Escolar Documentos
Profissional Documentos
Cultura Documentos
February 2006
ISBN 1-897101-15-5
Table of Contents
CHAPTER ONE INTRODUCTION ............................................................................................................................. 1
1.0
OVERVIEW.......................................................................................................................................................... 1
1.1
PRELIMINARY CONSIDERATIONS ..................................................................................................... 2
1.1.1
Pre-Application .................................................................................................................................... 2
1.2
DEVELOPMENT PLAN DOCUMENTS ................................................................................................. 3
1.2.1
Development Plan ...................................................................................................................................... 3
1.2.2
Development Plan Summary ................................................................................................................ 5
1.3
ANCILLARY DOCUMENTS................................................................................................................... 5
1.3.1
Safety Analysis and Commitment ........................................................................................................ 5
1.3.2
Environmental Impact Statement (EIS)................................................................................................ 5
1.3.3
Socio-Economic Impact Statement: Sustainable Development ............................................................ 5
1.3.4
Satellite Developments......................................................................................................................... 7
1.4
DECISION BY BOARD............................................................................................................................ 8
1.5
AMENDMENT TO THE APPROVED DEVELOPMENT PLAN ........................................................... 8
CHAPTER TWO - DEVELOPMENT PLAN SUMMARY ........................................................................................... 11
2.0
INTRODUCTION............................................................................................................................................... 11
2.1
TYPICAL SUMMARY ........................................................................................................................... 11
CHAPTER THREE - DEVELOPMENT PLAN............................................................................................................. 13
3.0
INTRODUCTION............................................................................................................................................... 13
3.1
PROJECT OVERVIEW........................................................................................................................... 13
3.2
GEOLOGY AND GEOPHYSICS ........................................................................................................... 14
3.3
PETROPHYSICS .................................................................................................................................... 14
3.4
RESERVOIR ENGINEERING................................................................................................................ 15
3.5
RESERVE ESTIMATES ......................................................................................................................... 15
3.6
RESERVOIR EXPLOITATION.............................................................................................................. 16
3.6.1
Deferred Development ....................................................................................................................... 17
3.7
DEVELOPMENT DRILLING AND COMPLETIONS .......................................................................... 17
3.8
DESIGN CRITERIA................................................................................................................................ 18
3.8.1
Physical Environmental Criteria......................................................................................................... 18
3.8.2
Functional Criteria.............................................................................................................................. 18
3.8.3
Geotechnical Criteria.......................................................................................................................... 19
3.9
PRODUCTION AND EXPORT SYTEMS ............................................................................................. 19
3.9.1
Production Installation ....................................................................................................................... 20
3.9.2
Topside Facilities ............................................................................................................................... 20
3.9.3
Subsea Production System ................................................................................................................. 21
3.9.4
Export System .................................................................................................................................... 22
3.10
CONSTRUCTION AND INSTALLATION ........................................................................................... 22
3.11
OPERATIONS AND MAINTENANCE ................................................................................................. 23
3.11.1
Organization ................................................................................................................................. 23
3.11.2
Operations and Maintenance Procedures ...................................................................................... 23
3.11.3
Ice Management Plan ................................................................................................................... 23
3.11.4
Operability of the Proposed Development.................................................................................... 23
3.11.5
Logistics ....................................................................................................................................... 24
3.11.6
Communications........................................................................................................................... 24
3.11.7
Contingency Plans ........................................................................................................................ 24
3.11.8
Vessel Surveillance....................................................................................................................... 24
3.11.9
Production Safety ......................................................................................................................... 25
3.12
DECOMMISSIONING AND ABANDONMENT .................................................................................. 25
3.13
DEVELOPMENT AND OPERATING COST DATA ............................................................................ 25
3.14
GUIDELINES FOR DEVELOPMENT PLAN (PART II) ...................................................................... 26
CHAPTER FOUR SAFETY ANALYSIS AND COMMITMENT ............................................................................. 27
4.0
INTRODUCTION............................................................................................................................................... 27
4.1
CONCEPT SAFETY ANALYSIS AND TARGET LEVELS OF SAFETY ........................................... 27
4.2
RISK ASSESSMENT PLAN................................................................................................................... 27
4.3
QUALITY ASSURANCE AND QUALITY CONTROL........................................................................ 28
4.4
TRAINING PLAN................................................................................................................................... 28
4.5
SAFETY MANAGEMENT SYSTEM AND SAFETY PLAN................................................................ 28
4.6
SECURITY .............................................................................................................................................. 28
ii
OVERVIEW
1
2
PRELIMINARY CONSIDERATIONS
1.1.1
Pre-Application
The proponent should provide early written notification of its intention to develop
a pool or field. Once a decision has been made by the Board respecting the form
and conduct of a public review, the proponent will be notified.
Formal review of a Development Application by the Board may commence only
when a complete Development Application is received in accordance with these
Guidelines and the Canada-Newfoundland and Labrador Benefits Plan
Guidelines. It is only at that point that the Board can forward the Development
Application to the Public Review Body for a hearing of the Development
Application, at which time the staff of the Board will also commence its technical
review. As part of pre-consultation, any design requirements will be discussed
with the proponent to clarify the requirements to ensure a complete application is
filed in accordance with the Guidelines.
1.2
1.2.1
Development Plan
The primary purpose of the Development Plan is to provide the Board with
information necessary to assess the acceptability of the proponents plan and to
assist the Board to make an informed decision. A secondary purpose is to make
appropriate information available for public examination. The proponent should
consult with the Board on the number of hard copies of the Development Plan to
be submitted for review. A digital copy of the Development Plan should be
provided.
