Reducing duplication in offshore decommissioning: the case for a single integrated plan

Australia’s offshore oil and gas regulatory framework requires titleholders and operators to prepare three main separate approvals: an Environment Plan (EP), a Well Operations Management Plan and a Safety Case. While this approach provides clarity within each regulatory domain, it often leads to duplication, inconsistent treatment of risk and difficulties in presenting a clear picture of how safety, environmental and well integrity risks are managed collectively. A key criticism is that the EP process, originally designed with new oil and gas developments in mind, imposes extensive consultation requirements that may be seen to be disproportionate for late-life and decommissioning activities. These extensive consultation obligations, while appropriate for exploration drilling, production operations and field developments with broad stakeholder impacts, can delay decommissioning approvals and create inefficiencies without delivering commensurate environmental or social benefits. International practice offers useful comparisons. In the UK, operators are required to submit a single Decommissioning Program, submitted under the Petroleum Act 1998 (UK), which integrates environmental assessment, safety risk evaluation and technical well abandonment. Norway adopts a similar model through its Petroleum Safety Authority, which requires operators to demonstrate integrated risk management across all domains in a consolidated framework. These examples demonstrate the value of a single decommissioning plan such that it provides streamlined oversight, proportionate consultation and a clearer balance of safety, environmental and technical risks. For Australia, such reform could reduce inefficiencies, improve regulatory transparency and deliver better outcomes for industry, regulators and the community without lowering the standards of protection.