5. The marine environment, offshore operations and management plans
As a coastal and marine nation, Norway aims for an integrated, ecosystem-based management of its marine resources and ecosystems. The first integrated ocean management plan for the Barents Sea and the areas outside of Lofoten came about in 2006. This plan has since been extended to include the Norwegian Sea and the North Sea and Skagerrak. The most recent plan update appeared in the Norwegian Parliament´s White Paper (2019 – 2020). The white paper brings together all management plans for the first time.
The next revision of the integrated ocean management plans will take place in 2024, and the scientific grounds for the revision were submitted to the Norwegian government on 16th. May.
In addition to the integrated ocean management plans, other overlapping processes within ocean management are also taking place, such as marine conservation and the following up of international commitments (the Kunming-Montreal Global Biodiversity Framework), as well the development of industry plans. Offshore Norge believes it is important for ocean management to continue to be integrated and sees the ocean management plan as the primary tool to ensure this.
5.1 Integrated ocean management plans for the Norwegian sea areas
The purpose of the plans is “to create value through the sustainable use of resources and ecosystem services whilst maintaining the structure, function, productivity, and diversity of the ecosystems.”
The petroleum industry has always supported this approach and wishes to assist in ensuring an optimum foundation for the management plans. The integrated ocean management plan must, in our opinion, be based on the following:
- Value creation through sustainable practices as an important factor
- Equal treatment of industries in the sea areas
- Practice of the precautionary principle regarding the Act for the management of biological, geological and landscape diversity
- Involvement of interest groups
There are three main marine industries in Norway today which are assessed in the management plans, namely fishing, shipping and the petroleum industry. There are also new industries coming into play, such as offshore wind, carbon capture and storage (CCS), mineral extraction and aquaculture (outside of 12 nm).
The Norwegian Parliament´s white paper confirms the current balance between sustainable use and conservation. Environmental conditions in the Norwegian sea areas are good in many respects, but are increasingly impacted by climate change, which is having a very clear effect on the state of the ecosystems both in the North Sea and in the northern Barents Sea. The impact of discharges from the petroleum industry during normal operations is insignificant, whilst the fishing industry has the largest impact. The fish species are generally sustainably managed, meaning that sustainable use and conservation are currently in balance.
The next revision of the integrated ocean management plan is underway, and information and updates on the scientific basis can be found on the Havforum website. The scientific basis was submitted to the Minister of Climate and Environment on 16th. May 2023. The basis consists of a primary report and several supplementary reports, including:
- Particularly valuable and vulnerable areas (SVO) in Norwegian sea areas – environmental value
- Environmental values´ vulnerability in Norwegian sea areas
- Environmental status in Norwegian sea areas
The participation of interest groups is an important part of ecosystem-based management. In the upcoming update, less resources have been labelled for such participation compared to the current management plan. The petroleum industry has been a significant contributor for many years towards building expertise on environmental values and on the potentially environmentally harmful effects of activities from operations on the NCS. It is important that this expertise also forms a part of the scientific basis and is included in the ocean management plan.
Offshore Norge works actively with our members to highlight this expertise, regularly sharing information and providing feedback. In this update round, we have participated in input meetings and submitted our written input to the SVO report on environmental values, as well as responses to the consultation on factual errors/inadequacies of the scientific basis.
5.2 Particularly valuable and vulnerable areas (SVO)
Particularly valuable and vulnerable areas are identified by the integrated ocean management plan for the sea areas. As per today, 7 SVOs have been identified in the Barents Sea – Lofoten region, 12 in the Norwegian Sea and 11 in the North Sea. Within the marine areas are sub-areas which stand out as particularly valuable and vulnerable from an environmental and resource perspective. These areas have been identified by scientific assessments as being of great importance for biodiversity and biological production, and where potential harmful effects may have long-term or irreversible consequences. The areas are identified based on specific criteria, with significance for biodiversity and productivity being the most important. Criteria such as uniqueness, pristine condition, representativity, and scientific and pedagogical value are supporting criteria.
