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Abstract
This article examines the challenges faced by Norway in implementing intergenerational equity in its offshore petroleum licensing regime. Norway has been considered by many to be a leader in the regulation of its offshore petroleum, with an emphasis on state control and encouraging a prudent approach by operators, but also emphasising rational and efficient solutions. Unlike some other countries, it has also enacted legislation to support its convention obligations in relation to matters like pollution and the protection of biodiversity. These obligations are also reflected in its constitution. But climate change and other challenges as it moves exploration into more sensitive northern areas are throwing a spotlight on the conflict between those matters and Norway’s vital oil economy.
Disclosure statement
No potential conflict of interest was reported by the author.
Notes
1 John AP Chandler, ‘Improving Outcomes for Future Generations in Petroleum Licensing Regimes – an Assessment of the United Kingdom’s Regime: Part 1 – the Assessment Methodology’ (2020) JENRL 182669 <www.tandfonline.com/[Articlehttps://doi.org/10.1080/02646811.2020.1826669>
2 Bard Lahn of the Center for Climate Change Research in Oslo in an interview with Jariel Arvin; Jariel Arvin, ‘Norway Wants to Lead on Climate Change. But First It Must Face Its Legacy of Oil and Gas’, 15 January 2021 Vox <https://www.vox.com/22227063/norway-oil-gas-climate-change>
3 Kenneth W Dam, Oil Resources: Who Gets What How? (University of Chicago Press 1976) 55
4 Ernst Nordtveit, ‘Legal Character of Petroleum Licences under Norwegian Law’ in Tina Soliman Hunter, Jorn Oyrehagen Sunde and Ernst Nordtveit (eds), The Character of Petroleum Licences: A Legal Culture Analysis (Edward Elgar, 2020) 168
5 White Paper No. 76, Exploration for and Exploitation of Subsea Natural Resources on the Norwegian Continental Shelf (1970–1971)
6 Regulator Interview, January 2020. Interviews were conducted pursuant to The University of Western Australia Human Research Ethics Approval RA/4/20527. See also Nordtveit (n 4) 167. The ten principles are often referred to as the ten commandments. The first is that ‘National supervision and control must be ensured for all operations on the NCS (Norwegian Continental Shelf)’. For more general background on the parliamentary system and its relationship to the executive see Tonje Pareli Gormley and Merete Kristensen ‘Hydrocarbon Policy and Legislation: Norway’ in Eduardo G Pereira and Henrik Bjornebye (eds), Regulating Offshore Petroleum Resources: The British and Norwegian Models (Edward Elgar, 2019)
7 This provides that ‘The Norwegian State has the proprietary right to subsea petroleum deposits and the exclusive right to resource management’
8 White Paper (no 45, Principle 7). Statoil changed its name to Equinor in 2018. Petoro took over holding the Norwegian state’s direct financial interest in 2001
9 Regulator interview, January 2020
10 Ibid and Dam (n 3)
11 Norwegian Petroleum, Fundamental Regulatory Principles <norskpetroleum.no>. The website is run in cooperation by the Norwegian Ministry of Petroleum and Energy and the Norwegian Petroleum Directorate
12 Ibid – or, as it is expressed there, ‘The regulatory framework for petroleum activities has therefore been designed to give the best possible balance between the companies’ and the authorities’ interests’
13 Its correct name is the Government Pension Fund Global. The Ministry of Finance has overall responsibility for the Fund, and Norges Bank Investment Management is the manager. For more information see the manager’s website: The fund <nbim.no>
14 Regulator interview, January 2020
15 The expression ‘The Dutch Disease’ was first used in the 1970s in discussing the effect of gas on the Dutch economy
16 Regulator interview, April 2021
17 See the manager’s website (n 13). Its value then was 12,340 billion kroner
18 See The Government Revenues <https://www.norskpetroleum.no/en/economy/governments-revenues/>
19 See Government Pension Fund Global (GPFG) < https://www.regjeringen.no/en/topics/the-economy/the-government-pension-fund/government-pension-fund-global-gpfg/id697027/>
20 Gormley and Kristensen (n 6) 50
21 Regulator Interview, April 2021
22 See further in Section 2.4
23 Nordtveit (n 4) 161–168
24 Ibid
