Notice to Lessees and Operators (NTL) of Federal Oil, Gas,
and Sulphur Leases in the Outer Continental Shelf

Deepwater Operations Plans

Outer Continental Shelf (OCS) lessees and operators have expressed concerns about the uncertainty of developing deepwater projects because the existing Minerals Management Service (MMS) regulations do not address the design and operating issues facing such projects. MMS formed a workgroup to address deepwater regulatory concerns. The workgroup's final report, dated April 17, 1995, identified several initiatives to improve the MMS deepwater regulatory program. The primary recommendation was that the information necessary to evaluate the operational aspects of a deepwater/subsea development project should be integrated into a Deepwater Operations Plan (DWOP) for MMS review.

This Notice to Lessees and Operators (NTL) alerts lessees/operators (you) that MMS, in accordance with 30 CFR 250.3 (b) and 30 CFR 250.34 (b)(5) and (7), now requires a DWOP for all deepwater development projects (water depths greater than 1,000 feet) and all projects utilizing subsea production technology. Projects that use conventional fixed-leg platforms do not need a DWOP.

The DWOP is designed to address industry and MMS concerns by allowing an operator to know, well in advance of significant spending, that their proposed methods of dealing with situations not specifically addressed in the regulations are acceptable to MMS. The DWOP will provide MMS with information specific to deepwater/subsea equipment issues to demonstrate that a deepwater project is being developed in an acceptable manner as mandated in the OCS Lands Act as amended and 30 CFR 250. MMS will review deepwater development activities from a total system perspective, emphasizing the operational safety, environmental protection, and conservation of natural resources.

You should submit a DWOP in three parts: Conceptual, Preliminary, and Final. Attachment 1 provides general guidance on when it may be appropriate to submit each part of the DWOP to MMS. For projects already beyond the conceptual part, you should submit a preliminary plan as soon as possible. MMS will give approval to each part of the plan. MMS has designed the phased submittal of the plan to facilitate early dialogue between MMS and the lessee or operator, recognizing the evolution of the project information as planning proceeds.

Your DWOP should address all the appropriate sections of the attached guidelines for preparing a DWOP (Attachment 2). These guidelines were modeled on subsea development projects. Plans for projects based on floating production systems (including Tension Leg Platforms and Spars) and nonconventional fixed platforms (guyed towers, compliant towers, etc.) should follow the applicable parts from the enclosed guidelines. You should also consult with MMS on additional information needs relative to these facilities.

You should submit 3 copies of a DWOP to the MMS's Gulf of Mexico OCS Region, Attention: Chief, Technical Assessment and Operations Support Section (MS 5221). If your project involves more than one MMS District, you should submit 4 copies of the DWOP. Once MMS determines that each part of the DWOP contains all the necessary information, MMS will approve each part within the following time schedule (calendar days):

Conceptual Part - 30 days
Preliminary Part - 90 days
Final Part - 60 days

The guidelines for the DWOP do not require you to submit documentation addressing resource conservation. This type of documentation will be addressed in a subsequent NTL being developed by MMS covering a Supplemental Plan of Exploration (SPOE). You should submit detailed reservoir management information with the SPOE, or the initial Development and Production Plan, or Development Operations Coordination Document.

MMS does not intend for the DWOP to replace other submittals (plans, applications, permits, etc.) required by the regulations. You may minimize duplication by cross-referencing information whenever appropriate. Your plan, in conjunction with the existing MMS regulations, will be the basis by which you operate the deepwater project.

MMS may require additional operations summaries for deepwater projects. These summaries will be similar to the annual unit operations plan. You must provide pertinent information regarding project milestones and achievements, expected operations that could affect the development strategy, and updated reservoir and geologic information obtained from the drilling or completion of additional wells.

[signed] Lucy R. Querques
Acting Associate Director for Offshore Energy and Minerals Management
DATE: August 9, 1996

This NTL can also be found at the MMS worldwide website at HTTP://WWW.MMS.GOV.

2 Attachments as follows:

  1. General Timing for the Three Parts of the Deepwater Operations Plan

  2. Guidelines for Deepwater Operations Plan for Subsea Projects

These two attachments are lengthy. Therefore, we've made them available for viewing or downloading with the Adobe Acrobat .PDF reader.

  Documents are in Adobe Acrobat's .pdf (portable document file) format. These files can be downloaded and read using the free Adobe Acrobat Reader.

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Last Updated: 08/14/2008, 09:57 AM