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N i c n e w m a n o x f o r d . c o m
2019
INDONESIA’S
DECOMMISSIONING
CHALLENGE
Oil and gas
By Nicholas Newman
Nicnewmanoxford.com
Commissioned by the consulting and
advisory arm of London and Aberdeen
based Precision Media &
Communications
Nicholas Newman [email protected]
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CONTENTS
Executive Summary ............................................................................................................................................. 3
Introduction and background ............................................................................................................................ 4
Oil and gas fields .............................................................................................................................................. 4
Ownership/operating conditions ................................................................................................................... 4
Top 5 leading oil and gas producers ............................................................................................................... 5
The scale of the problem ................................................................................................................................. 5
The size of the problem ................................................................................................................................... 6
Funding decommissioning ............................................................................................................................. 7
Challenges ............................................................................................................................................................. 8
Decommissioning experience ......................................................................................................................... 8
Industrial Capacity .......................................................................................................................................... 8
Decommissioning experience elsewhere ...................................................................................................... 9
The North Sea experience ........................................................................................................................... 9
South East Asian experience ...................................................................................................................... 9
Managing costs ................................................................................................................................................... 10
knowledge Management between regulators, operators and service sector firms................................ 10
Choosing optimal commercial and contracting strategy .......................................................................... 10
Adopting innovative technologies to cut costs ........................................................................................... 10
Indonesia’s legal and regulatory framework .................................................................................................. 12
MEMR PUBLISHED REGULATION NO. 23 of 2018................................................................................ 12
Regulation update .................................................................................................................................... 13
International treaties ............................................................................................................................................ 14
United Nations Convention on the Continental Shelf 1958 ............................................................................. 14
United Nations Convention on the Law of the Sea 1982 (UNCLOS). ................................................................ 15
Basel Convention 1989 and 2011. .................................................................................................................... 15
Regional Agreements ............................................................................................................................................ 16
Coordinating Body of the Seas of South East Asia (COBSEA) Regional Sea. ..................................................... 16
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ASEAN Council of Petroleum (ASCOPE) Guidelines .......................................................................................... 16
Other opportunities ........................................................................................................................................... 17
Renewables opportunities ........................................................................................................................ 17
Conclusion .......................................................................................................................................................... 18
Sources ................................................................................................................................................................. 18
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EXECUTIVE SUMMARY
Many of Indonesia’s oil and gas fields, both on and offshore, are coming to the end of
their commercially viable operational lifespan. More than 60% of Indonesia’s oil and
more than 30% of gas production comes from late-life-cycle resources i spread
across the world's largest island country. Despite investment and use of enhanced oil
field recovery measures, as well as increasing automation to extend the economic
lifespan of these assets, decommissioning will soon become necessary.
However Indonesia, like many countries new to the prospect of decommissioning
energy infrastructure, face many key technological, fiscal, environmental, regulatory
and industrial capacity issues, which need to be addressed by both government and
industry decision makers.
This report takes a look at many of the issues Indonesia and other South East Asian
oil producing nations are likely to face with the prospect of decommissioning.
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INTRODUCTION AND BACKGROUND
Indonesia has important energy resources, starting with oil. It has 22 billion barrels
equivalent of conventional oil and gas reserves of which, about 4 billion, are
commercially viable with current technology. That’s equal to about 10 years of oil and
50 years of gas production.
Indonesia’s oil and gas production amounted to 1.8 million barrels of oil equivalent
per day (boepd) in the first half of 2019, only 89 percent of the targeted 2.02 million
boepd, according to data from the Country’s regulator Upstream Oil and Gas
Regulatory Task Force (SKK Migas).
OIL AND GAS FIELDS
Oil and gas assets are spread across Indonesia, from Sumatra in the West to Papua in
the East, an area three times the size of Texas. However, about 75% of oil and gas
exploration and production are located in Western Indonesia in Sumatra, the Java
Sea, East Kalimantan and Natuna.ii See figure 1.
Figure 1
Source 1
https://www.eia.gov/beta/international/analysis_includes/countries_lo
ng/Indonesia/images/indonesia_map.png
OWNERSHIP/OPERATING CONDITIONS
The country’s oil and gas is owned by the government on behalf of the nation and
company access is governed by Production Sharing Contracts (PSC) iii in which
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International oil companies (‘IOCs’) act as contractors (‘Contractors’) to the host
government and assume the exploration and development risk. Contractors recover
their costs and profit from a share of subsequent production. 2017 saw the
introduction of the Gross Split PSC which removes the cost recovery element. Now
all production is directly split between the government and industry participants.