25 See paragraph following n 6
26 NMPE’s website says: ‘The principal responsibility of the Ministry of Petroleum and Energy is to achieve a coordinated and integrated energy policy. A primary objective is to ensure high value creation through efficient and environment-friendly management of Norway’s energy resources’ <https://www.regjeringen.no/en/dep/oed/id750/>
27 Hans Jacob Bull, ‘Norwegian Offshore Petroleum: The Legal and Administrative Response’ (1981) 25 Scandinavian Studies in Law 31, at 40
28 See Norwegian Petroleum Directorate, About Us, updated 15 November 2021 <https://www.npd.no/en/about-us/>
29 NPCA s 81 states that at national level the pollution control authorities are ‘the King, the Ministry and the Norwegian Pollution Control Authority’. Section 8 says that the provisions of the act apply to ‘exploration for and production and utilization of natural subsea resources on the Norwegian part of the continental shelf, including decommissioning of facilities’
30 See the NEA’s website: <https://www.environmentagency.no/norwegian-environment-agency/about-us/>
31 For the history see the webpage of the NPSA, ‘How It Began’ <https://www.ptil.no/en/about-us/role-and-area-of-responsibility/our-history/>. For more on the NCA, including its history, see its website <https://kystverket.no>
32 Nordtveit (n 4) 164
33 Constitution of the Kingdom of Norway, LOV 1814-05-17 no. 00: Kongeriget Norges Grundlov <Lovdata.no>. For an unofficial English translation of the Constitution see <https://lovdata.no/dokument/NLE/lov/1814-05-17>
34 Supreme Court Justice Dr Juris Arnfinn Bardsen, ‘Guardians of Human Rights in Norway: Challenging Mandates in a New Era’, Centre on Law and Social Transformation in collaboration with Bergen Resource Center, Litteraturhuset Bergen (11 May 2016) 4 <https://www.domstol.no/globalassets/upload/hret/artikler-og-foredrag/guardians-of-human-rights---11052016.pdf>. He states that one consequence was that ‘in the hierarchy of legal norms that are applicable within the Norwegian jurisdiction, constitutional rights have the highest possible rank’. Human rights conventions ratified by Norway include the European Convention on Human Rights (ETS 5), opened for signature 4 November 1950 (entered into force 3 September 1953)
35 Constitution of the Kingdom of Norway (n 34), Article 112
36 In the 1992 version the opening two sentences read: ‘Every person has a right to an environment that is conducive to health and to natural surroundings whose productivity and diversity are preserved. Natural resources should be made use of on the basis of comprehensive long-term considerations whereby this right will be safeguarded for future generations’. On this see the judgement in English of Foreningen Greenpeace Nordern and others v The Government of Norway; case number 16-1666741TVI-OTIR/06 Oslo District Court 32, 5
37 Greenpeace Case (n 36)
38 For the judgement in English see <https://elaw.org/system/files/attachments/publicresource/OsloDistrictCt_20180104.pdf>. This does not appear to be an official translation. An unofficial translation of the Court of Appeal decision is available at <https://climate-laws.org/geographies/norway/litigation_cases/greenpeace-norway-v-government-of-norway>. For a discussion of the decision see Petra Minnerop and Ida Roestegaard, ‘In Search of a Fair Share: Article 112 Norwegian Constitution, International Law and Emerging Inter-Jurisdictional Discourse in Climate Litigation’ (2021) 44 Fordham Journal of International Law 847
39 Greenpeace Case (n 36) 19
40 Ibid 19
41 Ibid 45
42 Ibid 30
43 Ibid 27
44 Four judges found fault with the procedures followed in the Decision, but the majority disagreed
45 The Supreme Court decision has not been translated into English at the time of writing. The comments made in this and the next paragraph are based on an interview in February 2021 with a regulator involved in the case. For a discussion of the Supreme Court decision and the prior decisions see Christina Voigt, ‘The First Climate Change Judgement before the Norwegian Supreme Court: Aligning Law with Politics’ (2021) 33 Journal of Environmental Law 697