The Development Plan is to be submitted in two parts5:
PART I
PART II
6
7
ANCILLARY DOCUMENTS
1.3.1
The purpose of this document is to describe how the proponent has integrated
safety into the design of the proposed development, the management systems,
policies and procedures, planning processes, personnel selection, training and
management.
1.3.2
8
9
10
Satellite Developments
11
Any project which involves the use of a previously assessed and approved production facility or infrastructure in
operation in the Newfoundland and Labrador Offshore Area.
In addition to the documentation outlined in sections 1.1 and 1.2, the Board may
require the submission of any report relating to previously conducted
environmental assessments, when reviewing an Application for a satellite
development. The Board may also require other ancillary documents in support of
the Development Application, including any impacts on existing offshore
operations which had previously been approved without contemplation of a
satellite development.
1.4
DECISION BY BOARD
The Board is required by the Acts to make two specific decisions in respect of a
Development Application:
In its consideration of the Development Application, the Board will take into
account the findings and recommendations of the Public Review Body (if
established), any screening report, comprehensive study report and/or
Environmental Assessment Determination Statement issued by the Minister of
Environment pursuant to the CEAA, comments and advice received from federal
and provincial departments and agencies, submissions from interested parties (if a
Public Review Body was not established), and the results of its own internal
review.
In its Decision Report, the Board may require the proponent to submit additional
information as a condition of approval. Where such information would typically
be made public as part of a Public Review process respecting the Development
Application, the information will be subject to public disclosure when the Board is
satisfied that the condition has been satisfied.
The Board may, as a condition of approval of the Development Plan, require the
proponent to provide third party access to its processing, storage and/or
transportation facilities.
1.5
(b)
(c)
The Board will review the information and advise the operator if the proposed
modification or addition constitutes an amendment to the Development Plan.
Depending on the activities associated with the proposed amendment, it may
require an environmental assessment pursuant to the CEAA, and possibly may
require a Benefits Plan Amendment.
10
INTRODUCTION
TYPICAL SUMMARY
A typical Summary includes ancillary documents and may follow this outline:
1.
Introduction
2.
Development Plan
2.1 Geology
2.2 Reservoir Engineering
2.3 Design Criteria
2.4 Geotechnical Design Considerations
2.5 Production and Transportation System
2.6 Construction and Installation
2.7 Development Drilling and Well Completions
2.8 Production Operations
2.9 Development Costs
11
3.
Environmental Impacts
3.1 Description of Existing Environment
3.2 Effects Assessment
3.3 Mitigative Measures
3.4 Residual Effects
4.
Socio-Economic Impacts
4.1 Existing Social and Economic Setting
4.2 Effects and Mitigative Measures
4.3 Residual Effects and Benefits
5.
Safety Analysis
5.1 Concept Safety Analysis
5.2 Risk Assessment Plan
5.3 Quality Assurance and Control
5.4 Training Plan
5.5 Safety Management System and Safety Plan
5.6 Security
6.
12
INTRODUCTION
This chapter provides guidance for the preparation of the Development Plan and
outlines the factors that will be considered by the Board in its assessment. The
Development Plan should, to the level of detail which the development of the
design concepts permits:
PROJECT OVERVIEW
13
3.2
A brief description of the geological setting and features of the field, and of each
pool or hydrocarbon-bearing reservoir, should be presented, including:
A copy of the maps should be submitted to the Board in digital form. Where a
geostatistical approach has been used to construct the geologic model for the
reservoir unit, the proponent should consult the Board on the information to be
provided.
3.3
PETROPHYSICS
14
RESERVOIR ENGINEERING
As it is important for the Board to ascertain the oil production capacity for the life
of the field, a description of the reservoir data for each pool is required, including:
RESERVE ESTIMATES
assumptions and parameters used ( the economic cut-off criteria for estimating
the reserves should be clearly stated);
volumetric estimates of oil and gas-in-place, distinguishing between solution
gas, gas-cap gas and non-associated gas. The volumetric estimate should be
presented for a downside, most likely, and upside case. For pools or
hydrocarbon-bearing intervals containing a gas cap or non-associated gas, an
estimate of the natural gas liquids, including condensate and liquids that may
be produced during processing of the gas, along with an estimate of the gas-inplace remaining once these liquids are extracted, should be provided ;
sensitivity analysis reflecting uncertainty in the data and assumptions;
15
RESERVOIR EXPLOITATION
16
3.6.1
Deferred Development
Where hydrocarbons have been identified in a portion of the development area for
which development is not proposed, a discussion of the reasons for not proceeding
with development should be included, setting forth the following information:
potential reserves;
factors which might lead to future development and the possible timing of such
development; and,
steps planned to obtain additional information concerning the hydrocarbon
accumulation.
3.7
This section of the Development Plan should provide an overview of past drilling
activities, and the proposed drilling program and typical completion designs for
the development wells. The proponent is not required to submit detailed
equipment designs and operating procedures in this section. These will be
examined and approved through the Drilling Program Authorization process and,
in the case of individual well designs, through the Approval to Drill a Well
Canada-Newfoundland & Labrador Offshore Petroleum Board
17
3.8
DESIGN CRITERIA
The design philosophy for the production and export systems should be described,
with particular reference to any policies which have been adopted to ensure there
will be due regard for safety and loss control. The manner in which this
philosophy will be incorporated in design calculations should be described,
identifying the rules, codes, standards and specifications to be used.
The design criteria for the production and export systems should consider their
construction, transportation, installation and operation phases. The criteria for the
design of the systems should be divided into environmental, functional and
geotechnical categories.