The current gross split incentivises contractors to optimise investments, but at the
same time, they take on more risk.iv
Concessions to explore and produce oil and gas can be led by state owned operators
such as PT PERTAMINA or foreign operators such as Mobil. For example,
PERTAMINA took over production of the Markam bloc from Total last yearv whilst
the Cepu field is operated by US-based Exxon Mobil.vi
These ownership/operator conditions mean that the government can’t simply order
oil companies to decommission their assets, since this would discourage future
exploration and development of oil and gas fields. Moreover, the government itself
has neither the funds nor the expertise to implement a decommissioning policy.
TOP 5 LEADING OIL AND GAS PRODUCERS
The five biggest oil producers in Indonesia - who together account for 73.34 percent
of the nation's total oil production – are:
Chevron Pacific Indonesia
ExxonMobil
Pertamina EP
Pertamina Hulu Mahakam
China National Offshore Oil Corporation (CNOOC)
In addition, the five aforesaid companies - oil and gas cooperation contract holders
(KKKS) - also contribute 66.50 percent to Indonesia's total gas production.vii
SKK Migas recorded oil production at 752,000 barrels oil per day (bopd) up to June,
or 97 percent of the target set at 775,000 bopd, while gas production was 1.05 million
boepd, 84 percent of the targeted 1.25 million boepd.viii
THE SCALE OF THE PROBLEM
High operating costs and the low oil price have made increasing numbers of
Indonesia’s maturing oil and gas fields commercially unviable. The exact number of
rigs in operation, both on and offshore is unknown, but one report suggests that
there are at least 450 oil rigs in Indonesian waters of which, three quarters are over
20 years old.
Another report suggests that 65 percent of Indonesia’s entire oil and gas assets
including platforms, rigs, pipelines etc., are over 30 years old. The decommissioning
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prospect for the next decades could be as big as 613 offshore platform operated in
Indonesia, 335 of them has already operated for 20 years or more,ix 100,000 km of
pipelines and as many as 15,000 wells.
Therefore, the potential size of Indonesia’s decommissioning market is huge and the
opportunity is almost imminent. Moreover, local decommissioning capacity and
skills are lacking. The scale of the decommissioning requirement is such that it would
pay Indonesia to create and build up its own decommissioning industry, able to fully
or partially dismantle energy infrastructurex or repurpose for some other use.xi
As of January 2017, the following offshore platforms were ready to be
decommissioned, these were the:
Pertamina ONWJ (Formerly as BP West Java) which had 6 old offshore
platforms to be decommissioned.
Chevron, which had 7 old offshore platforms to be decommissioned.
But the decommissioning process was cancelled due to Indonesia regulations
regarding cost since the Non-Productive platforms had no budget at the beginning
for this decommissioning process.xii
THE SIZE OF THE PROBLEM
The North Sea and the Gulf of Mexico are examples where the establishment of a
pioneering industry in decommissioning rigs, sometimes the height of the Eiffel
Tower, is underway. See Figure 2.
Figure 2
Source 2 By Office of Ocean Exploration and Research National Oceanic
and Atmospheric Administration (NOAA), US Department of Commerce
-
http://oceanexplorer.noaa.gov/explorations/06mexico/background/oil/
media/types_600.htmlhttp://oceanexplorer.noaa.gov/explorations/06m
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exico/background/oil/media/types_600.jpg, Public Domain,
https://commons.wikimedia.org/w/index.php?curid=10407950
The North Sea is home to some 600 platforms of which 470 are in the UK sector.
The aging infrastructure also comprises 5,500 oil wells and 10,000 kilometres of
pipelines. In the period between 2015 and 2024, experts forecast that the industry is
expected to spend £16.9bn on taking out of action, just 79 platforms and 1,200 wells.
A case in point is the dismantling of Shell’s giant Brent Delta 3 storey rig platform,
weighing 24,500 tons, in a single-lift operation using the heavy lift catamaran
Pioneering Spirit. The operation left behind the three supporting 170 metre concrete
legs in place in April 2017.
FUNDING DECOMMISSIONING
It is not only the cost of decommissioning which is a concern, but how it is to be
funded.
Companies can pay for necessary decommissioning costs by directly self-insuring
with the purchase of specialist insurance products, or indirectly by creating a
licensed insurance company to provide coverage for itself. Alternatively, companies
can self-pay by contributing to designated reclamation bonds or common bond pools
held by states or regulators or, more directly, with letters of credit and escrow
accounts.