46 The main sources of those obligations are the Convention on Biological Diversity (CBD), opened for signature 5 June 1992, 1760 UNTS 79 (entered into force 29 December 1995) and the Bern Convention (ETS No 104) opened for signature at Bern on 19 September 1979 (entered into force on 1 June 1982). Norway ratified it in May 1986 with effect from 1 September 1986. Article 1 of the CBD sets out objectives including conservation of biological diversity and sustainable use of its components, which are mirrored in the NDA. Also relevant are the following conventions that Norway has ratified: Convention Concerning the Protection of World Cultural and Natural Heritage (World Heritage Convention), opened for signature 16 November 1972, 1037 UNTS 151 (entered into force 9 March 1977) and The Convention on Wetlands of International Importance Especially as Waterfowl Habitat (‘Ramsar Convention’), opened for signature at Ramsar 2 February 1971, 996 UNTS 245 (entered into force for Norway 21 December 1975)
47 Also relevant are the Wildlife Act 1981 (Norway), the Marine Resources Act 2008 (Norway) and the Salmonids and Freshwater Fish Act 1992 (Norway)
48 NDA s 1
49 NDA s 2 says they apply ‘to the extent they are appropriate’. They include the purpose of the act (s 1), management goals (ss 4 and 5), other general principles of sustainable use (ss 7–10), the principles for the management of species and wild salmonids and sea-birds (ss 15 and 16) and access to genetic material (ss 57 and 58)
50 NDA s 4
51 s 5
52 ss 9 and 10
53 For example, a decision under NPCA s 11 – regarding which see Section 2.4 – will be supplemented by NDA s 9
54 World Heritage Convention (n 46). Norway has eight listed world heritage sites – see <https://whc.unesco.org/en/committee>
55 Ramsar Convention (n 46). Norway has 63 Ramsar sites – see <https://www.ramsar.org/wetland/norway>
56 Report No 37 to the Storting (2008–2009) Integrated Management of the Marine Environment of the Norwegian Sea < Report No. 37 (2008–2009) to the Storting <regjeringen.no> 7–10
57 See Gormley and Kristensen (n 6)
58 NPCA s 4
59 NPCA s 1
60 For the offshore, the important ones are The United Nations Convention on the Law of the Sea (‘UNCLOS’) opened for signature 10 December 1982, 1833 UNTS 3 (entered into force 16 November 1994), particularly Articles 60 (3), 120 and 194. The London Convention on the Prevention of Marine Pollution by Dumping of Wastes and other Matter of 1972 (London Convention) opened for signature 29 December 1972, 1046 UNTS 1977, as amended by the 1996 Protocol (entered into force 30 August 1975). The Oslo/Paris Convention for the Protection of the Marine Environment of the North East Atlantic (‘OSPAR’) 2354 UNTS 67, opened for signature 22 September 1992 (entered into force 25 March 1998)
61 Other causes mentioned in the definition are noise, vibrations, light, radiation and changes in temperature
62 NPCA s 2 Guidelines
63 Regulator interview, December 2020
64 They are all available on the website of the Safety Authority <www.ptil.no/en/>
65 NEFR s 10 requires activities to be prudent based on an assessment of all relevant factors
66 NEFR s 11
67 NEFR s 11
68 NEFR s 12
69 These start with The United Nations Framework Convention on Climate Change (A/RES/48/189) opened for signature on 4 June 1992 (entered into force 21 March 1994)
70 Climate Change Act 2018 (Norway) ss 5 and 6. Norway submitted an enhanced target in February 2020 to reduce greenhouse gas emissions by at least 50 per cent and towards 55 per cent by 2030
71 White Paper No 13 (2020–2021) Climate Plan for 2021–2030
72 Ibid 20
73 White Paper No 36 (2020–2021)
74 White Paper No 14 (2020–2021)
75 Ibid at 9
76 Ibid at 13
77 Norwegian Ministry of the Environment, Norwegian Climate Policy, Summary in English: Report to the Storting No 34 (2006-7) 39. See Norwegian Petroleum Directorate, Options for Reduced Greenhouse Gas Emissions in the Petroleum Sector <https://www.npd.no/globalassets/norsk/1-aktuelt/nyheter/klimakur2020/faktaark-eng.pdf>; and Norwegian Petroleum, ‘Emissions to Air’ <https://www.norskpetroleum.no/en/environment-and-technology-/emissions-to-air>
78 Norwegian Petroleum Directorate, Options (n 77). The Long Term Perspectives on the Norwegian Economy 2021 paper (n 74) announces at 19 the aim that by 2030 ‘the petroleum industry will be producing oil and gas efficiently’
79 Norwegian Minstry of Climate and Environment, Fourth Biennial Report Under The UN Framework Convention on Climate Change <www.regjeringen.no/contentassets/22242455513549449fe30c2a835da953/t-1569e.pdf> 30