The designation of an area as a SVO does not have any direct effect in the form of restrictions on commercial activities, but indicates that these are areas in which it is important to show special caution.
As a part of the scientific basis for this white paper, all assessments across all sea areas have been merged, and all SVOs have been thoroughly reviewed in order to highlight the grounds for their value and vulnerability. In June 2021, the Institute of Marine Research (HI) presented the report “Particularly valuable and vulnerable areas in Norwegian sea areas – Environmental value”. The report delineates, describes, and states the reason for identifying areas of environmental value which meet the necessary criteria. These areas are referred to as proposed SVOs. A vulnerability assessment was published in the autumn of 2022, containing information about the environmental values´ inherent vulnerability towards various impacts in the areas. A new methodology was implemented to assess vulnerability in the report. The scientific forum believes that further work needs to be carried out on vulnerability and has therefore used the environmental values for this further work as a basis. Offshore Norge believes that vulnerability is a part of the SVO definition and must be taken into account when defining the areas.
The proposed SVO areas are a merger of several previously defined areas, an adjustment of previous areas and an introduction of new areas. The number of SVOs is fewer, but the total area is significantly larger (approximately 60% of the Norwegian economic zone). Offshore Norge believes that the size alone of the proposed areas will pose a challenge to optimal management of the entire area, since the presence of natural resources will necessarily vary from one SVO to another. A qualitative assessment of many topics/factors per area will lead to large areas being defined as valuable, which may weaken the intention of SVOs to be viewed as particularly valuable areas.
5.3 Marine conservation/international agreements associated with biodiversity
Measures for conservation, sustainable use and expertise are key components in an integrated ocean management plan. Area conservation can be achieved through marine conservation as well as other effective area-based conservation measures, as discussed in the Storting White Paper 29 (2020 – 2021), Comprehensive National Plan for the Conservation of Important Areas for Marine Nature. Marine conservation areas may be established pursuant to the Nature Diversity Act. This law has a limited reach on the NCS and the regulations for defining marine conservation areas do not apply outside of 12 nm. Area-based measures can be implemented in accordance with sector legislation, and this has been carried out, for example, within fishery management plans, where several coral reef areas are protected against any harmful impact from fishing activities.
Norway has also signed a number of international conventions and agreements on nature diversity and has participated actively in implementing them. The United Nations Convention on Biological Diversity (CBD), informally known as the Biodiversity Convention, was passed in 1992, and in December 2022 a new nature agreement, named the “Kunming-Montreal Global Biodiversity Framework”, was passed in Montreal.
The Norwegian government has started follow-up work of the new global framework, and a part of this work will be to put in place a new marine environment law allowing areas outside of 12 nm also to be protected.
5.4 Environmental risk and the precautionary principle
Knowledge of vulnerable environmental resources which can be impacted by the petroleum industry´s operations is important, and large-scale resources are invested in mapping, environmental monitoring, impact studies and risk analyses in all phases of petroleum-based operations.
Knowledge of the factual vulnerability of the environmental values is important in order to make informed decisions on any operational limitations placed on industrial activities. Both the government and the responsible body may be better equipped to avoid costly activity limitations during those periods when the vulnerable resources are not present and/or when operations do not impact the resource in question. Offshore Norge has previously commented that the vulnerability assessments made in the scientific basis for the integrated ocean management plans have not been sufficiently precise. Before making any large-scale changes and ensuing limitations on the existing SVOs, there must be complete clarity on what the valuable component of the ecosystem is actually vulnerable towards.
The Nature Diversity Act and 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 biological, geological or landscape diversity. It is clear from the Nature Diversity Act and from supporting material that the precautionary principle should be made at a decision-making level. It should not be applied “for safety´s sake”, nor in cases of general or hypothetical uncertainty. The principle ensures a risk-based decision based on professional input, data, and science. It is not advisable for the precautionary principle to be drawn into the scientific decision-making criteria, nor for it to be presented to the decision-making body as an increased potential for damage, as a widening of potential outcomes or as an increased uncertainty. The role of science and its institutions is to present the best factual understanding and the most accurate estimates, highlighting the actual uncertainty range as well as the uncertainty indicated by the material.