3.8.1
Functional Criteria
A description and list of the functional criteria to be used in the design of the
production and export systems are required. This description should include
Canada-Newfoundland & Labrador Offshore Petroleum Board
18
Geotechnical Criteria
The Acts require that a Development Plan contain, in Part I, a description of the
production system and any alternative production systems that could be used for
the development12. Approval of Part I of a Development Plan is a fundamental
decision, i.e., the Boards decision to approve must be approved by Ministers in
order to become effective.
The mode of development and alternatives therefore are an important part of the
decision-making process. It is a given that an alternative must be technically
feasible; and, the range of technically feasible alternatives to be considered in the
Development Plan should be the subject of prior consultations by the proponent
with governments and the Board. Within the field of technically feasible and
reasonable alternatives, there are several criteria which are required as the basis of
a decision. For the proponent, the criteria will clearly be maximization of recovery
and overall optimization of project economics. These criteria will also be
important to the decision-making process of the Board and the governments. As a
consequence, these criteria should be fully examined by the proponent for each
alternative in the Development Plan.
For the Board and the governments, there are further criteria which should be fully
examined by the proponent for each alternative. The potential CanadaNewfoundland and Labrador benefits to the Provinces and Canadas economy
including a projection of revenue flows to governments within the context of
existing tax and royalty structures, will be important criteria for the Board and
governments in their assessment of each alternative. Therefore, these criteria
should also be examined and described by the proponent.
The proponent should provide an economic assessment of the preferred option and
alternatives. For alternatives, the assessment should present, on a project basis,
12
19
capital and operating cost information necessary to calculate each alternatives net
income contribution to the Province and Canada. This would include for each
alternative a presentation of:
Production Installation
the marine systems of a floating structure including the general utilities and
facilities for mooring, propulsion and ballast;
the safety systems including environmental monitoring systems, alarm and
shutdown systems, marine lifesaving appliances, ballast control equipment,
emergency services and damage control equipment;
the functional requirements for systems such as well conductors, J-tubes,
risers, riser handling, sea water supply and discharge, shale chute, crude oil
storage and utilities and produced water handling;
a discussion of the visual inspection and instrumentation planned to monitor
the integrity of the foundation and structure; and,
a discussion on the design considerations for the effect of sea ice and icebergs
on the structure.
3.9.2
Topside Facilities
20
21
The scope and flexibility for future modification and expansion to address any
potential for upside, incremental and satellite field development, should be noted
identifying any spare capacity designed into the system.
3.9.4
Export System
the capacity, efficiency factors and operational aspects for each component;
the effect of sea ice and icebergs on the operating criteria for, and loads on, the
export system;
the features incorporated in any tanker loading, oil storage or support system to
minimize the risk of an oil spill;
ballast and, where appropriate, displacement water discharges from storage
facilities and crude transport tankers; and,
a description of any proposed pipelines to or from existing facilities, or for
export to shore.
The scope and flexibility for future modification and expansion to address any
potential for upside, incremental and satellite field development, should be noted
identifying any spare capacity designed into the system to allow for future
development or third party tie-ins.
3.10
a project schedule including key events and decision points in the design,
procurement and construction stages of all major elements of the development;
the proposed approach to project management;
temporary or permanent construction facilities including any associated port or
marine terminal;
special transportation or installation facilities and equipment;
major construction materials and services; and,
quantities and characteristics of any expected toxic wastes, debris, effluents
and emissions, including noise associated with construction.
The proponent will be required to submit a Safety Plan with each application for
any project construction, or any installation activity or group of activities, as
Canada-Newfoundland & Labrador Offshore Petroleum Board
22
appropriate, which takes place within the jurisdiction of the Board. Please refer to
the Boards Safety Plan Guidelines for further guidance in this regard.
3.11
This section of the Development Plan should describe the production and
maintenance operations associated with the project in the manner indicated below.
3.11.1 Organization
23
3.11.5 Logistics
An outline of the contingency plans that the proponent intends to establish to deal
with major emergencies affecting the safety of personnel or the integrity of the
installation is required. The outline should include a description of:
24
This section of the Development Plan should describe the provisions included in
the design to facilitate decommissioning and abandonment of the installation at the
end of its production life. An overview plan of the decommissioning and
abandonment program and a discussion of the feasibility of the proposed
procedures should be provided. A description of the measures that would have to
be taken to leave the site in a fishable and navigable state should be included.
3.13
This section of the Development Plan should document past expenditures and
provide an estimate of development and operating costs in sufficient detail to
permit comprehensive financial and economic analysis of the project in support of
reservoir development and depletion throughout the life of the field. This
information is necessary for monitoring and enforcement to ensure waste does not
occur and to provide for maximum recovery of the oil and gas reserves. The cost
data should be provided in constant dollars, accompanied by a description of the
methodology, assumptions and basis for the cost estimates. A summary of the
annual capital and operating costs for the major components of the proposed mode
of development, and each alternative evaluated, should be provided. The following
cost information is required:
pre-project costs for seismic, exploration drilling, delineation drilling and
studies;
drilling capital expenditure;
facilities capital expenditure for each major component;
decommissioning expenditure;
field operating cost, excluding tariffs; and,
tariff operating cost.
25
The Development Plan should contain a provision for providing and updating this
information as necessary throughout the life of the field.
3.14
Part II of the Development Plan should consist of the studies, analyses and
evaluations, or other information and proposals, in support of Part I of the Plan. In
accordance with the Acts, proprietary information provided in Part II will not be
disclosed without the proponent's consent.