80 Ibid. Norway also has a Greenhouse Gas Emissions Trading Act
81 Royal Ministry of Foreign Affairs Norway, National Strategy for Sustainable Development <www.regjeringen.no/globalassets/upload/kilde/ud/bro/2003/0013/ddd/pdfv/171847-nsbu.pdf>
83 Ibid 7
84 Ibid 19. The other principles are the precautionary principle, the ecosystem approach, the polluter-pays principle, common but differentiated responsibilities, coordination across policy areas and joint responsibility for joint efforts
85 Ibid 34
86 Ibid
87 Regulator Interview, January 2021. Also see Nordtveit (n 4) 163 who considers that other directives, such as those related to licensing, have been very influential on the Norwegian regime
88 [2001] OJ L197/30. While there appears to be some disagreement about following this directive in Norway for programmes in general, s 3.1 shows that impact assessment is used extensively
89 European Union Council Directive 2009/147/EC (‘EU Birds Directive’) ([2009] OJL 20/7); European Union Council Directive 92/43/EEC (‘EU Habitats Directive’) ([1992] OJL 206/7)
90 Directive 2013/30/EU of the European Parliament and of the Council of 12 June 2013 on Safety of Oil and Gas Operations, which requires a competent authority to be appointed to approve major hazard reports
91 Such as the Bern Convention (n 46) and the Agreement for Cooperation in Dealing with Pollution of the North Sea by Oil 1969 (Bonn Agreement) <www.bonnagreement.org/>. Norway also appears to be implementing the European Union Marine Strategy Framework Directive (2008/56/EC of the European Parliament and of the Council of 17 June 2008), regarding which see Report No 37 (n 56) 9. An important focus of the strategy framework is achieving good environmental status for marine ecosystems in Europe’s seas – see EU Coastal and Marine Policy <https://ec.europa.eu/environment/marine/eu-coast-and-marine-policy/marine-strategy-framework-directive/index_en.htm>
92 See Chandler, ‘Improving Outcomes’ (n 1) 4
93 For a review of the history from 1972 including the Stockholm and Rio conferences see Ved P Nanda and George (Rock) Pring, International Environmental Law and Policy for the 21st Century (Brill 2012) ch 4
94 United Nations Environment Programme What Is Impact Assessment <www.cbd.int/impact/whatis.shtml>
95 John AP Chandler, ‘Developing Offshore Petroleum to Meet Socio-economic Objectives: Lessons from Australia, Norway and the United Kingdom’, 144 Energy Policy (2020) 111618
96 Regulator Interview, January 2021. Norway has an impact assessment process for onshore planning programmes under the Planning and Building Act 2008 (Norway) s 4–2
97 Convention on Environmental Assessment in a Transboundary Context, a United Nations Economics Commission for Europe Convention, signed at Espoo in Finland in 1991 (entered into force on 10 September 1997). Norway ratified the protocol on 14 September 2007. In the protocol Norway agrees to implement strategic environmental assessment of plans and programmes of the kind listed, which include offshore hydrocarbon production, that are ‘likely to have significant environmental, including health, effects’
98 NPA s 4–2; NPR s 22
99 Christopher Wood, Environmental Impact Assessment: A Comparative Review (2nd edn, Pearson Educational 2003) 6 sets out eight iterative steps of the EIA process emanating from that developed in the USA. These commence with consideration of alternative means of achieving objectives, designing the selected proposal, screening to determine if the process is necessary, scoping to determine the topics to be covered, preparing the EIA report (describing the proposal and assessing the magnitude and significance of impacts), reviewing the adequacy of the report, making a decision on the proposal and monitoring impacts if it is implemented. Setting evaluation criteria and evaluating a system is a more complex task. For suggested criteria see Wood 12
100 NPA s 1–6 defines petroleum activities as ‘all activities associated with subsea petroleum deposits, including exploration, exploration drilling, production, transportation, utilisation and decommissioning, including planning of such activities, but not including, however, transport of petroleum in bulk by ship’
101 Regulator Interview, January 2021
102 Ibid
103 NPR s 6(a)
104 NPR s 6(b)
105 NPR s 6(c)
106 For the steps see Wood (n 99)