The precautionary principle does not imply zero risk. In administrative areas where the principle has been well incorporated into decision-making processes, the decisions made are also based on a risk acceptance, and the precautionary principle is seen relative to cost/benefit assessments.
Historical data from the NCS indicates that over the course of fifty years of oil and gas operations, no unintentional spills have caused a significant environmental impact. This includes offshore operations, associated transport, and associated onshore facilities. The industry does not, however, claim that a serious incident cannot occur from its operations. The petroleum industry has therefore prioritized further learning about actual potentials for damage, as well as developing methods to convey this knowledge, to give a complete picture of possible outcomes and uncertainties.
Expertise is essential regarding when environmental resources are at their most vulnerable, when they are present and which activities pose the greatest environmental risk. Examples of this work include the mapping and monitoring of seabirds, (e.g. SEAPOP and SEATRACK), research on the effects upon fish and other resources in the water masses (e.g. PROOFNY and SYMBIOSES), and the research and development of models to predict the presence of seabirds and sea mammals (e.g. MARAMBS).
5.5 Environmental monitoring
The industry has invested significant resources to understand which discharges could cause an impact, so that the most effective measures can be implemented. This commitment includes environmental mapping and monitoring to assess conditions, continuously improved methods of monitoring, and research. It involves preventive measures as well as measures designed to reduce consequences, such as the substitution of chemicals (see chapter 4.4) and oil spill preparedness.
An important element of this work is the comprehensive annual environmental monitoring on the NCS. The aim is to document the condition of the environment and its development as a result of both human impacts and naturally occurring variations. Substantial research work is also being carried out by individual companies. This includes the development of monitoring methods and an increased understanding of the impact of petroleum industry discharges on the marine environment.
The Norwegian Pollution Control Authority (SFT, now the Environment Agency) already demanded in 1973 that operators prepare annual environmental reports, and environmental monitoring on the Norwegian continental shelf has therefore been ongoing for almost 50 years. SFT's first guideline for environmental monitoring came into effect in 1990. Today, monitoring is carried out in accordance with the Environment Agency's guide M-300 (M-408 English version). The extent of monitoring should be related to offshore petroleum activities in the respective regions, and the monitoring program is planned by the operators. Environmental monitoring is conducted 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 Environment Agency.
Monitoring includes investigations of the water column, seabed sediments and benthic animals. Visual inspection of the seabed is also carried out in areas containing particularly vulnerable species such as corals and sea sponges. Data collected from the environmental monitoring, which is not protected by confidentiality or competitive significance, is shared and uploaded to Mareano. Mareano is an interdisciplinary program for the mapping of the seabed in Norwegian marine areas, and is led by the NEA, whilst the Institute of Marine Research, the Geological Survey of Norway (NGU) and the Norwegian Mapping Authority are responsible for daily scientific operations.
Water column monitoring
Water column monitoring consists of field examinations and methodology development. The examinations are carried out every third year and must, as a minimum, contain hydrographic measurements, chemical measurements, and examinations of caged organisms (primarily mussels), as well as freely living organisms (primarily fish). The time period between any two field examinations is used for the further development and qualifying of methodologies for future water column monitoring.
In 2021 a comprehensive program was carried out in the Ekofisk region. This work is referenced in more detail in Offshore Norge´s 2022 Climate and Environmental Report.
Several attempts were carried out in 2021 and 2022 to develop methodologies for future field surveys, but no major surveys were carried out in the field. Several of the findings were presented during the Forum for Offshore Environmental Monitoring in the autumn of 2022.