The Acts also require that petrophysical, fluid, core and well testing data, analyses
and evaluations, be provided to the Board for reasons other than as part of the
Development Plan submission. If the proponent wishes to rely on this material to
support the Development Plan, the material should be referenced explicitly but
need not be resubmitted. The confidentiality status of such information will be
determined in accordance with the relevant provisions of the Acts.
The following are to be provided where applicable and when available:
geological studies;
geophysical studies;
petrophysical studies;
reservoir engineering studies, including rock and fluid data and analyses, and
reservoir simulation studies;
original oil and gas-in-place and recoverable reserves studies;
production engineering information and studies;
field hydraulic studies;
production and transportation systems studies;
environmental studies and analyses;
plans for waste treatment and disposal;
development cost data and economic analyses of alternatives;
information related to matters of conservation, safety of operations and
pollution prevention; and,
any other studies that were used in support of the Development Plan.
26
INTRODUCTION
These ancillary documents should explain how the proponent has integrated safety
into the design of the proposed development. This not only includes the design of
structures, facilities and equipment, but also of management systems, policies,
procedures, planning processes and personnel selection, training and management.
4.1
The proponent should describe and discuss the Concept Safety Analysis, which
is required pursuant to section 43 of the Newfoundland Offshore Petroleum
Installations Regulations, and state the Target Levels of Safety the proponent
has set as acceptance criteria. The discussion should cover:
all systems that are subject to major hazards including structures, topsides,
pipelines, flow-lines, sub-sea installations, loading facilities and riser, with
particular attention paid to those systems that are important in mitigation;
all major hazards that could result in loss of or serious threat to life, loss of
structural integrity of an installation, equipment failure or uncontrolled or
unauthorized discharges; and,
all assumptions and measures proposed to mitigate damage or ensure the threat
to life or damage to the environment will be reduced to an acceptable level,
including contingency plans and monitoring procedures.
The complete analysis should be attached as an appendix to the Development
Plan.
4.2
This Risk Assessment Plan should contain a listing of the various specific risk and
safety analyses that may be required as detailed design proceeds. It should also
provide a plan for the completion of these studies and analyses and an explanation
of how this process is integrated into the design process. Finally, it should provide
an explanation of the methodologies to be utilized and a discussion of their
validity and relevance in the overall process. A more detailed stand-alone plan
may be required to support the proponents commitments in this regard.
27
4.3
This section should contain a description of the approach the proponent intends to
follow for quality assurance and quality control during design, fabrication,
construction, installation and operation of the proposed facility. This description
should indicate how this process will be employed in connection with the
Certificate of Fitness required pursuant to the legislation.
4.4
TRAINING PLAN
This section should describe the proponents plan for ensuring the training and
qualifications of all personnel to be employed in association with the proposed
development. It should include, in so far as is possible, a description of the
training and qualifications required for each classification of production
installation, transportation system, and standby vessel personnel. This description
should take into account all operational and safety procedures that such persons
may be required to carry out, including emergency procedures. A discussion of the
approach the proponent will use to ensure that all personnel are qualified and
competent, and how certificates and other training information will be tracked,
should also be included.
4.5
These documents describe the proponents proposed strategy for the safe
management of the proposed development. It should cover such issues as whether,
and to what extent, the proponent plans to utilize its Corporate Safety
Management System to manage the safety of operations or develop a projectspecific safety management system. This section should also explain the
proponents approach to the development of the Safety Plan required by the
Newfoundland Offshore Area Petroleum Production and Conservation
Regulations, and how the plans and analyses previously discussed in this Chapter
will be utilized to form the basis for this plan. Please refer to the Boards Safety
Plan Guidelines for further guidance in this regard.
4.6
SECURITY
The proponent should acknowledge its plan for security of the proposed
installation. The Government of Canada has sharpened its focus on potential
threats to the integrity of energy infrastructure. In this context, security is regarded
as an aspect of safety, hence the necessity for an assessment of security measures
in the development application process. Guidance for the preparation of a Security
Plan has been based on the International Maritime Organization (IMO) code for
Canada-Newfoundland & Labrador Offshore Petroleum Board
28
security, International Ship and Port Security (ISPS). Pursuant to subsection 51(3)
of the Newfoundland Offshore Area Petroleum Production and Conservation
Regulations, the proponent is required to prepare a Security Plan for the
installation. The Security Plan will not be a part of any public review process.
However, its review will include consultations with the federal government.
29
INTRODUCTION
The EIS and CSR must be consistent with the requirements of the CEAA, and
include those factors listed in subsections 16(1) and 16(2) of the CEAA, as
appropriate.
If a Valued Ecosystem Component (VEC) based approach for the environmental
assessment is used, a definition and rationale for choosing the particular VEC
should be provided. The temporal boundaries of the assessment should be
explicitly defined and should consider all project activities, from construction
through to abandonment and decommissioning. The spatial boundaries of the
assessment also must be clearly defined, and a rationale for each boundary
provided. Spatial or temporal boundaries may vary amongst different VECs and
13
CEAA, sections 15, 16, 21, Species at Risk Act, section 137.
30
PROPOSED DEVELOPMENT
The EIS and CSR should contain a description of all project activities associated
with the construction, installation, operation, maintenance, modification,
decommissioning and abandonment of the petroleum production facility, subsea
facilities, drilling and workover activities, and any activities ancillary to the
project (support vessels, onshore facilities, transportation of product, well site
surveys, vertical seismic profiling, etc). Illustrations of major project facilities and
maps indicating any proposed traffic routes for tankers and other associated
vessels should be included. The spatial boundaries of the assessment also should
be clearly illustrated on one or more maps.
