Guidance for Submitting Exploration Plans and Development Operations Coordination Documents

UNITED STATES DEPARTMENT OF THE INTERIOR
MINERALS MANAGEMENT SERVICE
GULF OF MEXICO OCS REGION

NOTICE TO LESSEES AND OPERATORS OF FEDERAL OIL, GAS, AND SULPHUR
LEASES IN THE OUTER CONTINENTAL SHELF, GULF OF MEXICO OCS REGION

Guidance for Submitting Exploration Plans and
Development Operations Coordination Documents

This Notice to Lessees and Operators (NTL) supersedes NTL No. 2002-G08, effective August 29, 2002. The table below summarizes the changes. The purpose of this NTL is to provide guidance on preparing Exploration Plans (EP’s) and Development Operations Coordination Documents (DOCD’s) that are required by current 30 CFR 250, Subpart B.

NTL Part	Description of Change
General Requirements for EP’s and DOCD’s	On page 3, deletes the trigger that requires automatic revision of an approved EP or DOCD to conduct an activity if more than 10 years has elapsed since any previous activity was conducted.
Copies of EP’s and DOCD’s	On page 4, adds a recommendation that you submit electronic copies of EP’s and DOCD’s as a single file.
Appendix A	Adds a sentence to paragraph (D) for DOCD’s concerning information on the platform installation method.
Appendix B	Adds prospect name to EP information.
Appendix C	Clarifies that shallow hazards assessments are required only for surface locations that the MMS GOMR has not previously approved. Clarifies under Hydrogen Sulfide (H₂S) Information in this Appendix that you may consider any reference to correlative stratigraphic sections to be proprietary.
Appendix D	Changes the title to Biological and Physical Information. Updates the reference for “Remotely Operated Vehicle (ROV) Surveys” to NTL No. 2003-G03 for guidance on providing ROV survey information. Adds a reference to live bottoms reports and archaeological survey reports.
Appendix E	Clarifies when to provide “disposed wastes information” and corrects the website address for a listing of exempted areas for deepwater drilling operations.
Appendix F	Reformats the appendix to provide triggers with each information item, makes reference to subregional OSRP’s, eliminates the need to list all companies covered by your OSRP, clarifies EP worst case scenario description, clarifies the instances when facility tanks and production vessels information is provided, and exempts oil characteristics information from EP’s.
Appendix I	Adds guidance for preparing coastal effects evaluations for Louisiana; in Attachment 1, removes the phrase “and discharges” from Louisiana’s required necessary data and information; and, in Attachment 1, modifies paragraph (b) and adds paragraphs (d) through (k) as information that Florida has specifically identified in their management program as required necessary data and information.

Please note that the Minerals Management Service (MMS) published a Notice of Proposed Rulemaking (NPR) to restructure and revise the current 30 CFR 250, Subpart B regulations (May 17, 2002, FR 35372-35396). In connection with the proposed rulemaking, the MMS Gulf of Mexico OCS Region (GOMR) developed a draft companion NTL to provide guidance on the proposed regulations. The draft NTL is posted with the NPR on the MMS Internet website at http://www.mms.gov/federalregister/2002.htm.

Information required by 30 CFR 250, Subpart B informs MMS, affected States, and the public of planned exploration, development, and production operations. Sections 30 CFR 250.196(a) and (b) specify the data and information that must be made available to the public without the consent of the lessee and under what circumstances and time period. Pursuant to 43 CFR 2.13(c)(9), we have determined that the following information you submit with an EP or DOCD may be considered proprietary. If you omit required information that is not proprietary from the Public Information copy of an EP or DOCD, the MMS GOMR will not deem the plan submitted. All information furnished as part of an EP and DOCD, except that identified below as being proprietary, will be made available to the affected States and the public in the Public Information copy of the plan.

Appendix	Item	Justification
Appendix A	EP and DOCD Item (A) – Discussion of the geological objectives (including a brief description of the hydrocarbon trapping elements). EP and DOCD Item (B) – BHL, TVD, MD information.	Geological information
Appendix B	DOCD Item (C) – Production rates and life of reserves	Geological information
Appendix C	All items under Geological and Geophysical Information except for the non-proprietary shallow hazards assessment in Item (E) and under Hydrogen Sulfide (H₂S) Information, any reference to correlative stratigraphic sections.	Geological and geophysical information
Appendix D	None	N/A
Appendix E	None	N/A
Appendix F	None	N/A
Appendix G	None	N/A
Appendix H	None	N/A
Appendix I	None	N/A
Appendix J	BHL, TVD, MD information.	Geological information

Before you conduct any exploration activities on an OCS lease or unit, MMS regulations require you to submit, and the MMS must approve, an EP that covers those activities. Before you conduct any development and production activities on an OCS lease or unit in the western Gulf of Mexico, MMS regulations require you to submit, and the MMS must approve, a DOCD that covers those activities. Before you conduct any development and production activities on a lease or unit in any OCS area in the eastern Gulf of Mexico, MMS regulations require you to submit, and the MMS must approve, a Development and Production Plan (DPP) that covers those activities. The MMS GOMR will provide guidelines for DPP’s at a future date.

