Integration of Best Management Practices into Application for Permit to Drill Approvals and Associated Rights-of-Way
UNITED STATES DEPARTMENT OF THE INTERIOR
Bureau of Land Management
Washington, D.C. 20240 http://www.blm.gov
November 8, 2006
In Reply Refer To:
3100/ 2800 (310, 350) P
EMS TRANSMISSION 11/17/2006
Instruction Memorandum No. 2007-021
Expires: 09/30/2008
To: All Field Officials
From: Director
Subject: Integration of Best Management Practices into Application for Permit to Drill Approvals and Associated Rights-of-Way
Program Areas: Oil & Gas Operations; Geothermal Operations; Helium Operations; Lands and Realty
Purpose: The purpose for issuing this Instruction Memorandum (IM) is to reemphasize the Bureau of Land Management’s (BLM) policy that Field Offices use appropriate environmental Best Management Practices (BMPs) for mitigating anticipated impacts to surface and subsurface resources.
Policy/Action: All Field Offices shall incorporate appropriate environmental BMPs into proposed Application for Permits to Drill (APD), sundry notices, and associated on- and off-lease Rights-of-Way approvals after appropriate environmental review.
Environmental BMPs to be considered in nearly all circumstances include the following:
- Interim reclamation of well locations and access roads soon after the well is put into production;
- Painting of all new facilities a color that best allows the facility to blend with the background, typically a vegetated background;
- Design and construction of all new roads to a safe and appropriate standard, “no higher than necessary” (see BLM 9113 Roads Manual) to accommodate their intended use; and
- Final reclamation recontouring of all disturbed areas, including access roads, to the original contour or a contour that blends with the surrounding topography.
Other environmental BMPs are more suitable for Field Office consideration on a case-by-case basis, 1) depending on their effectiveness, 2) the balancing of increased operating costs vs. the benefit to the public and resource values, 3) the availability of less restrictive mitigation alternatives that accomplish the same objective, and 4) other site specific factors. Examples of typical, case-by-case BMPs include, but are not limited to, the following:
- Installing raptor perch avoidance;
- Burying of distribution power lines and/or flow lines in or adjacent to access roads;
- Centralizing production facilities;
- Installing submersible pumps;
- Placing wellheads below ground;
- Drilling multiple wells from a single pad;
- Using noise reduction techniques and designs to reduce noise from compressors;
- Monitoring wildlife;
- Placing seasonal restrictions on public vehicular access;
- Avoiding placement of production facilities on hilltops and ridgelines;
- Screening facilities from view;
- Bioremediating oil field wastes and spills; and
- Using common utility or Right-of-Way corridors.
A menu of typical BMPs can be found on the BLM Washington Office Fluid Minerals web site at: www.blm.gov/bmp. The web site is updated frequently. Submission of new BMPs and photos is encouraged.
Environmental BMPs have been developed and used by numerous oil and gas operators throughout the nation. When implementing new BMPs, Field Offices are encouraged to work with an affected operator early in the process, to explain how BMPs may fit into their development proposals and how BMPs can be implemented with the least economic impact to the operator. Field Offices should discuss potential resource impacts with the operator and seek the operator’s recommended solutions. The Field Office should also encourage the operator to incorporate necessary and effective BMPs into their project proposal. Environmental BMPs not incorporated into the permit application by the operator may be considered and evaluated through the environmental review process and incorporated into the permit as APD Conditions of Approval or Right-of-Way stipulations.
Remember that, Field Offices must be cautious to avoid the “one size fits all” approach to the application of BMPs. Environmental BMPs, by their very nature, are dynamic innovations and must be flexible enough to respond to new data, field research, technological advances, and market conditions. Following implementation, Field Offices should monitor, evaluate, and modify BMPs as necessary for use in future permit approvals.
The overall goal of the BLM is to promote the best examples of responsible oil and gas development. Public lands should be showcases of good stewardship while providing for responsible, sustainable, and efficient development of the nation’s oil and gas resources. The BLM will use the Quality Assurance Team and General Management Evaluation processes in order to review our progress.
To recognize good environmental stewardship work through the use of BMPs, the BLM has established an annual “Environmental Best Management Practice” awards program with annual awards for industry and the BLM offices at: www.blm.gov/bmp/BMPAwards.
Timeframe: Immediately.
Background: Environmental BMPs are state-of-the-art mitigation measures applied on a site-specific basis to reduce, prevent, or avoid adverse environmental or social impacts. Environmental BMPs are applied to management actions to aid in achieving desired outcomes for safe, environmentally responsible resource development, by preventing, minimizing, or mitigating adverse impacts and reducing conflicts. The early incorporation of BMPs into APDs by the oil and gas operator helps to ensure an efficient and timely APD process.
