Learnings from recent offshore project proposal submissions

Abstract

The offshore project proposal (OPP) process was introduced in 2014 as part of the streamlining of regulatory processes under the Offshore Petroleum and Greenhouse Gas Storage Act 2006 and Environment Protection and Biodiversity Conservation Act 1999 to provide for offshore petroleum developments to be assessed early in the project lifecycle. The OPP process involves the assessment of environmental impacts and risks of petroleum activities conducted over the life of an offshore project by the National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA). An OPP for an offshore project must be accepted by NOPSEMA before a titleholder can submit environment plans for activities that make up the offshore project. Although the OPP process is not new, it has proven complex to navigate, with four revisions to the OPP contents requirements guideline published by NOPSEMA since inception, and only three OPPs reaching the public consultation stage to date. An OPP is required to describe the offshore project; describe the environment that may be affected by the project; set out environmental performance outcomes for the project; describe feasible alternatives to the project or its activities; and evaluate environmental impacts and risks of the project. This paper provides insight to the OPP drafting, submission and assessment process, with shared key learnings based on actual examples of OPP submissions made. In particular, we will focus on the crucial elements that haven proven to make an OPP submission effective, including project aspect scoping, understanding relationships between aspects and receptors, building flexibility within set project boundaries and demonstrating acceptability.