A hybrid HSE governance system incorporating goal based/performance criteria supplemented by specific prescriptive elements for selected areas is adopted for the management of HSE issues in the offshore oil and gas sector in Lebanon. Such a governance system is based on the principle of risk management which means it is based on the identification, assessments and mitigation of specific risks associated with a specific installation and activities. Operators will have to show that they are in control of their operations by regularly identifying, assessing, mitigating and monitoring all HSE risks and that the general risk level is as low as reasonably practical.

The concept of risk management gives the operator flexibility in applying their preferred solutions and ensures focus is prioritized on those risks that are most significant. It also promises high level of preparedness as well as early warning systems which allow effective response and management.
Accordingly, the main advantages of such a system are:

• Flexibility as well as the ability to incorporate changes of insight rather quickly ensuring best practice operations;
• Focus on priority risks associated with a specific installation;
• Developing a goal-based system is a relatively simple process as focus is on output and less on content;
• It promotes self-regulation on behalf of the companies and minimizes the authorities’ own risk and liability as it’s up to the operator to ensure safe operations.

The system consists of:

• HSE management requirements and operational criteria which includes the applicable concepts (risk management, barrier management, asset integrity, etc.) and acceptance criteria in the field of HSE governance that operators will have to comply with in addition to the form of approvals to be used (AoCs, consents, permits, etc.);
• Compliance assurance (inspection, auditing, monitoring, verification bodies);
• Social management which involves stakeholder and communities’ engagement, as well as social impact assessments;
• Emergency preparedness and response and crisis management; and
• Security (security risk assessment, security plan, etc.).

Strategic Environmental Assessment 2012
In preparation for the first licensing round, initially planned for 2013, and in compliance with the requirements of Law 132/2010 (Offshore Petroleum Resources Law), the Government of Lebanon carried out a Strategic Environmental Assessment (SEA) for the Offshore Petroleum Sector in Lebanon in 2012. The SEA was undertaken by the International Consultant RPS Energy.

The SEA report evaluated the likely environmental and social effects of introducing and developing oil and gas activities in Lebanon. The SEA considered different potential development scenarios and assumptions during the assessment. The SEA report extended its focus to the likely results of the licensing program, including exploratory and production drilling, processing and transportation. The report helps in informing ministerial decisions through consideration of the environmental and social implications of the proposed actions.

The SEA identified a number of recommendations to form an action plan for the next phases of work. The individual operators acquiring the petroleum rights will be contractually committed, amongst other requirements, to providing Environmental Impact Assessments (EIA) in sufficient detail to identify their location and project specific impact assessments and full baseline studies before carrying any activities. The Lebanese Petroleum Administration (LPA) has initiated several projects in line with the suggested recommendations including cooperation programs with international agencies such as the Norwegian Oil for Development (OfD) Program and the United Nations Development Program (UNDP).

Vol 1 SEA Report - SEA for Petroleum Activities

Vol 2 National Contingency Plan - SEA for Petroleum Activities

Vol 3 Stakeholder Management - SEA for Petroleum Activities

Vol 4 Gap Analysis - SEA for Petroleum Activities

Vol 5 GIS - SEA for Petroleum Activities

Vol 6 Registers - SEA for Petroleum Activities

Vol 7 Onshore Pipeline Route - SEA for Petroleum Activities

Vol 8 Field Survey Instruction Manual - SEA for Petroleum Activities

Strategic Environmental Assessment 2020

In preparation for the second licensing round, planned for 2020, and in compliance with the requirements of Law 132/2010 (Offshore Petroleum Resources Law) and the Decree 8312/2020, the Government of Lebanon initiated an update to the 2012 Strategic Environmental Assessment (SEA) in 2018. The Strategic Environmental Assessment (SEA) for the Exploration and Production Activities Offshore Lebanon was finalized in 2020.

The SEA was conducted under the European Union (EU) financed PROMARE Technical Assistance Project (“Technical assistance to support the Government of Lebanon's preparation of exploiting and producing offshore oil and gas resources“) and prepared by the international GFA Consulting Group and its consortium partners, and led by Earth Link and Advanced Resources Development (ELARD).
The objectives of this SEA are to:

•    Inform the exploration activities in the awarded blocks (4 & 9) and subsequent exploration activities arising from future licensing rounds taking into consideration environmental criteria;
•    Inform the next licensing rounds with respect to blocks to be opened taking in consideration environmental criteria;
•    Inform the Development and Production Plans (PDP) taking into consideration environmental criteria;
•    Ensure consistency of E&P activities with other national, regional, sectorial plan/strategies /policies and international commitments;
•    Engage stakeholders including interested public in a participatory approach and build trust;
•    Advise on the need for transboundary notification and consultation;
•    Advise on filling existing gaps in environmental and social requirements;
•    Provide environmental management and monitoring frameworks for the sector; and
•    Streamline the EIA process for E&P activities that will be subject to an EIA study.

The SEA strategically assesses the social, environmental and economic impacts, both positive and negative, potentially related to the offshore oil and gas activities, and more importantly, provides a comprehensive management framework for the mitigation of these impacts and monitoring performance against a holistic set of indicators based on the SDGs. Recommendations of this study provide further guidance for the development of the oil and gas sector, mainly from an environmental point of view addressing data collection, block opening, mainstreaming of impact assessments, development options and environmental management.

