Third Party Access to Infrastructure in the United Kingdom Continental Shelf - OGEL by Yanal

Oil, Gas & Energy Law Intelligence www.ogel.org : ISSN Issue : Published :

1875-418X Vol. 12 - issue 1 January 2014

This paper is part of the OGEL special on "Offshore Petroleum Exploration and Production: Challenges and Responses" prepared by: Simon Amaduobogha (CEPMLP, University of Dundee) and Dr. Sergei V. Vinogradov (CEPMLP, University of Dundee)

Third Party Access to Infrastructure in the United Kingdom Continental Shelf: An unhappy mix of Heavy-Handed Regulation and Light-Handed Regulation. by Y. Abul-Failat

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Third Party Access to Infrastructure in the United Kingdom Continental Shelf: An unhappy mix of Heavy-Handed Regulation and Light-Handed Regulation.

Abstract: “An unhappy mix of poorly-drafted legislation; Statutory Guidance relative to the Ministerial power which is unfit for purpose; and a well-meaning but essentially useless industry code of best practice.”1 The objective of this paper is to provide a synopsis on both hard law and soft law instruments addressing third-party access (“TPA”) to infrastructure in the UKCS. Firstly, the paper will outline the scope and purpose of TPA; followed by an outline and evaluation of the regulatory regime under the recently enacted Energy Act 2011 (“Act”) and the Infrastructure Code of Practice (“ICOP”). Finally, it will provide a conclusion on whether these instruments adequately address the issues of TPA and whether they are effective.

Greg Gordon (2012) Access to Infrastructure. LLM Oil and Gas Law, University of Aberdeen 1 March 2012.

Introduction The regulation of access to inherently monopolistic natural markets is somewhat of a controversy world wide as there is no general consensus on the correct way to regulate these industries through legislation, policy, practice codes and regulations. There is a difference in approach generally in the measures taken with regards to these resources as either preventative or managing conflict between the owners of the infrastructure and the third parties seeking access, whilst there are clear advantages to both strategies. It is suggested that a combination of these approaches will generally be the most satisfactory in regulation. That is to say that regulation which is both preventative (providing compliance templates or guidelines for negotiations and management) as well as corrective (recourse in the event of abuse of power or unsatisfactory terms of agreement) may well be the best approach whilst being mindful of the advantages and disadvantages of both. Through examination of the current legal framework, which is primarily retrospective, one can see the need for a more proactive and binding approach to the management of these negotiations. In the theory of light-handed regulation, there is less, yet significant government intervention and regulation of natural monopolies, to which general competition law is applied.2 Lighthanded regulation which is based on the threat of governmental intervention does have general advantages, such as saving on the cost of regulation of resources and reducing the danger of regulatory capture.3 The private sector is less cautious of high prices and secures desirable aims as an outcome. It is feared that firm regulation of these natural monopolies will deter investors because of these high compliance costs, constraints on commercial negotiations, high potential for regulatory negligence and the distortion that this may cause on pipeline investment.4 For this reason, there is massive appeal for light-handed regulation at face value. However, in practice, regulation in many cases is applied as a mixture of heavy-handed regulation and light-handed regulation law. This is the case in the UKCS which has raised concerns over the decommissioning of the overall infrastructure, stranding reserves. Decommissioning liability has become even more important as the infrastructure in 2

Sean Rush, ‘Access to Infrastructure on the UKCS: The Past, the Present and … a future’ (2012) Memery

Crystal LLP 1, 17 http://www.memerycrystal.com/uploaded/Articles/other%20files/Access%20to%20Infrastructure%20on%20the %20UKCS%20-%20SR%20-%20Feb%202012.pdf Accessed 9 July 2012. 3

Ibid.

Fatih Ozbugday, 'Light - Vs. Heavy-Handed Regulation of Natural Monopolies: The Case of New Zealand and

Electricity Distribution Industry' (Master's Thesis Tilburg University, 2008) 18. 2

the UKCS is aging and respectively the decrease in production of the larger older fields raises the need to extend the life of the asset by taking on new volumes.5 The general consensus is that the high cost of firm regulation does not outweigh the potential benefits thereof.6 It is possible however to conceive a set of regulations that forwards guidelines for compliance without moving out of the spectre of light-handed regulatory.

