The Professional Association of Ecologists of Ukraine (PAEU) criticized part of the requirements of the Ministry of Environmental Protection and Natural Resources regarding obtaining permits and reporting for oil and gas production, in particular in the EIA procedure.
They think it's not contributes to an increase in the production of energy resources, attracting investments and negatively affects the energy independence of Ukraine, reports ECOBUSINESS.
“We seem to strive for the standards of the European society in the field of environmental protection, but we often imitate that we strive. This is especially acute in the EIA procedure," the environmentalists noted.
The article explained that there are certain features for business entities in the oil and gas industry.
Ecologists pointed out contradictory moments in the construction of oil and gas wells using the example of one of the real positive conclusions from the EIA for 2022:
- the construction of water wells, as well as the formation of associated formation waters and their return to the reservoir, were not assessed by this procedure for assessing the impact on the environment.
- the disposal of drilling waste, including any other waste, within the boundaries of drilling sites was not assessed by this environmental impact assessment procedure;
- treatment with associated formation waters shall be carried out in accordance with the requirements of Articles 72 and 75 of the Water Code of Ukraine, and in case of return of associated formation waters to underground horizons, by any business entity, ensure the implementation of an environmental impact assessment;
- not to dispose of drilling waste, including any other waste, within the boundaries of drilling sites;
- in the case of plugging and liquidation of wells unsuitable for operation, ensure an assessment of the impact on the environment.
It was explained that drilling an oil and gas well without water intake is almost impossible, since a significant amount of water (several hundred m3) is needed to drill a well, prepare drilling mud, and cement fluids. In addition, a significant amount of water is also required to ensure the cooling and flushing of drilling equipment and the sanitation needs of workers.
“Most of Ukraine's fields are depleted or in the final stages of development, so there will usually be associated water, especially in oil fields. And the most rational and environmentally safe is their return to underground horizons,” the environmentalists noted.
The material explained that, according to the Water Code, the return to underground horizons of the associated reservoir waters of oil and gas fields is established by the regional, Kyiv, Sevastopol city state administrations, the executive authority of the Autonomous Republic of Crimea on environmental protection. Also, the return of associated formation waters is carried out according to technological projects agreed with the central executive authority and does not provide for the conduct of EIA.
Ecologists emphasized that in Art. 3 of the Law of Ukraine "On Environmental Impact Assessment" there is also no requirement regarding EIA for the return of associated formation waters during oil and gas production. And if there is no such requirement, such activities are not subject to environmental impact assessment.
“During the drilling process, and especially when testing or developing a well, cement bridges are installed, interlayer crossflows are isolated, and in the absence of an industrial inflow of hydrocarbons or for technical reasons (accident), the well can be liquidated. It is impossible to predict everything at the stage of designing or preparing a report on EIA,” the PAEU explained.
Ecologists stressed that, thus, this conclusion provides an opportunity for the developers of the EIA Reports to complete four more Reports and delay the well construction process for several months, or maybe even years.
They also criticized the requirement to provide information on a monthly basis about the waste generated at the enterprise, its quantitative and qualitative composition, as well as information about a specialized organization that ensures their disposal. Indeed, in the Conclusions for the past years, such information should have been provided once a year.
Ecologists stressed that in accordance with the requirements of the Tax Code of Ukraine for the payment of environmental tax, the reporting period is a quarter. According to the requirements of the regulations of the State Statistics Service of Ukraine, a report on the generation and management of waste in accordance with the form No. 1-waste is submitted annually. Not every day, week or month, but annually.
“The question arises, why is this information for the Ministry of Natural Resources? - says the material. “In addition to the Withdrawal from the EIA, enterprises must also obtain an emission permit for the so-called temporary sources, since the well drilling period is 5-6 months, and the period of validity of the permit for the second group is seven years.”
Environmentalists noted that the procedure for obtaining this permit is also quite lengthy. It is also necessary to obtain a permit for special water use for a period of three years.
Earlier, EcoPolitic wrote, that Professional Association of Ecologists of Ukraine (PAEU) criticized the Ministry of Natural Resources for not considering 7 proposals business to the new draft law "On Environmental Impact Assessment".
As EcoPolitic reported earlier, in Ukraine, of the numerous initiatives of the authorities to deregulate doing business in the field of environmental protection, adopted during martial law, actually only two work – the ability to continue or obtain permits based on the filing of a declaration and a moratorium on scheduled inspections.