Budget Impacts: Minimal.
Manual and Handbook Sections Affected: None.
Coordination: Renewable Resources and Planning (AD-200), Division of Lands and Realty (WO-350).
Contact: Please direct questions to Jim Perry, Washington Office Division of Fluid Minerals (WO-310), at 202-452-5063; or by E-mail at jim_perry@blm.gov.
Signed by: Authenticated by:
Michael A. Ferguson Robert M. Williams
Acting, Director Division of IRM Governance, WO-560
The purpose for issuing this Instruction Memorandum (IM) is to reemphasize the Bureau of Land Management’s (BLM) policy that Field Offices use appropriate environmental Best Management Practices (BMPs) for mitigating anticipated impacts to surface and subsurface resources.
All Field Offices shall incorporate appropriate environmental BMPs into proposed Application for Permits to Drill (APD), sundry notices, and associated on- and off-lease Rights-of-Way approvals after appropriate environmental review.
Environmental BMPs to be considered in nearly all circumstances include the following:
- Interim reclamation of well locations and access roads soon after the well is put into production;
- Painting of all new facilities a color that best allows the facility to blend with the background, typically a vegetated background;
- Design and construction of all new roads to a safe and appropriate standard, “no higher than necessary” (see BLM 9113 Roads Manual) to accommodate their intended use; and
- Final reclamation recontouring of all disturbed areas, including access roads, to the original contour or a contour that blends with the surrounding topography.
Other environmental BMPs are more suitable for Field Office consideration on a case-by-case basis, 1) depending on their effectiveness, 2) the balancing of increased operating costs vs. the benefit to the public and resource values, 3) the availability of less restrictive mitigation alternatives that accomplish the same objective, and 4) other site specific factors. Examples of typical, case-by-case BMPs include, but are not limited to, the following:
- Installing raptor perch avoidance;
- Burying of distribution power lines and/or flow lines in or adjacent to access roads;
- Centralizing production facilities;
- Installing submersible pumps;
- Placing wellheads below ground;
- Drilling multiple wells from a single pad;
- Using noise reduction techniques and designs to reduce noise from compressors;
- Monitoring wildlife;
- Placing seasonal restrictions on public vehicular access;
- Avoiding placement of production facilities on hilltops and ridgelines;
- Screening facilities from view;
- Bioremediating oil field wastes and spills; and
- Using common utility or Right-of-Way corridors.
A menu of typical BMPs can be found on the BLM Washington Office Fluid Minerals web site at: www.blm.gov/bmp. The web site is updated frequently. Submission of new BMPs and photos is encouraged.
Environmental BMPs have been developed and used by numerous oil and gas operators throughout the nation. When implementing new BMPs, Field Offices are encouraged to work with an affected operator early in the process, to explain how BMPs may fit into their development proposals and how BMPs can be implemented with the least economic impact to the operator. Field Offices should discuss potential resource impacts with the operator and seek the operator’s recommended solutions. The Field Office should also encourage the operator to incorporate necessary and effective BMPs into their project proposal. Environmental BMPs not incorporated into the permit application by the operator may be considered and evaluated through the environmental review process and incorporated into the permit as APD Conditions of Approval or Right-of-Way stipulations.
Remember that, Field Offices must be cautious to avoid the “one size fits all” approach to the application of BMPs. Environmental BMPs, by their very nature, are dynamic innovations and must be flexible enough to respond to new data, field research, technological advances, and market conditions. Following implementation, Field Offices should monitor, evaluate, and modify BMPs as necessary for use in future permit approvals.
The overall goal of the BLM is to promote the best examples of responsible oil and gas development. Public lands should be showcases of good stewardship while providing for responsible, sustainable, and efficient development of the nation’s oil and gas resources. The BLM will use the Quality Assurance Team and General Management Evaluation processes in order to review our progress.
To recognize good environmental stewardship work through the use of BMPs, the BLM has established an annual “Environmental Best Management Practice” awards program with annual awards for industry and the BLM offices at: www.blm.gov/bmp/BMPAwards.
Minimal
Environmental BMPs are state-of-the-art mitigation measures applied on a site-specific basis to reduce, prevent, or avoid adverse environmental or social impacts. Environmental BMPs are applied to management actions to aid in achieving desired outcomes for safe, environmentally responsible resource development, by preventing, minimizing, or mitigating adverse impacts and reducing conflicts. The early incorporation of BMPs into APDs by the oil and gas operator helps to ensure an efficient and timely APD process.
None
Please direct questions to Jim Perry, Washington Office Division of Fluid Minerals (WO-310), at 202-452-5063; or by E-mail at jim_perry@blm.gov.
Renewable Resources and Planning (AD-200), Division of Lands and Realty (WO-350).