REPORT AUGUST

678 2024

Guideline for comparative

assessment in decommissioning
Acknowledgements
This Report was prepared by Catalyze Ltd, under the supervision of the Comparative
Assessment Expert Group of the Decommissioning Committee.

Front cover photography used with permission courtesy of

© shaunl/iStockphoto and © Stock1987/Shutterstock

About
This document is a guideline on how to conduct a successful comparative assessment (CA).

A comparative assessment evaluates different decommissioning options in a structured

way that provides the asset owner or operator with the information needed to make a robust
decommissioning recommendation and plan for the regulator to approve. The CA helps to
ensure that all obligations have been met to satisfy the regulatory authorities. It also provides
an asset owner with confidence that all factors and considerations have been examined in the
decommissioning plan.

This guideline was developed in consultation with industry experts experienced in CA. It sets
out principles, methods, and techniques for conducting successful CAs. It is designed to
provide a useful guide for CAs of any scale and in any location. This guideline will enable CAs
of consistently high standard in all parts of the world.

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IOGP welcomes feedback on our reports: publications@iogp.org

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liability is hereby excluded. Consequently, such use is at the recipient’s own risk on the basis that any use by the recipient constitutes agreement to the terms
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Please note that this publication is provided for informational purposes and adoption of any of its recommendations is at the discretion of the user. Except
as explicitly stated otherwise, this publication must not be considered as a substitute for government policies or decisions or reference to the relevant
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 REPORT AUGUST
678 2024

Guideline for comparative

assessment in decommissioning

Revision history

VERSION DATE AMENDMENTS

1.0 August 2024 First release

Guideline for comparative assessment in decommissioning

Contents

Introduction 6

1. What makes a good quality decommissioning decision? 7

1.1 Context of decision-making in decommissioning projects 7
1.2 Good quality decommissioning decisions 8
1.2.1 Objectivity in decision-making 8
1.2.2 Structure for decision-making 9
1.2.3 Uncertainty in decision-making 9
1.2.4 Scalability 10
1.3 The IOGP principles for comparative assessment 10

2. What is a comparative assessment? 11

2.1 Multi-Criteria Decision Analysis 11
2.2 The CA process for decommissioning decisions 12
2.3 CA around the world 13
2.4 Variants and alternatives to CA 14

3. How is a comparative assessment conducted? 15

3.1 Initiating a CA 15
3.1.1 Purpose 15
3.1.2 Context 15
3.1.3 Governance structure 15
3.2 Stage 1: framing and scoping 16
3.2.1 Purpose 16
3.2.2 Context 16
3.2.3 Understand the decision context 16
3.2.4 The comparative assessment plan 18
3.2.5 Output of the framing and scoping stage 19
3.3 Stage 2: options development and screening 19
3.3.1 Purpose 19
3.3.2 Context 20
3.3.3 Options development 20
3.3.4 Screening and options refinement 20
3.3.5 A generic criteria set 21
3.3.6 Using the criteria for screening 22
3.3.7 Outputs of the options development and screening stage 26

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Guideline for comparative assessment in decommissioning

3.4 Stage 3: Preparation 26

3.4.1 Studies 26
3.4.2 Criteria development 27
3.4.3 Further preparation of options 29
3.4.4 Output of preparation stage 29
3.5 Stage 4: assessment 30
3.5.1 Scoring the options 30
3.5.2 Weighting 33
3.5.3 Option analysis 37
3.5.4 Verification and Validation of the CA 38
3.5.5 Outputs of the assessment stage 39
3.6 Stage 5: recommendation and consultation 39
3.6.1 Recommendation 39
3.6.2 Formal consultation 41
3.7 Stage 6: submission 41

4. Concluding remarks 42

Appendix A: The IOGP comparative assessment principles 44

Appendix B: The Framing Document (Template) 45

Appendix C: Suggested documentation 47

Glossary 49

References 51

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Guideline for comparative assessment in decommissioning

Introduction

This document provides a practical guideline for comparing options and making recommendations
about the decommissioning of oil and gas production assets. The focus is on consistent and
appropriate application of Comparative Assessment (CA), a method recognized both within
and beyond the oil and gas industry as a good practice approach to the application of reasoned
judgement that balances competing factors based on robust evidence.

An improved understanding and consistent application of CA provides confidence to regulators,

stakeholders, and the wider public that, given all the evidence available, the recommended option is
the one that best balances all the relevant factors.

Not every decommissioning situation requires a CA. This document assumes that a CA is required;
it does not set out to define the conditions in which a CA is required.

This guideline supports the planning and execution of a CA. It is not a manual or template. It provides
information to describe what needs to be done to build a credible CA and how to do it, but this is not
a comprehensive step-by-step guide to cover every conceivable decommissioning situation.

A CA should be as simple as possible. The guideline describes the steps of a complex CA, but
it indicates how those steps may be simplified or omitted so that the CA arrives at a robust
recommendation in the simplest and most efficient way.

Who is this guideline for?

This guideline is intended to be globally applicable. It covers regions that already have established
assessment methodologies for decommissioning decision-making, as well as those that have none.

There are four main intended audiences:

• asset owner personnel responsible for decommissioning planning
• regulators and other officials responsible for approving decommissioning plans and
implementing related policies
• professionals providing expert advice into the CA
• interested members of the public or interested groups who are invited to, or wish to, engage in
the CA

This guideline consists of the following sections:

• Section 1 – The main attributes of a good quality decommissioning recommendation and
why comparative assessment provides a reliable process to develop a good decommissioning
recommendation
• Section 2 – An overview of the comparative assessment process, the methods behind it, and its
compatibility with existing guidance and processes
• Section 3 – Practical guidance for planning and executing a comparative assessment

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Guideline for comparative assessment in decommissioning

1. What makes a good quality

decommissioning decision?
This Section introduces the context for decision-making and the key principles behind
making a good quality decommissioning recommendation. This Section:
• describes the context of a decommissioning decision
• explains the four most important features that contribute to good quality decision-
making, linked to the IOGP principles for comparative assessment (these principles
can be found in Appendix A)
• concludes that there is a need for a systematic process that, if followed properly,
will result in a recommendation which is accepted as evidence-based, credible, and
pragmatic

1.1 Context of decision-making in decommissioning projects

When an oil or gas asset (e.g., an installation and its associated infrastructure) approaches
the end of its operating phase,there are decisions to be made on the appropriate end-state
for each component (e.g., steel jacket footings, piles, pipelines, and cables). The decision-
making authority belongs to the regulator but it is the responsibility of the asset owner
or operator to submit a recommendation to the regulator for the end-state of an asset. In
many cases, the end-state for an asset is mandated by local regulations, and this does not
require any assessment of alternative options. In some cases, there may be other end-
states available that requires the owner or operator to explore alternative options including
partial removal or decommissioning in place.

There may also be choices for how to reach the end-state, such as alternative engineering
techniques, reuse/recycling or other disposal options, and consideration of waste streams.
Decommissioning projects are subject to international, regional, national and local
regulations – all of which may restrict the end-state options available for specific types of
infrastructure.

Regional regulations1 and precedent vary: the baseline case in most jurisdictions is to
remove offshore infrastructure entirely, based on the 1958 United Nations Convention on
the Law of the Sea (UNCLOS), Convention on the Continental Shelf2 and the 1996 London
Convention and Protocol. When considering options other than full removal, the London
Protocol states: “An analysis of each disposal option should be considered in the light of
a comparative assessment of the following concerns: human health risks, environmental
costs, hazards, (including accidents), economics and exclusion of future uses”.

1
IOGP Report 584 - Overview of International Offshore Decommissioning Regulations provides more in-depth guidance on national, regional
and international regulations regarding the decommissioning of offshore oilfields.
2
UNCLOS III Article 60, no 3

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Guideline for comparative assessment in decommissioning

The evaluation of decommissioning end-states will need to consider factors such as

health and safety, technical feasibility, and the potential environmental or socioeconomic
impact. Any decommissioning option represents a choice of how to balance the positive
and negative impacts and risks across these factors. This requires the application of
reasoned judgement supported by an evidence comprising quantitative and qualitative data,
mathematical modelling, expert judgement, and stakeholder perspectives. More complex
cases will generally require more effort to develop sufficiently robust evidence.

It is the responsibility of the owner or operator of the asset to submit a decommissioning

plan in accordance with the requirements of the regulator (or regulators) for approval. The
ultimate decision belongs to the national or other relevant authority.

1.2 Good quality decommissioning decisions

There are four features to emphasize to ensure that a decommissioning decision is “good
quality”. They are:
• objectivity in decision making
• structure in decision making
• uncertainty in decision making
• scalability

These four themes are expanded on through the rest of Section 1.

1.2.1 Objectivity in decision-making

Decision-making is a human activity to be made as objectively as possible, using reasoned
judgement after having considered available evidence and consulted sufficiently with
stakeholders and experts. Those involved in the decision-making process should be
supported with robust evidence the justification of any recommendation should be properly
scrutinized.

To be as objective as possible, a good decision-making process should:

• involve the right people, including those impacted by the decision, ensuring all
relevant perspectives are sufficiently represented throughout the process and given
fair hearing
• be informed by good quality quantitative and qualitative evidence, interpreted and
assured by experts
• provide clarity on any misalignment of purpose and establish trust between
stakeholders even if they hold fundamental disagreements

The CA process documented in these guidelines ensures that high quality qualitative and
quantitative evidence is accessible to stakeholders so that they are able to contribute in the
most effective way. The process guides decision makers to be ambitious and challenges
them to be as objective as possible.

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Guideline for comparative assessment in decommissioning

1.2.2 Structure for decision-making

A clear structure for the decision-making process creates transparency and aids
understanding. Navigating through the options and the evidence to evaluate options can
sometimes become complex and technical. By structuring the decommissioning decision-
making process in an accessible way, it becomes possible to communicate complex
technicalities with non-expert stakeholders so that they can be appropriately engaged with
the decision-making process.

Where the decision context has high complexity, the interaction of the different aspects can
make it harder to manage the process in a way that everyone finds clear. It is advantageous
to segment the entire decision, including the evidence base, into manageable topics
for analysis and debate. These segments can then be brought together in a way that
deliberatively balances the positive and negative impacts and risks.

The CA process documented in these guidelines has been designed to provide a structure
for the decision so that people can engage with accessible evidence and reach a
considered, robust and balanced decommissioning decision.

1.2.3 Uncertainty in decision-making

The decision-making process should recognize and accommodate uncertainty directly.
The evidence base should be properly researched but it is never possible to fully eliminate
uncertainty. Those involved in the process must acknowledge this, be clear about the
degree of uncertainty present, and be clear on how to manage that uncertainty

Within a decommissioning project, sources of uncertainty may include:

• margins of error, particularly around the long-term safety, environmental, and
socioeconomic effects of certain options.
• project delivery estimates, including time, cost, and resource.
• the capability and effectiveness (feasibility) of novel best available technologies.
• information uncertainty, such as data gaps or variations in data feeding assessments
and estimates.
• level of stakeholder experience, expertise, and representation.

The CA process documented in these guidelines has been designed with an iterative
approach to information gathering to identify and minimize uncertainty to tolerable levels
(within the context of risk and cost of further reducing uncertainty). It includes scenario
analysis to factor in areas of uncertainty so that a robust recommendation and decision can
be made in a way which respects the Precautionary Approach (in line with Article 3 of the
London Convention and Protocol (as amended in 2006)).

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Guideline for comparative assessment in decommissioning

1.2.4 Scalability
The investment of time and resources into the decision-making process should reflect the
magnitude, complexity, and level of risk of the decision.