However, such methods have proved insufficient in meeting the full costs of
decommissioning and rehabilitation of sites. A case in point is Canada’s Alberta’s oil
sands bond decommissioning pot which holds just over $2 billion CND, but which
needs much more according to Professor Lee Foote, of Alberta Botanic Garden
University, who notes, “as for the bonding, a few years back, there was just over $2
Billion CND in the reclamation fund for all of oil sands. My rough calculations put
the basic cost at $12+ Billion.”
To fill a gap in the market, London based trust company Quatre Ltd, xiiimarkets an
investment and insurance package in which oil and gas companies, can securely and
efficiently, set aside an amount each year to fund future liabilities, providing
stakeholders with the assurance that future decommissioning and reinstatement
liabilities will be met in full.
Meanwhile, because of the pioneering nature of the decommissioning business, there
are genuine concerns that local banks and other financial institutions do not have
sufficient fiscal expertise and capacity to provide the appropriate funding packages
for decommissioning.
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CHALLENGES
Not surprisingly, current legal frameworks are not as extensive as those of Canada,
Norway or Britain where decommissioning has already begun. For the benefit of the
country’s economic development and environment however, the government and oil
and gas companies need to co-operate in framing a decommissioning policy of
regulations and financial contributions. Existing challenges needed to be addressed,
especially shortages of skills, experience and industrial capacity.
DECOMMISSIONING EXPERIENCE
At present, like many oil and gas producing developing nations, Indonesia’s domestic
industry has limited experience in setting policy and a regulatory framework to
address future decommissioning. For example, Indonesian regulators have not yet
fully clarified requirements related to the process, financial security and technical
issues of decommissioning. Nor has the government yet issued detailed plug and
abandonment guidelines. In fact, production-sharing contracts made before 2008
lacked allocated funding for eventual decommissioning.
Nevertheless, Indonesia is starting to attract experienced contractors including
Dutch Royal Basalis Westminster N.V. and regional contractors such as Malaysia’s
Sapura Energy Berthed and China’s COOEC-Fluor for its potential decommissioning
projects. xiv
INDUSTRIAL CAPACITY
At present, Indonesia does not have sufficient industrial capacity to tackle the
problems faced in decommissioning especially the huge offshore projects, destined
for retirement, in the coming years.
Although not really tested, Indonesia has a large volume of yard capacity,
experienced work and cheap workforce and equipment to facilitate decommissioning
activities. However, government regulations are strict and often seek to protect local
populations. This would mean that decom businesses would need to operate
extremely cautiously to avoid being shut down over environmental concerns. A new
yard in Bintan looks like the most promising site for decommissioning.xv
But, fortunately, Singapore’s Keppel Yard is well equipped to develop into a regional
hub for decommissioning offshore rigs. Just in the same way that Aberdeen, acts as
the North Sea’s decommissioning hub.
In May 2019, Singapore’s Sembcorp Marine launched at the Keppel Yard, the world’s
largest semi-submersible crane vessel – the Sleipnir.xvi The Sleipnir is named after
Norse god Odin's eight-legged horse. It is equipped with two 10,000-tonne revolving
cranes which can lift loads of up to 20,000 tonnes in tandem. The Sleipnir, which is
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bigger than the London Eye, will serve for offshore oil, gas, and renewable energy
installation and decommissioning projects.xvii
DECOMMISSIONING EXPERIENCE ELSEWHERE
The eventual cost of decommissioning and making good will depend not only on
existing treaties and what policy makers require –ranging from full to partial
removal but also the size and number of installations to be decommissioned and the
practical, engineering and technological methods chosen by other stakeholders.
THE NORTH SEA EXPERIENCE
For example, in the case of the North Sea, decommissioning is governed by the 1998
Convention for the Protection of the Marine Environment of the Northeast Atlantic
(OSPAR),xviii which bans dumping installations and requires operators to return the
marine environment to its natural state. Under the auspices of OSPAR, between now
and the mid-2050s, around 470 platforms, 5,000 wells, 10,000 km of pipelines and
40,000 concrete blocks will have to be removed from the North Sea.