5.2
The EIS should include a detailed description of the physical and the biological
environments within the area potentially affected by the project, as it exists prior
to project development, and against which the effects of the project can be
identified and evaluated.
The proponent should include a discussion of the natural variability of
environmental phenomena, identify knowledge gaps and discuss their implications
on the reliability of any predictions of effects. The proponent is encouraged to
consider and use all relevant available information, including that which may have
been assembled for other projects. Original research or environmental studies of
particular relevance to the proposed development performed by or for the
proponent should be described, as well as plans or proposals for research or data
collection to fill any identified information gaps.
31
The following outline is intended as a guide to the nature, scope and level of detail
of information considered necessary to describe adequately the existing
environment. As indicated above, the scope of the project and scope of the
assessment is determined during the Scoping exercise undertaken pursuant to the
CEA Act and will determine the level of information required to complete the EIS
and CSR. The description of physical environmental parameters outlined below
should be structured so as to facilitate an assessment of these factors on the
project, and of their effects on personnel safety, integrity of production structures
and the overall efficiency of the operations. The description of the physical
environment contained in the EIS and CSR will be the basis for the discussion of
section 3.8 (Design Criteria) of these Guidelines.
5.2.1
Geotechnical Environment
This section should provide an overview of the seabed and subsoil conditions as
they relate to the geotechnical aspects of the project. The discussion should
include site investigations, foundation design, the influence of the soil and natural
processes on the foundation components, and geotechnical factors affecting the
construction, installation, operation and abandonment or removal of the facilities.
The discussion should also include a description, supported where appropriate by
field data and interpretations, of the investigation of regional geotechnical
processes that significantly affect the foundation characteristics, including:
A description of the proponent's investigation of the seabed at the site should also
be provided and should include:
32
5.2.2
Atmospheric Environment
33
5.2.3
Oceanic Environment
The baseline description of the oceanic environment should include, for the region
defined:
5.2.4
the occurrence, concentration, type, floe size and thickness of pack ice;
the occurrence, dimensions, height, draft, mass, and scour of icebergs; and,
the combinations of events which could affect project activities, safety and/or
operational efficiency, and an assessment of these effects on the project.
5.2.5
Shoreline Environment
34
5.2.6
Biological Environment
This section should describe the biological communities within the project area,
with emphasis on ecological processes and their role in the stability, productivity,
variability and resiliency of the various species or types of species within that
ecosystem. The description should not be limited to the VECs identified for the
environmental assessment, but provide a general description of the biological
environment.
In describing species within the biological communities, key factors in their life
requirements such as habitat, food, abundance, seasonal distributions and
movements, and natural population-limiting mechanisms should be included. The
sensitivity of the communities and species being considered, and their
vulnerability to potential changes to their natural circumstances, should be
discussed.
With the foregoing in mind, a description of the biological environment should
include, but not be limited to, the following:
35
ENVIRONMENTAL EFFECTS
The rationale and factors determining the selection of each VEC (as described in
Section 5.0) should be provided in this section. It also should systematically
identify the interactions between the various project phases and the physical,
biological and geological environments within the defined spatial and temporal
scope of the project. The effects assessment should be consistent with the
requirements of the CEAA, and the scoping document referred to in Section 5.0.
The assessment of cumulative environmental effects should be consistent with the
CEAA and any related guidance that is published pursuant to it, and will include a
consideration of environmental effects that are likely to result from the proposed
project in combination with other projects or activities that have been or will be
carried out (i.e., other projects or activities for which formal plans or applications
have been made).
5.3.1
Effects Assessment
The methods used to assess the significance of adverse effects and the definition
of significance should be consistent with the CEAA and its associated guidance. It
should be clearly described in sufficient detail to enable a determination of the
appropriateness of the methodology selected, as well as to allow the non-technical
reader to understand how the conclusions were derived.
Potential environmental effects should be discussed both in qualitative and
quantitative terms for all phases of the project, as defined by the scoping
document.
36
5.3.2
Project Effects
5.3.3
Accidental Events
the probability of occurrence, the type, flow rate and duration of spill;
the characteristics, behaviour and ultimate fate of the spilled hydrocarbon;
the potential effects on birds, marine mammals, fish and other marine animal
and plant life, species at risk, shorelines and shoreline facilities;
the potential effects on the fishing industry associated with loss of access and
potential for, or perception of, tainting of fish;
a summary description of contingency planning measures and environmental
effects monitoring plans respecting accidental events (The details of such plans
are not typically known at the pre-planning stages of a development); and,
spill trajectory analysis results.
37
Models used to predict trajectory and dispersion of oil should be described. The
models should, where possible, be based upon actual oceanographic and
meteorological data for the study area. The model predictions should include a
consideration of weathering effects and the presence of sea ice, where applicable.
Limitations in the model(s) and the data base(s) used to define and test the model
also should be discussed. The potential for, and extent of, subsurface transport and
disposition of spilled hydrocarbon should be evaluated.
5.4
Follow-up Monitoring
14
38
This section should contain a discussion, to the limit of detail possible, of the
Operators plans for response to accidental events throughout the life of the
project, with particular emphasis on countermeasures for environmental
emergencies. The discussion on contingency planning related to personnel and
operational safety is contained in section 3.11 (Operations and Maintenance) of
these Guidelines.
The proponent's detailed Contingency Plans are submitted to the Board as part of
the Environmental Protection Plan and Safety Plan, approvals of which are
required prior to issuance of a Production Operations Authorization.
