Atmospheric Emissions – Reporting | OEUK Environmental Legislation

Atmospheric Emissions – Reporting

For information on the impact of Brexit on oil and gas environmental legislation, please refer to the pdf document downloadable from the Home Page.

Key Legislation:	The UK is party to a number of international conventions and EU Directives that require the provision of atmospheric emission inventories, in particular: EC Decision 93/389/EEC for a monitoring mechanism of Community CO2 and other greenhouse gas emissions – European Pollutant Emissions Register (EPER). EC Directive 2008/1/EC concerning integrated pollution prevention and control, which consolidates EC Directive 96/61 and its amendments. EC Directive 2003/87/EC establishing a scheme for greenhouse gas emission allowance trading within the Community and amending Council Directive 96/61/EC (EU Emissions Trading Scheme – EU ETS). EC Directive 2016/2284 on the reduction of national emissions of certain atmospheric pollutants, implemented by the National Emission Ceilings Regulations 2018 in England, Wales, Scotland and Northern Ireland. EC Regulation 166/2006 concerning the establishment of a European Pollutant Release and Transfer Register (E-PRTR). EU Regulation 842/2018 on binding annual greenhouse gas emission reductions by Member States from 2021 to 2030 contributing to climate action to meet commitments under the Paris Agreement. Geneva Convention on Long-Range Transboundary Air Pollution 1979 and its protocols. UN-ECE Protocol on Pollutant Release and Transfer Registers (PRTR). United Nations Framework Convention on Climate Change 1992 (Rio Convention) and its protocols (e.g. Kyoto Protocol). For more detail on the Legislation relevant to this page, please use the following links: Main UK Legislation Atmospherics Legislation
Supporting Legislation:	Directive (EU) 2016/802 of the European Parliament and of the Council of 11 May 2016 relating to a reduction in the sulphur content of certain liquid fuels The CRC Energy Efficiency Scheme (Revocation and Savings) Order 2018 revokes the CRC Energy Efficiency Order 2013. This Order ends the CRC scheme, and as a result no organisations will be required to register for the CRC Scheme beyond 31 March 2019, however current participants will still have to meet their obligations and the Scheme Administrator will still have to manage elements of the Scheme. The CRC helpdesk is now closed, however for ongoing requests, contact details are provided on the UK Government website. The Greenhouse Gas Emissions (Kyoto Protocol Registry) Regulations 2021 The Offshore Combustion Installations (Pollution Prevention and Control) (Amendment) Regulations 2018 amend The Offshore Combustion Installations (Pollution Prevention and Control) Regulations 2013. The Pollution Prevention and Control (Industrial Emissions) Regulations (Northern Ireland) 2013 amended by The Pollution Prevention and Control (Industrial Emissions) (Amendment) Regulations (Northern Ireland) 2018.
Guidance:	Clean Air Strategy 2019: This document sets out a new air quality policy through which the government aims to tackle atmospheric emissions from activities such as emissions from small industrial sites and the use of certain products which release air pollutants. Cost Benefit Analysis Tool User Aid: when a PPC permit holder, with Open Cycle Gas Turbine classed as Large Combustion Plant, needs to make a request for derogation from the BAT-Associated Emissions Levels (AEL), this process must involve an assessment to demonstrate the disproportionality of the costs and benefits of complying with the BAT-AEL. OPRED published guidance for the offshore oil and gas industry on the LCP BREF BATc and derogation under Article 15(4) in July 2020. This requires that a cost benefit analysis (CBA) is the basis of the quantitative assessment to be used in requests for derogation, and advised that the CBA tool developed by The Department for Environment, Food & Rural Affairs (DEFRA) and the Environment Agency (EA) should be used. Department for Energy Security & Net Zero Offshore Pollution Prevention and Control (PPC) Guidance. This guidance relates to the Offshore Combustion Installations (Pollution Prevention and Control) Regulations 2013 and is intended for operators who have qualifying combustion plant under these regulations. Environmental reporting guidelines: including Streamlined Energy and Carbon Reporting requirements: Guidance to help companies comply with the Streamlined Energy and Carbon Reporting regulations, including greenhouse gas (GHG) reporting. Guidance on Operator Monitoring Assessment: Environmental Permits – The Environment Agency published guidance on how they assess operators to ensure they are complying with the monitoring requirements their permits. NSTA Stewardship Expectation 11 – Net Zero: This