OGA Plan - Emissions Reduction

The OGA Plan sets out emissions reduction requirements on the path to net zero, including electrification, and guides the NSTA’s considerations on whether electrification of an existing asset is reasonable. 

The NSTA has developed an internal process for NSTA staff to undertake an ERA (the ‘ERA process’). The NSTA will usually apply this ERA process to those matters where electrification is a relevant consideration.

The ERA process has four phases, which will be followed as appropriate, to the circumstances of a hub – phase 1: initiation and framing, phase 2: data gathering and analysis, phase 3: develop recommendation; and phase 4: an expressed position. 

While the NSTA’s position for a hub does not predetermine the outcome of future regulatory decisions or stewardship actions, it will be taken into account in the NSTA’s considerations. For example, as provided in the OGA Plan, where the NSTA considers that it is reasonable to electrify an existing asset, but relevant persons have chosen not to electrify, they should have no expectation that the NSTA will issue any future decisions that give access to additional hydrocarbon resource on that asset.

Whether or not electrification is reasonable will depend on the overall situation in respect of a particular hub, taking into account a range of factors, including matters  such as achieving optimum levels of performance, reducing emissions, the weighing of total remaining value of reserves and resources that may be developed through that hub, and the expected emissions reductions from electrification against the expected cost of electrification.

To understand the hub, the NSTA needs to know the characteristics of the hub itself, reserves and resource opportunities, electrification infrastructure potential in the area, current emissions, committed and future emissions reduction opportunities and the associated emissions abatement potential. Accordingly, a dataset will be collated from the data requested from the hub operator and available to the NSTA (e.g. UKCS Stewardship Survey). The NSTA may also ask for further information from relevant persons.

The data will be reviewed and analysed by the NSTA to reach a position on the reasonableness to electrify a hub, which will be notified to the hub operator in writing. 

Where the views of the NSTA and the hub operator on the reasonableness to electrify are not aligned, the NSTA will provide to the hub operator the key points to justify its provisional position, the opportunity to make representations and provide any further information, and then an expressed position which takes this into consideration. 

The NSTA’s expressed position is the position at the point the ERA has been completed and may be revisited in the future, should relevant circumstances change in respect of the hub.