Offshore Norge – Climate and Environmental Report 2024

In April 2024, the Norwegian government presented the revised ocean management in the Norwegian Parliament’s White Paper (2023-2024): "Norway’s Integrated management plans for the Norwegian marine areas. Barents Sea, the areas off Lofoten, Norwegian Sea, North Sea, and Skagerrak" , hereinafter referred to as Meld. St. 21 (2023–2024). It clearly states that the purpose of the management plan is to create value through the sustainable use of marine area resources and ecosystem services while maintaining the structure, function, productivity, and biodiversity of ecosystems. Currently, there are primarily three major marine industries in Norway that are considered in the management plans. These are fisheries, shipping, and petroleum activities. Additionally, new industries such as offshore wind, CCS, mineral extraction, and aquaculture (outside 12 nm) are also included.

The management plans are a good and democratic tool, and Offshore Norge's members have been, and will continue to be, active contributors to building knowledge about the marine areas on the NCS and the impact that various industrial activities can have on marine natural resources. The petroleum industry has for many years been an important contributor to building knowledge about environmental values and the environmental impact of its activities on the NCS. It is important that this knowledge also becomes part of the professional basis and is utilized in management.

Offshore Norge actively works with our members to highlight this knowledge and participates with input. In this update cycle, we have participated in consultation meetings and submitted written input on the SVO report regarding environmental values , responses to factual errors/omissions in the professional basis , responses to the final professional basis , and responses to the Meld. St 21 (2023–2024) on ocean management plans for the Norwegian marine areas (2023–2024). The next revision of the ocean management plans is underway, and data about updates on the scientific basis can be found on Havforum .

The participation of interest groups is an important part of ecosystem-based management. In the process leading to the final professional basis for the management plan, the involvement of industries has been significantly weaker than in previous updates of the professional basis. The Meld. St 21 (2023–2024) released in April 2024 now proposes the development of a concrete plan for involving affected interest groups in the work on the professional basis for the next management plan paper.

It is important that the management plan remains the overarching governance tool for Norwegian marine areas alongside relevant sector regulations.

Particularly valuable and vulnerable areas (SVO) have been identified through ocean management plans for marine areas. These are areas that, based on scientific assessments, are of great importance for biodiversity and biological production, and where potential harmful effects may have long-term or irreversible consequences. The areas have been identified based on the EBSA criteria (Ecologically or Biologically Significant Marine Areas), an internationally recognized methodology for identifying environmental values in the sea.

SVOs do not have direct effects in the form of restrictions on industrial activity but signal the importance of exercising particular caution in these areas. Such caution is maintained through management measures, for example, through area-specific frameworks for petroleum activities. This can include restrictions such as drilling time limits, environmental mapping, measures to reduce the risk of acute discharges and emissions or long-term environmental damage, and requirements for monitoring and environmental assessments to follow up on the impact of petroleum activity. Which management measures are relevant should be assessed based on the distribution of environmental values in time and space, and where and when the relevant environmental values are vulnerable to different activities.

In Meld. St 21 (2023–2024), there are 19 SVO areas, which is a consolidation of several previously defined areas, adjustments of earlier distributions, as well as the introduction of new areas. The number of SVOs is fewer, but the total area is significantly larger (approximately 60 percent of the Norwegian economic zone). Offshore Norge believes that when the management plan defines larger SVO areas, it underscores the need for concrete caution assessments and targeted measures to ensure relevant considerations for various environmental values. The areas have varying degrees of vulnerability and distribution in time and space, and without such concrete and sector-specific assessments, the significance of the SVO concept will be diluted. A qualitative assessment of many factors per area means that large areas are defined as valuable, which can weaken the intent of SVOs as particularly valuable areas. The white paper emphasizes that area-specific frameworks for activities should not coincide with SVO boundaries and that management measures should be based on the best available knowledge of the distribution of environmental values in time and space. Offshore Norge believes that commercial activity should only be restricted if there are actually vulnerable environmental values where the activity is planned, in order to avoid regulations based on environmental values that are not present in the relevant area.

Measures for conservation, sustainable use, and expertise are key components of comprehensive marine management. Conservation of areas can be achieved through marine conservation and other effective area-based conservation measures and is mentioned in St.meld.no. 29 (2020–2021) Comprehensive National Plan for the Conservation of Important Areas for Marine Nature . Marine conservation areas can be established under the Nature Diversity Act. This law has a limited scope on the NCS, and the rule for establishing marine conservation areas does not apply beyond 12 nautical miles. Area-based measures can be implemented based on sector legislation, and this has been done, for example, within fisheries management, where several coral reef areas are protected against harmful impact from fishing activities.

Norway has also signed several international conventions and agreements on biodiversity and has actively contributed to implementing them. The UN Convention on Biological Diversity was adopted in 1992, and in December 2022, a revised nature agreement was adopted in Montreal, "Kunming-Montreal Global Biodiversity Framework." The new agreement includes specific targets for conservation, restoration, and financing, and states that 30 percent of all nature (land and sea) must be protected by 2030.

The Norwegian government has begun working on the implementation of the new global framework, and part of this work will involve establishing a new marine environment law allowing areas beyond 12 nautical miles to also be protected.

As pointed out by the UN Nature Panel, the world is experiencing a dramatic and accelerating loss of biodiversity caused by human activities. Nature and climate are mutually dependent, and challenges related to climate and nature must therefore be addressed together and simultaneously. This balance and the ability to find holistic solutions will be important in the coming years.