In addition to Initial EP’s and DOCD’s (which are defined as the first OCS plans to be submitted after the lease is awarded), the MMS GOMR has determined that there are three types of revisions to EP's and DOCD's:

A Revised Plan, a revision to an approved OCS plan, proposes changes such as those in the location of a well or platform, type of drilling unit, or location of the onshore support base.

A Supplemental Plan, a revision to an approved OCS plan, proposes the addition of an activity that requires a permit.

Each of these types of OCS plans needs to contain only that information related to or affected by the proposed revision. However, make sure the description of the proposed revision is complete and includes the rationale for the proposed changes as they relate to the approved or pending OCS plan. It would also be helpful if you would reference in the revised OCS plan the approval date or MMS control number, if known, of the approved OCS plan you are revising.

1. Change the type of drilling rig (e.g., jack-up, platform rig, barge, submersible, semisubmersible, or drillship), production facility (e.g., caisson, fixed platform with piles, tension-leg platform, etc.), or transportation mode (e.g., pipeline, barge) you will use to carry out the activities under your approved plan.

2. Change the surface location of a well (or associated anchor) by more than 100 feet in water depths less than 400 meters, or by more than 500 feet in water depths 400 meters or greater.

3. Increase the emissions of an air pollutant to an amount greater than that in your approved plan.

4. Request a new hydrogen sulfide (H₂S) area classification or encounter a concentration of H₂S greater than 500 parts per million (ppm).

6. Change the approved anchor array pattern associated with your activities or increase the anchor radius by more than 500 feet if the MMS GOMR did not approve a specific anchor pattern.

Supplement your approved EP or DOCD when you propose to conduct activities on the lease(s) or unit that require permits and are not covered by your approved EP or DOCD.

To expedite the review and coordination of your EP’s and DOCD’s, the MMS GOMR recommends that you submit the following number of copies for both EP's and DOCD's:

1. Initial and Supplemental OCS Plans that describe activities on leases and unit areas on the OCS that affect the State of Florida (22 copies: 5 Proprietary and 17 Public Information).

2. Initial and Supplemental OCS Plans that describe activities on leases and unit areas on the OCS that affect the State of Alabama (10 copies: 5 Proprietary and 5 Public Information).

3. Initial and Supplemental OCS Plans that describe activities on leases and unit areas on the OCS that affect both the States of Mississippi and Louisiana (11 copies: 5 Proprietary and 6 Public Information).

4. Initial and Supplemental OCS Plans that describe activities on leases and unit areas on the OCS that affect both the States of Mississippi and Louisiana and that are exempted from Coastal Zone Management (CZM) certification requirements (9 copies: 5 Proprietary and 4 Public Information).

5. Initial and Supplemental OCS Plans that describe activities on leases and unit areas on the OCS that affect only the State of Louisiana (9 copies: 5 Proprietary and 4 Public Information).

6. Supplemental OCS Plans that describe activities on leases and unit areas on the OCS that affect only the State of Louisiana and that are exempted from CZM certification requirements (8 copies: 5 Proprietary and 3 Public Information).

7. Initial and Supplemental OCS Plans that describe activities on leases and unit areas on the OCS adjacent to the State of Texas (9 copies: 5 Proprietary and 4 Public Information).

8. Supplemental OCS Plans that describe activities on leases and unit areas on the OCS adjacent to the State of Texas and that are exempted from CZM certification requirements (8 copies: 5 Proprietary and 3 Public Information).

The MMS GOMR recommends that you submit 7 copies (5 Proprietary and 2 Public Information) for all revised and amended plans.

If you so choose, you may submit the copies above on separate CD-ROM’s. (However, submit at least one Proprietary copy on paper.) In order to expedite our review, the MMS GOMR recommends that you submit at least one Proprietary and one Public Information copy as single files on separate CD-ROM’s. Please ensure that all files are in portable document format (PDF) or other acceptable format.