Where a decision is straightforward, an elaborate decision-making process is not

necessary, though it may be necessary to present a rationale with underpinning evidence
base. However, in a complex, highly uncertain context, the rationale and evidence base
for a decommissioning decision is likely to require a greater investment of time, money,
and input from subject matter experts and those familiar with conducting comparative
assessments. It is important to ensure that the investment of time and resource into
a decommissioning decision is proportionate to the decommissioning context under
consideration. The CA process documented in these guidelines is scalable. It begins with an
initial estimate of the complexity to be considered and how that translates into a resource
requirement and a CA plan.

1.3 The IOGP principles for comparative assessment

IOGP has established the following seven principles for a robust CA:
• CAs are objective in option selection with option ranking driven by cost-risk benefits
trade-offs.
• CAs are adaptable and scalable.
• We maximize transparency to increase stakeholders’ trust in the CA process.
• We are aligned with international and national regulatory frameworks, principles, and
guidance.
• In the CA, process impact information that is relevant to the decommissioning project
and data that is credible in the quality of its collection and source.
• Technology feasibility, availability and risk of failure are always considered in CA.
• CA facilitators are competent and qualified.

These principles reinforce what is required for a CA to be a good quality process for
making recommendations and decisions. Appendix A provides extended descriptions of the
principles.3

3
See IOGP Report 2022dws - IOGP Decommissioning Workshop on comparative assessment processes

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Guideline for comparative assessment in decommissioning

2. What is a comparative assessment?

This Section describes the IOGP guidance for CA.

• The CA in this guideline is based on a version of Multi-Criteria Decision Analysis
(MCDA) specifically tailored to the context of decommissioning oil and gas assets.
MCDA is a method that is widely used in other industries.
• There are six stages to this CA process. The approach is scalable to the nature of any
specific decommissioning decision. Some stages can be shortened, some may only be
necessary in more complex CAs.
• CA is a process that is already in use in various jurisdictions. The six-step process
described in this guideline is broad enough to accommodate alternative versions of
CA, though some may vary in the detail of the technical approach.

2.1 Multi-Criteria Decision Analysis

The CA process described in these guidelines adopts MCDA as the core process.
MCDA is a method for evaluating options that is well suited to supporting good quality
decommissioning decisions as introduced in section 1. MCDA4 is used globally across
industries to aid decision-making on complex problems which typically have:
• a diverse set of options with vastly disparate scopes and no clear optimal choice
• a range of diverse stakeholders
• competing priorities that need to be balanced
• high uncertainty

The MCDA method compares discrete options using a set of criteria to ascertain which
option is preferred. It documents why it is preferred and how robust the preference is (that
is, how much would the context need to change for the preference to change). The benefit
of using a MCDA method is that it:
• leads decision makers to genuinely explore and understand the problem
• provides a way to structure and present evidence
• provides a clear and common framework, language, and environment to enable a
structured debate
• includes different stakeholder views
• addresses competing objectives
• breaks a complex decision down into more manageable segments
• can account for both qualitative and quantitative inputs
• probes the strength of decision components where there is uncertainty or
disagreement, accounting for and focussing subjectivity where it is required
• may generate alternative options
• scales up or down depending on the complexity of the problem

4
Keeney, R.L and Raiffa, H, (1976). Decisions with Multiple Objectives: Preferences and Value Trade-offs. New York: Wiley. Reprinted
Cambridge University Press, 1993.

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Guideline for comparative assessment in decommissioning

Recognizing that decisions around decommissioning can be complex, MCDA offers

a methodology that ensures decisions are based on evidence and wide stakeholder
engagement, where all relevant factors are considered, to arrive at a robust and objectively
reasonable decision with the widest possible agreement.

2.2 The CA process for decommissioning decisions

There are six stages to the CA process. These are derived from the MCDA process tailored
to decommissioning of oil and gas assets. Figure 1 outlines each stage of the process.
The stages are sequential, but it is possible to revisit previous stages during the CA. Stage
2 (options development and screening) is likely to be iterative: the screening refines the
options until a good set of options is developed – and this can be informed by future stages.
Guidance on how to conduct each stage is provided in Section 3.

STAGE PURPOSE OUTPUT

Framing and Establish the decision • Framing document

1 scoping context • CA plan

• Short list of options

Ongoing stakeholder engagement

Options development Generate a good set of

2 and screening options for assessment
• Rejected options with reasons
for rejection

Prepare the evidence • Refined criteria set

3 Preparation Refine the options and the • Refined options set
criteria for decision making • Evidence pack Simplified CA in
cases of low
complexity
Score, weight and
4 Assessment • CA findings report
analyze options

• CA recommendations report
Recommendation Apply reasoned judgement
5 and consultation and seek public response
• Formal consultation material
• Response to formal consultation

• Decision summary proforma

Take the preferred option
6 Submission
through to final endorsement
• Documentation for regulatory
approval

Figure 1 – The six-stage decision process

The design of this CA process means that, in some cases, a preferred option may emerge at
stage 2. In such cases, the CA process can be simplified and scaled down without the need
for stages 3 and 4.

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Guideline for comparative assessment in decommissioning

2.3 CA around the world

Comparative risk assessments are referenced in the International Maritime Organization
(IMO) London Convention/London Protocol (Annex 8, Revised specific guidelines for
assessment of platforms or other man-made structures at sea).

Comparative evaluation assessments for the disposal of offshore installations are

referenced within OSPAR 98/3 (Oslo-Paris Convention for the Protection of the Marine
Environment of the North-East Atlantic, Decision 98/3 on the Disposal of Disused Offshore
Installations).

There are a number of different MCDA-based decommissioning decision-making

techniques that are in use in various regional jurisdictions:
• The Oil & Gas UK “Guidelines for Comparative Assessment in Decommissioning”
(2015) describes three levels of CA that are applied in the North Sea. Additionally, the
UK Government Offshore Petroleum Regulator for Environment and Decommissioning
(UK OPRED) published a Guidance Note titled “Decommissioning of Offshore Oil and
Gas Installations and Pipelines” (2018). This includes an annex with a guide to CA.
• The Australian Petroleum Production & Exploration Association (APPEA) produced
their “Offshore Oil and Gas Decommissioning Decision-making Guidelines” (2016).
• Norsk Olje & Gass have a handbook on “Impact assessment for offshore
decommissioning” (2020).
• The Safety, Health and Environment National Authority (SHENA) of Brunei has
published “Brunei Darussalam Decommissioning and Restoration Guideline for
Onshore and Offshore Facilities” (2018).
• The “Technical Regulation for Decommissioning of Oil and Natural Gas Exploration
and Production Installations in Brazil” is a 2020 regulation that requires the
“comparison of decommissioning options” so that proposals presented for the
decommissioning of maritime installations should be “clear and duly substantiated”5
• “The Environmental Guidelines for Decommissioning of Oil and Gas Facilities in
Malaysia”, published in 2019 by the Malaysian Department of Environment, refers to
an options assessment comparing alternative end-states for assets.

All of these approaches are compatible with the six steps of CA in this guideline.

5
https://www.legisweb.com.br/legislacao/?id=393623

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Guideline for comparative assessment in decommissioning

2.4 Variants and alternatives to CA

CA is a structured decision-making process, considering a range of impacts, including
environmental, safety, technical, societal, cultural, and economic. IOGP recommends
the use of CA, but other structured methods are also used to support decommissioning
decisions. Whilst not attempting to provide a comprehensive list of such approaches,
the following methods are relevant and compatible with the CA approach set out in this
guideline:
• Net environmental benefit analysis (NEBA) is a risk-benefit approach for comparing
the net environmental benefits and risks between alternative options. NEBA typically
builds from a starting point of current status, rather than a presumption of full
removal. There is a NEBA-CA with an emphasis on the environmental benefits and
harms considered over the long and the short term.
• Best Practicable Environmental Option. “The BPEO is a systematic and consultative
decision-making procedure which emphasizes the protection and conservation of the
environment across land, air, and water. The BPEO procedure establishes, for a given
set of objectives, the option that provides the most benefit or least damage to the
environment as a whole, at acceptable cost, in the long term as well as in the short
term.”6
• The Analytic Hierarchy Process (AHP) is a variant of MCDA. The AHP is compatible
with the six-stage process described in Figure 1. However, the details in Section
3 of this guideline are different to the AHP approach, specifically stages 2 and 4 –
screening, scoring, and weighting. The AHP is an acceptable variant of MCDA and can
be used for a CA.
• Decision Quality (DQ) is a structured way of considering problems, researching
the evidence base, and understanding the trade-offs to be made in order to gain a
commitment to action on a preferred outcome. DQ is not a version of MCDA, but many
of the principles of DQ have been influential in developing this guideline.

6
Royal Commission on Environmental Pollution: twelfth report: Best practicable environmental option. HMSO. 1988

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Guideline for comparative assessment in decommissioning

3. How is a comparative assessment

conducted?
Section 3 explains how to design and deliver a CA. It is structured to take the reader
through the key elements of a CA, providing advice on good practice. It draws on the
themes from section 1 and provides examples to illustrate the process.

3.1 Initiating a CA

3.1.1 Purpose
To ensure successful execution of the CA through the establishment of the CA team and
appropriate governance structures.

3.1.2 Context
As an asset approaches the end of life, the asset owner must decide at what point to start
planning the decommissioning process. Part of that planning will include a decision about
whether a CA is required. This guideline assumes that the decision has been made to
conduct a CA.

3.1.3 Governance structure

The scale of the CA will vary from case-to-case, but establishing the CA as a project using
local or business-specific project management approaches is good practice. This will help
ensure the governance and resources to deliver the CA are in place.

Depending on the complexity, the internal team governance may include:

• accountable body within the asset owner organization, responsible for confirming the
recommended decommissioning option that will be put forward for regulatory review.
• steering group within the asset owner organization, to provide direction and guidance
for the CA.
• CA lead and team, who will deliver the CA process. The team includes project
managers and specialists such as facilitators and data analysts.
• subject-matter experts, such as engineers and technical experts, who play a key
role in the CA process, providing deep expertise to understand the decommissioning
options. These stakeholders, as with the rest of the internal team, are often drawn
from across the asset owner organization to ensure the best resources are applied to
the CA.

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Guideline for comparative assessment in decommissioning

3.2 Stage 1: framing and scoping

STAGE PURPOSE OUTPUT

Framing and Establish the decision • Framing document

1 scoping context • CA plan

• Short list of options

Ongoing stakeholder engagement

Options development Generate a good set of

• 2 understand the decision context. Build an understanding of the
• Rejected decision
options context,
with reasons
and screening options for assessment
including the complexity and scope, to inform the design
for of the CA process.
rejection

• develop the CA plan. Design the CA process, tailoring the standard process, and
Prepare the evidence • Refined criteria set
create a plan from that process design.
3 Preparation Refine the options and the • Refined options set
criteria for decision making • Evidence pack Simplified CA
3.2.1 Purpose cases of low
complexity
Score, weight and
4
To design the CA process and develop a plan for delivering •aCA
Assessment CAfindings
that draws
report together the
analyze options
evidence, information, and perspectives required to make a robust decommissioning
recommendation. The CA process and plan should be appropriately scaled to the decision
context. • CA recommendations report
Recommendation Apply reasoned judgement
5 and consultation and seek public response
• Formal consultation material
• Response to formal consultation
3.2.2 Context
• Decision summary proforma
Every Take the preferred option
6 decommissioning
Submission decision has unique features which
through to final endorsement
make the decision
• Documentation more
for regulatory
(or less) complex. The CA approach described in these guidelines provides
approval a scalable
method that can be tailored and adjusted appropriately depending on the complexity of the
scenario. Before designing the CA process, it is important to understand the features of the
decision which affect the complexity because complexity often shapes how elaborate the CA
may need to be. Documenting these features provides a useful common reference point for
people involved in the decision-making process.

3.2.3 Understand the decision context

Before developing a CA plan, the CA team should evaluate the decision context and capture
this evaluation in a framing document. This evaluation is likely to draw on a range of
internal stakeholders, such as engineering and decommissioning experts. In some cases,
it may be informed by initial conversations with external stakeholders, including regulators.
This evaluation is designed to identify and clarify the requirements and implications for the
CA process.