The technological challenges will depend also on the size and amount of installations
being decommissioned. For example, in April 2017, when Shell’s Brent Delta
platform’s topside, weighing 24,000 tons, the same as 2,000 London buses, was
separated from its supporting legs and removed in a single-lift operation. A specially
designed series of cranes, placed between the bows of the twin-hulled giant
catamaran, lifted and transported the topside to a yard in the English North Sea port
of Hartlepool for disassembling.
SOUTH EAST ASIAN EXPERIENCE
The choice of technology and engineering solutions employed, such as full or partial
removal of an offshore rig, can impact on navigation, pollution, fisheries and animal
life. Leaving structures underwater to create artificial reefs is both cheaper and more
environmentally friendly than full removal.
A good example from 2018 is that of Malaysia’s national oil company Petronas,
which opted for the rig-to-reef solution for two platforms at its Dana and D-30 fields
in Block SK-305 offshore Malaysia. The rig-to-reef method comprises using the
decontaminated platform structures to create an artificial reef at a designated
location.xix
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MANAGING COSTS
One thing is clear Indonesia stakeholders will have to make use of a variety of
strategies to manage cost. These include usage of knowledge management
frameworks, project management strategies and adopting innovative technologies to
cut costs in an environmentally sustainable and economic manner.
KNOWLEDGE MANAGEMENT BETWEEN REGULATORS, OPERATORS
AND SERVICE SECTOR FIRMS
Indonesian stakeholders including regulators, operators and contractors will need to
establish knowledge management frameworks. Such frameworks should include
information sharing circles and work with already established global leaders and
local stakeholders in the field, if costs are to be controlled.
CHOOSING OPTIMAL COMMERCIAL AND CONTRACTING STRATEGY
Implementing good project management and contracting practices are vital to avoid
projects being delayed and over budget.
In the North Sea, three contracting strategies are often used. These are lump sum,
unit cost and day rate, depending on the levels of potential risk.
But certainly popular is the use of unit cost contracts, where the contractor performs
well plug and abandon or facility removal at a fixed cost per unit that includes a
margin.
ADOPTING INNOVATIVE TECHNOLOGIES TO CUT COSTS
It is sometimes possible to delay the start of decommissioning by investing in
enhanced oil field recovery measures to boost and extend production, together with
increases in automation to cut operating costs. However, it is neither always
desirable nor economic to do this, thus paving the way for decommissioning.
In the North Sea, some operators are achieving cost savings by adopting different
approaches, learning and sharing with others and challenging previous norms. In
addition, the supply chain is also bringing new solutions to the market in terms of
pricing structures, business models and technology.xx
For example, making use of single lift vessels to remove topsides, such as Allseas’
Pioneering Spirit, has enabled project cost reductions of up to 30 percent. Also,
increasing the maximum weight of heavy lift vessels from 5,000-tonne to 10,000-
tonne could have an impact of eventual costs. See figure 3.
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Figure 3 heavy lift ship and oil rig
Source 4 Copyright: <a href="https://www.123rf.com/profile_tele52">tele52 / 123RF
Stock Photo</a>
Moreover, for fields with a large number of aging wells and platforms, batch
decommissioning could bring huge cost-saving opportunities. This approach could
be extended further across blocs with different operators, with participants jointly
contracting for a larger piece of work, thus reducing per-unit costs. Sumatra and its
offshore fields are prime candidates for these cost saving approaches.
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INDONESIA’S LEGAL AND REGULATORY FRAMEWORK
Not surprisingly, Indonesia’s legal and regulatory frameworks regarding decommissioning
are still in their infancy. The lack of a clear and full developed regulatory picture especially
over the decommissioning cost is a major blocking point on progress.xxi Nonetheless, an
important step forward is contained in a current regulation which obliges new production-
sharing contracts to stipulate inclusion of a company plan for abandonment and site
restoration as well as details of what provisions is made to ensure that sufficient finance is
available when the time comes for decommissioning its infrastructure.
Here is a brief overview of the available legislation in terms of its regulations concerning
decommissioning in Indonesia
The latest generation of Production Sharing Contracts requires that contractors pay for and
complete a site abandonment and restoration process.
In addition, the Oil and Gas Law highlights post-operation responsibilities to safeguard
environmental management and protection, and Government Regulation 35 obligates
contractors to earmark funds for post operation undertakings.
MEMR PUBLISHED REGULATION NO. 23 of 2018
In addition, the MEMR Regulation 23/2018, requires that outstanding post-
operation obligations of a production sharing contract (PSC) nearing its end are to be
carried out by an entity that has been appointed by the MEMR to resume the PSC,
which could be PT Pertamina and/or some other another contractor.
