The establishment of a new HSE regulator in Australia led to a backload of unapproved or rejected permit applications. Feedback indicated that the regulator aimed to raise the bar on environmental performance. The new regulatory requirements led to difficulties with coordinating timelines and therefore threatened to have rigs waiting idle. Due to the inconsistent nature of the rejections and the absence of detailed regulator guidance, operators were not sure how they could meet regulatory expectations. Closer examination revealed a gap between corporate and asset level documentation and which the current permit applications had failed to close.
Not addressing this problem would have resulted in schedule delays; consequently impacting drilling costs, cash flow and reduced regulatory and shareholder confidence.
A restructuring of the environmental permit application was proposed, including a realignment of the companies risk assessment methodology and the governmental definition of ALARP. The new approach was put to the test and resulted in first-time regulatory approval. Most noteworthy, it was successfully replicated by in-house consultants on subsequent permit applications.