OGA return to pre-COVID licence amendment approach
In response to the global COVID-19 pandemic which first affected the UK in early 2020, the OGA announced in March 2020 that it would seek to ease the pressures on industry by taking a pragmatic approach to considering amendments to timelines.
The OGA recommended that Operators/Licensees engage early with the OGA in a timely and evidence-based manner on specific licence requests. The OGA also deprioritised stewardship reviews, only holding such reviews with operators in relation to regulatory or materially significant matters.
The OGA committed to keep its approach to considering amendments to licence timelines under review to ensure continued fitness for purpose given the dynamic nature of COVID-19’s impact on the oil & gas industry, and the wider economy.
The UKCS oil and gas sector responded well to the constraints on activity resulting from the pandemic by putting in place appropriate contingency and mitigation measures.
The OGA now rarely receives requests for licence management amendments which cite COVID as the primary reason for the amendment request and has therefore reviewed the approach which was initially put in place in March 2020.
Following this review, the OGA will therefore return to making licence amendment considerations on a similar basis as was done pre COVID (a business as usual approach).
For Innovate Licences, due to the flexibility available at the time of Application to set Initial Term Phase durations, the OGA would not envisage having to vary (extend) the durations of individual Phases or Terms.
This does not preclude the OGA from considering exceptional licence requests that might still emerge where there is a demonstrable impact due to COVID impact, as while the impact of COVID on the UKCS is being managed by the mitigating processes and procedures that industry has established, the OGA recognises that the pandemic is still very real.