Key features of the decommissioning decision context include:

• scope: Which assets are included in the decommissioning decision
• legal and political context: The regulatory requirements which the decision must
meet, including options, evidence, time frames and stakeholder engagement
• engineering and technical context: The technical challenges and precedents
associated with the decommissioning, including, for example, any track record
• environmental context: Environmental considerations, challenges, or knowledge
gaps

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Guideline for comparative assessment in decommissioning

• socioeconomic and cultural context: Who might be impacted by the decision and
which stakeholder groups may have an interest in the process
• financial and commercial context: Where financial and commercial responsibility for
decommissioning sits, internal precedent, asset history and other decommissioning
projects that might be relevant

Appendix B provides an example question set and document outline that can be used when
exploring the decision context.

The evaluation of the decommissioning context informs what type of CA is required.

For example, if the potential decommissioning options are well understood, there is
engineering precedent, good alignment of stakeholders, and few unknowns and challenges,
a simpler form of CA may be appropriate. A more complex CA process is required where
the simpler process is unable to sufficiently differentiate between the options available.

The scope of a decommissioning project may cover multiple assets, and the
decommissioning of an asset may involve multiple decisions. The same principles of how
to develop and assess options can be applied to all these decisions through a series of
separate but related CAs within the same decommissioning project.

The findings of this decommissioning context evaluation should be captured in a framing

document to provide a record of the scope and common reference point for all stakeholders
in the process. It will help identify requirements of the CA process and inform the
development of the CA plan.

The format and level of detail in the framing document can be determined by the CA
team and should be kept as brief as possible. The content can be updated and enhanced
throughout the process, as more is understood about the decision context. Some elements
of the document could be presented in a format to help internal and external stakeholders
engage with the decommissioning decision for the first time, for example an infographic or
video.

Example A: A decision context of low complexity will have a well understood regulatory
framework, a clear candidate technical solution that presents no novel challenges and that
satisfies all stakeholder groups whilst remaining commercially viable. In a low complexity
situation, the framing document will explain what the technical solution is and why it is
evidently preferable to stakeholders and to regulators without a comprehensive CA.

Example B: Whenever there are stakeholders who may potentially disagree on the
preferred outcome, then the decision context is not low complexity. Any context where
there may be a proposal to seek exemption from a locally mandated base-line case would
likely fall into the category of higher complexity. The framing document will explain where
the complexity arises. This is important in developing the CA plan because the CA should
allocate time and resources matched to the nature of complexity identified.

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Guideline for comparative assessment in decommissioning

3.2.4 The comparative assessment plan

The CA plan is developed by the CA team and describes how and when the CA will be
delivered. The CA team should build on the information in the framing document to design
a process and define a plan tailored to the complexity of the decision context. The CA
plan includes elements covering option development, stakeholders, communications,
information gathering and regulatory approval. It sets out an initial schedule for the CA and
will be refined as the CA is delivered.

Together with the framing document, the CA plan will be key throughout the process and
may include the following elements:
• options generation process that describes how the options will be developed (with
appropriate engineering solutions) in the detail required to enable assessment of a
preferred option. In some cases, the options will be relatively mature before the start
of the CA process but may still require refinement during the process.
• assessment methodology that sets out how the options will be compared during the
CA process (for example using the structured approach described in this guide) and
lays out the different workshops and activities. The assessment methodology will
include the initial criteria that will be considered through the CA and describe how
they may be matured and refined during the process.
• supporting information plan that sets out an estimate of the information required.
It specifies known gaps in existing knowledge and how those gaps will be addressed.
This element of the plan will develop iteratively as the options and decision criteria
are refined. Information that could eventually be required includes:
– Technical feasibility and execution studies
– Environmental impact assessments
– Cultural impact assessments
– Social impact assessments
– Cost and schedule estimates
– Economic studies
• stakeholder engagement plan that identifies all relevant stakeholder groups and
describes how they will be involved in the CA process. Good stakeholder engagement
will improve the quality of the evidence base, create common understanding, and
strengthen the eventual recommendation. The plan should specify how and when
particular stakeholders will be engaged. Typical stakeholders may include:
– Regulators
– People directly affected by the decommissioning decision
– Stakeholder representative groups
– Independent experts involved in the process either through direct contribution
or review. Independents are not expected to work “free of charge” but they
should have a strong reputation with peers and other stakeholders for expertise,
integrity and impartiality.
– Parties with commercial interests

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Guideline for comparative assessment in decommissioning

• communications plan that considers the channels of communication needed to keep

stakeholders, and members of the public, informed. Some jurisdictions may insist
on levels of responsiveness to requests for information from the public. (The framing
document should have this type of requirement already specified.)
• timeline that sets out the timing of the key stages of the CA, including option and
criteria development, and options assessment, and milestones of the CA process,
including regulatory milestones.
• resource requirements based on the timeline and the elements of the CA plan. This
will include an estimate of the expertise required for developing options, gathering
information, and facilitating the option assessment.

3.2.5 Output of the framing and scoping stage

The framing and scoping stage sets the foundations for the CA process, captured in two
outputs:
• framing document which sets out a common understanding of the decision context
• CA plan which encapsulates the process design and describes how and when the CA
will be delivered and who will be involved

3.3 Stage 2: options development and screening

This Section describes how to generate a set of options to take forward to the next stages
of CA:
• options development: identifying, describing and developing options to be considered
• screening and refinement: performing an initial assessment of the relative strengths
and weaknesses of the options to understand which should be taken forward

There are three varieties of screening described to accommodate CAs of varying

complexity. In lessSTAGE PURPOSE
complex CA, the screening process may be sufficientOUTPUT
to produce a robust
justification to recommend a single option. This becomes clear through the screening
process, and itFraming
may beand
possible to move from
Establish stage 2 directly
the decision to stage
• Framing 5 without performing
document
1
the more detailed CA process steps.
scoping context • CA plan

• Short list of options

Ongoing stakeholder engagement

Options development Generate a good set of

2 and screening options for assessment
• Rejected options with reasons
for rejection

Prepare the evidence • Refined criteria set

3 Preparation Refine the options and the • Refined options set
3.3.1 Purpose criteria for decision making • Evidence pack Simplified CA
cases of low
Develop a mature set of feasible and clearly defined options to take forward for detail complexity
Score, weight and
4
assessment. Assessment
For less complex CAs, this stage will identify the
• CArecommended
findings report option with
analyze options
supporting evidence.

• CA recommendations report
Recommendation Apply reasoned judgement
5 and consultation and seek public response
• Formal consultation material
• Response to formal consultation

19 • Decision summary proforma

Take the preferred option
6 Submission
through to final endorsement
• Documentation for regulatory
approval
Guideline for comparative assessment in decommissioning

3.3.2 Context
Given the decision context, this stage develops a suitable set of options to be assessed in
the CA. It builds deeper understanding of the competing priorities (the criteria) which then
shapes the information plan and further option development work. It may be iterative as
options are refined and discounted.

3.3.3 Options development

The nature of options development will vary significantly based on the decision context,
described in Section 3.2.1. Initially, option development should be broad and can start
by developing a long list of potential options to be explored, tested and refined. When
developing this list, the CA team should:
• include full removal: the set of possible options should, where feasible, include at
least one full removal option. This is often a regulatory requirement and provides a
baseline option for CA. In some exceptional cases full removal is not feasible. If this is
the case then the reasons should be clearly documented and communicated.
• consider a broad range of options: all options to consider should be feasible and may
include reuse of all/part of the asset, recycling all/part, disposal on land, disposal at
sea, rig-to-reef, and in-situ decommissioning.
• avoid creating outlier options (if possible): The options should aim to provide good
coverage of the decision space, meaning that options are not outliers. For example,
a full removal option will typically be included even where it is extremely complex to
deliver and may be the least technically feasible option being considered. Including
more technically feasible options which remove as much of the asset as possible,
provide an important comparator.
• consider innovative technology: the set of feasible options should not be accused of
lacking ambition. Principles of Best Available Technology Not Entailing Excessive Cost
(BATNEEC) may be considered.

A company’s technical experts will play a central role in advising on the options and
developing the option set. Structured workshops can be used to review and challenge the
options with input from other technical experts independent of the company’s technical
team to promote innovation and ambition. The CA team may choose to engage stakeholders
at this early stage, although waiting until the option set is better understood will reduce the
risk of stakeholders becoming fatigued by engagement in the process.

In the initial option development phase, the list of feasible options will not necessarily be
complete. Options may be specifically chosen to provide good coverage of the decision
space, ready to be tested and refined in a structured way.

3.3.4 Screening and options refinement

Having developed an initial set of options, the screening process tests and refines each
option, filtering out the less preferred ones in order to reach a suitable set of options for the
assessment stage. This stage is iterative: throughout this stage of the process options may
be rejected or redesigned as they become better understood.

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Guideline for comparative assessment in decommissioning

In conducting an option screening there is a range of techniques which can be used. In this
section of the guide, a generic criteria set may be used to build a structured framework
for the screening process. The screening may be narrative-based, or it may use a simple
scoring system.

For some CAs, this screening will produce a single option that is clearly preferable to all
others. This may be sufficient to provide the final recommendation, which could reduce or
remove the requirement for stages 3 and 4 of the CA process in this guide.

3.3.5 A generic criteria set

In this section a generic CA criteria set is described which provides a framework for
comparing and contrasting options. This framework is used to refine and filter the options
to arrive at a suitable set for a more detailed CA. These criteria cover factors that are
widely recognized as important considerations in oil and gas decommissioning CAs. For
many screening activities this set will provide a sufficiently comprehensive and applicable
framework, however the set may be reviewed given a particular decision context and
adjusted if required.

This criteria set is structured to explicitly consider both long-term and short-term (project)
impacts, which can be the key differentiators in deciding between options. As a guide,
“short-term” typically covers the period of decommissioning operations up to the formal
closure of the decommissioning project and “long-term” covers the period following.

Table 1 – Generic criteria set

Criteria category Description

Short term criteria

Health and Safety The extent to which the option may pose health and safety risks in the short term, both during
decommissioning activities offshore and during disposal activities onshore.
This includes both decommissioning operators, and other users of land and sea.

Environmental The extent to which the option impacts on the marine and non-marine ecology from activities in
the short term.
The extent of greenhouse gas emissions and any other known pollutant impacts.
This could include impacts to sensitive species, short-term changes to hard structure habitat,
exposure to contaminants, as well as the energy and emissions associated with recycling
materials compared to the extraction of new resources.

Socioeconomic The extent to which the option has short-term socioeconomic impacts resulting from
decommissioning activities.
This may include fishing interruption, commercial or naval vessel diversion, and onshore
community impacts due to noise, pollution and traffic. It may also include socioeconomic benefits
to the onshore community through employment opportunities.

Cultural The extent to which the option impacts on cultural heritage in the short term. This may include
impacts on cultural traditions or beliefs, or damage to heritage sites.

Technical Feasibility The short-term technical risk that the option does not achieve the intended end-state on time. For
example, the risk of equipment failure or unavailability, or the potential for schedule overrun.

Commercial The extent to which the option presents commercial risk.

This may include joint venture risk or a risk to commercial survival.

Cost The cost of the option.

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Guideline for comparative assessment in decommissioning

Criteria category Description

Long term criteria

Health and Safety The extent to which the option may pose health and safety risks in the long term.
For example, navigational risks or trawling snagging risks.

Environmental The extent to which the option impacts on the marine ecology over the long term.
This impact may include enduring changes to water quality, or the long-term impact of changes
in a hard-surface ecosystem.

Socioeconomic The extent to which the option causes socioeconomic impacts over the long term.
For example, long-term impacts on commercial fishing, tourism or recreation.

