Prior written consent of the Secretary of State for the Department for Energy Security and Net Zero is required for the siting of the offshore installation – whether mobile or permanent – in any part of the UKCS. A Consent to Locate (CtL) is required for the following:

• Mobile Installations, e.g. MoDUs, Flotels, Crane Barges
• Mobile Vessels, e.g. Well Intervention Vessels, Well Operations Vessels
• Permanent/Fixed Installations, e.g. Manned Platforms, NUIs, FPSOs, FSUs, Production Buoys
• Permanent/Fixed Structures, e.g. Well Templates, Wellheads and Xmas Trees
• Pipeline and Cable Systems, e.g. Oil and Gas Pipelines, Water Injection Pipelines, Power Cables and Umbilicals
• Other Operations, e.g. Installation of Surface Buoys and Moorings

New applications for CtLs for mobile installations, mobile vessels and permanent/fixed installations must be supported by a Vessel Traffic Survey (VTS) and, if the shipping density is high, they should also be supported by a Collision Risk Assessment (CRA).

Construction operations associated with CtLs for permanent/fixed structures and pipeline and cable systems must be supported by a Vessel Traffic Survey (VTS) and, if the shipping density is high, should also be supported by a Collision Risk Assessment (CRA), unless they are covered by a related application, consent or consent variation, e.g. a CtL to cover MoDU or crane barge operations. The seabed structures and associated deposits do not require a VTS or CRA.

For a CtL for Other operations applications that have any sea surface structures or operations that will involve a vessel being physically connected to the seabed or subsea infrastructure for a significant period and which are unable to disconnect and move away immediately in an emergency, then the application may require to be supported by a Vessel Traffic Survey (VTS) and, if the shipping density is high, may also require to be supported by a Collision Risk Assessment (CRA).

There are a number of operations that are excepted under Section 77(1) of the MCAA that may require a CtL if undertaking the operations would result, or be likely to result, in an obstruction or danger to navigation (during or subsequent to the operation). A list of the operations that may apply can be found on page 14 of the draft guidance document.

There are also specific requirements around navigational issues for decommissioning programmes (see Decommissioning – Navigation)

To apply for a Consent to Locate (CtL) in relation to offshore oil and gas operations, offshore gas storage and unloading operations and offshore elements of Carbon Capture and Storage operations, either a SAT must be created in association with the MAT for the proposed operation or a standalone application can be created on the UK Oil Portal. Multiple CtL SATs can be applied for in association with one MAT, providing they relate to the same general location.In considering an application for consent the Department for Energy Security and Net Zero has to evaluate the risk to shipping which may arise from the installation of facilities of all kinds including pipelines, and measures to reduce such risks. The following aspects are considered:

• Evidence of shipping movements in the vicinity of the proposed operations
• The impact of likely changes in shipping movements as a consequence of the operations
• Any constraints that would be imposed on local navigation as a consequence of the operations
• Collision risks with respect to vessels and the operations, and between vessels as a result of the action taken to avoid the operations
• The reduction in risk as a consequence of the implementation of mitigation measures

Guidance is available on the Department for Energy Security and Net Zero website.

Disused Pipeline Notification – Updated

The Department for Energy Security and Net Zero requires operators to submit details of pipelines or sections of pipelines that are to be taken out of use.

The disused pipelines notification has been updated to include more specific requirements on the information to be provided. The form is available on the Department for Energy Security and Net Zero website.

It is preferred and less problematic to operators and the Department for Energy Security and Net Zero if applications for new developments address all the facilities to be placed rather than a series of piecemeal applications. Consent can then be given to cover the whole operation, e.g. template, drilling, jacket, topsides, pipelines, etc. Difficulty has arisen in the past for some operators where uncontroversial seabed works have been put forward for consent before and without details of more sensitive surface works. A limited consent, e.g. for exploratory drilling only does not imply that consent will necessarily be given for other operations at the same site.

Consent to locate in such areas are unlikely, and if consent is given stringent conditions limiting the time allowed on site are likely to be imposed.

A notice was published by the Offshore Major Accident Regulator in August 2022 which provides guidance on reporting the movements of offshore installation. The notice is available here.

The guidance details the following:

• Reports, using the template in Annex 1 of the guidance note are to be sent to:
  • Local Helicopter bases – simultaneously, to the local helicopter bases serving the old and new locations;
  • MOD Hydrographer and Maritime and Coastguard Agency (MCA)- Notify oilandgas@hmcg.gov.uk for aspects a) to e) listed below:
    • a) the appropriate Coastguard Operations Centre (CGOC) must be given warning of movements at least 48 hours before them taking place;
    • b) when an installation being established arrives at its intended location (or intermediate position if necessary);
    • c) when a precise position has been established at the new location;
    • d) when an installation commences a move to leave UK waters; and
    • e) when an installation has left UK waters.
  • Health and Safety Executive (HSE)- notify ED.Offshore.Rigmoves@hse.gov.uk prior to entering or leaving UK Waters;
  • Police – OEUK has agreed that operators will notify Chief Constables of the location of installations over which they exercise police jurisdiction.
  • Department for Business, Energy & Industrial Strategy (BEIS):
    • a) notify bst@beis.gov.uk prior to entering or leaving UK Waters; and 
    • b) notify bst@beis.gov.uk when moving from one location to another within UK Water.

• The provision of any lights, signals or other aids to navigation
• The stationing of guard ships in the vicinity of the operations
• The taking of any other measures for the purposes of, or in connection with, controlling the movements of ships in the vicinity of the operations,

must be reported immediately to BEIS, and copied to the UK Hydrographic Office and other relevant consultees, using the reporting form appended as Annex H (PDF document) of the draft guidance.