The concept of ‘Third-Party Access to Infrastructure’ (“TPA”) Pipelines and offshore processing facilities amongst other upstream oil and gas infrastructure are usually owned by the field owner.7 In such infrastructure, ullage is commonly available and may be used by third-parties upon successful negotiation of a tariff;8 however major players in the oil and gas industry have indicated that more regulation of these tariffs may be desirable.9 Access to this infrastructure however is plagued by other regulatory problems relating to liability and compensation, and the Template Transportation, Processing and Operator Services Agreement.10 Commentators have indicated that there is much room for abuse in these negotiations and there is no standard for indemnity, calling on the state to lead the way in terms of providing a template for agreements, as well as negotiated agreements with insurance companies to mitigate the problems of indemnities and liabilities.11 The notion of sharing infrastructure was established with the aim to reduce the costs of developing new fields and also to avoid abundance of pipelines.12 The UKCS has become a 5

Judith Aldersey-Williams, 'First Referral for Dispute Resolution over Access to North Sea Infrastructure'

(Law-now, 26 May 2010) http://www.law-now.com/lawnow/2010/First+Referral+for+Dispute+Resolution+over+Access+to+North+Sea+Infrastructure260510.htm?cm ckreg=true accessed 23 April 2012. 6

Kenneth Abbott and Duncan Snidal, 'Hard and Soft Law in International Governance' in Judith Goldstein,

Legislation and World Politics (MTI Press 2001) 50. 7

Louise Smith, ‘Offshore Oil and Gas Industry’ (31 May 2011) House of Commons standard note SN/SC/5985,

9 www.parliament.uk/briefing-papers/SN05985.pdf accessed 18 April 2012. 8

Peter Roberts, Gas Sales and Gas Transportation Agreements: Principles and Practice (3 edn, Sweet &

Maxwell 2011) 63. 9

Rush (n 2) 5.

Ibid 4.

Ibid.

DECC, Guidance on Disputes over Third Party Access to Upstream Oil and Gas Infrastructure (March 2012)

para 44 http://og.decc.gov.uk/assets/og/ep/infrastructure/tpa-guide.pdf accessed 01 April 2012. 3

mature province with insufficient reserves to justify a field’s own infrastructure.13 As a result, TPA has become an essential approach in maximising economic recovery when exploiting oil and gas fields.14 Owners however, are interested in profiting from their facilities15 and hold extensive bargaining powers when negotiating a TPA tariff.16 Hence, new entrants may not be able to access infrastructure on ‘fair and reasonable terms’ hindering the economic viability of their upstream projects.17 Simultaneously, such monopolistic behaviour obstructs the offshore regulator from achieving its objectives; namely, ensuring the recovery of all economic hydrocarbon reserves, protecting the environment and securing energy supply at competitive prices.18 Accordingly, even though TPA involves the private property of upstream companies and is a commercial endeavour; the government has a legitimate concern in hastening and regulating the negotiations between infrastructure owners and third-parties.19 Such interference has been developed through a combination of heavy-handed and lighthanded regulation.

The Energy Act 2011 & the Guidance Under the legislative framework, TPA was mainly regulated by the provisions of The Pipelines Act 1962, The Gas Act 1995, The Petroleum Act 1998 and the Energy Act 2008. The Act which came into force on 21 March 2012 has re-enacted in a consolidated and rationalised form all prior legislation.20 DECC has also published Guidance on Disputes over Third Party Access to Upstream Oil and Gas Infrastructure (“Guidance”) to support the Act

Marc Hammerson, Upstream Oil and Gas: Cases, Materials and Commentary (Globe Law and Business

2011) para 5.1.2. 14

Uisdean Vass, ‘Access to Infrastructure’ in Greg Gordon, John Paterson and Emre Usenmez (eds.), Oil and

Gas Law: Current Practice and Emerging Trends (2nd edn, DUP 2011) para 7.1. 15

Roberts (n 88) 226.

Alexander Kemp and Euan Phimister, 'Economic Principles and Determination of Infrastructure Third-Party

Tariffs in the UK Continental Shelf' (2010) University of Aberdeen, North Sea Study Occasional Paper No. 116, 1 http://www.abdn.ac.uk/~pec144/acreef/acreef%20papers/nso-116.pdf accessed 12 April 2012. 17

Vass (n 14).

Guidance, para 9.

Hammerson (n 13).

