U.S. DEPARTMENT OF THE INTERIORBUREAU OF LAND MANAGEMENT
UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240
September 25, 2007
In Reply Refer To:
2800/3100 (300) P
EMS TRANSMISSION 10/04/2007
Instruction Memorandum 2007-203
To: All Field Officials
From: Assistant Director, Minerals, Realty and Resource Protection
Subject: Process Improvement for Oil, Gas, Geothermal, Geophysical, and Related Rights-of-Way Approvals - Self-Assessment Report Implementation
Program Areas: Fluid Minerals Operations and Related Rights-of-Way
Purpose: The purpose of this Instruction Memorandum (IM) is to implement recommendations from the 2006 Application for Permit to Drill (APD) Process Improvement for Oil, Gas, Geothermal, Geophysical, and Related Rights-of-Way Approvals - Self-Assessment Report.
Policy/Action: State (SO) and Field Offices (FO) with oil and gas programs shall review and implement the recommendations found in the Self-Assessment report (Attachment 1) and continue to implement the process improvements identified in Appendix 1 of Washington Office (WO) IM 2006-071 Process Improvement for Oil, Gas, Geothermal, Geophysical, and Related Rights-of-Way Approvals, (included within Attachment 1).
Timeframe: Implement immediately.
Background: During the past four years, the Bureau of Land Management (BLM) WO Division of Fluid Minerals (WO-310) has increased its oversight of the Fluid Minerals Surface Management Program by developing new regulations, policy, workshops, training courses, handbooks, and outreach materials. The intent has been to improve guidance on environmentally responsible energy development while improving process efficiency.
WO-310 conducted a self-assessment of the Oil and Gas Surface Management Program during Fiscal Year (FY) 2006 and continued through FY 2007. The objective of the assessment was to determine if the Fluid Minerals Application for Permit to Drill processes are being conducted in a manner that is timely, consistent, and in compliance with environmental laws and policies, and, if not, to recommend necessary changes to office procedures.
Initiated by IM No. 2006-071, Process Improvement for Oil, Gas, Geothermal, Geophysical, and Related Rights-of-Way Approvals (01/19/2006), the self-assessment was responded to by 23 field offices with Oil and Gas, Geothermal, Geophysical, and related Rights-of-the-Way programs that averaged 20 or more APDs per year over the past 5 years.
The FOs reported that areas of significant delay in the APD process resulted from cultural resource assessments, personnel and training, and surface management agency communication.
The most common cause for delay resulted from operators not submitting cultural resource surveys early or with the APDs. The WO has provided policy guidance for conducting and submitting cultural surveys. Instruction memorandum No. 2003-147 Application for Permit to Drill (APD) - Process Improvement #3 - - Cultural Resources (04/14/03), promotes early coordination between the operator and the BLM Cultural Resource Specialist.
The next leading APD processing delay factor for many offices was staffing issues involving increased workload and the uniformity of certain skill levels among the staff. Some FOs are adapting by improving internal coordination, cross-training, sharing skills between offices, and utilizing BLM and outside training to increase the skill set of the available staff.
Another important source of delay involves the inefficient communication between the BLM and other surface management agencies. In some locations, the new multi-agency Pilot Offices will help to resolve this situation. Some BLM offices have been working with the Forest Service to identify more effective APD procedures and to encourage operators to initiate the permitting process with the appropriate Forest Service Ranger District as early as possible.
The majority of the offices are implementing some of the WO recommended strategies to improve APD process efficiency and ensure environmentally responsible oil and gas development. Some offices are taking extraordinary steps to implement their own innovative solutions.
The WO acknowledges that many SOs and FOs have been working exceptionally hard to help meet America’s increased demand for domestic supplies of energy through improved business and environmental practices. Your efforts are to be commended.
Budget Impact: Minimal.
Manual/Handbook Sections Affected: None.
Coordination: The evaluation was coordinated with WO Division of Evaluations and Management Services (WO-830).
Contact: Please address any questions related to this IM to Jim Perry, Senior Natural Resource Specialist, WO-310, firstname.lastname@example.org , or by telephone at 202-452-5063.