U.S. DEPARTMENT OF THE INTERIORBUREAU OF LAND MANAGEMENT
EMS TRANSMISSION 01/25/2006
Instruction Memorandum No. 2006-071
To: All Field Officials
Subject: Process Improvement for Oil, Gas, Geothermal, Geophysical, and Related Rights-of-Way Approvals DD: 04/01/2006, 05/01/2006
Program Areas: Oil and Gas Exploration and Operations; Geothermal Operations; Lands and Realty; Environmental Coordination
Purpose: This Instruction Memorandum (IM) establishes procedures for improving the Application for Permit to Drill (APD) process and ensuring that environmental studies are timely, consistent among field offices, and comply with applicable environmental laws.
Policy/Action: Field office managers with Oil and Gas, Geothermal, Geophysical, and related Rights-of-Way programs that averaged 20 or more APDs per year over the past 5 years are directed to take the following actions:
1) Form a process improvement team to review the APD process currently used by the office, including associated on-and off-lease rights-of-way and related environmental reviews;
2) Make changes to improve process efficiency with the objective of reducing current processing times, while maintaining an interdisciplinary review and ensuring development is conducted in an environmentally responsible manner; and
3) Report findings and efficiency improvements to their respective State offices by April 1, 2006. Field offices that have been reviewed by a Washington Office Quality Assurance Team or by the State office should address the effectiveness of improvements resulting from the reviews.
Regardless of program size, field office managers shall remain personally and actively involved in the energy development program to ensure the process is both efficient and interdisciplinary, and also to ensure that energy resources are developed in an environmentally responsible manner using appropriate environmental Best Management Practices. State Directors shall support field office process improvement teams by providing advice; verifying implemented improvements; consolidating findings; and reporting results to the Washington Office Fluid Minerals Group (WO-310) by May 1, 2006.
The report need not be lengthy. It shall include: the field office; review-team members; meeting dates; process delays identified; consistency issues that were identified within offices and within the State; and process and consistency solutions that are being implemented. State Directors shall remain actively involved in oversight of field office energy development programs, ensuring process and environmental improvement through training, guidance, and periodic reviews.
Process improvement strategies for APD and National Environmental Policy Act (NEPA) processes are included as Attachment 1. Field offices shall adopt these strategies.
Background: State and field offices have worked exceptionally hard to meet America’s increased demand for domestic supplies of energy. Many offices have met this challenge by developing and implementing improved business and environmental practices. Your efforts are to be commended. While we have achieved much, there remains more that we, as an agency, can do.
The Office of Inspector General (OIG), in its February 2004 report Audit of Oil and Gas Permitting Process, identified “The lack of effective management oversight and accountability” as a problem that significantly delayed and impeded BLM’s ability to effectively process and approve APDs. The OIG made a set of recommendations to improve the APD process. Recommendation No.7 states:
“Establish procedures for completing environmental studies that are timely, consistent among field offices, and comply with applicable environmental laws.”
The Bureau of Land Management’s Fluid Minerals Group conducted Quality Assurance Team reviews in seven field offices. A primary objective of these reviews was to evaluate the efficiency of APD processing practices. Adherence to Onshore Oil and Gas Order No. 1 requirements, timeliness, and quality were of particular concern. Subsequent Automated Fluid Minerals Support System (AFMSS) reports showed that average BLM APD processing times varied between offices, from 56 to 534 days for
The Quality Assurance Teams concluded that the more personally involved the field manager is in the APD process, the more timely and efficient the office becomes. The Teams’ report makes several recommendations, including:
· Each office must evaluate its NEPA process and make necessary changes to expedite internal reviews and paperwork flows.
· Increase the usage of the Documentation of NEPA Adequacy worksheets [and the new Section 390 Categorical Exclusions] by writing more site-specific field development Environmental Assessments (EA) and Environmental Impact Statements (EIS).
· Expand the use of multiple APD or Plan of Development (POD) EAs.
Section 362 of the Energy Policy Act of 2005 requires development and implementation of Best [Business] Practices to ensure timely action on oil and gas APDs. Best Business Practices are included on Attachment 1.
Section 390 of the Energy Policy Act established five new categorical exclusions for oil and gas development projects (see Washington Office IM 2005-247). For most offices, these new categorical exclusions will result in changes to office procedures for documenting environmental reviews.
A streamlined APD and NEPA review process is expected to reduce costs for both the Bureau and operator, generate additional time for preplanning with operators and the public, and increase the Bureau’s ability to monitor permit compliance.
Timeframe: Implement immediately. Field offices report accomplishments of the process improvement teams to their respective state offices by April 1, 2006. State offices report process improvement results by E-mail to Jim_Perry@blm.gov , by May 1, 2006.
Budget Impact: Limited travel funding will be necessary for state office personnel to assist field office process improvement teams.
Manual/Handbook Sections Affected: None.
Coordination: This IM was coordinated with the Washington Office Fluid Minerals Group; Planning, Assessment and Community Support Group; Land and Realty Group; and Department of the Interior - Office of the Solicitor.
Contact: Please direct any questions to Jim Perry, Washington Office Fluid Minerals Group (WO-310) at (202) 452‑5063 or firstname.lastname@example.org , Chuck Otto, Washington Office Planning, Assessment and Community Support Group (WO-210) at
(202) 785-6592 or email@example.com , Ron Montagna, Lands and Realty Group (WO‑350) at (202) 452-7782 or firstname.lastname@example.org .