DECC, 'Energy Act 2011: Third Party Access to Upstream Oil and Gas Infrastructure' (2012) Energy

Development Unit www.decc.gov.uk/assets/decc/11/policy-legislation/energy act 2011/3208-ea2011-thirdpartyaccess-upstream-oil-gas.pdf accessed 19 April 2012. 4

and provide statutory interpretation regarding provisions related to TPA.21 Under the current framework, companies seeking TPA should first apply to the owner.22 As with previous legislation, if such application or negotiation is not agreed on satisfactory terms, the thirdparty may apply to the Secretary of State (“SS”) for a notice to grant and determine the terms of access.23 The Guidance explains how the SS would generally determine terms for the most likely scenarios in which they would be called upon.24 These settings include placing terms for infrastructure built as part of an integrated field development project; infrastructure built, oversized or maintained with a view to taking third-party business; infrastructure associated with a field at or near the end of its economic life; and cases where there is competition for limited ullage.25 One can see how there would be a need for more regulatory guidelines for negotiation agreements, as this has the potential to shorten processes of negotiation, the potential for abuse and the occurrences of recourse to the SS. Upon issuance of a notice, the SS may include provisions as they consider necessary to; secure to the applicant the right for access; assist in exercising access; secure ancillary or incidental rights; and to regulate relevant charges.26 Such a notice may only be issued by the SS if it does not prejudice ‘the conveying by the pipeline, or the processing by the facility of the quantities of substances’ which the owner, an associate of the owner or any other person with a right to access requires or may reasonably be expected to require.27 In exercising their power to give a notice, the SS must consider matters including,28 available capacity; technical incompatibilities; anything that may hinder the efficient, current and planned future production of petroleum; maintenance of security of supply; and the number and interests of all parties.29 The Guidance clarifies that this is not an exhaustive list and that the SS may take into account other considerations such as financial information, other existing users and compensations for any prejudiced parties.30 When considering an application, the SS must 21

Guidance, para 2.

Ibid, para 1.

Act, s 82 (4).

Guidance, para 15.

Ibid, paras 15-16.

Act, s 82 (11).

Ibid, s 82 (9).

Ibid, s 83 (4).

Ibid, s 82 (7).

Guidance, para 12. 5

decide whether they will reject, adjourn to enable further negotiations between the parties, or consider further.31 In the case of the latter, the SS will offer an opportunity to hear the applicant, the owner, and any person with the right of access, the Health and Safety Executive and such other person as the SS thinks appropriate.32 The Act offers further flexibility over its predecessors by extending the SS’s powers. Firstly, it allows the SS to request modifications to oil and gas processing facilities for the purpose of TPA rights.33 Secondly, the SS may intervene in disputes even if a formal application has not been made.34 For instance, the SS may request information regarding any TPA negotiations.35 The Guidance outlines the type of information which may be required such as data related to owners’ rights, a demonstration of their tariff calculation methodology, and forecasts of available capacity.36 Moreover, the SS can issue an access notice upon his initiative provided that there is no prospect of reaching such an agreement and that there was reasonable time to do so.37 This power however, would only be used in limited circumstances as ‘it would override the right of a prospective user to make an application to the [SS] at the time they see fit.’38 Despite the above developments, the intention of the Guidance is that such provisions should ‘be only a backstop, against the possibility that normal commercial negotiations are not successful.’39 Hence, what remains unchanged is that companies seeking TPA must first apply and negotiate with the owner. Vass explains that third-parties are reluctant in applying to the SS due to a ‘shame factor based on the notion that oilmen should be able to sort things out on a direct basis.’40 Moreover, the industry is globally operated by a small number of companies and third-parties may not apply to the SS in order to avoid any conflict which may affect their relations with other companies around the global market.41 31

Act, Article 82 (6) (a).

Ibid, s 82 (6) (b).

Ibid, s 84.

Ashurst, 'Access to Oil and Gas Infrastructure in the UK under the Energy Act 2011 (Ashurst, October 2011)

www.ashurst.com/doc.aspx?id_Content=6396 accessed 20 April 2012. 35

Ibid, Article 87.

Guidance, Annex 3.

Ibid, ss 83 (2), 83 (3).

Guidance, para 9.

DECC (n 20) 1.

Vass (n 14) para 7.16.