Cultural The extent to which the option causes impacts to cultural heritage over the long term.

Commercial The extent to which the option has long-term commercial obligation, the impact this may have on
commercial survival.

Cost The long-term cost liability.

This may include the cost of monitoring or maintenance of assets left in-situ.

3.3.6 Using the criteria for screening

3.3.6.1 Narrative screening

To begin, the criteria provide a framework for capturing narratives about the strengths
and weaknesses of options. For each option, the impact against the criteria is discussed,
debated, and captured descriptively. The debate should include experts and, at the
discretion of the CA team, it may include stakeholder representatives. The assessment
narrative should reflect whether the impacts are more (or less) preferable when compared
with the other options being considered. This approach may be sufficient to screen options
out if it performs consistently poorly across the criteria set. Any poorly performing option
should be reviewed to see if there is any possibility of strengthening it.

During the narrative screening, thresholds may be applied to filter out options that are not
acceptable. For example, an option may be rejected if it has intolerable levels of risk that
significantly exceed normal levels of worker risk in similarly complex offshore operations.

3.3.6.2 Simple score screening

At this initial screening phase, the CA team may choose to capture assessments of impact
against each criteria using scoring scales. These scales can vary in complexity. Possible
scales described below include a three-point ‘RAG’ screening and a more granular five-
point scale.

The scoring for this initial screening should be based on existing evidence and expert
opinion, as far as possible. Scoring is inevitably subjective to some degree, but any
differences of expert opinion may indicate areas for further research. Where there are gaps
in knowledge these should be recorded to be addressed in the information plan.

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Guideline for comparative assessment in decommissioning

3.3.6.3 Red, Amber, and Green (RAG) scale

A three point-scale is commonly used with Red, Amber, and Green (“RAG”) scoring, where
the most desirable options are scored as green, the least desirable options are scored as
red, and options in between are scored as amber. The resulting RAG assessment matrix
provides a visual guide to indicate which options perform relatively well and relatively poorly
against each criterion.

Table 2 – Example RAG matrix

Option A Option B Option C

Short term criteria

Health and Safety Red Amber Green

Environmental Red Amber Green

Socioeconomic Green Green Red

Cultural Amber Red Green

Technical Feasibility Red Amber Green

Commercial Red Amber Green

Cost Red Amber Green

Long term criteria

Health and Safety Green Green Red

Environmental Green Red Amber

Socioeconomic n/a n/a n/a

Cultural Green Red Red

Commercial Green Amber Red

Cost Green Amber Red

However, there are limitations with the RAG matrix. The three-point scale does not provide
much fidelity between the options. Options that score red can sometimes be mistakenly
rejected, as red may be instinctively equated with “unacceptable” or “bad” rather than just
the “least desirable”. For example, if all the options have already passed the threshold
for acceptable safety risk, it would be a mistake to then reject an option based solely on a
red score for safety. This demonstrates the need to consider the range of differentiation
between most and least desirable – and whether this range is important.

3.3.6.4 Five-point scale

A five-point scale, ranked from highest to lowest desirability, may provide more useful
granularity to differentiate between the options.

As with the RAG assessment, scoring is relative, meaning there will always be at least
one option at the top of the scale (scoring five in this case) and at least one at the bottom
(scoring one). The remaining options will be distributed relative to the highest and lowest
options. It is possible that a criterion may be considered to provide no differentiation as all
the options are indistinguishable. In this situation, the options do not need to be scored.

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Guideline for comparative assessment in decommissioning

3.3.6.5 Differentiators and uncertainty in screening

A further extension to address some of the limitations is to capture the range of
differentiation between the top and bottom of the scale, and level of uncertainty.

When scoring the options against the criteria, an important consideration is whether
the range of difference between the highest score and the lowest score is likely to be
a significant factor in the screening. This is referred to as the level of “differentiation”.
The criteria with a wide difference between highest and lowest scores are called “strong
differentiators”. These strong differentiators can play an important role in the screening
process. This is especially true if any form of ranking of options is used in screening. This
theme is described more fully in section 3.5.1 in the Assessment stage.

A final consideration when assessing options in the screening process is what level of
uncertainty there is in the assessments. At this stage it may be sufficient to capture an
assessment of uncertainty at criteria level. For example, if there is significant uncertainty
or evidence gaps on the long-term environmental impacts for some of the options this
should be noted. Options might be retained and not be filtered out, where there are highly
uncertain assessments. Uncertainty is considered further in Section 3.5.1.

Table 3 – Example output from the CA screening approach

Level of Level of
Option A Option B Option C
differentiation uncertainty

Short term criteria

Health and Safety 1 4 5 Low Low

Environmental 1 3 5 Medium Medium

Socioeconomic 5 5 1 Low Low

Cultural 2 1 5 Low Low

Technical Feasibility 1 4 5 High Medium

Commercial 1 2 5 Medium Medium

Cost 1 3 5 Medium High

Long term criteria

Health and Safety 5 5 1 Low Low

Environmental 5 1 2 High High

Socioeconomic n/a n/a n/a None None

Cultural 5 1 1 Medium Low

Commercial 5 2 1 Low Medium

Cost 5 3 1 Low Medium

This screening approach provides a structured framework for understanding which options
are relatively strong or weak, see Table 4. The discussion and debate that informs the
assessments will give a good indication of the overall strength of the options, and a visual
inspection of the assessments and supporting narrative can be sufficient to screen options
in or out and to identify where options need to be developed further.

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Guideline for comparative assessment in decommissioning

There is a natural temptation to add up the assessment scores to produce an overall score
and option ranking. This is likely to be misleading as it ignores the level of differentiation,
the relative importance of the criteria, and uncertainty in the assessments. It is therefore
not recommended at this stage. If there is a need to create a ranking at the screening then
weighting the scores is a necessary step, and the approach in section 3.5.2 should be followed.

Table 4 – Example CA screening output - with clear preference for option B

Level of Level of
Option A Option B Option C
differentiation uncertainty

Short term criteria

Health and Safety 5 5 1 High Medium

Environmental 3 5 1 High Medium

Socioeconomic 1 5 5 Low Low

Cultural n/a n/a n/a None None

Technical Feasibility 5 5 1 High Medium

Commercial 5 5 1 Low Low

Cost 5 4 1 Medium Medium

Long term criteria

Health and Safety n/a n/a n/a None None

Environmental 1 5 2 High High

Socioeconomic n/a n/a n/a None None

Cultural 3 5 1 Medium Low

Commercial 1 4 5 Low Medium

Cost 1 5 5 Low Medium

3.3.6.6 What type of screening is advisable?

A narrative screening may be sufficient in cases where the experts are confident that their
assessment of options in totality is robust to challenge. A simple scoring screening may be
sufficient if the experts in the CA team are confident that the RAG approach or the five-
point scale provides a fair assessment that is robust to challenge. The use of the level of
differentiation and uncertainty (see table 4) may improve the robustness of selection of
options by, since they help explicitly indicate which factors are driving the justification to
discard or retain any particular option through the screening process.

3.3.6.7 When is screening complete?

The options development and screening phase may be iterative as new options are
developed, reviewed and less satisfactory options are rejected. Screening is complete once
it becomes clear that further research is needed to address areas of uncertainty and a
more detailed assessment is required to distinguish between the remaining options. The
CA team should review the supporting information plan to specify the studies and further
research required to thoroughly evaluate the remaining options. This will pay particular
attention to areas of uncertainty exposed in the screening and to any areas of disagreement
exposed during the debate.

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Guideline for comparative assessment in decommissioning

3.3.6.8 What happens if there is only one option left after screening?
The screening could produce a single option that the CA team and all relevant stakeholders
agree is the most preferred, and they could agree that this preference is unlikely to change
with further research. In this case, it may be appropriate to move from stage 2 straight into
stage 5 of the CA process, without undertaking stages 3 (preparation) and 4 (assessment)
of the CA. The example in Table 4 indicates an overall preference for option B, which may be
considered sufficiently clear to move to stage 5 (recommendation and consultation).

3.3.7 Outputs of the options development and screening stage

The output of the options development and screening stage are:
• a shortlist of options: a set of feasible options that are clearly described, ready to
be assessed. In some cases, it may be that all but one option is screened out. This
remaining option would then become the one to take forward as the recommendation.
There may be no need for stages 3 and 4 of a more detailed CA. The process can move
directly from this screening stage to stage 5.
• a list of rejected options: this should document the options which were considered
but screened out, and the reason for this.
• update to the information plan: the
STAGE screening phase will produce
PURPOSE a specification for
OUTPUT
the studies required to address areas of uncertainty.
Framing and Establish the decision • Framing document
1 scoping context • CA plan
3.4 Stage 3: Preparation
This section describes how the research commissioned through • Short the revised
list of options supporting
Ongoing stakeholder engagement

Options development Generate a good set of

2
information plan is used to
and screening develop the criteria set and
options for assessment further refine
• Rejected the shortlisted
options options.
with reasons
for rejection

Prepare the evidence • Refined criteria set

3 Preparation Refine the options and the • Refined options set
criteria for decision making • Evidence pack Simplified CA
cases of low
complexity
3.4.1 Studies
4 Assessment
Score, weight and
• CA findings report
analyze options

3.4.1.1 Purpose
• CA recommendations report
Recommendation Apply reasoned judgement
Studies
5 should be conducted to gain sufficient understanding of theconsultation
• Formal options tomaterial
allow for an
and consultation and seek public response
evidence-based assessment of the options against the criteria.
• Response to formal consultation

3.4.1.2 Context • Decision summary proforma

Take the preferred option
6 Submission
through to final endorsement
• Documentation for regulatory
The supporting information plan specifies the further research approval
and data collection required
to address evidence and understanding shortfalls identified during the screening. The
results of these studies form the core of the evidence underpinning the CA. Studies should
focus on the finalized options and support the assessment of the options against the criteria.

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Guideline for comparative assessment in decommissioning

3.4.1.3 Studies for decommissioning

The studies should seek to:
• compile required knowledge to address known gaps in the evidence base (such as
impact of options against criteria over time)
• reduce uncertainty
• clarify points of controversy

In commissioning studies, the CA team should specify the nature and quality of evidence
required within the timescales expected for the CA to meet the obligations set out in the
framing document.

The studies must be objective, expert, and robust. Where appropriate, some studies may be
carried out by the asset owner – such as feasibility of the options. The CA team may also
consider the use of independent experts to conduct studies or to review the studies and
their outcomes. Independent expertise is a way of assuring objectivity, filling knowledge
gaps and further improving the reputation of the CA for objectivity.

In undertaking the studies identified in the supporting information plan, the following
guidelines may be useful reference material:
• IOGP 650 - Habitat retention strategies for decommissioned offshore jacket structures
(June 2022)
• IOGP 667 - Guidelines for upstream pre-project decommissioning estimates (Sept 2023)
• IOGP 632 - Offshore oil and gas pipeline decommissioning briefing (November 2021)
(Specifically, Section 3.1)
• Norsk Olje & Gass: Impact assessment for offshore decommissioning (June 2020)
• Ipieca: Offshore impacts to fisheries: practitioner guidance for social baselines (2023)
• IMO London Convention/ London Protocol’s Annex 8 Revised specific guidelines for
assessment of platforms or other man-made structures at sea (2019)

Studies should continue until enough is understood to enable an informed analysis. There
comes a point where more data and information does not add to the quality of the analysis
but simply adds a delay to the analysis. This point is determined pragmatically.

