By email only Clerk to the Committee – House of Lords Environment and Climate Change Select Committee O"shore Petroleum Regulator for Environment & Decommissioning Department for Energy Security and Net Zero AB1 Building Crimon Place Aberdeen AB10 1BJ OPRED@energysecurity.gov.uk

Flare consent, regulated by the NSTA under the Energy Act 1976 and Petroleum Act 1998, limits the quantity of hydrocarbon to be ﬂared. Please - NSTA Flaring and Venting Guidance (June 2023). OPRED regulates CO2 emissions from ﬂaring under the UK Emissions Trading Scheme (ETS), including ﬂare activity data (ﬂow), which is independently veriﬁed. Total mass ﬂow rate is measured and a gas composition applied to this measurement. Which is reported - Petroleum Production Reporting System (PPRS) - environmental Emissions Monitoring System (EEMS) - Manage your UK Emissions Trading Scheme reporting service (METS) Hydrocarbon mass of ﬂared gas is submitted to the NSTA’s Petroleum Production Reporting System (PPRS) by operators. Methane is not directly measured but is determined indirectly from the hydrocarbon mass ﬂow and using methane standard emission factors. Installations that fall under the UK ETS monitor and report Hydrocarbon sent to ﬂare in OPRED’s ‘Manage Emissions Trading System (METS) which calculates the CO2 assuming 98% combusted leaving 2% methane. Hydrocarbon sent to ﬂare is veriﬁed independently by the operator, to ETS veriﬁcation regulations. Type Regulator Regulation What is measured, and reported How is methane measured and reported? EEMS database % methane O&G UKCS Venting NSTA regulates the vent consent which is based on total hydrocarbon to be vented and not directly on methane itself. Vent consent is regulated by the NSTA under the Energy Act 1976 and Petroleum Act 1998, limiting the quantity of hydrocarbons to be vented. Please NSTA Flaring and Venting Guidance (June 2023) Venting of hydrocarbons from production installations are not covered by regulations under OPRED’s remit, such as UK ETS and O]shore PPC. Energy Portal consents section - Hydrocarbons vented (including periods of unlit ﬂares) are entered to NSTA’s PPRS by operators and into the Energy Portal consents section. Vent consent is based on reported hydrocarbon emissions to the NSTA PPRS database. Methane is not directly measured but is determined indirectly from the hydrocarbon mass ﬂow and using methane standard emission factors. There is currently no veriﬁcation of vented mass data in regulations. Methane slip (combustion plant) OPRED Permits approved under The O]shore Combustion Installations (Pollution Prevent and Control) Regulations 2013. Unburnt hydrocarbons (mostly methane) from fuel combustion ine]iciency in turbines, engines and heaters/boilers is calculated using standard emission factors. Two alternative methods may be used and entered into EEMS. Methane can be measured directly by exhaust stack testing or alternatively standard equipment speciﬁc emission factors can be used. Fugitives Not regulated No speciﬁc direct regulatory requirement for Methane. Emissions data entered into EEMS voluntarily In the absence of data from a veriﬁed system EEMS provides default emission factors for operators to estimate fugitive emissions from process plant and pipework. Oil Tanker Loading Not regulated No speciﬁc direct regulatory requirement for Methane. Emissions data entered into EEMS voluntarily. Volumes of oil reported into PPRS PPRS data on oil loading volumes is used in conjunction with EEMs for NAEI reporting. ~1%

Type Regulator Regulation What is measured, and reported How is methane measured and reported? EEMS database % methane O&G UKCS Mobile Drilling Units NSTA issue consents Flare and Vent consents regulated by NSTA Well activity consents regulated by NSTA. Volumes of ﬂared gas entered into NSTA’s PPRS. Emissions data entered into EEMS In the absence of data from a veriﬁed system, EEMS provides default emission factors for operators to use for drilling opera<ons. Decommissioning at cessation of production – ﬂaring and venting OPRED Flaring and Venting of hydrocarbons approved by OPRED under the Energy Act 1976. Methane emissions are not included in Decommissioning Plans. Methane emissions are not reported post Cessation of Production. Not reported into EEMS Gas release HSE regulate release Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) Safety perspective HSE Currently no mechanism for reporting Could only report an o]ence under OPPC to OPRED if it was condensate that went to sea. Further information Both OPRED and NSTA sit on the working group of ONshore Energies UK Methane Action Plan, which provides a framework for industry to reduce methane emissions from their assets on the UK Continental Shelf (UKCS). In addition, there are other organisations and stakeholders that OPRED and the NSTA engage with in pursuit of continuous improvement in measurement, monitoring, reporting and veriﬁcation (MMRV) techniques within the sector. UK Emissions Trading Scheme scope expansion In July 2023, the ETS Authority announced that expanding UK ETS coverage to the upstream oil and gas sector could provide an additional driver for methane emission reduction. The Authority are reviewing this policy and will consult in due course. The expansion of UK Emissions Trading Scheme (ETS) scope to include methane from the upstream oil and gas sector is being considered by DESNZ. The method of its inclusion is still to be determined. OPRED is supporting the wider DESNZ ETS team’s policy development concerning methane emissions from the upstream oil and gas sector, in the context of the UK Emissions Trading Scheme. Systems for reporting emissions The Environmental and Emissions Monitoring System (EEMS) Emissions are reported by ONshore Oil & Gas Operators to the Environmental and Emissions Monitoring System (EEMS). EEMS is the environmental database of the UK upstream oil and gas industry that records data relating to emissions and discharges from upstream oil and gas installations. This includes the permitted oNshore production installations and mobile drilling units. The system is maintained by OPRED (DESNZ) and is only accessible to oNshore oil and gas operators. However, the data reported is utilised by various bodies, including OEUK and the NSTA. It is also used to feed into the National Atmospheric Emissions Inventory.
Petroleum Production Reporting System The NSTA have their own hydrocarbon petroleum production reporting system (PPRS) which collects monthly data from the reporting of hydrocarbon production from both onshore and oNshore ﬁelds and terminals in the UK Continental Shelf (UKCS). This data is submitted by operators to PPRS via the Energy Portal and then placed in the public domain on the OGA’s website after two months. Manage your UK Emissions Trading Scheme reporting service (METS) The UK ETS is managed through an online platform for permitting and reporting referred to as METS. All the UK ETS regulators use this platform but is managed by the UK ETS policy team in DESNZ. Installations that fall under the UK ETS are required to monitor, verify and report hydrocarbon gases that are ﬂared. For ﬂaring this assumes that 98% of the ﬂared gas is combusted leaving 2% methane and other gases un-combusted. This data is also independently veriﬁed by an accredited veriﬁer prior to submission to OPRED by the operator. The UK Pollutant Release and Transfer Register (PRTR) The UK Pollutant Release and Transfer Register (PRTR) is a publicly accessible database that provides detailed information about pollution emissions from industrial sites across the United Kingdom. ONshore Oil and Gas Operators are required to report methane emissions over 100,000 kg (100 tonnes) per year. Data is extracted from EEMS (i.e. the wider database) on an annual basis by OPRED and reported. PRTR is maintained by the Department for Environment, Food & Rural ANairs (DEFRA). PRTR only collates data on installations that exceed the prescribed threshold.