The OCS Lands Act requires the MMS GOMR to review, analyze, and take final regulatory action on EP’s and DOCD’s within a relatively short period of time after their receipt. In addition, when requested, the MMS GOMR attempts to accomplish these tasks in even shorter periods to accommodate your drilling, platform installation, or pipeline construction schedules, or for other reasons. This expediting sometimes causes disruptions in the normal review and analysis process and makes it extremely difficult to meet the mandated deadlines for other OCS plans that have been submitted timely. Therefore, we seek your cooperation in ensuring that you submit all OCS plans and permit applications to the MMS GOMR sufficiently in advance to provide the MMS GOMR with the maximum review time possible.

The information requirements for OCS plans are specified in 30 CFR 250.203(a) and (b) for EP’s and 30 CFR 250.204(a) and (b) for DOCD’s. According to 30 CFR 250.203(b)(21) and 30 CFR 250.204(b)(17), the MMS GOMR may require data and information to be included in EP’s and DOCD’s in addition to that specified by the regulations. Conversely, 30 CFR 250.203(d) and 30 CFR 250.204(e) allow the MMS Regional Director to limit the amount of information to be included in EP’s and DOCD’s to that necessary to comply with the OCS Lands Act, as amended; other laws; applicable regulations; and lease provisions.

The President’s National Energy Policy (May 2001) directs Federal agencies to streamline and expedite permitting processes. In line with this Policy, you no longer need to provide broad regional-scale environmental descriptive information that is readily available in the extensive information and analyses contained in the latest MMS EIS’s (e.g., Lease Sale 189 for the Eastern Planning Area), as well as the numerous historical and recently completed Environmental Studies. However, under MMS regulations, you must provide site-specific environmental information, such as water depth and seafloor morphology, as a matter of routine and identify any project-specific environmental impacts, such as onshore construction, that would result from conducting the activities proposed in the plan.

The MMS GOMR has developed Appendices A through J of this NTL as guidelines for preparing your EP’s and DOCD’s in the Gulf of Mexico. You should consider these Appendices as guidance documents. These appendices are:

Appendix	Title	Page
Appendix A	Contents of the EP or DOCD	7
Appendix B	General Information	9
Appendix C	Geological, Geophysical, and H₂S Information	11
Appendix D	Biological and Physical Information	15
Appendix E	Wastes and Discharges Information	17
Appendix F	Oil Spill Information	18
Appendix G	Air Emissions Information	24
Appendix H	Environmental Impact Analysis	28
Appendix I	Coastal Zone Management Consistency Information	29
Appendix J	OCS Plan Information Form	34

In preparing your EP or DOCD, you may reference information and data discussed in other documents previously submitted or otherwise readily available to the MMS GOMR and other reviewers.

The information collection referred to in this NTL is intended to provide clarification, description, or interpretation of requirements contained in 30 CFR 250, Subpart B. The Office of Management and Budget (OMB) has approved the information collection requirements in these regulations and associated forms under OMB control number 1010-0049. In addition, the NTL refers to information collection requirements in 30 CFR 250, Subpart C (1010-0057) and Subpart D (1010-0141); 30 CFR 254 (1010-0091); and 30 CFR 256 (1010-0006). The OMB has approved the information collection requirements in these regulations and assigned the OMB control numbers indicated in parenthesis for each. This NTL does not impose any information collection requirements subject to the Paperwork Reduction Act of 1995.

Contact

Please contact the MMS GOMR Plans Section at (504) 736-2419 if you have any questions regarding this NTL.

NTL Part

Description of Change

General Requirements for EP’s and DOCD’s

Copies of EP’s and DOCD’s

Appendix A

Adds a sentence to paragraph (D) for DOCD’s concerning information on the platform installation method.

Appendix B

Adds prospect name to EP information.

Appendix C

Clarifies that shallow hazards assessments are required only for surface locations that the MMS GOMR has not previously approved. Clarifies under Hydrogen Sulfide (H2S) Information in this Appendix that you may consider any reference to correlative stratigraphic sections to be proprietary.

Appendix D

Changes the title to Biological and Physical Information. Updates the reference for “Remotely Operated Vehicle (ROV) Surveys” to NTL No. 2003-G03 for guidance on providing ROV survey information. Adds a reference to live bottoms reports and archaeological survey reports.

Appendix E

Appendix F

Appendix I

Contact

Clarifies that shallow hazards assessments are required only for surface locations that the MMS GOMR has not previously approved. Clarifies under Hydrogen Sulfide (H₂S) Information in this Appendix that you may consider any reference to correlative stratigraphic sections to be proprietary.