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Onshore Regulatory Environment Challenges
Environmental Permitting for Onshore Gas Developments

An existing UK onshore gas operator has experienced major problems with produced water leading to ‘watering off’ of production wells and significantly reduced rates of gas recovery. The problem is exacerbated by the fact that historically, all produced water has been injected back to the production formation. The magnitude of the problem is so severe that it jeopardises the commercial viability of gas production.

Envireau Water was commissioned to look at alternative ways of disposing of produced water. One option was identified whereby the produced water could be disposed of to a different geological formation, which would eliminate the problem with watering off and moreover, would not present a risk to the environment.

Initial consultation with the relevant UK environmental authority suggested that whilst the concept was technically sound and there were no risks, the existing environmental regulations would prohibit such an activity from being permitted. Envireau Water therefore carried out a detailed review of the environmental regulations, the governing acts and European Directivities; and together with expert legal advice from specialist environmental lawyers presented a robust case why the activity could be permitted.

The legal position was underpinned by a detailed technical report prepared by Envireau Water focusing on the geology and hydrogeology to demonstrate that the proposed method of produced water disposal presented no risk to the local environment. The study robustly concluded that the proposed injection formation was deep and isolated from ‘useful’ shallow aquifer systems and contained water of a quality that was several times more saline than seawater and had no perceivable resource value.

A series of discussions and negotiations took place over an 18 month period at all levels within the regulatory authority to present the concept and obtain regulator approval, prior to submission of an application for an environmental permit. A permit for the activity that 18 months previously “could not be permitted” was finally received in Spring 2014.

Envireau Water has been actively involved in UK onshore gas development since 2006 and more intensely as UK environmental policy has developed since 2012. We have been solving problems related to water abstraction, water discharge and disposal, aquifer protection and risk assessment for over 25 years and, as this case study shows, we know exactly how to work with the regulatory bodies – and where necessary challenge the system – to obtain these permits.