Thanks. Our principal regulators are OGA (NTSA), HSE and EA, and statutory bodies such as planning authorities. There is some overlap but less than might be helpful. Our compliance team now exceeds in number our technical team (excluding field operators), with two dedicated HSE liaisons, one EA liaison, one OGA liaison, one general planning and permitting lead.
We are a small company and the breadth of legislation, regulation, standards and so forth is daunting. Nonetheless our management systems have developed beyond recognition in the last two years and this is necessary when dealing with high pressure gas which is, after nuclear, one of the most hazardous businesses in the UK.
In terms of environmental compliance, the actual Saltfleetby Field presents fewer environmental hazards than a traditional oil field, as there is much less risk of fluid contamination to ground and water. Additionally electronic monitoring of flow has (for human safety) to be much more precise and involved than in traditional oil field practice. So on the whole we would regard the Saltfleetby Field as representing a much higher human safety risk but a much lower environmental risk than an oil field.
The exception is emissions to air. We require a flare at startup and some (but not all) maintenance events to acheive national grid specification gas, but otherwise we should not need to use the flare at all during the life of the field, although a tiny pilot flare is kept alight at all times to meet statutory requirements for emergency blowdown. Blowdown (i.e. flaring) for us means loss of principal inventory and commercial return – this is not an oilfield with associated gas as a headache. Gas is our reason for being here.
We have two scheduled group Zoom calls a day and, without any doubt, every day an issue of environmental compliance arises and is dealt with. At one level it is simply compliance (“what will EA think of this”) but at another level it is purposive (“what should we be doing or how could we do this better”). This is a sea change from the Angus of old.
We are committed to improving our carbon footprint – but we are led by an unforgiving Technical Director who rightly has regard to the “through-the-cycle” carbon cost of new equipment. Two innovations are planned – (a) a closed loop geothermal system for on site power generation up to 1MW and potentially retiring one gas fired generator and (b) a tie-up with a vertical farming operation which would take both heat, power for lighting and potentially CO2 emissions from the site for assisted agriculture.
We do, as a small company, adhere to the QCA. Up until December, on the strong encouragement of the Board, and whilst we awaited procurement and delivery of equipment to Saltfleetby, almost 50% of management time during 2021 was spent in developing our deep geothermal programme in southwest England. We are sincere in our desire to be an innovative part of Transition, but bear in mind that we are a small company at present focused on acting as a safe and responsible Operator in the immediate term and delivering good returns to those who have funded these operations..