| Ms Sarah.J.Burton Director, Campaign for Sane Energy, Greenpeace UK Canonbury Villas London, N1 2PN |  |
| Shell-Mex House Strand London 26th June 1997 |
Dear Ms. Burton
I refer to your letter of the 23rd June. Shell U.K. Exploration and Production (Shell Expro) is an active member of UKOOA and while I am not a member of the UKOOA Environment Committee, Shell Expro is represented by a senior member of staff.
Whilst we have been unable to trace the source, or a copy, of the leaked note that you quote, I am disappointed to note that your immediate conclusion has been to suspect our credibility and our commitment to openness. We are also aware that you approached journalists with this information before contacting ourselves for an explanation, which, if I may say so, falls short of even basic courtesy.
There is no record that we need to 'put straight', the wording in the 'leaked' note is simply wrong.
Let me be clear. The SCOPEC figures for 1995 are enclosed.
Shell Expro together, with a number of other operators, is still in the process of finalising its figures for the 1996 SCOPEC database. Consequently, SCOPEC has not yet submitted the total industry figure for 1996 to the DTI. You may be interested to know that, counter to your claims of secrecy and collusion, UKOOA is already proposing to publish a summary of the 1996 data on the web site.
As you will determine, by checking your assumptions with the enclosed data frorn the SCOPEC Atmospheric Emissions inventory, our reported emissions are in proportion to the size and scale of our activities on the UKCS.
Furthermore, we have not kept our figures from public scrutiny. Our flaring figures have been available to the public in the DTI Brown Book since 1981. The latest figures can be found in the April 1997 edition. This quotes a daily rate expressed as million cubic metres per day. The Shell contribution is broken down on a Field basis.
In addition Shell UK published stand-alone Environmental Reports in 1995 and 1996. They include data on Expro's flaring and venting performance. In some cases the figures we have published are based on a more conservative calculation methodology than that used by SCOPEC. In plain terms, we publish an overestimate of our own emissions. Each year, we have commented to this extent in the notes to the tables in our annual environmental reports. The SCOPEC methodology is undoubtedly more accurate and we hope to update our own methodology next year.
I enclose a copy of the 1996 report and you will find the figures in Appendix 1 -Table A. As you will see we have reduced our venting and flaring by 45% since 1991 - a reduction achievement confirmed by the data in the DTI Brown Book - and set ourselves an ambitious objective for the year 2000. Furthermore it is not just total volumes that have continued to fall. As a function of our hydrocarbon production, flared and vented gas has come down from 2.1% in 1991 to 1% in 1996. This is an Impressive performance and we are proud of it.
We do not keep a log of outside requests for environmental information.
Finally, I refute completely any suggestions that we are colluding with the regulatory authorities or that we are trying to cover up in any way details of our environmental performance. Shell Expro was one of the first offshore operators to report publicly on all aspects of its environmental performance through the annual Shell UK Environmental Report. This year the report, including the data contained in it, was independently verified by Lloyds Register- just as DNV, in a much more specific context, verified data relating to the contents of Brent Spar.
In March of this year the Royal Dutch Shell Group re-stated its commitment to Health, Safety and Environment. One of the commitments is to report openly on HS&E performance. We are doing this and will continue to do so. In this context, simplistic Greenpeace conclusions, or attempts to manipulate information for publicity purposes is, in my considered view, less than helpful.
Yours sincerely
Heinz Rothermund