MEMR PUBLISHED REGULATION NO. 15 OF 2018
In 2018, the MEMR published Regulation No. 15 of 2018 concerning Post-Operation
Upstream Oil and Gas Business Activities ("MEMR Reg. 15/2018"). This regulation
calls for PSC Contractors to conduct post-operation activity by using post-operation
activity funds. A post-operation activity plan is required to be proposed, prepared
and submitted to the government agency SKK MIGAS through the submission of a
Work Plan and Budget (if the PSC is in the exploration phase) or as part of the field
development plan (if the PSC is in the exploitation phase).
Meanwhile, before implementing post-operation activities, PSC contractors are also
required to gain approval of the post-operation activity plan from the Director
General of Oil and Gas. PSCs that do not contain provisions regarding post-operation
obligations are subject to MEMR Reg. 15/2018. The required processes and
procedures required allocating and deposit abandonment and site restoration
funding are detailed in SKK Migas PTK (Pedoman Tata Kerja) No. 040 of 2018.
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MEMR Regulation No. 02P/1992
Also there are more detailed duties required to be completed by the various
stakeholders concerned, including land reclamation under MEMR Regulation No.
02P/1992. Also, Government Regulation No. 17 of 1974 regarding supervision of
Implementation of Offshore Oil and Gas Exploration, which requires a
dismantlement of facilities that are no longer used. A PTK regulation issued in 2015
on Work Completion Approval, lists well-plugging, as one item making up
completion of drilling work.
Regulation update
The Indonesia Oil & Gas Regulator (SKK) has recently released a new regulation in
2018 that all new platforms shall retain 5% of revenue for decommissioning
process.xxii
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INTERNATIONAL TREATIES
Indonesia is subject to a variety of international and regional agreements concerning
its onshore and maritimexxiii territories, as they apply to well abandonment and
decommissioning. These include membership of the ASEAN (Association of South
East Asian States) Council of Petroleum Guidelines (ASCOPE), Geneva Convention
1958, United Nations Law of the Sea 1958 and 1982, Basel Convention 1992 and
2011, and COBSEA. Here below is an example of where international treaties might
affect decommissioning in Indonesia. See Figure 4.
Figure 4 United Nations Convention on the Law of the Sea
Source 53 By historicair 16:23, 22 April 2006 (UTC) - Adapted from Image:Zones maritimes UNCLOS.jpg by an anonymous user, CC BY-SA
3.0, https://commons.wikimedia.org/w/index.php?curid=726139
UNITED NATIONS CONVENTION ON THE CONTINENTAL SHELF 1958
The Conventionxxiv set the original presumption of removal as the base case for
decommissioning, requiring disused installations to be entirely removed, however it
does not include pipelines as part of the infrastructure to be removed
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UNITED NATIONS CONVENTION ON THE LAW OF THE SEA 1982 (UNCLOS).
UNCLOSxxv concerns any abandoned installations and structures are to be removed,
while adopting international standards established by competent international
organizations.
BASEL CONVENTION 1989 AND 2011.
The Basel Convention on Trans-boundary Wastexxvi was developed to regulate the
international shipment and disposal of hazardous wastes. Under this Convention,
waste can only be exported if both state of import and export have given their
consent in writing to the import.
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REGIONAL AGREEMENTS
The two significant agreements that apply to decommissioning are COBSEA and
ASCOPE.
COORDINATING BODY OF THE SEAS OF SOUTH EAST ASIA (COBSEA) REGIONAL
SEA.
The organisation promotes compliance with existing environmental treaties,
although it does not make specific reference to decommissioning of oil and gas
installations.xxvii
ASEAN COUNCIL OF PETROLEUM (ASCOPE) GUIDELINES
The guidelines were drafted to compliment member countries’ own
decommissioning procedures rather than replace them. Thailand, Malaysia,
Indonesia, Brunei and Myanmar are all members of ASCOPE.xxviii
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OTHER OPPORTUNITIES
It is not only Indonesia, but also the whole of the Southeast Asian region, where
future opportunities for oil and gas rigs decommissioning are plentiful.
One study estimates that there are over 380 oil and gas fields in the region destined
to cease production in the next decade. This would involve some 35,000 offshore
wells, serviced by 2,600 platforms representing 7.5 million tons of steel and over
55,000 kilometers of pipelines. According to energy consultants, Wood Mackenzie's
latest analysis, decommissioning would cost at least $100 billion.
