Recently, the Ministry of Ecology and Environment issued the “Notice on Further Strengthening the Management of Environmental Impact Assessment of the Petroleum and Natural Gas Industry”
(EIA Letter  No. 910, hereinafter referred to as “Notice”). Relevant persons in charge of the Department of Environmental Impact Assessment and Emissions Management of the Ministry of Ecology and Environment answered questions from reporters regarding the background, compilation ideas, and environmental management requirements of the Notice.
Q: What is the background of the announcement?
Answer: Oil and natural gas are important energy sources in China. The Party Central Committee and the State Council attach great importance to this and have made a series of major decisions and arrangements on deepening the reform of the oil and gas industry system and accelerating the construction of the natural gas production supply, storage, and sales system. Environmental impact assessment is the prerequisite for project construction and is one of the key factors related to the landing of major oil and gas development projects. In recent years, local governments have certain differences in the implementation of the environmental impact assessment policies of the oil and gas development industry. There have been inconsistencies with the new characteristics of the industry, the new stage of development, and the new requirements for the reform of the “emission management services” of the environmental impact assessment. In this context, our Ministry organized a large number of investigations on the status of industry environmental assessment management and industry development needs, communicated with experts, enterprises, industry associations, etc., sorted out outstanding issues in the current industry, and researched and formulated the Notice. It is of great significance to further strengthen and standardize the environmental impact assessment management of the oil and gas industry, accelerate the implementation of oil and gas development projects, and promote the green development of the industry.
Q: What is the idea for the preparation of the Notice?
In the preparation of the "Notice", the following ideas were mainly followed: First, the overall evaluation was emphasized. Combined with the characteristics of rolling and regional resource development, strengthen the overall evaluation of oil and gas production blocks, weaken the evaluation of single-well engineering, deepen the analysis and evaluation of the impact on the regional ecological environment, propose more practical ecological environmental protection measures, and improve the effectiveness of environmental impact assessment. At the same time, the use of block EIA instead of single-well EIA reduces the number of approvals for construction project EIA documents and improves the efficiency of EIA. The second is to emphasize the management of the whole process, industry and field. Covering the entire process of planning-exploration-construction-operation-decommissioning, focusing on the environmental impact characteristics of oil and gas extraction, highlighting key technological processes and key environmental factors. In terms of industry-wide management, the "Notice" includes onshore and offshore oil and gas exploration and development projects, and has achieved "land-sea coordination." In terms of management in all areas, in addition to oil and gas development projects, management requirements for environmental impact assessments in long-distance pipelines, oil and gas storage projects and other related areas are also put forward. The third is to strengthen supervision after the event. Effective connection has been achieved in the aspects of environmental impact assessment-environmental supervision during construction-post-evaluation of environmental impacts, etc. It is proposed to give full play to the company's own management functions, the company's active reporting, and include the "double random and one open" law enforcement supervision of the competent authorities to strengthen the corporate responsibility and ecology Regulatory responsibilities of the environmental sector.
Q: What are the requirements of the Notice for planning environmental impact assessment?
The "Notice" further clarified the scope, responsible subjects, form and content of the planning environmental impact assessment, and the linkage relationship between the planning environmental impact assessment and the project environmental impact assessment. In the planning environmental impact assessment, the requirements of “three lines and one order” (red line for ecological protection, bottom line for environmental quality, online use of resources, and checklist for ecological environment access) were introduced. The "Notice" further strengthened the guidance for government agencies to prepare special planning environmental impact assessments. At the same time, considering that PetroChina, Sinopec, CNOOC and other companies or their subordinate companies are also preparing related oil and gas plans, the "Notice" encourages enterprises to carry out environmental impact assessments while preparing the plans. In the future, our ministry will adopt pilots and other methods to promote the planning and environmental assessment of enterprises as needed.
Q: The "Notice" proposes "Block EIA", what is the relationship with the existing EIA system? How is the block determined?
The essence of "Block EIA" is to carry out the EIA based on the development block. It is not independent of the existing EIA management system and still belongs to the EIA of construction projects. The concept of the block is proposed for the management of oil and gas exploration and mining rights and the characteristics of "rolling development". The construction content of the block project includes the new wells, infill wells, adjustment wells, stations, equipment, pipelines and cables planned to be built in the block. And its replacement projects, disposal projects, supporting projects, etc. At the same time, for those who have not yet determined the scale of capacity construction, exploration wells or exploration projects will still carry out environmental assessment in accordance with the established requirements. After the capacity construction scale is determined, in principle, the single-well EIA cannot be continued in the name of exploration to avoid the repeated EIA of the single well.