Ibid. 6

Infrastructure Code of Practice The government’s response to the above issues is the use of soft law instruments.42 Accordingly, the development of the ICOP was historically based on the lack of transparency and the apparent monopoly of the owners of certain downstream pipelines.43 These monopolies led to disproportionate tariffs and an abuse of ownership rights to the detriment of the third parties aiming to access the infrastructure.44 As a result, in 1994 the Government has raised explicit concerns regarding the ineffectiveness of the legislative framework in addressing these issues which led to formulation of the D’Ancona Committee which was essentially a collective between industry representatives and the Department of Trade and Industry.45 The committee has decided to formulate a code to resolve the above said issues; and so in 1996, the Rules and Procedures Governing Access to Offshore Infrastructure (“RPGA”) was created backed by ministerial powers.46 Although the RPGA did not succeed, many of its principles were reiterated by the ICOP which came into force in August of 2004.47 The voluntary ICOP was last revised in 2009 and was introduced to promote ease and efficiency in the management and negotiation process of TPA.48 Although, it is a nonstatutory code, parties are obliged to abide by its doctrines and procedures.49 The ICOP is simply a guide for TPA negotiations and its principles include non-discriminatory access, separation of services, transparency, standardisation and timelines.50 Moreover, it requires the parties to make information available, requiring owners to publish both ‘High Level Capacity Information’ and ‘Specific Information.’51 Further information may be exchanged during the

Hammerson, (n 13) para 5.4.1.

T Daintith and G Willoughby, United Kingdom Oil and Gas (Sweet &Maxwell 1984) para 1-733.

Vass (n 14) 186.

Daintith (n 43); Rush (n 2) 24.

Vass (n 14).

ICOP para 1(4).

Oil and Gas UK, ‘Code of Practice on Access to Upstream Oil and Gas Infrastructure on the UK Continental

Shelf’ (January 2009) www.oilandgasuk.co.uk/publications/viewpub.cfm?frmPubID=24 3 accessed 23 March 2012. 49

Daintith (n 43); ICOP, para 1(2).

Vass (n 14) para 7.17.

ICOP, para 6. 7

negotiation process between the parties interse.52 With regards to tariffs, the ICOP requires the owner to charge tariffs on ‘fair and reasonable’ terms for services which should be provided on an unbundled basis as far as practical.53 The purpose of these provisions is to ‘strike a fair balance between the parties’ whilst facilitating competition in the market.54 The UK government has stated that the above principles are crucial to maximise ‘the economic recovery of the UK’s oil and gas production’.55 However, ICOP’s greatest contribution is the Automatic Referral Notice (“ARN”) process which addresses the ‘shy applicant’ by mandating the involvement of the SS when negotiations fail.56 This process should be utilised within 6 months (may be extended) after the commencement of negotiations unless the bona fide enquirer informs DECC that a TPA agreement has been concluded or that access is no longer necessary.57 Complemented by the Guidance, ICOP offers broad assistance to the SS when reviewing an ARN. It provides that the SS shall take into account effective competition,58 existing contractual commitments, reasonable provision for their own production, realistic impact of prospective new businesses on their system, fair and reasonable tariffs, and the risks which should be compensated.59 Despite the title and the purpose, the process is not actually automatic; an ARN must be submitted by a third-party for it to operate and the companies’ attitude remains that ‘one should not tell the teacher and speak out on a dispute.’60 The 2006 Review of the ICOP has noted that on certain occasions the ARN process has not worked efficiently due to the parties’ lack of understanding and adherence to ICOP’s time related provisions or even due to early ARN submissions.61 Moreover, it noted other 52

Ibid.

Ibid, para 11(1), para 12.1 (1).

Vass (n 14) paras 7.29, 7.31.

Smith (n 7) 13.

ICOP, 8(1).

ICOP, paras 7(4), 8 (2).

ICOP, para 2(3).

Ibid, para 12.

Judith Aldersey-Williams, 'First Referral for Dispute Resolution over Access to North Sea Infrastructure'

(Law-now, 26 May 2010) http://www.law-now.com/lawnow/2010/First+Referral+for+Dispute+Resolution+over+Access+to+North+Sea+Infrastructure260510.htm?cm ckreg=true accessed 23 April 2012. 61

