1.Change of Operator

All companies entering the UKCS as a potential new operator, either as a licence applicant or following the purchase or reassignment of an existing asset, must demonstrate to the Department of Energy and Climate Change (DECC) that they would be acceptable as a UKCS Production Operator. It is recommended that potential new operators should initially contact DECC Licensing Exploration and Development (LED), Licensing Administration, to establish what documentation is required by DECC. Further information can be found at:

Potential new operators should also contact the relevant LED Field Team Leader and the LED Consents Manager to discuss any existing or required consents (e.g. production and flare consents) or pipelines works authorisations. Further information can be found at:

Further details of the legal process relating to licence / operatorship transfer can be found at:

(a)Environmental Review

All potential new operators must satisfy a number of environmental requirements. Those requirements are detailed in Appendix C of the licensing guidance, and further information can be found at:

(i)New operators on the UKCS

New operators on the UKCS will be required to submit the Appendix C requirements as part of their licence application, and may be requested to attend an environmental interview with DECC in Atholl House, Aberdeen. If invited to interview, applicants will be required to give a short presentation on environmental issues relating to their potential activities on the UKCS, and to discuss DECC’s environmental requirements and timetables. Applicants may wish to be accompanied by their environmental adviser(s) at the meeting.

The scope of the issues that will have to be addressed in the application and at any interview will include:

Environmental Management Systems

Applicants will be required to have an Environmental Management System (EMS), and to obtain external verification of the EMS by a UKAS accredited body before they commenced any offshore operations.

Pollution liability arrangements

Applicants will be required to provide details of proposed pollution liability arrangements. This could be evidence that the proposed operator of a licence has, or intends to, register its operatorship with the Offshore Pollution Liability Association Ltd (OPOL).

Environmental sensitivities and issues

Applicants will be required to provide details of the environmental sensitivities pertinent to the area of interest. However, in the case of a change of operator, it is likely that the previous operator will have already provided a sensitivity assessment, or hold existing approvals that are supported by a more detailed environmental impact assessment. DECC is therefore likely to waive the requirement for a new assessment, but may still wish to discuss this with the applicant.

(ii)Established Operators

Companies that are existing operators on the UKCS would not be subject to a detailed environmental review, but may be requested to confirm that activities under the new licence would be covered by the information provided for existing operations.

(b)Transfer of Environmental Permits etc

When an asset is to be sold or assigned to anew operator, it will be necessary to transfer all of the relevant environmental applications, permits etc relating to the facilities associated with that asset to the new operator.

The transfer process should beinitiated by the new operator, who mustwrite to DECC Offshore Environment and Decommissioning (OED), Environment Management Team (EMT), on headed notepaper, outlining their intention to take over operatorship of a particular facility or facilities at a specified time on a specified date. The letter should be addressed to the addressee detailed below, and should preferably be sent by e-mail to and copied to . The letter should also be copied to the existing operator.

Environmental Management Team

Department of Energy and Climate Change

Offshore Environment and Decommissioning

Environmental Management Team

Atholl House

86-88 Guild Street

Aberdeen

AB11 6AR

EMT will contact relevant teams within LED to confirm that the relevant Petroleum Act licence assignment or assignments, and the new operator arrangements, have been confirmed; and will contact relevant teams within OED to compile a list of all the relevant permits etc that require to be transferred to the new operator. If the permits include a Greenhouse Gases Emissions Permit (EU ETS), OED will also contact the existing operator to confirm whether the existing permit can be transferred, or whether it will require to be surrendered because the Schedule1 Activities will cease over a full reporting year prior to the transfer or because the aggregated thermal capacity of the Schedule 1 Activities has dropped below the 20 MW(th) threshold detailed in Schedule 1. DECC will then reply to the new operator:

  • Confirming any outstanding issues that must be resolved before the transfers can be effected;
  • Confirming all the relevant DECC environmental permits etc that require to be transferred;
  • Advising the new operator that, if the Greenhouse Gases Emissions Permit has to be transferred, they must additionally complete form ETS10 and submit the form to ; and that, as soon as they receive the transferred permit, they should contact the Environment Agency at to request a new EU ETS registry account for the installation;
  • Advising the new operator that, if the Greenhouse Gases Emissions Permit has been, or will be, surrendered prior to the transfer and they wish to re-commence Schedule 1 Activities, it will be necessary to apply for a new permit and to complete an application for the allocation of allowances from the New Entrant Reserve. Application forms and further information about the application and NER process can be found at
  • Advising the new operator of any permits etc that cannot be transferred and must be the subject of a new application or submission to DECC. For example, it will usually be necessary to submit new Oil Pollution Emergency Plans, and approval of the plans can take two months. It may therefore be necessary to agree interim arrangements with DECC to cover the period prior to approval of the new OPEP’s;
  • Advising the new operator to contact the existing operator to ask them to request variations of the existing permits etc to effect the transfer to the new operator at the specified time on the specified date;
  • If any of the permits etc are maintained on the UK Oil Portal, advising the new operator how to set up a Portal account; and
  • Providing the names and contact details of a DECC Environmental Manager and Offshore Environmental Inspector who will be assigned to the new operator.