3.4.2 Criteria development

The generic criteria set described in Section 3.3.2 forms a good basis for any CA. However,
during the screening, it may become apparent that there is a need to modify the criteria set,
perhaps by providing greater detail on one or more of the criteria. This is not a unilateral
decision on the part of the asset owner; any modification to the generic criteria set should
be done in a transparent way so that regulators and stakeholders are content with the
modification. The preparation stage of the CA is the opportunity for the CA team to develop
a criteria set that is ideally matched to the decision context. This may involve:
• amending the generic criteria set either by addition or deletion of criteria
• re-structuring the generic criteria set
• refining the generic criteria set by developing sub-criteria to provide necessary detail
specific to the decommissioning decision context

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Guideline for comparative assessment in decommissioning

It is important that the criteria set captures the key trade-offs, and areas of interest and
potential disagreement across stakeholders. Criteria development is an ideal opportunity
for stakeholder input to ensure stakeholder concerns and views are incorporated into the
CA. This also helps support stakeholder ownership of the CA and outcomes.

The CA team should document the justification for amending or re-structuring the generic
criteria set, but refinement is not unusual. For example, the regulator may be interested
in the reason why the generic criteria set was adapted. In developing the criteria, IOGP
recommends that the CA team follows the good practice as described in section 6 of
“Guidelines for Comparative Assessment in Decommissioning Programmes”, Oil & Gas UK
(2015).

Some of the generic criteria might be split into sub-criteria to provide the necessary detail
and assessment within the decision context. For example, the “short-term environmental
impact” criteria may be split into two sub-criteria:
a) Marine life impact: The extent to which the option minimizes the marine impact of
operations spills, discharges to sea, disturbance to seabed and underwater noise.
b) Natural resource consumption: The extent to which the option minimizes energy or
other resource consumption.

Dividing criteria into sub-criteria can help simplify option assessment.

Within the CA these sub-criteria replace the “short-term environment” criterion and
options are assessed against the sub-criteria – they become part of the criteria set. The
criteria set is the union of all the sub-criteria and the criteria which do not have sub-
criteria.

Adhering to CA best practice, the set of criteria should be:

• complete – they should cover all the dimensions that matter to stakeholders; this
includes the “softer” elements that are less tangible but no less important.
• independent – they should avoid the possibility of double counting.
• assessable – using either data or expert judgement.
• significant – they should avoid unnecessarily fine detail.
• relevant – they should be useful in discrimination between the options.

Sub-criteria should be clearly defined within a single criterion and follow similar principles
within the scope of that criterion, namely complete (within the criterion), independent
(within the criterion), assessable, significant and relevant.

To aid the assessment of options, it is important criteria are clearly defined. It can be useful
to define inclusions, exclusions, and examples. In defining a criterion, it may help to start
with the phrase: “The extent to which the option maximizes/minimizes…”.

As part of the criterion definition, the means of assessing each criterion may also
be specified, for example “measured in terms of tonnes of CO2 emitted during
decommissioning.” In specifying a measure, it will become apparent how much careful
consideration is needed to define boundaries – for example, should this measure of CO2
emissions include rock quarried for pipeline remediation?

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Guideline for comparative assessment in decommissioning

Such estimates will be useful in the assessment stage of the process. For qualitative
criteria it is also useful to phrase them in terms of the “The extent to which the option
maximizes/minimizes…” even though there is no means of measurement. This will support
the assessment of options.

The CA team should strive to develop a set of independent criteria, but in practice this can
be difficult. The two main points to consider are correlation and double-counting.
• Criteria are often related. The most common relationship is correlation, where the
assessment of the options on one criterion is statistically aligned with the assessment
of the options on another criterion. For example, the impact on fishing might be a
determining factor in the assessment of two criteria, “long-term health and safety”
(due to the long-term risk to trawlers of snagging nets on residual material) and
“socioeconomic” impacts (due to the economic impact of each option on the fishing
industry). The assessment of the options on both these criteria is correlated, but can
be considered independently.
• However, double-counting should be avoided. This is where the desirability
assessment on one criterion depends on another. For example, “energy usage
during decommissioning” and “CO2 emissions during decommissioning” might
be considered as criteria below the “short-term environmental impact” criterion.
However, CO2 emissions might be as a result of energy usage, and hence the
assessment of the criteria are dependent: this is “double-counting”.

3.4.3 Further preparation of options

As part of the preparation for the full assessment, the CA team should collate the results
of the various studies into a comprehensive evidence pack that shows how each option
performs against each of the criteria.

3.4.4 Output of preparation stage

The main output of the preparation stage is the refined CA criteria set and an evidence
pack for each option summarizing all available information and evidence about the options
structured using the criteria. This evidence pack is used as the basis for the assessment
stage.

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Guideline for comparative assessment in decommissioning

3.5 Stage 4: assessment

STAGE PURPOSE OUTPUT

The main elements of the assessment stage of the CA process are:

Framing and Establish the decision • Framing document
• 1 scoring: The assessment of the options
scoping context
against the criteria set using a combination of
• CA plan
data and judgement
• weighting: The assignment of weights to the criteria within the context of the options
• Short list of options
Ongoing stakeholder engagement

Options
• 2 option development
analysis: Generate
Using the scores anda good set ofto compare and understand the
weights • Rejected options with reasons
and screening options for assessment
options, and on balance determine which option is most forpreferred.
rejection
• sensitivity analysis: Test the robustness of the results to changes in the scores and
Prepare the of
weights. Directly addressing questions subjectivity.• Refined criteria set
evidence
3 Preparation Refine the options and the • Refined options set
• scenario analysis: Directlycriteria
addressing questions
for decision making of uncertainty.
• Evidence pack Simplified CA
cases of low
complexity
Score, weight and
4 Assessment • CA findings report
analyze options

• CA recommendations report
Recommendation Apply reasoned judgement
5 and consultation and seek public response
• Formal consultation material
3.5.1 Scoring the options • Response to formal consultation

• Decision summary proforma

3.5.1.1
6 Purpose
Submission
Take the preferred option
• Documentation for regulatory
through to final endorsement
approval
Assessment of the options is done by an objective relative scoring process that considers
each of the options against each of the criteria.

3.5.1.2 Context
By the time of the assessment stage, this criteria set has been expanded, and studies
have been commissioned to gather evidence and data to support the assessment of the
options. As described in the criteria development section (3.4.2 Criteria Development) this
set of criteria will likely consist of sub-criteria defined below the generic criteria introduced
within the screening stage.

The approach described in this section provides a framework and series of principles to
assess the options against the criteria in a rigorous, robust, and transparent manner.

3.5.1.3 Evaluation workshops

It is recommended that a series of workshops are convened by the CA team to assess
the options against the criteria. These evaluation workshops provide the opportunity
to gather technical experts, and potentially the regulator, to consider the evidence and
assess the options against the criteria. It may be advisable to involve representatives of
the relevant stakeholder groups. This participatory approach can improve understanding
and provide more representative assessments, through good and robust dialogue. This
may also increase confidence amongst internal and external stakeholders. However, it
may be better to consider other ways of engaging with stakeholders at this stage of the CA
without involving them in time-consuming technical debate. The decision on stakeholder
engagement is at the discretion of the CA team.

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Guideline for comparative assessment in decommissioning

The number of workshops will vary depending on the size and complexity of the CA. It
might be appropriate, and efficient, to convene one large workshop to assess the options
across all criteria. For other CAs, separate workshops may cover each different criterion or
criteria groups. For example, all the environmental criteria may be considered and scored
within one workshop. The benefit of this approach is that subject matter experts, and
stakeholders, can attend the appropriate workshops.

If multiple workshops are used, it is recommended that a core set of stakeholders attend
all workshops to provide oversight and understanding of the criteria and options. This
will help drive consistency across the assessment process and help with stakeholder
engagement, understanding and alignment.

3.5.1.4 Scoring process

Irrespective of the number of workshops, the purpose and mechanics of the evaluation
workshop is the same. The workshop facilitator will invite the participants to focus on a
specific criterion and assess all the options against that criteria in isolation. Workshop
participants should be given the opportunity to ask questions and challenge the presented
evidence such that they can advise on the assessment of the options against the criterion
under consideration. Experts should be open to challenge so that non-expert participants
can be reassured, but the views of experts should be respected within their domain of
expertise. In all cases, the debate should be informed by the evidence pack.

The workshop facilitator will then invite workshop participants to summarize their
collective view by scoring each option on a relative preference scale. A scale from 0 to
100 is a very practical and pragmatic example of a relative preference scale. The “most
desirable” option will receive a score of 100, and the “least desirable” a score of 0, and the
other options will be scored on this 0 to 100 scale. It is recommended that participants are
first asked to identify the “most desirable” option against the criterion, and then the “least
desirable”. This defines the top and bottom ends of the scale. Other options can then be
ranked relative to each other with respect to the 0 to 100 scale.

Example A: Safety during decommissioning.

A Hazard Identification Study (HAZID) is carried out on each decommissioning option. All
options are deemed safe, and each option has a clear mitigation plan and HAZID register.
Even so, the safest option is scored 100 and the least safest is scored 0 with the mid
ranking option scored 20, since its HAZID was closer to the least safest rather than the
most safe.

Example B: Technical feasibility. For technical feasibility it might be difficult to derive

a metric or data to inform the assessment of the options. The assessment of technical
feasibility will require input from engineers and technical experts, considering novelty of
the decommissioning approach and asset specific characteristics. Within an evaluation
workshop participants would be asked to consider the evidence presented by the subject
matter experts to inform the assessment. An option that requires limited intervention might
be assigned a score of 100 as the “most desirable” from a technical feasibility perspective.
While an option that uses an unproven novel approach might be scored 0 as the “least
desirable” on this criterion. The other options can be scored relative to these two options.

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Guideline for comparative assessment in decommissioning

If it is not possible to gain a consensus view of the group, then alternative scores will be
noted along with the reasons for the unresolved disagreement. The facilitator can use the
chairperson to adjudicate such disagreements.

During the discussion it is important that participants are reminded that:

• they must focus on the criterion being assessed.
• they should consider the evidence presented.
• they should listen to and consider perspectives of others.
• the score represents a relative assessment of the desirability of the option with
respect to the criterion. For example, if option A scores 100, option D scores 50 and
option C scores 0. Option A is twice as desirable as option D, when compared to
option C.
• options can score the same if they are equivalent with respect to the criterion.
• if all options are considered equivalent, then the criterion does not differentiate the
options.

Once all options are assessed, the facilitator moves the participants on to consider the next
criterion. The facilitator follows precisely the same method for each criterion in turn. In
planning, the CA team must decide whether all criteria can be covered in a single workshop
or whether it is better to schedule a number of events so that the debate can be given
sufficient time.

3.5.1.5 Considering uncertainty during scoring

At the evaluation workshop(s), the facilitator will ensure that uncertainty is discussed and
captured in the scoring. The interpretation of modelling evidence will require expertise and
this is one area where a lack of transparency may arise (particularly when the evidence has
been generated by analysis and mathematical models, such as emission estimates or the
long-term environmental impact). Workshop participants should be encouraged to focus
on the “most likely” scenario, but it may also be advisable to consider separate scoring
for the “reasonable best case” and “reasonable worst case”. This is a way of quantifying
the uncertainty and it would be in line with a pragmatic application of the precautionary
approach. These scenarios can then be explored within the option analysis to explicitly
factor in the role of uncertainty.

3.5.1.6 Identifying the differentiators

As part of the CA, all criteria are scored on a range of 0 to 100. For some criteria this
range may be very large and for others the range may be very small. During scoring it is
recommended that the workshop facilitator seeks the participants’ views on the range
of the scores; for example, whether the range in the scores are close or far apart from a
desirability perspective. It is useful to have this conversation within the scoring workshop
while the scores and criteria are being discussed. This initial assessment of the strength of
the differentiation for each criterion will support the next process step to apply weights to
the criteria.

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Guideline for comparative assessment in decommissioning

3.5.1.7 Output of scoring workshops

Once all workshops have been concluded and all options have been scored against the
criteria, the scoring process is complete.

The outputs of the evaluation workshops provide an important evidence base for the
decommissioning recommendation. It is important scores are recorded at the workshop as
these will be used in the analysis later.