The conceptual discussion of environmental contingency planning and
countermeasures should include consideration of the following:
39
This section describes the proposed characteristics of EEM programs for both
routine and accidental events, including the process by which these programs will
be designed. Proposed parameters for monitoring and the rationale for their choice
should be provided. The section should identify any site-specific baseline
information that may be required to support the effects monitoring program.
5.4.5 Biological Observation Programs
This section should describe any programs that are planned to undertake
observation of seabirds, marine mammals, reptiles, and/or Species at Risk during
all phases of the project.
5.4.6
Forecasting Programs
The programs which will be used for the operational prediction of environmental
conditions during the project should be outlined. The description should include:
40
the provision of site-specific and areal weather and sea state forecasts for both
routine and emergency operations;
the methods, including drift models, to be used for the prediction of pack ice
and iceberg movement in the vicinity of operations; and,
the anticipated points of interface between these programs and government
forecasting programs.
5.4.8
Post-Abandonment/Decommissioning Monitoring
This section should provide a brief summary, to the extent possible, of the plans
for abandonment and/or decommissioning of the project area and facilities
following termination of production, and identify any anticipated requirements for
post-abandonment monitoring.
5.5
RESIDUAL EFFECTS
The nature, extent and duration of effects that are predicted to remain after
mitigative measures have been incorporated should be discussed.
5.6
CONCLUSION
APPENDICES
The appendices should include references cited, reports prepared in support of the
EIS, and field data used to describe the environment and to undertake the impact
analysis.
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INTRODUCTION
The powers of the Board in relation to the Public Review are broad. The Board is
required to conduct a Public Review of the Development unless the Board
determines a review is not necessary in the public interest. Examples of typical
Applications that may not be subject to a more formalized public review include:
42
applications for fields that use proven production technology for an area which
has been subjected to a previous public review.
The first two of these examples would likely attract a screening level of
assessment under the CEAA, and for all other development applications, a
comprehensive study level of assessment.
6.2
The scale and scope of the Public Review should be commensurate with the scale
of the development and the degree to which new and innovative techniques and
approaches are proposed. The Board, where possible, will have the Public Review
held concurrently with any CEAA assessment (see Appendix A - Concurrent
Review). The form of review should not impact any technical requirements to be
met in the Application. However, consideration will be given to technology that
has been previously assessed by the Board and proven in the Newfoundland and
Labrador offshore area when determining the form of review necessary in the
public interest.
For example, if the project is in a greenfield area which has no previous
development plan approvals, the scope of the Public Review may be
commensurate with the appointment of a commissioner or a joint CEAA/Accord
panel. On the other hand, a tie-in to an existing development which had previously
been the subject of a public review, may not itself require a formal Public Review
if no substantive issues are evident, additional to those previously addressed in a
public forum.
6.3
BOARD REVIEW
The Board will, in all cases, carry out its own evaluation of the Development Plan,
including an internal technical analysis by staff of the Board concurrently with the
Public Review, and will ensure public distribution of both the Development Plan
and the Benefits Plan. In the event the Board determines a Public Review will not
be held, it may invite written submissions from interested parties, and any such
submissions will be made available to the proponent and the public. The internal
technical analysis will include consultation with government departments and
agencies and such other experts as may be necessary. The Board will consider
analysis conducted by staff of the Board, the Public Review Body report, any
recommendations from the Minister of the Environment and written submissions
by interested parties in making a decision to permit a development to proceed.
Such a decision would be a Fundamental Decision and subject to approval or
rejection by appropriate ministers.
43
6.4
If a Public Review is conducted pursuant to the Acts, the Board will determine
whether there will be a CEAA/Accord panel or commissioner(s) (Public Review
Body). A Public Review must be conducted and completed within 270 days, or
such shorter period as determined by the Board, of the receipt of the Application
by the Public Review Body. The Public Review will not commence until the
Board has determined that the Application submitted by the proponent is a
complete submission in accordance with the requirements of these Guidelines, and
the Benefits Plan Guidelines.
6.5.1
CEAA/Accord Panel
If, pursuant to the CEAA, the Minister of Environment determines that a panel
review is necessary, then the Board will pursue with the Canadian Environmental
Assessment Agency, and other departments or agencies as appropriate, the
development of a joint CEAA/Accord panel review process that will satisfy the
requirements of both the Acts and the CEAA. This will be done in accordance
with the Memorandum of Understanding as discussed in section 5.0.
6.5.2
Commissioner(s)
Where a CEAA/ Accord Panel review is not required, the Board will appoint a
commissioner or in conjunction with governments, a panel of commissioners to
the Public Review Body. Where there is more than one commissioner, the Board
may appoint based upon nominations from the Ministers15.
6.5.3
The Board will give public notice of the appointment of the Public Review Body,
and immediately thereafter file with it all documents to be reviewed in the process.
The Public Review process is intended to provide all interested parties with an
opportunity to become informed about a proposed development, and to make their
views known.
15
44
conduct public hearings in accordance with the Terms of Reference for the
Public Review as established by the Board, and in accordance with the
schedule established by the Board;
examine and review the plans and statements referred to it by the Board;
provide to all interested parties an opportunity to be heard and/or make written
submissions in accordance with suggested hearing procedures more
particularly described in Appendix B;
exercise those powers which may be granted to its members as commissioners
under the Public Inquiries Act16 and the Inquiries Act17. (It would not be
typical, however, to require the swearing-in of participants or to require
submissions to be made under oath);
submit to the Board and the Energy Ministers, a report of its findings,
including recommendations to the Board respecting the documents referred to
it by the Board. This report must be submitted no later than two hundred and
seventy (270) days following receipt by the Review Body of all such
documents, or such shorter period as the Board may establish. The Review
Body will be required to ensure that sufficient copies of its report for public
distribution are provided to the Board within the above time frame; and,
the Public Review Body will be given opportunity to present its report and
findings to the Board.
