Dear John

REQUESTS FOR ENVIRONMENTAL INFORMATION

You may be aware we have had regular requests for environmental information from the Marine Conservation Society (MCS) since the autumn of last year. The MCS has required this information under the Environmental Information regulations 1992 which require that we disclose any information on the environment which is provided to us under our statutory function.

Thc MCS has been pushing ever harder for the release of environmental information which has been provided to us under statutory provisions. The requests have gone on to ask for information on our level of monitoring and seek virtually any other environmental information we hold. The MCS had asked for data from 1985 onwards in a form which meant we were unable to access the information without a significant amount of work. However, this request has now been restricted to any information which is available in a readily accessible form.

We have responded with information which is supplied by the oil and gas industry under a statutory provision, mainly oil spill and discharge data by operator and installation. It seems inevitable the MCS will use this to pick out what it judges to be the worst examples and may then approach the operator concerned. I thought you might wish to warn your members of this possibility. I attach a description of the data which has been provided.

We hope the information we have provided will be sufficient to satisfy the MCS requirement but it is possible they will come back for other information which is currently provided on a voluntary basis eg. use of non oil muds, chemicals etc. The legal position on the release of this information seems unclear but is favouring towards the release if asked. We may tberefore find ourselves obliged to provide the data and any views you had on this would be welcome.

Turning to another issue, we now have some six months or so experience of carrying out our offshore environmental inspection programme and this has identified issues of both a specific and general nature. Whilst the specific items can be addressed with individual operators there are issues which seem to be more widespread. We are wondering how best to bring this to the attention of the whole industry. You and I are due to meet shortly for our quarterly review meeting, and I would like, at that time, to discus our general findings and where this is taking us in structuring both our routine and non routine inspection programmes. I wonder if you could give some thought, in advance of the meeting, to how UKOOA might be able to help bring about change especially in some of those areas where the offshore environmental legislation is somewhat limited.

Please do not hesitate to contact me if you wish to discuss any of this.

Yours sincerely

A S Wilson
Director of Development, Production and Decommissioning Branch

cc James May