The main points of the debate and rationale for the scores also forms an important part of
the evidence base and should be recorded. It is recommended this record is included within
the CA findings report and circulated to participants for transparency.

3.5.2 Weighting

3.5.2.1 Purpose
Applying weights to the criteria in the context of the options to derive an overall desirability
score for the options.

3.5.2.2 Context
To understand the relative desirability of the options, the scores captured in the scoring
step must be combined to a single desirability score and narrative. This is achieved by
applying weights to the criteria.

Care should be taken when setting weights as it is easy to skew the results of the analysis.
To ensure good and informative results weights must be considered in the context of
the options being considered. Weighting should be agreed after scoring, for the reasons
described below.

This section describes how this is best achieved to help ensure robust and correct
application of CA.

3.5.2.3 Stakeholder involvement in weighting

As with scoring, weighting is a consultative process best achieved at a workshop. It is
common practice for the CA team to invite stakeholders to participate in scoring workshops
to provide input. Such perspectives are important to be considered by the asset owner and
this can heighten understanding and transparency across the stakeholder community.
Ultimately, the CA team should decide who should participate in the weighting process and
how best to incorporate stakeholder views.

Within a workshop setting, participants may be provided with an updated evidence pack.
This should be an updated version of the evidence pack from the scoring workshop with the
scores and the record of the scoring narrative which includes the initial assessments of the
strength of the differentiators for each criterion.

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Guideline for comparative assessment in decommissioning

3.5.2.4 The weighting process

Weighting is the means by which all the information captured in the rich discussion of the
scoring workshops is combined into a single score. Ultimately, every recommendation
reduces to “X is preferred to Y”. It is the weighting discussion that produces this single
score, and it is this discussion that captures the reasoned judgement behind why X is
preferred to Y. The weighting discussion must be documented carefully since it articulates
the way that reasoned judgement is explained – this may become useful in future
communications.

Weighting is typically more challenging than scoring, and it is important that the facilitator is
familiar with the technicalities of this part of the CA process. As with scoring, it is useful to
have a nominated chairperson within the weighting workshop who can adjudicate as required.

Stronger

Lower Higher
weighting weighting
applied applied
Strength as a
differentiator

Lowest Lower
weighting weighting
applied applied

Weaker
Lower Importance Higher

Figure 2 - Guidance on weighting

As depicted in Figure 2, weighting is a question of two parts:

• what is the importance of the criterion? (Shown on the x-axis in Figure 2)
• what is the strength of the criterion as a differentiator between the options. (Shown
on the y-axis in Figure 2)

Both of these factors need to be considered when weighting. If the strong differentiators
are not given sufficient weight then the CA outcome is likely to be skewed. For example, if
one option is an outlier when considered against a particular criterion, then that criterion
is likely to be a strong differentiator and, if it is also regarded as of high importance, then it
should be weighted accordingly. This is the way that the CA is able to compare options that
have significantly different scopes.

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Guideline for comparative assessment in decommissioning

There is no benefit in agreeing the relative importance of the criteria before scoring. It
is useful to debate the relative importance and the criteria strength as differentiators
together to agree the weights. When participants are given the opportunity to explore
both dimensions of Figure 2 simultaneously, a richer and better-informed discussion and
set of weights is produced. The weighting discussion should be documented carefully to
describe how the weights are derived. This will aid the next steps of the process, and wider
communications. (See the weighting example below). When conducting weighting, the
facilitator should remind participants that:
• Weights must represent the range of difference between the options
• Criteria ranges should be brought to life through the options and/or real-world
context, for example comparing operating safety to day-to-day operations
• Important criteria can attract low weights if the range of difference on the criteria is
low; For example, if all options have little potential impact on the environment this
may be given a very low weight, or no weight at all, as it is not a key differentiator in
the decision
• Applying even weights to multiple criteria may appear fair, but it is not good practice:
ranges of difference across the criteria scales are never equal and this will skew the
results from the analysis
• Weighting is specific to the options being considered: it is unlikely the same set of
weights can apply to multiple CAs

The facilitator will guide participants through the weighting process. This may begin with
an invitation to the group to grade the criteria based on the strength as a differentiator and
relative importance. The highest weighted criteria would be identified through discussion,
and assigned a weight of 100. The group would then consider the other criteria against this
benchmark.

Weighting example: Participants might consider that safety during operations is the
most important factor in the decision. Instinctively it might seem reasonable to give
the safety criterion a high weight. But if the options being considered have all been
designed to be extremely safe, then the relative safety merits may not need to be a
significant factor in the decision.

A HAZID assessment for three options deemed that all were safe with acceptable
mitigation plans and HAZID registers. Even so, Option A was safest and so assigned a
score of 100. Option C was least safe and so scored 0. Option B was given a score of 25.

The same three options are compared using the short-term socioeconomic criteria.
The evaluation workshop participants agree that the main driver behind assessing this
criterion is the disruption of local communities as a result of the onshore operations.
The disruption of option A is judged to be significant, there is significantly less
disruption with option B, and option C is judged to have little or no negative impact on
the local community.

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Guideline for comparative assessment in decommissioning

The scores are:

Short-term H&S Short-term socioeconomic

Option A 100 0
Option B 25 60
Option C 0 100

A high weighting for safety, determined before the scoring, might skew the
recommendation towards option A even though the difference on health and safety
between all the options is negligible, and the socioeconomic impact is large.

With the help of the facilitator, the range of difference on each scale is considered from
0 to 100, and the weights applied in this case are:

Short-term H&S Short-term socioeconomic

Weight 15 100

The scores are scaled according to the weights, and the weighted scores are summed
across the criteria, to produce a ranking of options:

Weighted Weighted Sum of

short-term short-term weighted Rank
H&S socioeconomic scores
Option A 15 0 15 3
Option B 3.75 60 63.75 2
Option C 0 100 100 1

With these weights, option C becomes the highest scorer which, on reflection, is
probably intuitively correct.

Weights reflect the values of stakeholders, and within a workshop setting it should be
recognized that some people might never agree – alignment may not always be possible.
It is conceivable that the workshop does not reach a consensus. However, disagreements
are useful to note and explore in the option analysis. A common approach is to convene
separate workshops for different stakeholder groups to provide criteria weights for
consideration, which are subsequentially considered with the scenario analysis. Ultimately,
the asset owner needs to consider the views of the stakeholders and consider how these
play into the option analysis and final CA recommendations.

3.5.2.5 Output
Once criteria weights have been captured, and stakeholders have been engaged, the
weighting process is complete.

The criteria weights should be recorded, including an articulation of the ranges and main
points of discussion leading up to the weights, as these will feed the option analysis and
form part of the CA findings report.

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Guideline for comparative assessment in decommissioning

3.5.3 Option analysis

3.5.3.1 Purpose
Analyse and test the options, using outputs from the scoring and weighting workshops, to
form a recommendation.

3.5.3.2 Context
The CA team use the scores and weights to compare and analyse the options. Scores and
weights capture the discussion in quantitative terms. The overall score for each option is
the weighted sum of its scores against each of the criteria using the agreed set of weights.
This provides an overall ranking of the options.

The CA team needs to analyse the scoring data to account for uncertainty and any subjectivity
in the scoring. There is a level of uncertainty within all evidence and estimates (as discussed in
Sections 1.5 and 3.5.1). In addition, all the scoring and all the weighting is the combined work
of a group of stakeholders; a different group of stakeholders may score and weight differently.

Before making any recommendations based on the ranking of the options, the CA team
must explore the robustness of the ranking using scenario analysis and sensitivity analysis.

3.5.3.3 Scenario analysis

There are three types of scenario analysis: one to factor in uncertainty, one to factor in
alternative stakeholder views, and one to consider specific points of interest:
• Scenario analysis to factor in uncertainty: it will never be possible to eliminate all
uncertainty from the CA. The impact studies may have an estimate of reasonable
worst case (RWC) and reasonable best case (RBC). In the facilitated scoring
workshops, the participants would score based on the most likely case, using
reasonably conservative assumptions.7 This analysis will explore alternative scoring
scenarios based on RWC and RBC. This will produce an estimate on the measure of
confidence in the ranking, given the known uncertainties.
• Scenario analysis to factor in alternative stakeholder perspectives: participants in
the scoring workshop may have unresolved differences on the scores against specific
criteria or they may have unresolved differences in their view of the weighting. As
described within the weighting step it may be useful to elicit different sets of weights
from different stakeholder groups. Different sets of scores and weights represent
different scenarios against which analysis can be applied. In simple terms these
scenarios are used to understand whether the preferred option changes between
them. If the same option is the preferred option across all scenarios (or a majority of
them) the result can be considered robust.
• Scenario analysis can focus on a selected subset of the criteria set to consider
specific points of interest: for example, by selecting only the environment criteria and
the cost criteria, it becomes possible to analyse the “environmental value-for-money”
implications. This type of analysis may prove useful in the application of rational
judgement anticipated in stage 5 (recommendations and consultation).

7
The London Convention states that the CA “should define the nature, temporal and spatial scales and duration of expected impacts based
on reasonably conservative assumptions.”

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Guideline for comparative assessment in decommissioning

3.5.3.4 Sensitivity analysis

The scoring and the weighting should be based on the evidence pack. Even so, there is
a high level of human judgement involved. Sensitivity analysis considers the nature of
subjectivity in scoring by experimenting to see how robust the ranking and preferred option
is if scores and weights are changed. This provides a method to understand what changes
to the scores or weights are required to change the ranking.

The degree of change (“perturbation”) required to impact the ranking is a measure

of robustness of the ranking. A robust ranking is unaffected by changes unless those
perturbations are large; a non-robust ranking is changed under small perturbations.

Sensitivity analysis may be considered for each of the scenarios emerging from the
scenario analysis.

3.5.3.5 Output
The resulting option analysis should be presented within the CA findings report. This will
include the option ranking, the sensitivity analysis and the scenario analysis.

The CA team may make a strong recommendation based on the analysis, or it may direct
the decision makers to the information they need to determine the crux of the decision.
This will form the basis for the final recommendation before formal consultation.

3.5.4 Verification and Validation of the CA

3.5.4.1 Purpose
Provide confidence and assurance of the results of the option analysis.

3.5.4.2 Context
To perform option analysis the CA team will have developed a set of data and equations
to calculate and visualize the ranking. This will be employed to support sensitivity and
scenario analysis. The equations, the criteria, the scores and the weightings together
are sometimes referred to as a “decision model”. Verification and validation (V&V) of the
decision model is important because it provides assurance that the equations used to bring
criteria, scores, and weightings together are correct and that the theoretical outputs are
valid, given a range of inputs.

3.5.4.3 Verification and Validation (V&V)

Decision model verification involves testing the model with a range of inputs to establish
that the calculations of the model are correct.

Decision model validation involves inputting a range of test scenarios to demonstrate

that the outputs are sensible. This will also demonstrate that the decision model is not
predetermined to a specific outcome. (The distinction between sensitivity analysis and V&V
is this: V&V demonstrates that the decision model is valid as a model, sensitivity analysis is
looking at the recommendation itself to determine how robust it is.)

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Guideline for comparative assessment in decommissioning

The CA team should consider the use of independent experts for model validation. The
CA team may also consider the use of independent experts to validate the CA process in
its entirety. Any independent review should not seek to replicate the whole CA. It should
be limited to an assurance role: checking that the guidance has been followed, that the
evidence is robust and objective, and that the analysis has been rigorous.

3.5.4.4 Output
The CA team should document a V&V log and would typically include the log as an annex to
the CA findings report.