publication gives operators and licensees clarity on expectations and good practices regarding greenhouse gases emissions reduction within the UK continental shelf. Measuring and reporting environmental impacts: guidance for businesses: Guidance for businesses on measuring and reporting their energy use and greenhouse gas emissions to meet Streamlined Energy and Carbon Reporting requirements. Monitoring emissions from some environmental permitting activities – RPS C20: it replaces Monitoring emissions from some environmental permitting activities (RPS C7), which expired on 30 September 2020. Normally all permit holders must comply in full with all the conditions in their permits, including monitoring emissions to air and water and other environmental monitoring. This RPS allows permit holders to make reasonable adjustments to monitoring requirements, but only if you can’t comply with your specified monitoring requirements due to COVID-19 restrictions. OEUK: Methane Action Plan 2021. This document highlights the actions the oil & gas industry will take to cut methane emissions on the UK Continental Shelf. OEUK Methane Action Plan Guidelines 2022. This guideline provides a framework for operators to identify, quantify and finally mitigate the methane emissions from their assets. Furthermore, the guidelines provide an overview of the UK regulatory requirements within the context of international regulations and commitments. Offshore Emissions Monitoring Guidance – this guidance was produced for operators that hold a permit under the Offshore Combustion Installations (Pollution Prevention and Control) Regulations 2013 (as amended) (‘PPC Regulations’). It provides guidance on the monitoring plans required for emissions monitoring to comply with the PPC Regulations. The accompanying emissions monitoring plan template is available here, and the letter to industry explaining the process of submitting the monitoring plan is available here. OGA Plan: The OGA Plan was published in 2024 under the OGA Strategy. The OGA Strategy incorporates a range of net zero obligations for the UK oil and gas industry, including a requirement for relevant persons to, in securing that the maximum value of economically recoverable petroleum is recovered, and take appropriate steps to assist the Secretary of State in meeting the net zero target. This includes reducing greenhouse gas emissions from sources such as flaring, power generation and venting, aligning with the NSTA Stewardship Expectation 11 (Net Zero). The OGA Plan outlines the steps to be taken by relevant persons to help achieve the OGA Strategy, where relevant persons refer to holders of petroleum licences; operators under petroleum licences; owners of upstream petroleum infrastructure; persons planning and carrying out the commissioning of upstream petroleum infrastructure; and owners of relevant offshore installations. The OGA Plan includes requirements for relevant persons to reduce emissions via four broad headings: investment and efficiency, platform electrification and low carbon power, inventory and flaring and venting. The OGA Plan requires relevant persons to produce an Emissions Reduction Action Plan (‘ERAP’) for each asset. They also place low carbon requirements for upcoming developments (with first oil and gas 1^st January 2030) (e.g. assets to be partly or fully electrified or run on low carbon power). Technical Guidance Note on Monitoring of stack gas emissions from medium combustion plants and specified generators: A guidance for organisations that service and maintain medium combustion plants and other specified generators to monitor stack gas emissions. The Environment Agency recently published several guidance notes relevant to monitoring stack emissions: Monitoring stack emissions: techniques and standards for periodic monitoring – This guidance note outlines how to choose an appropriate periodic monitoring technique and standard for monitoring stack emissions to air. Monitoring Stack Emissions: Techniques and Standards for CEMS and Automated Batch Samplers – This guidance note outlines how to choose an appropriate technique to measure substances using continuous emissions monitoring systems and lists the standards for automatic batch samplers. Guidance on Monitoring Stack Emissions: Technical Guidance for Selecting a Monitoring Approach – The guidance lists different approaches to monitoring, what is required for ‘successful’ monitoring as well as how to report the results. Monitoring Stack Emissions: Maximum Uncertainty Values for Periodic Monitoring – This guidance note lists the maximum uncertainty values when assessing stack emissions to ensure they are within the limit values of environmental permits. Monitoring stack emissions: measurement locations: This guidance note outlines the standard for stack emissions monitoring sample locations – requirements for measurement sections and sites (this guidance was formerly called M1).