UKOOA, Infrastructure Code of Practice 2006 Review Report, 4. 8

problems such as a lack in the publication of relevant data,62 establishing high indemnities which impede the negotiation process,63 and that a number of capacity owners did not sign the code.64 Nevertheless, the review’s attitude remains positive stating that through advocating awareness and understanding of the code; it will benefit from better results as the and enhance the parties’ behaviour.65 Accordingly, the Review provides although the ICOP needs further work to meet its intention; the ‘overall consensus from third party system operators and users is that the code is fit for purpose and is working well’.66 Nonetheless, the House of Commons Energy Climate Change Committee report issued in 2009 stated that: Smaller companies in particular are having difficulties accessing infrastructure... because in some cases of unrealistic demand by infrastructure’s owners. The ICOP is not working in this respect… we do think the government has to take a more active part in ensuring the successful outcome negotiations about access arrangements.67 This is evident in the two noteworthy cases submitted to the SS via the ICOP namely: Rochelle and Bacchus. The Endeavours referral is unprecedented and was based on the unreasonable tariff requested by the Scott Platform owners to transport gas from Endeavours Rochelle Field Development.68 The application was filed in 2010, to practice rights for the Scott platform and the gas pipeline that connected Scott to the Southern Area Gas Evacuation pipeline which was being constructed as part of the Beryl field development.69 The work was delayed for year while the application was processed which means that Rochelle’s net present value of the project was reduced by the investor annual cost of capital and also for the Scott owners which lost a year worth of tariff revenue.70 Rush explains that although both parties were affected by this time loss it did not necessarily affect them equally; there is a difference in approach between a pipeline carrier and exploration and production company as the former 62

Ibid 15.

Ibid 3.

Ibid 20.

Ibid 26.

Smith (n 7) 11.

Aldersey-Williams (n 60).

Offshore Technology ‘East Rochelle Oil and Gas Field, Block 15/27, North Sea, United Kingdom’ (Offshore-

Technology Online 2011) http://www.offshore-technology.com/projects/east-rochelle-oil-gas-field/ Accessed on 9 July 2012. 70

Rush (n 2) 29. 9

is concerned with shipping new production and that latter is only concerned when it’s their own production at stake.71 In any case, in April 2011 commercial terms have been agreed for the transport and processing of Rochelle gas production but no details of the agreement was given in Endeavours statement.72 The other application was filed by the Bacchus field owners in February 2011 to gain access to the FPS.73 Although over 10 months have passed, the application is still in consideration and the details are being scrutinised putting all information in strict confidentiality.74 Thus, the fact remains that the Secretary has yet not made any determinations and the lack of use of the statutory powers ‘may be a signal that the legislation is ‘bad’ law in that is either unnecessary or practically unworkable...[and] does not provide the certainty needed to investors to backstop negotiations under ICOP in a timely and predictable manner.’75 DECC and Oil and Gas UK have both considered the effects of competition law on the UKCS infrastructure. Investigations mainly revolved around Article 81 of the EC Treaty which prohibits anti-competitive agreements and Article 82 which prohibits abuse of dominant position.76 Interpretive guidelines of national or EU competition law in the context of upstream oil and gas were never provided by the Office of Fair Trading. Nevertheless, before the realisation of the ICOP, the Office of Fair Trading has informally advised UKOOA on the code compliance with the 1998 Competition Act and EC competition law; particularly on the information sharing provisions.77 In their non-binding advice they have stated that '[w]e take the view, based on the text of the Code and our understanding of the way in which it will be applied, that the Code is pro-competitive by object and that it is highly unlikely that we would find otherwise in any investigation.'78 Similarly, in the case of

Ibid.

Ian Forsyth, 'Operators Resolve North Sea Dispute' (The Press and Journal, 19 April 2011)

www.pressandjournal.co.uk/Article.aspx/2229062 accessed 13 July 2012. 73

Rush (n 2) 30.

Ibid.

Vass (n 14) 185.

Vass (n 14) 181.

ICOP Annex B. 10

Rochelle DECC did not find the infrastructure owners to have abused their dominant position as prohibited by Article 82 of the EC Treaty.79

Conclusion The act has introduced advents to mitigate the stigma of the ‘shy applicant’ by assigning to the SS a discretionary power to intervene in negotiations and to ensure DECC’s early involvement and right to request information. The Guidance indeed clarifies and interprets the provisions of the Act but there is little evidence of substantial or actual contribution to the regulatory framework of TPA negotiations and the related Ministerial powers. As to the ICOP, it further regulates negotiations through principles and mechanisms such as the ARN. The ICOP however, can only be complementary to the Act and cannot be as effective as hard sanctions due to its non-penal nature which allows companies to ‘cherry-pick standards and where to apply them.’80 Moreover, subscription to the code is not compulsory; so, companies who are not concerned with their reputation or their public scorecard may be unwilling to adopt the code, particularly as the code does not directly enhance profit which many agree that its ‘ the primary motive of business.’81 The Energy and Climate Change Committee has noted that, ‘the ICOP is not working well in protecting smaller companies against unrealistic demands of the owners’82 Despite the desire for light-handed regulation of this industry, intense intervention is not necessarily required. Rather than the regulatory structure including both legislation and the ICOP being retrospective, guidelines for compliance in addition to avenues for recourse in an attempt to be proactive and preventative may be a realistic alternative. This can still be achieved through light-handed regulation, enjoying the benefits of such regulatory structure. Regardless, the hope placed in them is not necessarily misplaced because they have the capacity to define the future shape of legislations relating to TPA issues affecting the upstream oil and gas development.