107 Tyra Ohman, ‘Strategic Environmental Assessment in Norway’s Offshore Oil and Gas’ (MA thesis, University of Saskatchewan, 2011) 67
108 Regulator Interview, December 2020
109 Courtney Fidler and Bram Noble, ‘Advancing Strategic Environmental Assessment in the Offshore Oil and Gas Sector: Lessons from Norway, Canada and the United Kingdom’ (2012) 34 Environmental Impact Assessment Review 12
110 Fidler and Noble (n 109) 14
111 Report No 37 (n 56) 92
112 For example Norwegian Ministry of Foreign Affairs, The High North Visions and Strategies (Report to the Storting), Meld. St. 7, 2011–2012
113 Its full title is ‘Guidelines for Plan for Development and Operation of a Petroleum Deposit (PDO) and Plan for Installation and Operation of Facilities for Transportation and Utilisation of Petroleum (PIO)’ (Ministry for Petroleum and Energy and Ministry for Labour and Social Affairs, 21 March 2018)
114 NPDO Guideline 22; NPA ss 4–2 and 4–3
115 NPDO Guideline para 2–3
116 NPDO Guideline para 2–4, 5–8 and 5–9; and NPR s 22(a). The proponent should also consider the NDA in devising the programme: NPDO Guideline 9
117 In practice it is usually the operator – NPDO Guideline 18
118 NPR s 22
119 NPR ss 22a and 22
120 Ibid
121 NPDO Guideline 8
122 Ibid
123 NPDO Guideline 18
124 NDA ss 33 and 35
125 NDA s 14. The Sami are indigenous people who inhabit large parts of northern Norway
126 Part IV of the Cultural Heritage Act 1978 (Norway). Also relevant is the World Heritage Convention (n 46)
127 See NPCA s 2.4 at n 59
128 2354 UNTS 67, opened for signature 22 September 1992 (entered into force 25 March 1968). Norway is a contracting party to OSPAR that contains obligations to protect and preserve the marine environment of the North East Atlantic. OSPAR Recommendations 2001/01 and 2012/5 deal with discharges. The recommendations are available at <www.ospar.org>, as is more information about the work of the OSPAR Commission
129 For example drainage water (s 60a) and injection of produced water – NPAR ch 3
130 OSPAR Decision 98/3 available at <www.ospar.org/work-areas/oic/installations>. Obligations are also fleshed out in IMO Guidelines and Standards 1989 published by the International Maritime Organization – website <imo.org>. For discussion of decommissioning and decommissioning plans in Norway see Catherine Banet, ‘Regulating the Reuse and Repurposing of Oil and Gas Installations in the Context of Decommissioning: Creating Incentives and Enabling Energy System Integration’ in AP de Fonseca and others (eds), The Regulation of Decommissioning, Abandonment and Reuse Initiatives in the Oil and Gas Industry (Wolters Kluwer 2020) 212–215
131 Norwegian Petroleum Directorate, Responsible Removal of Old Facilities <www.npd.no/en/facts/production/shutdown-and-removal/responsible-removal-of-old-facilities/>
132 Available at <www.ptil.no/en/regulations>
133 Regulations on greenhouse gas emissions: Forskrift om kvoteplikt og handel med kvoter for utslipp av klimagasser (klimakvoteforskriften) – Kapittel 1. Kvotepliktige utslipp – Lovdata
134 National Contingency Plan, Emergency Preparedness for Actual or Threatened Acute Pollution in Norway (Norwegian Coastal Authority 2015)
135 For example, seismic survey has to be reported to NPD and other regulators under s 6 NPR
136 For example, fines can be levied or offences created under NPA ss 10–16 and 10–17 for breach of orders issued under the NPA. An annual report is required under NPR s 47
137 See s 66 and 67 of the NEFR. See also the PSA’s website for its description of supervision <https://www.ptil.no/en/supervision/audit-reports/about-supervision/>
138 For an example see the investigation into the leak of 67 cubic metres of crude oil on loading from the Stratfjord A Facility in October 2015 <https://www.ptil.no/contentassets/dc5f95c30fc644f4bf7ddaf42320541e/investigation-report---statoil---statfjord-ols-b.pdf>
139 s 7–1 defines pollution damage as ‘damage or loss caused by pollution as a consequence of effluence or discharge of petroleum from a facility, including a well, and costs of reasonable measures to avert or limit such damage or such loss, as well as damage or loss as a consequence of such measures. Damage or loss incurred by fishermen as a consequence of reduced possibilities for fishing is also included in pollution damage’
140 NCPA s 53