The loss of nature and biodiversity is receiving increasing attention in public debate, and there are expected to be much greater demands for documentation and reporting in these areas moving forward, partly as a result of the EU's sustainability reporting (CSRD).

The work on climate risk has been ongoing for many years and is well established in the industry. Nature risk has many similarities with this, and it is natural to use the same approach and terminology where possible. The Nature Risk Committee was established in 2022 and delivered its work in February 2024 NOU 2024:2 In Harmony with Nature. Offshore Norge has provided input to this work.

Oil and gas activities have been ongoing on the NCS for more than 50 years, and significant resources have been invested in research and development during this period to document any impact on nature and ecosystems. This work has shown that it is possible to conduct commercial activities at sea with very low impact on nature and the environment.

At the same time, the actors on the NCS want to continue to be a driving force for further improvement, and several companies have therefore set ambitious goals related to biodiversity, biodiversity conservation, or nature positivity in their corporate objectives.  

Knowledge about vulnerable environmental resources that may be affected by the activities of the petroleum industry is crucial, and substantial resources are allocated for mapping, environmental monitoring, impact studies, and risk analyses in all phases of petroleum operations.

Knowledge of the factual vulnerability of environmental values is essential for making sound assessments of any operational restrictions imposed on commercial activities. Both authorities and the developer can better avoid costly restrictions on activities during periods when the vulnerable resources are not present and/or when activities do not affect the relevant resource. Offshore Norge has previously commented that the vulnerability assessments made in the scientific basis for ocean management plans have not been sufficiently precise. Before making any major changes to the existing SVOs with associated operational limitations, there must be complete clarity on what the valuable component of the ecosystem is actually vulnerable to.

The Nature Diversity Act with supporting documents (including Ot.prp. No. 52 2008-2009) makes it clear that the precautionary principle should only be applied if there is a risk of "serious or irreversible" damage to biodiversity. It is clearly stated in the Nature Diversity Act and supporting material that the precautionary principle should be used at a decision-making level. The precautionary principle should not be applied just in case nor in situations of general or hypothetical uncertainty. The principle ensures that uncertainties are considered within a professional, fact-based, and scientifically supported decision-making framework. It is not advisable for the precautionary principle to be incorporated into the scientific basis and presented to decision-makers as an exaggerated potential for damage, an expansion of possible outcomes, or an increased uncertainty. The role of science and scientific institutions is to present the best factual understanding and the most accurate estimates, highlighting the actual range of outcomes and the uncertainty inherent in the data.

The precautionary principle does not imply that the risk must be zero. In administrative areas where the precautionary principle is well-integrated into decision-making processes, decisions are also based on an acceptance of risk, and the precautionary principle is considered alongside cost-benefit assessments.

Historical data from the NCS shows that over the course of 50 years of oil and gas activity, no unintentional spills have occurred that have caused significant environmental harm, either from offshore operations, related transport, or associated onshore facilities. This does not mean that the industry claims a serious incident cannot occur from its operations. Therefore, it has been a priority for the petroleum industry to contribute to increasing knowledge about the actual potential for harm and to develop methods for communicating this in a way that provides a complete picture of possible outcomes and uncertainties.

This includes understanding when environmental resources are at their most vulnerable, when they are present, and which activities pose the highest environmental risks. Examples of such activities include the mapping and monitoring of seabirds (SEAPOP and SEATRACK), research on the effects on fish and other resources in the water column (such as PROOFNY and SYMBIOSES), and research and development of models to predict the presence of seabirds and marine mammals (for instance MARAMBS).

The industry has invested significant resources in understanding which discharges could cause an impact, so that the most effective measures can be implemented. This commitment includes environmental mapping and monitoring to assess its condition, developing better methods for environmental monitoring, and conducting research. Measures include both preventive actions and mitigation measures, such as the substitution of chemicals (see chapter 9.3) and oil spill preparedness.

A key part of this work is the comprehensive annual environmental monitoring of the NCS. Environmental monitoring on the NCS has been ongoing for nearly 50 years. The goal of the monitoring is to document the environmental condition and development, both as a result of human impact and natural variations. In addition, there is significant research activity organized by individual companies. This includes both the development of monitoring methodologies and a better understanding of the impact on the marine environment from the petroleum industry’s discharges.

Today, monitoring is carried out in accordance with the Norwegian Environment Agency's guidelines M-300. The extent of the monitoring is to be related to offshore petroleum activities in the respective regions, and the monitoring program is planned by the operators. The environmental monitoring is carried out by independent consultants according to guidelines and requirements from environmental authorities. The scope, methods used, and results are reviewed and quality-assured by an expert group on behalf of the Norwegian Environment Agency.

Monitoring includes studies in the water column, of seabed sediments, and benthic fauna. Additionally, visual mapping of the seabed is conducted in areas with presumed particularly vulnerable species, such as corals and sponges. Some of the data from the environmental monitoring, which are not confidential or commercially sensitive, are shared and uploaded to Mareano. Mareano is an interdisciplinary program for mapping the seabed in Norwegian marine areas, led by the NEA, with the Institute of Marine Research, the Geological Survey of Norway (NGU), and the Norwegian Mapping Authority responsible for its daily scientific operations.