3.5.5 Outputs of the assessment stage

The output of the assessment stage is the CA findings report. This includes:
• The main recommendation
STAGE (if there is one) with a summary of the
PURPOSE reasons
OUTPUT
underpinning it
• The main pointsand
Framing requiring further careful
Establish consideration
the decision (if thedocument
• Framing recommendation
1 remains finely balanced) with a summary
scoping context of the evidence
• CA plan
• Documentation from the scoring workshops
• Documentation from the weighting workshops • Short list of options
Ongoing stakeholder engagement

Options development Generate a good set of

•2 The validation and verification
and screening log (as
options an annex)
for assessment
• Rejected options with reasons
for rejection

3.6 Stage
3 5: recommendation
Preparation and consultation
Prepare the evidence
Refine the options and the
• Refined criteria set
• Refined options set
criteria for decision making • Evidence pack Simplified CA i
This section describes how the asset owner comes to endorse a final recommendation
cases of low
based on the CA findings report and associated evidence pack. It also discusses how a
complexity
formal
4 consultation may
Assessment
be used to seek
Score, wider
weight stakeholder
and input prior to submission
• CA findings report
of the
recommendation. analyze options

• CA recommendations report
Recommendation Apply reasoned judgement
5 and consultation and seek public response
• Formal consultation material
• Response to formal consultation

• Decision summary proforma

Take the preferred option
6 Submission
through to final endorsement
• Documentation for regulatory
3.6.1 Recommendation approval

3.6.1.1 Purpose
The asset owner must now apply reasoned judgement to arrive at a recommendation. The
CA findings report provides all the evidence and analysis to inform the recommendation.

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Guideline for comparative assessment in decommissioning

3.6.1.2 Endorsing a final recommendation

Especially at this stage, it is important to reinforce the principle that the final
recommendation is made by the asset owner and not by the team preparing the CA
or by the CA process itself. The purpose of the CA is to ensure that the asset owner’s
recommendation is made based on robust evidence and appropriate stakeholder
engagement. The CA team should be ready to respond to questions about the CA findings
and explain relevant information from the evidence pack to aid the discussion. For certain
CAs it might be appropriate to engage experts and stakeholders in these discussions, but
all the relevant information should be present in the CA findings and evidence pack.

In endorsing a recommended option, the asset owner/operator must be assured that:

• The recommendation aligns with the evidence
• The evidence is robust enough to support the recommendation
• All regulatory obligations are satisfied
• All stakeholders have been sufficiently engaged
• Uncertainty has been minimized and there is no merit in requesting further
information

It is possible that the CA has not narrowed the option set to a single recommendation.
This would not amount a failure of the CA process but would simply reflect the fact that
there remains a choice for the asset owner. In this case, the accountable body has all the
evidence required to make that choice.

Example: The CA team presented the CA findings report to the asset owner Executive
Team. Of the four options assessed, option B and option D were very much less desirable
and discounted, but the decision remained balanced between option A and option C.

The CEO took ownership of the discussion and asked each Executive Director in turn to
state which of A or C they preferred and why. The Board was split evenly between the two
options. The CEO summarized and, after reminding the Executive Team of its obligation
to collective responsibility, made the decision to recommend option C. The reasons for
option C being recommended were described and recorded.

3.6.1.3 Output
Once the decision is made and endorsed by the accountable body, the CA team will produce
a CA Recommendation Report and prepare documentation for formal consultation.

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Guideline for comparative assessment in decommissioning

3.6.2 Formal consultation

3.6.2.1 Purpose
Seek feedback from the public on the recommended decommissioning option and
associated decommissioning plan.

3.6.2.2 Consultation
In the framing document for the CA, there was an assessment of the legal and regulatory
environment which would include any specific requirements for formal public consultation.
The nature and format of formal consultation may be specified by the local regulator.
Where the regulator has no guidance on consultation, the CA team may choose to seek the
regulator’s advice on how they might achieve a useful and successful consultation. The CA
team may wish to consider any helpful guidance on consultation from other jurisdictions.
STAGE PURPOSE OUTPUT
Material for the formal consultation should be derived from the CA recommendations
report, the CA findings report and the evidence pack. It may be helpful to include material
Framing and Establish the decision • Framing document
from1 the framing document. The IOGP comparative
scoping assessment principle committing to
context • CA plan
transparency would see as much information as possible made available unless there
is good commercial reason not to. The CA team may choose to call on expertise from a
professional communications • Short list of optionsas possible.
development team to make theset
consultation as accessible
Ongoing stakeholder engagement

Options Generate a good of

2 and screening options for assessment
• Rejected options with reasons
for rejection
3.6.2.3 Output
Prepare the evidence • Refined criteria set
If the formal consultation concludes and there is significant public opposition, the CA team
3 Preparation Refine the options and the • Refined options set
may need to refer back to the asset owner
criteria and the
for decision regulator
making for advice
• Evidence packon how to proceed. Simplified CA i
cases of low
Otherwise, the CA team is now in a position to prepare formal documentation required for
complexity
regulatory approval. Score, weight and
4 Assessment • CA findings report
analyze options

3.7 Stage 6:Recommendation

submission Apply reasoned judgement
• CA recommendations report
5 • Formal consultation material
The CA teamand consultation
submits and seek public
the documentation response
required for regulatory approval.
• Response to formal consultation

• Decision summary proforma

Take the preferred option
6 Submission
through to final endorsement
• Documentation for regulatory
approval

At the scoping and framing stage of the CA, the precise requirements for formal
submission were recorded in the framing document (such requirements will be determined
by the relevant national regulatory authority). As the CA progressed, the evidence pack,
the CA findings report, the CA recommendations report and the material for formal
consultation and response should have been developed with the submission requirements
in mind. Because the CA is often highly technical, a short executive summary may assist
with communicating the recommendation.

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4. Concluding remarks

Comparative assessment (CA) is IOGP’s recommended process for evaluating options

on the end state of oil and gas production assets. Each CA will be bespoke, based on the
decision context. This guideline provides a good practice approach from initiation, through
the CA process, to arrive at a robust and well-evidence recommendation. A table of
suggested outputs for a CA is provided in Annex C.

A summary of practical advice:

• a CA should not be used to justify a decision already made. The CA is a vehicle
for gathering objective evidence and making sense of it to allow the application of
informed reasoned judgement through a process of comparison.
• the CA should be scaled to the complexity of the decision context. A straightforward
context does not need an extensive and exhaustive CA. A complex context will
probably require more significant investment in evidence gathering and stakeholder
engagement to truly understand the options and reach a sound and robust
recommendation. Complex is not always better. At the outset, the CA team should
estimate how complex the CA is likely to be and plan accordingly. This guideline
encourages the user to make the CA as simple as possible.
• consider engaging with the regulator early and often. This is not to influence the
regulator but to appreciate the regulatory perspective and to generate confidence that
the CA process is thorough and objective. This is all part of the decision context.
• develop a stakeholder engagement plan at the start of the process. Consider carefully
when and how to involve stakeholders.
• options development should be thorough and ambitious, possibly using Best Available
Technology Not Entailing Excessive Cost (BATNEEC).
• the generic criteria set provided in this guideline forms a good basis for any CA.
However, the CA should always be tailored to its context and this may require further
development of the criteria set.
• the generic criteria set offers a useful framework for screening. Be aware of the
strengths and limitations of narrative screening, RAG screening and five-point
screening.
• avoid weighting before scoring or the use of even weights. Make sure that weighting is
backed by real-world context and reasoned judgement.
• a CA must be able to compare options with widely differing scopes. This can be
captured by properly emphasizing the strong differentiators in the weighting.
• use scenario analysis to account for alternative perspectives and uncertainty.
• use sensitivity analysis to account for subjectivity and to test the robustness of the
results.
• make good use of independent experts. Use them to fill gaps in the evidence base.
Use them to provide challenge on ambition and innovation. Use them to challenge the
process for any lack of objectivity.

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Guideline for comparative assessment in decommissioning

• research and evidence gathering should continue until uncertainty has been reduced
to tolerable levels and there is no merit in requesting further information.
• the structure provided by the criteria set aids communication. Complex context
is hard to comprehend and the segmentation by criteria can be a helpful way to
generate understanding among stakeholders and senior decision makers.
• consider the use of a professional communications team to prepare material suitable
for public consultation. Professional communications expertise may also have a role
in preparing material for formal submission to the regulator.

Keeping these points in mind throughout the CA process should enable the CA team to
produce a credible decommissioning recommendation that is transparent to stakeholders
and methodologically robust.

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Guideline for comparative assessment in decommissioning

Appendix A: The IOGP comparative

assessment principles

Principles for CA What it means:

1. CAs are objective in option There is no preconceived answer. All feasible options are considered, not limited by
selection with option ranking driven stakeholder’s desired end-state. Full removal is one of the options, not necessarily the base
by cost-risk benefits trade-offs. case. Decisions is driven by cost-risk-value/benefits tradeoffs where all criteria and impacts
are analyzed.

2. CAs are adaptable and scalable. CAs are scaled appropriately. The choice between a simple vs. complex CAs are dependent on
the timing of the CA in the project, the purpose of the CA, and the complexity of the decision
and scope. A simple screening type CA may be one that uses a traffic light system and is
qualitative. A complex CA may be one that uses weightings and is quantitative.

3. We maximize transparency to As part of the CA process, we identify our stakeholders and ensure they are engaged in the
increase stakeholder’s trust in the design of the process. We clearly communicate logical rationales for the proposed end-state
CA process. to our stakeholders, as well as criteria used for CA assessment, including the cost-risk-
benefits trade-offs for each of the options ranked. We respond to stakeholders’ concerns and
negotiate reasonable time to collect sufficient information before responding and making a
decision. Data is made available to stakeholders.

4. We are aligned with International We seek to understand and align to applicable framework, principles, and guidance, and
and national regulatory support national aspirations e.g., net zero emissions, maximum local content, etc. We support
frameworks, principles, and the precautionary principle for all options considered. We will dialogue with stakeholders to
guidance. understand risk and urgency for actions.

5. In the CA, we process impact The descriptions, measurements or estimates of the safety, environmental, socioeconomic,
information that is relevant to the technological, and other impacts are consistent in scope and time with the activities of the
decommissioning project and data decommissioning options and end-states assessed in the CA. Data used for the CAs are of
that is credible in the quality of its high integrity and source referenced.
collection and source.

6. Technology feasibility, availability We support technology development. CA clearly considers availability and feasibility of
and risk of failure are always technology application. Technical feasibility alone does not default to execution. The risk of
considered in CA. technical failure is always present and is considered.

7. CA facilitators are competent and CA facilitators are competent and qualified to coordinate the CA process that are in line with
qualified. local regulatory requirements and uphold the principles of a genuine CA process.

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Guideline for comparative assessment in decommissioning

Appendix B: The Framing Document

(Template)
This template provides a guideline for the framing document (further to section 3.2.1). This provides
questions as prompts to consider the decommissioning decision. The impact on the decision
should be considered, such as the approach to the CA, the supporting information required, and the
stakeholder engagement plan.

Executive Summary

Provide a short overview of key findings

Scope

Questions to consider:
• What facilities are included and where is the boundary?
• Is this a single platform or is this a network of pipelines where decommissioning needs to be segmented into phases?
• Should there be a single CA for the entire network, or does it make sense to segment the CA according to the phases of the
decommissioning context?

Legal and political context

Questions to consider:
• What are the relevant international or regional treaty obligations?
• What is required by national legislation?
• What, if any, regulatory regime is in place? How mature is the regulatory regime?
• What are the specific expectations of the regulator?
• Are there mandated timeframes and decision gateways?
• Are there policy or political factors to be considered?
• Is there a mandated baseline to be considered?
• Is there precedent to consider?
• Is there a requirement for formal public consultation and, if so, what form does that take?
• What are the implications for the process of decision-making?

Technical context

Questions to consider:
• What are the main technical features of this decommissioning situation? How are these described in the most accessible way?
• Are there well-established engineering technologies available for this particular decommissioning challenge?
• If not, how much innovation is likely to be required and what technical risk does that entail?
• Is there a sufficiently robust supply chain to support implementation?
• What are the implications for the process of decision-making?
• Are there well-established engineering technologies available for this particular decommissioning challenge?

