The NSTA grants licences that confer exclusive rights to ‘search and bore for and get petroleum’. The terms and conditions of the licence are set out in the licence itself or incorporated by reference to secondary legislation (including model clauses). It is the responsibility of every licensee to be aware of all regulatory controls, including the model clauses, and to comply with them.
Consent from the NSTA is required to carry out certain UKCS well activities. Applications for consents are made on the NSTA’s Energy Portal using the NSTA’s Well Operations Notification System (WONS). The applications and subsequent notifications allow NSTA to consider whether licence conditions and the OGA Strategy objectives are being met.
The concept, responsibilities and obligations of a Well Operator or Installation Operator are set out in The Offshore Petroleum Licensing (Offshore Safety Directive) Regulations 2015 . Only entities that have been appointed pursuant to these regulations are permitted to conduct petroleum operations or well operations. The Well Operator is responsible for well operations and for any operation in relation to a well which may result in an accidental release of fluids from that well which could give rise to the risk of a major accident. Additional guidance on these roles is given on the OMAR website.
It is the licensees, not the OMAR Well Operator, who must have WONS consent for well activities under their licence and the Exploration or Field Operator that usually applies for that consent on the licensees’ behalf. If the OMAR Well Operator is not the licensees’ Exploration or Field Operator, then the licensees must ensure that the Well Operator is aware of all conditions relating to well consents.
Licensees require a consent before:
- a well foundation or other equipment is installed in advance of drilling operations,
- a well is spudded, side-tracked or drilling recommences,
- any part of a well comes within 125m of a licence boundary,
- a well test, or extended well test, is commenced,
- a well is abandoned,
- a well is suspended,
- completion work (including hydraulic fracturing) is carried out on a well,
- physical changes are made to a well (re-completion).
Licensees should contact the NSTA if they intend to carry out any work on a well not covered by these descriptions
If an application is made and a consent is given, the licensees will receive the consent electronically: • well activities should be carried out as described in the application and comply with any Licence and specific conditions in the consent,
- specific conditions may include, among others, requirements relating to timing, activity and reporting,
- notification of the resulting well configuration, status etc. must be submitted after the consented activity has been completed,
- there is a general licence obligation to execute all operations in or in connection with the licensed area in a proper and workmanlike manner in accordance with methods and practice customarily used in good oilfield practice.
Guidance on requirements and the considerations that NSTA take into account for each type of well operation can be found here.
Appointment of Well Operator
All well applications require a well operator to have been appointed under the Offshore Petroleum Licensing (Offshore Safety Directive) Regulations 2015 (2015 licensing regulations). To appoint a wells operator, licensees must notify the NSTA Licensing and Legal Team via email or letter. This may have been done as part of the licence award process. However, if this has not been done, or if the licensees wish to appoint a different well operator, the Offshore Safety Directive requires an application to be made three months before the date of the proposed appointment taking effect.
Extended Well Tests
Under the model clauses of a licence, the consent of the NSTA is required to undertake extended well tests (EWTs) - extended periods of test production from exploration or appraisal wells prior to development plan authorisation.
Further information on EWTs and the consenting process can be found here: Extended Well Tests guidance
All well applications require separate application/notification, with supporting information, to be supplied to the OSDR.
Environmental information needs to be submitted to DESNZ via the Portal Environmental Tracking System (PETS). Operators need to submit a drilling application via WONS before the well operator can submit data into PETS. The licence operator can initiate this process by submitting a provisional drilling application via WONS if they are not in a position to submit a full initial drilling application.
Formal data collection starts with the submission of the Provisional Drilling Application. Once a well has been spudded (seabed is penetrated), and the operator submits a spud notification on WONS, the NSTA will issue an official well number via WONS (see PON12), which is to be used for all data and records resulting from the drilling of the well.
All well data reporting requirements, for new wellbores, are set out in the documents Reporting and disclosure of Information and Samples Guidance (offshore) and PON 9b (onshore).
Onshore operators have a statutory obligation to also supply well data to the British Geological Survey (BGS).
Wellbore summary information held in WONS is an important System of Record for wellbore data and is used in many NSTA systems and processes and is accessed by a wide variety of stakeholders via the NSTA Data Centre, and overview of which is available here