European Pollutant Release and Transfer Register (E-PRTR):	Article 15(3) of the IPPC Directive requires the publication of an EC inventory of principal emissions and their sources. This provides information to the public, and helps authorities to assess the effectiveness of IPPC and identify priority areas. From 2007 onwards this reporting system has been the European Pollutant Release and Transfer Register (E-PRTR) under Council Regulation 166/2006. As a signatory state to the UNECE PRTR Protocol, the UK is also required to establish a national PRTR (UK-PRTR). The Department for Energy Security and Net Zerocollects emissions data for input to the UK-PRTR and the E-EPTR through the EEMS Reporting System (see below). The Department for Energy Security and Net Zero already collects emissions data for offshore oil and gas activities via EEMS. As such, it is not a new E-PRTR sector, but the reporting requirements of EEMS in terms of substances and thresholds will need to be extended to meet those of the E-PRTR Regulation. In this context, Oil & Gas UK commissioned an analysis (which has now been completed) to identify emissions of all E-PRTR pollutants that are relevant from an offshore perspective. The Department for Energy Security and Net Zeroand Oil & Gas UK will evaluate the results of this analysis to agree a way forward regarding compliance by the offshore industry with E-PRTR reporting requirements. In addition, The Department for Energy Security and Net Zero will continue to work closely with Oil & Gas UK on the intention to use the provisions of existing offshore regulations (e.g. the Offshore IPPC Regulations) for the purposes of enforcing the E-PRTR reporting requirements and imposing penalties for non-compliance. The Department for Energy Security and Net Zero will need to review and adjust accordingly the annual fees charged to operators for the maintenance of the EEMS database, in order to reflect new developments relating to E-PRTR/UK-PRTR reporting.
EEMS Reporting:	The Environmental Emissions Monitoring System (EEMS) was designed to enable the analysis of offshore (including terminals) oil industry environmental data, providing the offshore industry with an independent source of totalled environmental data on which to base its discussions with the government or within the industry itself. The dataset is accessible to both Government (Department for Energy Security and Net Zero) and industry (Oil & Gas UK) and acts as the primary data storage and reporting resource for both the UK Government and the offshore industry. EEMS provides the vehicle for offshore oil and gas industry emissions to be incorporated into annual UK inventories of atmospheric emissions that are required under a number of international conventions and EU instruments (see above). The EEMS reporting system now also includes a number of statutory reporting requirements, in particular reporting requirements under the Offshore Combustions Installations (Prevention and Control of Pollution) Regulations 2001 (as amended) (see Power Generation).
EU Emissions Trading Scheme:	In addition to atmospheric reporting through the EEMS system there are also other statutory reporting requirements under the EU Emissions Trading Scheme (see EU ETS for further details).
Energy Savings Opportunity Scheme	The Energy Savings Opportunity Scheme (Amendment) Regulations 2014 These Regulations amend Schedules 1, 2 and 4 to the Energy Savings Opportunity Scheme Regulations 2014 to correct drafting errors. Section 2.4 has been updated to provide further clarification on vessels supporting the offshore industry; Section 3.3.4 has been updated to introduce an alternative joint venture agreement for compliance of offshore assets; Section 5.3.2. now includes further clarification on independence of lead assessors; Section 7.1 includes amendments to sign-off requirements; Additional compliance checks have been added to Section 9.1; New Notification Questions have been added to Section 11. Guidance: The Department for Energy Security and Net Zerohave produced an Energy Opportunity Scheme guidance note for the oil and gas industry (available here). Complying with the Energy Savings Opportunity Scheme Guidance – This guidance was produced by the Environment Agency and outlines who is eligible for the Energy Savings Opportunity Scheme and the necessary procedures and processes pertinent to the scheme. It also outlines different means at which organisations can comply with the scheme. Additional guidance from The Department for Energy Security and Net Zero on the scheme is available here. The Department for Energy Security and Net Zero has also produced a report on the effectiveness of the ESOS scheme (available here).