In Focus, 'Endeavour Sets Precedent by Referring Dispute to DECC' (Oil and Gas News, 10 July 2010)

http://www.oilandgasnewsonline.com/pages/article.aspx?aid=29158 accessed 10 July 2012. 80

Bede Nwete, ‘Soft Law and Hard Sanctions in Upstream Oil and Gas in Developing Regions’ (2010)

CEMPLP Working Research Paper Series No 2010/05, 19 www.dundee.ac.uk accessed 20 April 2012. 81

Ibid, 3.

Energy and Climate Change Committee, UK Offshore Oil and Gas (HC 2008-09, First Report) para 44.

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The Energy Act 2008.



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

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

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

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

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

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

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

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

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Nwete B, 'Corporate Social Responsibility and Transparency in the Development of Energy and Mining Projects in Emerging Markets; Is Soft Law the Answer?’ (2007) 8 (4) GLJ 311, 312.

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

Kemp A and Phimister E, 'Economic Principles and Determination of Infrastructure Third-Party Tariffs in the UK Continental Shelf' (2010) University of Aberdeen, North Sea Study Occasional Paper No. 116 http://www.abdn.ac.uk/~pec144/acreef/acreef%20papers/nso-116.pdf accessed 12 April 2012.



Nwete B, ‘Soft Law and Hard Sanctions in Upstream Oil and Gas in Developing Regions’ (2010) CEPMP Working Research Paper Series No 2010/05, 3 www.dundee.ac.uk accessed 20 April 2012.



Rush S, ‘Access to Infrastructure on the UKCS: The Past, the Present and … A FUTURE’ (2012) Memery Crystal LLP 1 http://www.memerycrystal.com/uploaded/Articles/other%20files/Access%20to%20In frastructure%20on%20the%20UKCS%20-%20SR%20-%20Feb%202012.pdf Accessed 9 July 2012.



Smith L, ‘Offshore Oil and Gas Industry’ (31 May 2011) House of Commons standard note SN/SC/5985 www.parliament.uk/briefing-papers/SN05985.pdf accessed 18 April 2012.

Theses 

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Aldersey-Williams J, 'First Referral for Dispute Resolution over Access to North Sea Infrastructure' (Law-now, 26 May 2010) http://www.law-now.com/lawnow/2010/First+Referral+for+Dispute+Resolution+over+Access+to+North+Sea+Infr astructure260510.htm?cmckreg=true accessed 23 April 2012.



Ashurst, 'Access to Oil and Gas Infrastructure in the UK under the Energy Act 2011 (Ashurst, October 2011) www.ashurst.com/doc.aspx?id_Content=6396 accessed 20 April 2012.



In Focus, 'Endeavour Sets Precedent by Referring Dispute to DECC' (Oil and Gas News, 10 July 2010) http://www.oilandgasnewsonline.com/pages/article.aspx?aid=29158 accessed 10 July 2012.



Forsyth I, 'Operators Resolve North Sea Dispute' (The Press and Journal, 19 April 2011) www.pressandjournal.co.uk/Article.aspx/2229062 accessed 13 July 2012.

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Energy and Climate Change Committee, UK Offshore Oil and Gas (HC 2008-09, First Report).



Greg Gordon (2012) Access to Infrastructure. LLM Oil and Gas Law, University of Aberdeen 1 March 2012.



Offshore Technology ‘East Rochelle Oil and Gas Field, Block 15/27, North Sea, United Kingdom’ (Offshore-Technology Online 2011) http://www.offshoretechnology.com/projects/east-rochelle-oil-gas-field/ Accessed on 9 July 2012.



UKOOA, Infrastructure Code of Practice 2006 Review Report.