In addition, Australia offers a promising target for specialist decommissioning
contractors. Over the next 50 years, the anticipated cost for decommissioning
operations in Australia is over US$21 billion.xxix
RENEWABLES OPPORTUNITIES
Figure 5 Offshore wind
Source 4 Copyright: <a href="https://www.123rf.com/profile_tele52">tele52 / 123RF Stock Photo</a>
The ASEAN region alone has plans to acquire 23 percent of its primary energy from
renewables by 2025. Based on the International Renewable Energy Agency (IRENA)
analysis, achieving the target will require an estimated annual investment of $27
billion, equivalent to one percent of regional GDP, for the next eight years – a tenfold
increase on 2016 investment volumes. This implies that the region’s commercial
solarxxx and windxxxi installations with a life of just 20 years will require
refurbishment, with the first due for replacement or decommissioning, as soon as the
2030s. See figure 5.
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CONCLUSION
Indonesia, like other Southeast Asian states with a history of oil and gas exploration
and production, are at the early stages of creating and implementing the relevant
legislative and guidance frameworks necessary to implement the eventual
decommissioning of petroleum assets.
To tackle the knowledge gap, for example, American-based Chevron and Anglo
Dutch Shell are already collaborating with Thai and Bruneian regulators respectively,
with knowledge transfer and pilot project initiatives. Because of the pioneering state
of decommissioning efforts there is a considerable lack of local expertise, relevant
government policies and legislation.
One thing is certain, opportunities exist for increased information sharing and
capability building within and between both regulators and operators to further
encourage consistent, consensual and cost and time efficient outcomes. This
increased interaction and co-operation would be beneficial given the imminent need
to manage the large inventory of ageing infrastructure in the region.
SOURCES
i https://www.bcg.com/en-gb/publications/2017/upstream-oil-gas-energy-environment-indonesia-billion.aspx ii https://www.pwc.com/id/en/energy-utilities-mining/assets/oil%20and%20gas/oil-and-gas-guide-2017.pdf
iii https://academic.oup.com/jwelb/article/11/2/116/4958804
iv https://www.offshore-technology.com/comment/pertamina-poised-capitalise-indonesias-improved-gross-
split-psc-terms/ v https://www.offshore-technology.com/comment/thailand-indonesia-oil-and-gas/
vi https://en.wikipedia.org/wiki/Energy_in_Indonesia
vii https://www.indonesia-investments.com/news/todays-headlines/what-are-the-biggest-oil-gas-companies-
in-indonesia/item9000? viii
https://www.thejakartapost.com/news/2019/07/10/govt-misses-half-year-target-for-oil-gas-production.html ix [email protected]
x https://www.bbc.com/future/article/20160804-what-it-takes-to-dismantle-an-oil-rig
xi https://psmag.com/environment/rejiggering-the-rigs
xiii https://www.nicnewmanoxford.com/quatre-ltd-esms-products-services-provides-new-funding-
environmental-liabilities-solution-albertas-oil-gas-wells-oil-sands-extractive-industries-environmental-liabilities/ xiv
https://breakbulk.com/Articles/asias-decommissioning-tsunami xv
https://hmc.heerema.com/news-media/news/world-record-heeremas-crane-vessel-sleipnir-lifts-15300-tonnes/ xvii
https://www.offshoreenergytoday.com/worlds-largest-semi-submersible-crane-vessel-completed/ xviii
https://www.ospar.org/convention xix
https://blog.miragemachines.com/oil-and-gas-decommissioning-projects-awarded-in-2017 xx
https://www.energy-reporters.com/industry/uk-cuts-cost-of-north-sea-rig-decommissioning/ xxi
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xxii
[email protected] xxiii
https://www.nicnewmanoxford.com/maritime-boundary-disputes/ xxiv
https://treaties.un.org/Pages/ViewDetails.aspx?src=IND&mtdsg_no=XXI-4&chapter=21&clang=_en xxv
https://www.un.org/Depts/los/convention_agreements/convention_overview_convention.htm xxvi
http://www.basel.int xxvii
https://www.unenvironment.org/cobsea/ xxviii
http://www.ascope.org xxix
https://www.herbertsmithfreehills.com/latest-thinking/australian-decommissioning-discussion-paper-released xxx
https://www.nicnewmanoxford.com/solar-photovoltaic-pv-power-in-europe/ xxxi
https://www.nicnewmanoxford.com/wind-power-decommissioning-in-europe/