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Guideline for comparative assessment in decommissioning

Geographical and environmental context

Questions to consider:
• Are there any specific features about the geography or the environment which present particular challenges?
• Is the existing scientific understanding adequate? If not, what amount of research will be necessary to develop sufficient scientific
knowledge on impacts and benefits in the long and short term?
• What are the implications for the process of decision-making?

Socioeconomic and cultural context

Questions to consider:
• Are there any specific groups who might claim that their society, economy or culture is likely to be impacted (either positively or
negatively) by the decommissioning decision? This could include any long-term legacy of the decision or short-term disruption.
• What sort of alignment exists among the groups impacted? What level of disagreement is likely or possible?
• How can the CA meaningfully involve these groups?
• What are the implications for the process of decision-making?

Financial and commercial context

Questions to consider:
• Are there clear commercial lines of responsibility?
• What is the level of commercial risk?
• Are there tax implications or implications for government investment?
• What are the implications for the process of decision-making?

Complexity of the Decision

Based on the six features above, comment on the complexity of the decision.
If this is a low complexity situation explain what the technical solution is and why it is preferable to stakeholders and to regulators
without a comprehensive CA.
If it is not a low complexity situation, explain the source of the complexity.

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Guideline for comparative assessment in decommissioning

Appendix C: Suggested documentation

This table provides an overview of suggested documentation produced throughout the CA process.
The CA team may choose to combine some of these suggested documents or omit some entirely.
Specifics should be discussed and agreed with the regulator as part of initiating the CA.

Suggested Documentation Description Stage and reference

Framing document Sets out a common understanding of the Stage 1: Framing and scoping (Guideline
decision context. Feeds into the CA plan. section 3.2.1 Understanding the decision
Template provided in appendix B. context)

CA plan Describes how and when the CA will be Stage 1: Framing and scoping (Guideline
delivered, and who will be involved. A live section 3.2.2 The comparative assessment
document which will be updated as the CA plan)
progresses.
May include:
• Options generation plan
• Assessment methodology
• Supporting information plan
• Stakeholder engagement plan
• Communications plan
• Timeline
• Resource requirements

Options generation plan Part of the CA plan. Stage 1: Framing and scoping (Guideline
Describes how the options will be section 3.2.2 The comparative assessment
identified, defined and developed. plan)

Assessment methodology Part of the CA plan. Stage 1: Framing and scoping (Guideline
Sets out how the options will be compared section 3.2.2 The comparative assessment
during the CA process. plan)

Supporting information plan Part of the CA plan. Stage 1: Framing and scoping (Guideline
Specifies the further research and data section 3.2.2 The comparative assessment
collection required to address gaps in plan)
evidence and understanding. Stage 3: Preparation (Guideline section
3.4.1 Studies)

Stakeholder engagement plan Part of the CA plan. Stage 1: Framing and scoping (Guideline
Identified all relevant stakeholder groups section 3.2.2 The comparative assessment
and describes how they will be involved in plan)
the CA process.

Communications plan Part of the CA plan. Stage 1: Framing and Scoping (Guideline
Considers the channels of communication section 3.2.2 The comparative assessment
needed to keep stakeholders informed. plan)

Timeline Part of the CA plan. Stage 1: Framing and Scoping (Guideline

Sets out the key phases and milestones of section 3.2.2 The comparative assessment
the process. plan)

Resource requirements Part of the CA plan. Stage 1: Framing and Scoping (Guideline
An estimate of resources required section 3.2.2 The comparative assessment
to undertake the CA, based on other plan)
elements of the CA plan.

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Guideline for comparative assessment in decommissioning

Suggested Documentation Description Stage and reference

Shortlist of options Records the output of the screening stage. Stage 2: options development and
This may be one option to take forward for screening (Guideline section 3.3)
approval, or may be numerous options to
take forward to the preparation stage.

Rejected options list A list of options which were considered

but removed at the screening stage, and
the reason for this.

Stage 2: options development and

screening (Guideline section 3.3.)

Evidence pack The collated results of the studies and Stage 3: Preparation (Guideline sections
other data collection, showing how 3.4.1 Studies
each option performs against each of 3.4.3 Further Preparation of Options)
the criteria. This is the refined option
and criteria list to take forward for
assessment.

Criteria Set The final version of criteria and sub- Stage 3: Preparation (Guideline sections
criteria with full definition and any points 3.4.2 Criteria Development)
of clarification

CA findings report The output of the assessment stage, Stage 4: Assessment (Guideline sections
showing the results of a series of 3.5.1 Scoring the Options
evaluation workshops: 3.5.2 Weighting
• Scores assigned to options and the 3.5.3 Option Analysis
rationale. 3.5.4 Verification and Validation of the CA)
• Weights for the criteria and the
rationale.
• The option ranking.
• The findings of scenario and sensitivity
analyses.
• An annex showing a validation and
verification log.

CA recommendations report A narrative document explaining Stage 5: Recommendation and

recommendations based on the CA consultation (Guideline section 3.6.1
findings report and evidence pack. Recommendation)

Formal consultation material Material produced for use in public Stage 5: Recommendation and
consultation. Based on the CA consultation (Guideline section 3.6.2
recommendations report, the CA findings Formal Consultation)
report and the evidence pack, may include
information from the framing document.

Decision summary A short executive summary of the decision Stage 6: Submission (Guideline section 3.7
process and findings, to assist with Stage 6: Submission)
communicating the recommendations.

Documentation for regulatory approval Documents for submission to the Stage 6: Submission (Guideline section 3.7
decision makers or regulators. Precise Stage 6: Submission)
requirements will vary depending on the
jurisdiction.

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Guideline for comparative assessment in decommissioning

Glossary

Term Description

Asset Any piece of man-made infrastructure that is within the scope of decommissioning.

Comparative Assessment (CA) A process that compares positives and negatives of different decommissioning
options using specific criteria from regulators and stakeholders.

Complexity The degree to which the decommissioning decision is likely to be complicated. It is

broken down into six factors.

Criterion A factor that must be considered during the assessment.

Decision model The combination of scores and weights

Decision space The range of potential options available and the consequences of choosing those
options

Decommission To find a suitable end-state for an asset that is no longer required

Desirability The degree to which an option is rated highly when considered against one or more
criteria.

Differentiator How a criterion serves to distinguish between options

End-state The intended result of a decommissioning project in the long-term

Evaluation Workshop A working meeting to examine the evidence and to provide evidence-based scores
for each of the options

Expert A person with qualification, experience, reputation and track record in a specific
area.

Feasibility The measure of possibility, capability or likelihood of an option being successful

Multi-Criteria Decision Analysis A technique to aid decision-making that uses a set of criteria to simplify the
(MCDA) question

Objective Not influenced by personal feelings or opinions in considering and representing

facts.

Option A potential decommissioning project that results in an end-state

Pairwise Comparison A scoring technique that considers options two at a time to derive a ranking and
then a scoring

Precautionary Approach Where there are threats of serious or irreversible damage, lack of full scientific
certainty shall not be used as a reason for postponing cost-effective measures to
prevent environmental degradation

Preference An option that is favoured when compared with other options. The reason for the
preference is important.

Qualitative Data or information that is descriptive rather than numerical

Quantitative Data or information that is numerical rather than descriptive

Ranking An ordering of the options made on the basis of scoring and weighting

Requisite investment The allocation of resource which is suitable for the task, neither too little, nor too
much.

Scenario analysis A means to explore how different assumptions may impact on the recommendation.

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Guideline for comparative assessment in decommissioning

Term Description

Scoring A method of evaluation used to compare two or more options

Sensitivity analysis A means to determine whether the final recommended option is strongly preferred
to all other options or whether there remains an alternative that should not be
discounted.

Stakeholder A person who has a direct interest in the decision.

Subjective Based on personal opinions and feelings rather than on facts

Supporting study A piece of research commissioned specifically to address an area of uncertainty

within the CA

Trade-off The choice to be made between one criterion and any others when it is impossible
to have all in full.

Uncertainty Where factors relevant to the decision are not fully understood. The uncertainty
may be tolerable (which means that a decision can be made even without full
understanding).

Validation Validation involves inputting a range of test scenarios into the decision model to
demonstrate that the outputs are sensible.

Verification Verification involves testing the decision model with a range of inputs to establish
that the calculations of the model are sound.

Weighting A method of MCDA used to combine multiple scores into a single score to
determine the overall “value” of an option in comparison to other options.

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Guideline for comparative assessment in decommissioning

References

IOGP Report 584 – Overview of International Offshore Decommissioning Regulations

IOGP Report 650 – Habitat retention strategies for decommissioned offshore jacket structures
IOGP Report 667 – Guidelines for upstream pre-project decommissioning estimates
IOGP Report 632 – Offshore oil and gas pipeline decommissioning briefing
IOGP Report 2022dws - IOGP Decommissioning Workshop on comparative assessment processes
IPIECA – Offshore impacts to fisheries: practitioner guidance for social baselines (2023)
International Maritime Organization London Convention/ London Protocol’s Annex 8 Revised specific
guidelines for assessment of platforms or other man-made structures at sea (2019)
Offshore Energies UK (OEUK). “Guidelines for Comparative Assessment in Decommissioning
Programmes.” Offshore Energies U.K. ISBN 1903004551. 2015. Issue I, October (2015).
Offshore Energies UK (OEUK) Guidelines on Stakeholder Engagement during Decommissioning
Activities ISBN 1 903 003 97 0 (2013)
OSPAR. “OSPAR Decision 98/3 on the Disposal of Disused Offshore Installations.” Ministerial Meeting of
the OSPAR Commission. Sintra, Portugal. 22-23 July 1998.
Norsk Olje & Gass - Impact assessment for offshore decommissioning (June 2020)
Royal Commission on Environmental Pollution: twelfth report: Best practicable environmental option,
Chairman: Sir Jack Lewis, HMSO. (1988)

Further reading
Keeney RL and Raiffa H. Decisions with Multiple Objectives: Preferences and Value Trade-offs. New
York: Wiley (1976). Reprinted Cambridge University Press, 1993.
Nicolette, J.P A framework for a net environmental benefit analysis based comparative assessment of
decommissioning options for anthropogenic subsea structures: A North Sea case study, (2023) Front.
Mar. Sci. 9:1020334.doi: 10.3389/fmars.2022.1020334
Saaty, T.L. Decision Making for Leaders; The Analytical Hierarchy Process for Decisions in a Complex
World, latest edition, Pittsburgh: RWS Publications (2000).
Spetzler C, Winter H, and Meyer J. Decision Quality: Value Creation from Better Business Decisions.
Wiley (2016).
Caprace, J,et al. “A New Multi-Criteria Decision-Making Tool for Subsea Oil and Gas Asset
Decommissioning.” Proceedings of the ASME 2023 42nd International Conference on Ocean, Offshore
and Arctic Engineering. Volume 10: Professor Ian Young Honouring Symposium on Global Ocean Wind
and Wave Climate; Blue Economy Symposium; Small Maritime Nations Symposium. ASME 2023 42nd
International Conference on Ocean, Offshore and Arctic Engineering. Melbourne, Australia. June
11–16, 2023. V010T13A025. ASME. https://doi.org/10.1115/OMAE2023-108204

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 This document is a guideline on how
to conduct a successful comparative
assessment (CA).
A comparative assessment
evaluates different decommissioning
options in a structured way that
provides the asset owner or
operator with the information
needed to make a robust
decommissioning recommendation
and plan for the regulator to
approve. The CA helps to ensure
that all obligations have been met
to satisfy the regulatory authorities.
It also provides an asset owner
with confidence that all factors and
considerations have been examined
in the decommissioning plan.

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