In view of the many and different blocks in oil and gas development, the Circular does not make uniform provisions on block size and definition principles. After the implementation of the policy, enterprises can independently determine the scope of the EIA and the construction content to be included according to production or management needs and according to the distribution of oil (gas) reservoirs. As for the attributes of the block, it can be judged whether it is a new block or an old block according to the actual situation. The old block generally refers to the block that has previously carried out environmental assessment, rolling development, and encryption and well drilling to maintain production. For the definition of blocks, our department will continue to track the implementation and issue relevant regulations as needed.
Question: Aiming at issues such as reinjection and oil-based mud treatment and disposal during oil and gas development, what breakthroughs have been made in this document?
As unconventional oil and gas enter the stage of commercial development, the problems of fracturing fluid and oil-based mud treatment and disposal have become difficult problems in the oil and gas development industry. Solving these problems is also one of the original intentions of this document. Aiming at the problem of reinjection, the management principles of disposing difficult-to-use oil and gas extraction wastewater by reinjection have been clarified, and the water quality and target layer of the reinjection have been specified. The environmental feasibility of the reinjection must be demonstrated, and practical groundwater should be adopted. Pollution prevention and monitoring measures. In addition, it is also stipulated that no wastewater that is not related to oil and gas extraction may be reinjected, nor shall it cause groundwater pollution. Aiming at the management of a large number of hazardous wastes such as waste oil-based mud and oil-containing drilling debris generated by oil and gas extraction, enterprises are encouraged to build their own centralized treatment and comprehensive utilization facilities for oil-containing sludge, and improve the comprehensiveness of waste oil-based mud and oil-containing drilling debris and their treatment products. Utilization.
Question: What new regulations have been proposed for the development of offshore oil and gas when the document was issued?
The overall consideration of the development of terrestrial and offshore oil and gas is a highlight of the formulation of this document, and it also complies with the new requirements of institutional reform. The policies stipulated in the document also apply to the development of offshore oil and gas, and related regulations for the development of offshore oil and gas are proposed. For example, there are a large number of adjustment well projects in offshore oil and gas development, and the ecological environment impacts of some adjustment well projects are limited, but they occupy a lot of administrative approval resources. In order to implement the requirements for the reform of “emission management services” of the environmental impact assessment, the “Notice” put forward innovative requirements for environmental impact assessment approvals that were obtained before the “Notice” was issued, were not in the sensitive area of marine ecological environment, and were not included in the environmental impact assessment of the oil and gas production block capacity construction projects. For offshore oil and gas development engineering adjustment well projects that do not exceed the total amount of emissions approved by the original EIA, innovative implementation of environmental impact registration form record management was implemented. At the same time, it was also clarified that the oil spill response plan for offshore oil and gas exploration and development should be reported to the relevant marine ecological environment supervision and administration bureau for the record. Major changes to offshore oil and gas development, post-evaluation, etc. are separately stipulated.
Question: How does this document strengthen the post-event management of the oil and gas development industry?
While implementing the "Block EIA" reform measures to reduce the number of EIA approvals, the document provides for strengthening supervision during and after the event. First, the "Notice" stipulates major changes in terrestrial oil and gas development projects to facilitate supervision. The second is to strengthen the main responsibility of enterprises, and put forward requirements such as strengthening internal management of enterprises and submitting performance reports on a regular basis to provide support for the effective supervision of the competent ecological environment department. The third is to clarify the requirements of the competent ecological environment department to carry out "double random, one open" supervision and strengthen the technical review of relevant environmental assessment documents. Fourth, in view of the cumulative and long-term environmental impacts of oil and gas development, regulations for its acceptance and post-evaluation are made, and relevant ecological environmental protection measures are continuously monitored and optimized. Fifth, enterprises and ecological environment management departments have strengthened information disclosure. Enterprises have proactively disclosed project environmental information. Eco-environmental authorities at all levels have done a good job of information disclosure related to environmental review and approval, supervision and law enforcement, so as to facilitate timely and effective public participation and supervision.
Q: How effective is this reform? Have you done any calculations?
Prior to the release of the document, we organized a preliminary measurement of the effectiveness of the document after its implementation. In general, it played a significant role in reducing the workload of enterprises in the early stage and strengthening ecological environmental protection. Taking the number of approvals as an example, about 2,000 construction project environmental impact assessment documents are submitted to the national onshore oil and gas exploration industry for approval each year. According to preliminary calculations, after the implementation of the documents, the number of approvals for environmental impact assessment documents is expected to be reduced by more than 50%, which will greatly improve the efficiency of environmental impact assessment for oil and gas exploration and development, and reduce the pressure of approval by grass-roots ecological and environmental protection departments. At the same time, the “Block EIA” strengthened the requirements for the depth of groundwater surveys and the depth of impact prediction compared to the single-well EIA, and more comprehensive consideration of the overall layout of ecological environmental protection measures was also beneficial to ecological environmental protection.