Following receipt of the existing operator’s requests for variations of the existing permits etc. to effect the transfers, EMT will notify the existing operator (copied to the new operator):

  • Confirming any outstanding issues that must be resolved before the transfers can be effected;
  • Requesting that copies of all current permits etc that are not maintained on the UK Oil Portal, and any associated application forms and relevant correspondence relating to variations of those permits etc, should be forwarded to the new operator;
  • Requesting that arrangements are agreed with the new operator with respect to any on-going monitoring and/or reporting requirements that are a condition of the relevant permits etc., including the reporting obligations relating to any Greenhouse Gases Emissions Permit and the submission of the Annual Emissions Reports (ETS7);
  • Confirming that the relevant permits etc will be transferred to the new operator at the specified time on the specified date; and
  • Confirming that the relevant permits etc in the name of the existing operator will be revoked at the time of the transfer.

DECC may require the original permit etc holder or the proposed new permit etc holder to supply additional information to support the requests for variations of the existing permits etc to effect the transfer. This will be requested in writing.

Electronic copies of the relevant permits etc that are not maintained on the UK Oil Portal will be varied and transferred to the new operator by DECC on the specified date, or on the next working day if the specified date is during a weekend or public holiday.

In the case of permits etc that are maintained on the UK Oil Portal, the new operator's account will be activated on the specified date (subject to the working day limitation outlined above), and the new operator will be able to access all the relevant applications and permits etc via their Portal account. The new operator will also be able to “manage” the UK Portal account, and amend the list of contacts and their access rights.

When the new operator receives the copies of the current applications, permits etc, they must review the documents to determine whether there are any aspects that could prevent them from undertaking the activities in compliance with the existing permit terms and conditions. If such aspects are identified, the new operator should contact DECC at the earliest opportunity.

The new operator must identify whether any amendments are required to take account of the new operator’s details, operating practices, procedures, policies or commitments as applicable. Should the new operator require to amend any of the permits etc that are the subject of the transfer, they must submit an application for a variation within 8 weeks of the transfer date (and before undertaking any operation that is not currently permitted under the existing terms and conditions of the permit etc). All changes must be clearly highlighted in order to identify any deletions or additions to the original application. Should DECC determine to refuse the application to vary the terms and conditions, DECC will give notice in writing of their decision and discussions will take place with the new operator.

Should DECC wish to review the terms and conditions of any of the transferred permits etc, they will contact the new operator in writing and confirm their requirements. The latter may include submission of a new or amended application.

New operators are reminded that DECC may revoke any existing permit if the application contains or is supported by any information or statement which is false or misleading.

2.Change of Company Name

In the event of a change of company name, there will be no requirement for an Environmental Review, but simplified transfer of permit procedures will still apply, as outlined below.

The operator mustwrite to DECC Offshore Environment and Decommissioning (OED), Environment Management Team (EMT), on headed notepaper, outlining their intention to change the name of the company, and record the change with Companies House. The letter should be addressed to the addressee detailed below, and should preferably be sent by e-mail to and copied to .

Environmental Management Team

Department of Energy and Climate Change

Offshore Environment and Decommissioning

Environmental Management Team

Atholl House

86-88 Guild Street

Aberdeen

AB11 6AR

EMT will contact relevant teams within OED to compile a list of all the relevant permits etc that require to be transferred to the new company name. DECC will then reply to the operator:

  • Confirming all the relevant DECC environmental permits etc that require to be transferred;
  • Confirming any permits etc that do not require to be transferred, and the procedure that should be followed in such cases. For example, operators will be able to provide a bridging document confirming the name change for attachment to existing OPEPs, providing the content of the documents does not require any amendment;
  • Advising the operator that, if a Greenhouse Gases Emissions Permit has to be transferred, they must additionally contact the Environment Agency at to advise them that they will require to amendment of the EU ETS registry account for specific installations to reflect the new company name; and
  • Advising the operator to confirm the name change, on headed notepaper bearing the new company name, as soon as it is accepted and recorded by Companies House; and

Following receipt of confirmation that the name change has been accepted and recorded by Companies House, EMT will:

  • Advise the operator to request variations of the existing permits etc to effect the transfer to the new company name;
  • Advise the operator of any outstanding issues that must be resolved before the transfers can be effected; and
  • Advise the UK Oil Portal that the name change has been accepted and recorded by Companies House, so that relevant documentation can be transferred to the new company name following receipt of the relevant Portal requests for variations.

Following receipt of the requests for variations of the existing permits etc, and/or resolution of any outstanding issues (e.g. the provision of bridging documents for OPEP documents), EMT will convert the relevant permits etc to the new company name, and re-issue the documents or approvals, either electronically or via the UK Oil Portal as appropriate. Following conversion of the UK Oil Portal account, it will be possible to make any necessary amendments to the list of contacts and their access rights.

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