Seabed surveys
Monitoring of the benthic habitats consists of taking seabed samples, usually with the aid of a grab, and analyzing the physical, chemical and biological condition of the sediment. Certain stations have been surveyed regularly for over thirty years and these data are therefore very valuable to both researchers and to the government in assessing naturally occurring and anthropogenic changes to the environment over time. There is a keen interest in applying this material to the government´s ocean management plan.
A regional approach to the monitoring of each region once every three years was introduced in 1996. The NCS is divided into a total of eleven geographical regions for the purpose of seabed monitoring. In addition, all fields must complete a basic survey prior to start-up to document the natural environmental condition of the field.
The environmental monitoring program is extremely comprehensive, covering approximately 1,000 stations on the NCS. Field work and surveying are usually carried out in May and June. All the data are stored in the MOD database, which can be accessed provided one is registered on DNV´s Veracity Data Platform.
Once the production phase has ceased, two further monitoring surveys are carried out at three-year intervals to observe the development of the field once all discharges have come to an end. The NEA put out a proposal for consultation on 18th April 2023, proposing revised guidelines for petroleum monitoring and more specifically, a new chapter on surveys associated with decommissioning.
Several major research programs have been carried out by independent researchers to analyse the potential impact of oil and gas industry discharges to sea. These include The Research Council of Norway´s “Marinforsk” program, launched in 2015, and the former Oceans and Coastal Areas (PROOF/PROOFNY, from 2004 to 2015). The results of the environmental monitoring have also been used in several scientific papers.
In summary, PROOFNY concludes that the potential for harmful environmental impact from discharges to sea is generally moderate. The consequences of drilling operation discharges are only detectable in the immediate vicinity of the drilling location, and usually limited to 150 – 200 meters from the discharge source. The impact is often related to particle discharges and to the filter-eating bottom fauna such as brittle-stars.
The Offshore Environmental Monitoring Forum takes place every autumn, where the annual results from the monitoring programs are presented. Torgeir Bakke from NIVA gave a presentation in autumn 2021 on seabed monitoring on the NCS seen as a timeline from the 1970s until the present.
In autumn 2022, Jonny Beyer and Torgeir Bakke from NIVA initiated work on a new review, financed by Offshore Norge and the NEA. The article will provide an updated overview of the knowledge which has been gained over many years of environmental research and monitoring within the Norwegian offshore oil and gas industry. Based on the findings, the article will provide recommendations for future offshore environmental monitoring. The result of this initiative will be presented at the Offshore Environmental Monitoring Forum 2023, with the published version expected to be completed by the end of 2023.
Surveys and assessment of vulnerable seabed areas
The petroleum industry is present on the NCS in the North Sea, the Norwegian Sea and the Barents Sea. The industry is required to survey the seabed and bottom fauna prior to commencing activities. This provides a basis from which to explain the potential environmental impact of such activities and ensures a minimal footprint from the petroleum industry´s activities. The impact is primarily related to drill cutting discharges. The environmental monitoring is essentially carried out by collecting seabed samples with the aid of a grab, followed by analyses of the physical properties (particle size), chemical properties (hydrocarbons and metals), and biological properties (description of species diversity). In hard bottom areas, or where vulnerable benthic habitats are present, visual and acoustic surveys are carried out, either instead of or in addition to grab surveys of the seabed. This applies particularly to areas in which sponges and corals are present, as they are considered vulnerable to particle discharges from drilling activities. The purpose of visual surveys is to map the presence and scope of species and natural habitats which are red-listed in Norway. Coral reefs, hard bottom coral forests and sponge spike bottoms are considered to be near threatened. The visual monitoring is an effective tool for mapping incidents and avoiding damage to the natural environment.
Offshore Norge has commissioned DNV to update the guidelines for vulnerable benthic habitats, and the work is expected to be completed during 2023. The handbook will be revised pursuant to the report on red-listed species in Norway from 2021, as well as to OSPAR´s status report from 2022. The aim of this guideline is to avoid physical damage to coral reefs and sponge areas, inter alia.