6.6
PUBLIC PARTICIPATION
Terms of Reference for the Public Review Body, as well as the general purpose
and objectives of the reviews;
general instructions to intervenors, including procedures for submissions; and,
the address and name of a person from whom further information may be
obtained.
This notice usually will not include specific times and locations for the public
hearings. The Public Review Body will publish one or more notices providing
these details in a timely manner at least 10 days in advance of the first hearing.
16
17
45
6.6.1
During the Public Review, the proponent will be represented by the operator, or
other designated representative, who will be responsible for all submissions and
representations made on behalf of the proponent within that process. Proponents
should designate a contact person for liaison between the proponent and the
Board, and between the proponent and the Public Review Body, for the purpose of
gathering and responding to requests for further documentation, etc.
Any individual or organization wishing to express an opinion or to make a
recommendation respecting the proposed development, may participate in the
review process. A sample Submission Form for written comments is provided in
Schedule C. It is important to note that there is no authority in the Acts for the
Board to provide intervenor funding. The Board is therefore, unable to provide
such funding.
6.6.2
a Development Plan;
a Canada-Newfoundland and Labrador Benefits Plan;
a Socio-Economic Impact Statement; and,
an Environmental Impact Statement.
6.6.3
Submissions
The submissions made by the proponent will consist of the written information
filed with the Board pursuant to subsection 1.2 of these Guidelines and the
Benefits Plan Guidelines, as well as the project-specific requirements, together
with the oral submissions made by the proponent during the course of the Public
Review.
Each participant normally will be required to file a written submission with the
Public Review Body prior to the commencement of the public hearings, in
accordance with the instructions to intervenors. However, the Public Review Body
may waive that requirement for individuals who wish to make a personal
intervention at an individual hearing.
All other written submissions filed with the Public Review Body by interested
parties will be made available and accessible to the public. The Board, on behalf
46
of the Public Review Body, will ensure that a facility is provided in a reasonable
time frame wherein any interested person may examine and obtain a copy of any
submission that is filed.
The Public Review Body may require that participants file a minimum number of
copies of their submissions to permit adequate distribution. In the proponents
case, the number of copies will be determined by the Board on a project-specific
basis.
6.6.4
The first public sitting of the Public Review Body will be held in St. Johns,
Newfoundland and Labrador. Further sittings may be held in other locations
depending upon the public interest. The total period allowed for hearings, and time
for each sitting, will depend on the number of submissions from individual areas
of the Province. Notifications with respect to the specific locations and time
schedules will be published by the Public Review Body.
6.6.5
The Board may provide guidance to both the proponent and prospective intervenors
relating to the Public Review, which will be provided by the Board in a timely manner
prior to the commencement of such proceedings. A sequential summary of a typical
hearing is set out below:
6.7
Not later than 270 days after its receipt of the information to be reviewed, or such
shorter period as the Board may establish, the Public Review Body is required to
make a report of its findings, including any recommendations, to the Energy
Ministers and to the Board. The Public Review Body will submit its report, setting
47
48
INTRODUCTION
Upon receipt of a complete Development Application, the Board will establish the
Terms of Reference for the conduct of the Public Review by the Public Review
Body. The Board recognizes that each development will have unique
characteristics which may impact the scope of the review.
7.1
TERMS OF REFERENCE
To ensure an efficient and effective Public Review, the Board considers the
following areas to be essential to be included in the Terms of Reference:
7.2
the mandate of the Public Review Body that the Public Review Body
undertake a critical analysis of the Application and make recommendations to
the Board at the conclusion of the Public Review;
the scope of the Public Review;
the conduct of the Public Review;
the advisors to the Public Review Body;
any limitations on the mandate of the Public Review Body (as only the matters
enumerated within the Terms of Reference shall be considered);
the powers of the Public Review Body in the conduct of the Public Review;
and,
the relationship between the Public Review Body and the Board including the
basis for participation of Board Staff at the Public Review.
PROCEDURES
To assist the Public Review Body to conduct the Public Review in a timely
manner, the Board has developed Procedures for Public Reviews annexed hereto
as Appendix B as a guide which may be followed by the Public Review Body.
Once in receipt of the complete Application, the Public Review Body will have a
maximum of 270 days, or lesser time as established by the Board, to make any
recommendations to the Board.
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Scope
Determination
C-NLOPB/RAs
Review Track
Recommended
to MOE
Board announces
Atlantic Accord
Public Review
Process
Approx. 30 days
Draft
CSR
Review
Panel
154 Days
Board DA
Completeness
Review
Approx. 30 days
Board Internal
Process
DA Referred
to Public Review Body
Staff of Board
Completes
Technical Review
Public Review
Staff Prepares
Report to Board
293 Days
60 Days
Public Hearings
Board Considers
All Reports
Fundamental
Decision By Board
Fundamental
Decision
Process
Note: Accord Act Process; Public Review Process & CEAA CSR process are presumed to occur concurrently.
The timelines indicated are approximate days.
50
APPENDIX A:
CONCURRENT REVIEW
CEA Agency
DA
Development Application
MOE
RA
51
APPENDIX B:
SUGGESTED GUIDANCE FOR THE CONDUCT OF THE PUBLIC
REVIEW
1.
