Environmental monitoring – one size fits all?
Article published in the Regulator | Issue 4: 2012
There are no prescriptive requirements in the Environment Regulations for how environmental monitoring related to petroleum activities should be addressed. This could be viewed by operators as a challenge when designing monitoring programs and trying to meet the expectations of the regulator, but it is also a great opportunity to exercise the flexibility that is afforded by an objective-based regulatory regime
It encourages operators to be innovative in their approach to designing environmental monitoring programs that suit the nature and scale and environmental setting of their activity. Under this regime, operators define the objectives against which performance in protecting the environment is to be measured. Operators then design their programs, choose monitoring techniques, propose appropriate environmental indicators and threshold levels of environmental change to ensure that the objectives are being achieved and have the ability to inform any management actions required for continuous improvement.
The responsibility lies with the operator to demonstrate to the regulator in their environment plan why the objectives, measurement criteria and any associated monitoring program is fit for purpose and is suitable for the environment in which they are operating. Likewise, if no environmental monitoring program is proposed, the operator must demonstrate that this is appropriate to the nature and scale of the activity.
Environmental monitoring programs may not always be necessary in order to achieve defined objectives for environmental protection, so before writing a program or engaging specialist advice, consider a few important questions:
What are the environmental performance objectives that you are trying to achieve?
What is an acceptable level of change to the environment?
What is the level of certainty in the environmental impact predictions and do they need to be tested?
What controls can be put in place to prevent damage to the environment?
How could environmental monitoring be used to ensure environmental objectives are met?
Could an environmental monitoring program help provide evidence that could be used to support future submissions?
In many cases, proposed petroleum activities are very short-term and there may be sufficient supporting data to demonstrate that potential impacts do not pose unacceptable risk to the environment. In other cases, activities may be long term and the risk of impact from operations or emergency conditions may be uncertain or obviously greater. This is where the flexibility of the system is an advantage to operators, as there is no ‘one size fits all’ requirement for environmental monitoring.