Consent Needed:	A number of consents may be needed for atmospheric emissions, in particular EU ETS, Flaring, Venting and Power Generation. See specific topics for consent requirements. The following applies only to reporting requirements under EEMS.
How to Apply:	N/A
Who to Apply to:	N/A
When to Apply:	N/A

Performance Standards:

N/A

Measurements and Calculations:

The methodology involves the application of emission factors to process information which includes:

Fuel consumption in process turbines, heaters and engines
Flaring and venting volumes
Tanker loading volumes
Number and type of components (fugitive emission est.)

The EEMS spreadsheets use generic emission factors as developed by Offshore Energies UK. However, platform or vessel specific factors should be used in place of the default factors as per specific PPL and EU ETS consent requirements.

What to Report:	An annual report of all atmospheric emissions from the following must be submitted: Production of oil and gas from offshore reservoirs, including loading operations Onshore terminals engaged in processing/storing/loading Exploration, appraisal and development drilling rigs Emissions from support vessels, tankers on-route, helicopters and seismic vessels are not included, because these emissions are input by other sectors into the UK National Inventory. ERAP Reporting: The NSTA, via Stewardship Expectation 11, outlined that operators should develop, implement and maintain asset and/or infrastructure hubs’ GHG Emission Reduction Action Plans (ERAPs) in order to reduce their GHG emissions and support delivery of the UK’s net zero target. ERAP’s summarise and assess the applicability of available emissions abatement and emissions monitoring opportunities and technologies, and set out planned emissions reduction initiatives. The OGA Plan, published in 2024, provides further guidance in the associated ERAP explanatory note here. Additionally, OEUK have published a guideline that outlines a framework for implementing good practices within an ERAP – Emissions Reduction Action Plan (ERAP) \| Offshore Energies UK (OEUK).
How to Report:	Atmospheric emissions data should be reported by completing the EEMSATMO form which can be downloaded from the EEMS Website. The EEMS reporting form includes a number of calculations to assist in emission reporting. Additional guidance on how to complete the form and factors used in the calculations can be obtained from the Guidance Notes, also on the EEMS website. ERAP Reporting: Operators should produce and maintain their own plans / documents to fulfil the ERAP reporting requirements and have relevant documents available on request from the NSTA. This should include proportionate technical and economic assessments. The reporting requirements differ across various themes (e.g. flaring and venting management plans and electrification assessments), as detailed in the OGA Plan and associated ERAP explanatory note here.
Who to Report to:	Completed reports are to be submitted electronically to the EEMS website. ERAP Reporting: As above, generally the ERAP reporting requirements must be made available to the NSTA on request. However, some reporting requirements may be incorporated into existing submissions to the NSTA (e.g. reporting of flaring and venting quantities and associated emissions through the Emissions section of the UKSS).
When to Report:	Completed EEMS forms must be submitted by 7 February each year. For wells, the completed EEMS form must be submitted one month after completion of drilling. ERAP Reporting: ERAP’s must be submitted to the NSTA on request. The documents and plans produced as part of the reporting requirements must be refreshed at least every 2 years, as detailed in the OGA Plan and associated ERAP explanatory note here.

N/A

The Air Quality Provisional Common Framework	This command paper sets out how the UK government and devolved governments propose to work together on policies that aim to reduce harmful emissions and concentrations of air pollutants that can damage human health and the environment. (This includes national emission ceilings and ambient air quality.)
Clean Air Strategy 2019	The Clean Air Strategy 2019 outlines ambitions to reduce overall air pollution and make our air healthier to breath, protect nature and boost the economy. It highlights the importance of effective co-operation with the devolved administrations and sets out actions already underway in Scotland, Wales and Northern Ireland to cut air pollution right across the UK. It is currently under consultation.
Energy White Paper – Powering Our Net Zero Future	This paper details the Government’s plan to reach net zero targets. Chapter 6 of the paper outlines the steps to decarbonising the oil and gas industry and the governmental support for this.
Greenhouse gas reporting – Conversion factors 2018	The Department for Energy Security and Net Zero have released the emission conversion factors required when reporting on 2018 greenhouse gas emissions by UK based organisations of all sizes. Details are available here.
OGA Strategy	The OGA published a new strategy document in December 2020. This predominantly outlines the new net zero commitments and strategies for the oil and gas industry.
The Paris Climate Change Agreement gives companies clear incentive to look closely at how they are positioned for a low carbon future.	A deal was struck at UN COP 21 negotiations in December whereby nearly 200 companies agreed to keep the global average temperature to “well below 2C above pre-industrial levels” and to “pursue efforts to limit the increase to 1.5C”. The agreement states emissions should be net zero in the in the second half of the century. Businesses were heavily involved at COP21 showcasing initiatives on issues such as carbon reduction, energy efficiency and deforestation.
Updated Energy and Emissions projections: 2019	A report detailing projections of the UK emissions performance against national greenhouse gas targets under existing policies has been released by the Department for Energy Security and Net Zero. It includes projections of the demand for each type of fuel for different sectors of the economy. The report includes projected energy demand for electricity and indicates what mix of generation will meet it (link here).
Transitional National Plan (TNP): quarterly register	The TNP scheme allows large combustion plants (with a thermal rating equal to or greater than 50 megawatts) first licensed before 27 November 2002 to trade their annual allowances for sulphur dioxide, nitrogen oxide and particulate matter (dust) with other large combustion plants within the TNP scheme.