Definitions
In these Procedures,
a) Accord Acts means the Canada-Newfoundland Atlantic Accord
Implementation Act and the Canada-Newfoundland and Labrador
Atlantic Accord Implementation Newfoundland and Labrador Act;
b) Board means The Canada-Newfoundland and Labrador Offshore
Petroleum Board;
c) Benefit Plan Guidelines means the Canada-Newfoundland and
Labrador Benefits Plan Guidelines as published by the Board and
available at the Boards website (www.cnlopb.nl.ca) under
Publications;
d) Canada-Newfoundland and Labrador Benefits Plan has the meaning
set out in section 45 of the Accord Acts;
e) Public Review Body means the individual(s) appointed pursuant to
paragraph 44(2)(b) of the Accord Acts;
f) Development Application means all documentation provided to the
Board by the Proponent for the purpose of paragraph 44 (2)(c) of the
Accord Acts, to support approval of the Project and shall include but not
be limited to, an Environmental Impact Statement, a Socio-Economic
Impact Statement, a Development Plan and a Canada-Newfoundland
and Labrador Benefits Plan;
g) Development Plan Guidelines means the Development Plan
Guidelines as published by the Board and available at the Boards
website (www.cnlopb.nl.ca) under Publications;
h) Development Plan has the meaning set out in section 2 of the Accord
Acts;
52
Introduction
a) This document outlines procedures for the Public Review to be
conducted by the Public Review Body appointed to review the proposed
Project. Subject to the requirements of these Terms of Reference and the
Accord Acts, the review will include all relevant aspects of the proposed
development;
b) The Public Review will provide opportunities for individuals,
organizations, and the general public to provide their views and
opinions, and to present information on the effects of the Project. The
Proponent may also actively participate in the hearing of the
Development Application. These submissions will assist the Public
Review Body in reaching informed and objective conclusions with
regard to the Project, which will form the basis for its recommendations.
These recommendations will be submitted to the Board, the federal
Minister of Natural Resources, and the Minister of Natural Resources
for the Government of Newfoundland and Labrador;
c) A large number of Participants may wish to be present and be heard
during the Public Review sessions. These procedures are intended to
ensure that the review takes place in a fair and equitable manner, with
maximum co-operation and courtesy. The Public Review Body will
maintain order and efficiency in a structured but informal atmosphere.
As the Public Review Bodys conclusions and recommendations will
not have legal force but will be advisory, the review will not be
governed by the strict rules of procedure and evidence required by a
court. However, the Public Review Body will conduct the review in a
manner which will require accountability for statements made by the
Proponent and Participants;
53
54
4.
Oral Presentations
Persons may present their views or information orally, in written form, or
both. The following guidelines are provided for persons who may wish to
make oral presentations during the sessions:
a) Anyone wishing to make a presentation at any session should register as
a Participant by notifying the Public Review Bodys office at least five
(5) days prior to the commencement of the public review session. Any
person providing timely notice will be included as a Participant and will
be given priority to speak. When registering, Participants should provide
the information set out in paragraphs 5 b) i) to iv) below, unless such
information will be included as part of a written presentation pursuant to
paragraph 5 b);
b) A schedule listing the order of presentations by Participants will be
available at the beginning of each session;
c) Persons wishing to make a presentation at any session and who are not
pre-registered as a Participant, may register prior to the start of a session
or during intermission. However, the opportunity to present will depend
upon the time remaining after the pre-registered Participants have been
heard;
d) A Participant, including any other individual, group, organization or
entity on whose behalf it is acting, will be allowed to make one
presentation to the Public Review Body per session;
e) A Participant, including any other individual, group, organization or
entity on whose behalf it is acting, may make a presentation to the
Public Review Body at more than one session, provided the Participant
has registered to do so and presentations are not repetitious in substance;
f) Participants shall prepare presentations so that they can be concluded
within 15 minutes. A longer period may be granted at the discretion of
the Public Review Body if such a request for more time is provided to
the Public Review Bodys office at the time of registration;
g) More than one individual may participate in a presentation by a
Participant. When a presentation is made on behalf of a Participant by
several persons, the collective presentation should take place within the
time period assigned for that Participant;
55
Written Submissions
a) Anyone wishing to register a written submission with the Public Review
Bodys office should do so by filing twenty (20) copies of the entire
submission at least five (5) days prior to the commencement of the
public review session;
b) All written submissions should include:
i)
ii)
iii)
iv)
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v)
vi)
Order of Presentations
The order of presentations to the Public Review Body during public review
sessions will be as follows:
7.
a)
b)
c)
The Public Review Body will allow a reasonable opportunity for the
Proponent to present a reply to any oral presentation or written
submission.
57
iii)
8.
Transcripts
Written transcripts will be made of all sessions, and will be made available
for purchase by the public within a reasonable period of time by application
to the Public Review Bodys office. To facilitate the making of transcripts,
speakers should identify themselves when addressing the Public Review
Body.
9.
Representation by Agent
Participants who wish to make an oral presentation are encouraged to speak
on their own behalf and ask their own questions at the public sessions,
although representation by an agent such as legal counsel, or technical
professionals, will be allowed. The sessions generally will be informal in
nature and will not have the formality, tone or procedures of a courtroom.
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10.
Interpretation
Public sessions will be conducted in English. Where appropriate, the Public
Review Bodys Office will make every effort to accommodate requests for
translation at a public session, provided the request is received by the
Public Review Body in a timely manner as directed by the Public Review
Body, and where translation is required for the proper conduct of the
session.
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APPENDIX C:
FORM FOR PUBLIC COMMENTS
Development Project Name:
__________________________________
__________________________________