The SEA clarifies the environmental and social context and aims to reduce risks and liabilities and enhance competition and visibility for International Oil Companies (IOCs). On the other hand, it defines responsibilities on the International Oil Companies as well as on the various relevant government entities to ensure an integrative approach.

1- Cover page

2- Non Technical Summary - English

3- Non Technical Summary - Arabic

4- SEA E&P Lebanon Volume 1  SEA Report

• 4a- SEA E&P Volume 1 Appendices A, B, C & D
• 4b- SEA E&P Volume 1 Appendices E & F

5 - SEA E&P Lebanon Volume  2  Baseline Conditions

6 - SEA E&P Lebanon Volume  3 Legal

7 - SEA E&P Lebanon Volume  4 Stakeholder Engagement

8- MOE Approval Letter

Environmental Impact Assessment is a process adopted to evaluate the likely environmental impacts of projects and developments taking into account inter-related socio-economic, cultural and human-health impacts. The resulting Environmental Impact Assessment (EIA) studies are used as a decision-making tool that enables the early prediction and management of both beneficial and adverse environmental impacts associated with specific projects for both the regulator and the project owner.

The aim of these studies is to adapt planned projects to the local context, optimize their environmental and socio-economic benefits, reduce adverse impacts, cost and time of project design and implementation, and ensure compliance to the hosting country associated laws and regulations.

Legal Basis for the EIA process
The requirements of conducting EIA studies for petroleum activities are mandated in different environmental and petroleum related legislation.

The Offshore Petroleum Regulation Law (Law 132/2010), the Petroleum Activity Regulation (Decree 10289/2013) and the Model Exploration and Production Agreement (Decree 43/2017) specify the applications required during the life cycle of the petroleum activities including associated requirements on general environmental impacts assessments (Refer to Figure 1).  

As required by the Decree 10289/2013 Article 92, a drilling permit must be granted before commencement of any individual well or well path deeper than fifty (50) meters. Thus, the proponent is required to submit the Minister of Energy and Water, through the Lebanese Petroleum Administration, an application for a drilling permit no later than eight (8) weeks prior to the planned commencement of drilling. The Minister decides whether a drilling permit is granted to the applicant based on the review and technical recommendation of the Lebanese Petroleum Administration.

The Environmental Protection Law (Law 444/2002) introduced the EIA concept into the Lebanese legal framework and defined the scope of its implementation. The EIA Decree (Decree 8633/2012) elaborated further on the EIA process and associated requirements and defined projects necessitating the performance of an environmental studies.

Offshore Operators are required under legislation to prepare their own location specific Emergency Response Plan (ERP) that are fully integrated and coordinated with national plans and response capabilities. Nevertheless, a level of readiness and preparedness for the prevention of, and response to, potential emergencies offshore preparedness is required at the LPA and government level.

The Lebanese Government is developing a ‘National Emergency Response Framework’ (NERF) for the oil and gas Sector. The NERF governs the preparedness and response to emergencies at the national level for offshore exploration and production activities, in particular, offshore drilling operations in the short term and production activities in the longer term. The LPA is the main coordinator to follow-up and monitor the Operators’ readiness, emergency preparedness, response and management as well as highlight the role of the Joint Maritime Operations Chamber (JMOC) as the main coordination unit for accidents/incidents of maritime nature.

The Framework provides clarity in command and control, resource coordination and communications, and facilitates co-operation and integration of responding organizations, recognizing that the Government role is limited to monitoring, investigation, follow up and assurance of compliance.

National Oil Spill Contingency

The Lebanese Government has developed a ‘National Oil Spill Contingency Plan’ (NOSCP).
The aim of the National Oil Spill Contingency Plan in the Lebanese Waters (NOSCP) is to protect human life, natural resources, as well as the economy and preserve the coastal and marine environment from any adverse effects of an oil spill. This plan ensures the continuous commitment of the Lebanese Government to its national and international obligations.
The objectives of this NOSCP are to:

• Ensure preparedness and readiness of the involved entities,
• Establish a mechanism for mutual understanding among governmental and non-governmental entities, private and public sector organizations, and international agencies to co-ordinate and integrate their resources to respond effectively,
• Ensure the timely and effective response to oil spills and prevent further pollution,
• Identify the national high-risk areas and priority coastal areas for protection and clean-up,
• Establish processes for assistance and cooperation with other countries and international agencies.

The NOSCP was prepared under the framework of the UNDP/MOEW funded SODEL project by the international consultant Witt O’Brien in partnership with the national consultant SSTEPS.

NOSCP Vol A - Strategy and Process Feb 2017
NOSCP Vol A1 العملية والاستراتيجيات - Feb 2017
NOSCP Vol B - Risk Assessment Feb 2017
NOSCP Vol C  - Roles and Responsibilities  Feb 2017
NOSCP Vol C1 - الادوار والمسؤوليات Feb 2017
NOSCP Vol D - Supporting Documents Feb 2017

Click here to download the ESI maps.

• A draft decree is in preparation to enforce the NOSCP and put it in action.