, dehydration, gas export, and fuel gas. The OGA Flaring and Venting Guidance, 2021, also covers flaring and venting at terminals and other onshore facilities that serve offshore operations. However, consent applications for onshore facilities are submitted via email and not through the Energy Portal.
The OGA guidance on offshore field development plans must demonstrate that operators are taking appropriate steps to reduce GHG emissions from flaring and venting among other sources. Paragraph 56 of the OGA guidance for UKCS field development plans ask for “a detailed technical, economic and emissions assessment” to justify any flaring or venting. Licensees are also required to design facilities for “less wasteful alternatives should the economic or technical circumstances change.” Onshore guidance reflects the same principle of avoiding “unnecessary wastage” via flaring and venting. The Net Zero Stewardship Expectation 11 asks the oil and gas industry to reduce GHG emissions from all aspects of its upstream operations “as far as reasonable in the circumstances.” Development plans for greenfield projects need to demonstrate “consideration and economic assessment of GHG Emissions Reduction Action Plans.” These plans include “zero routine non-safety-related flaring/venting” and “gas recovery systems” in addition to low-carbon electricity options, better GHG measurements, new technologies to reduce emissions, and coordination with others to create energy hubs to avoid duplication of infrastructure. The OGA Flaring and Venting Guidance, 2021 , requires a Flaring and Venting Management Plan, which can be incorporated in the GHG Emissions Reduction Action Plan.
The Net Zero Stewardship Expectation 11 lists various expectations as applicable across the exploration, appraisal, development, production, late-life, and decommissioning phases of an oil and gas asset. Opportunities to reduce GHG emissions, including from flaring and venting, include improved measuring, reporting, tracking, and incorporating of net-zero targets in corporate decision making across all lifecycle phases of an asset. Some design considerations for greenfield projects are relevant to flaring and venting. Both the Net Zero Stewardship Expectation 11 and the North Sea Transition Deal call for a sharper focus on energy hubs, the sharing of facilities, and long-term planning for infrastructure repurposing. Improved measurement and tracking of emissions are key requirements for better economic assessment by operators the OGA asks to develop reduction strategies for flaring and venting. The OGA benchmarking analysis for flaring shows that some facilities have much lower flaring intensities than others. More accurate and detailed data are expected to improve the understanding of the lowest-cost approaches to reducing volumes of flared gas. The OGA is also developing a database for methane emissions, in order to replicate the benchmarking exercise for venting. The OGA Flaring and Venting Guidance, 2021 , formalizes these expectations. Operators are expected to demonstrate that they evaluated all options to reduce flaring and venting when applying for consents and when developing credible plans to reach zero routine flaring and venting.
According to the OGA Flaring and Venting Guidance, 2021 , the flaring or venting consent granted during commissioning is intended to cover the period from first oil production to the achievement of stable operations (one to three months). The operator must provide weekly reports to the OGA detailing the activities from the previous week, including daily rates of oil and gas production and gas exported, flared, vented, or used as a fuel; cumulative plots of production, flaring, and venting compared with consented quantities and of associated emissions; and the status of gas compressors and gas-processing plants, highlighting anything that affected equipment or plant performance. During production, unless specified otherwise in the consent, flaring volumes are included in routine reporting via the OGA Petroleum Production Reporting System via the Energy Portal . Under the Petroleum Act, 1998 , only the gas flared from the licensed area requires consent, but the OGA requires that the content of inert gases in the flare be provided for information. The OGA Flaring and Venting Guidance, 2021, lists several reporting requirements. Flaring and venting must be allocated by source category. New in the OGA Flaring and Venting Guidance, 2021, source categories are made consistent with the World Bank’s Zero Routine Flaring by 2030 initiative . They include the following: Category A: Routine flares under normal safe and efficient operating conditions Category B: Nonroutine flares that occur during normal operations beyond optimal levels for the facility Category C: Safety flaring during emergency conditions. Operators also report flaring and venting data and emissions from these activities via the Environmental and Emissions Monitoring System, the environmental database of the UK oil and gas industry maintained by OPRED.
The OGA is authorized to sanction operators for noncompliance with any of the licenses it issues, including consents for flaring and venting. Chapter 5 of the Energy Act, 2016 , on sanctions, details OGA’s disciplinary powers. Sanction notices can cover enforcement of “petroleum-related requirements,” financial penalties, revocation of licenses, and operator removal. Section 42 of Chapter 5 defines petroleum-related requirements, which include responsibilities imposed under Section 9C and 9A of the Petroleum Act, 1998 , requirements under the Energy Act, 2016 (including flaring and venting consents issued by the OGA), and any term of offshore licenses issued by the OGA. According to Sections 44–46 of Chapter 5, financial penalties are limited to £1 million (about US$1,400,000 as of October 2021), although the secretary of state can increase them up to £5 million (about US$ 6,800,000 as of October 2021). If a financial penalty notice is given to two or more parties, they are jointly and severally liable. The payment is recoverable as a civil debt if it is not paid before the deadline in the notice. Penalties must be paid into a consolidated fund. However, exact penalties must be defined in the guidance to be issued by the OGA. The most recent guidance from the OGA provides principles of best regulatory practices based on other regulators. As of 2021, OGA has not sanctioned any operator for violations of flaring or venting consents. Civil penalties for flaring or venting range from £500 to £50,000 (about US$680–US$68,000 as of October 2021) and can be issued by OPRED under the Offshore Environmental Civil Sanctions Regulations 2018. In addition, OPRED, the Environment Agency, the Scottish Environment Protection Agency, and the Scottish Environment Protection Agency can impose civil penalties for breaches of the UK ETS under the Greenhouse Gas Trading Scheme Order 2020 . This last penalty has become more pertinent, as flaring is no longer eligible for free allowances under the EU ETS Phase IV, which started in 2021. The UK ETS is expected to align with the EU ETS Phase IV.