141 Angela Carpenter, ‘Oil Pollution in the North Sea: The Impact of Governance Measures on Oil Pollution over Several Decades’ (2019) 845 Hydrobiologia (2019) 109
142 Ibid
143 See Carpenter (n 141) and the Bonn Agreement (n 91)
144 NPAR ch X; NMR s 5. The NEA publishes guidelines on monitoring and reporting
145 Regulator Interview, December 2020
146 For example, as stated in October 2019 by NPD in connection with an industry workshop (NPD, More Technology to Create Value <www.npd.no/en/facts/news/general-news/2019/more-technology-to-create-value/>
147 The regulator in Norway can attend meetings of licensee joint ventures and receives minutes. Regulator Interview, January 2020
148 Such as NPCA s 2 guideline 3; NEFR s 11; and the NPDO Guideline at 5 and 26
149 NPDO Guideline 10
150 Ibid 32
151 NPD (October 2019), More Technology to Create Value <www.npd.no/en/facts/news/general-news/2019/more-technology-to-create-value/>. Technology plans have been part of the OGA’s strategy in the UK <www.ogauthority.co.uk/media/5902/oga_se8_technology_deployment_july_2019.pdf>
152 Norway’s Technology Strategy, Research Council of Norway, Oil and Gas for the 21st Century – OG 21 (December 2012) <www.kooperation-international.de/uploads/media/OG21strategy013.pdf> 19
153 Ibid. For updates of the strategy see the NPD website at <www.npd.no/en/facts/technology/>
154 Norway's Technology Strategy (n 152) 27
155 NPA s 10–1
156 See, for example, ss 5.5 and 5.6 of the NPDO Guideline dealing with supervisory duty and organisation and implementation in the development part of the guideline (at 33 and 34); and ch VII of NPAR (see Section 2.3)
157 In April 2020 one industry publication described it as ‘the greatest challenge yet to face our industry’, with Norway still able ‘cover its costs but Government will see tax revenues plummet’. See Yvonne Telford, ‘The Current Challenges for the UK and Norway in the Face of Covid 19’ Energy Voice April 2020 <www.energyvoice.com/oilandgas/north-sea/232636/the-current-challenges-for-the-uk-and-norway-in-the-face-of-covid-19/>
158 NPD, ‘Cutting Oil Production’ (30 April 2020) <www.npd.no/en/facts/news/general-news/2020/cutting-oil-production/>
159 Regulator Interview, April 2021
160 This is supported by commentary, for example Gormley and Kristensen (n 6) and Dam (n 3); regulator interviews and government publications, such as the Norwegian Ministry of Petroleum and Energy’s An Industry for the Future: Norway’s Petroleum Activities (Meld. St. 28 (2010–2011) 6
161 Norwegian Petroleum, ‘Exploration Policy’ (updated 9 May 2017) <www.norskpetroleum.no/en/exploration/exploration-policy/>
162 An Industry for the Future (n 160) 6
163 Gormley and Kristensen (n 6) 51
164 See s 1.2 and, for example, An Industry for the Future (n 160)
165 Each year a review of activities is published. For 2019 it was <www.npd.no/en/facts/news/general-news/2020/the-shelf-in-2019--a-good-year-overall/>
166 Chandler, ‘Developing Offshore Petroleum’ (n 95)
167 Norwegian Ministry of the Environment, Norwegian Climate Policy, Summary in English: Report to the Storting No 34 (2006–7) 39. See Norwegian Petroleum Directorate, Options (n 77)
168 Regulator Interview, April 2021
169 See the discussion of the Greenpeace Case in Section 2.1
170 NPDO Guideline 9
171 NPR s 20. It must also state ‘measures which may be required in order to remedy significant negative effects on the environment’
172 See the discussion in Section 4.2
173 See Section 2.4
174 An Industry for the Future (n 160) 7
175 Ida Irene Bergstrom, ‘Reduced Norwegian Oil Exports Will Reduce Global Emissions According to Researchers’ (25 August 2021) <https://sciencenorway.no>
176 SGI Network < www.sgi-network.org/2019/Norway/Environmental_Policies>. In contrast, Australia ranks 33rd on environmental policy and the UK 6th
177 This was a significant factor delaying the opening of some new areas. For example, the government’s political platform was to not even consider an impact assessment of the area around Lofoten until 2021. This is a sensitive area because it is a breeding ground for cod, important for wildlife in general, and also attractive for tourism. Regulator Interview, January 2020
178 Ewa Krukowska and Milda Sepuyte, ‘EU to Import More Gas from Norway as Russia Cuts Its Flows’ (Bloomberg 22 June 2022) <www.bloomberg.com/news/articles/2022-06-23/eu-to-import-more-gas-from-norway-as-russia-cuts-its-flows>