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How will you gain project approval?
(Pre[NEPA]-planning)
Why do you want to do it?
(Purpose and Need)
What do you want to do?
(Project Description)
PRE-PLANNING
From concept to project definition…
internal first steps
Develop BIG picture description of future project.
– Project area location/definition.
– How many wells? Surface density? Spacing?
– Seismic: source line miles, types of sources.
Explain rationale behind big picture description.
– Reservoir characteristics.
– Area-specific emerging technologies (directional/horizontal
drilling).
– Varying mineral ownerships/surface owners, collocated wells.
Determine operational capacities  time frame for project.
– # of drill rigs in operation, etc.
– Seismic: survey crew/helicopter/data acquisition crew
availability.
PRE-PLANNING
Initiate agency contact - objectives
To secure agency buy-in and lay groundwork for expedited
project approval.
Preliminary knowledge of issues as seen by managing
agency.
Demonstrate company’s understanding of resource issues.
Better ability to refine scope of project and project time
frame.
Suggest a preferred NEPA approach.
Confirm project consistency with land use plan.
Value / positive result depends on agency/company culture
and staff.
PRE-PLANNING
Initial (BIG picture) meeting
Contact likely lead agency first, then meet with all
involved agencies.
Explore possible interagency MOU, if several
agencies.
Bring project description overview and maps.
Discuss NEPA contractor selection in preparation for
next meeting.
Review agency approval process steps in detail, with
time lines.
Identify possible sources of delays (example: NOI or
NOA review, Section 7 consultation).
PRE-PLANNING
Results
Viability of scope and timing for project.
Identify most obvious sources of delay.
– Funding opportunities.
– Staff support.
Confirmation of land use plan consistency.
– If not, agency determines if project warrants additional
consideration.
– Plan amendment/plan revision/new plan needed.
– Or, modify project to conform to scope of the land use
plan.
Assessment of agency cooperation / enthusiasm and its
willingness to work together to secure project approval.
Introduction of key players: POCs within agency and
company, possible cooperating agencies.
PURPOSE AND NEED
Purpose: Agency objectives for
considering a non-agency action.
– Regulatory framework for consideration of
proposed action and other resource objectives.
Need: Company objectives
– Who, what ,why, where, when.
– Describe resource opportunities or resource
problems.
PURPOSE AND NEED
Why is the P&N important?
Basis of alternatives evaluation.
“Purpose” provides the basis for development of
alternatives to Proposed Action by relating it to
other agency objectives.
“Need” sets the minimum standards that the
alternatives must meet.
Fully analyzed alternatives must meet the P&N.
Approved alternative must meet the P&N.
Cannot preclude legitimate, reasonable
alternatives.
PURPOSE AND NEED
Example: Geophysical P&N
To determine whether to attempt to develop hydrocarbon
resources, pursuant to its rights under valid existing oil and gas
leases granted by the BLM.
To determine with greater certainty the potential for occurrence of
oil and gas resources in geologic formations underlying the project
area;
To verify and/or supplement the existing subsurface geologic
data;
To generate new data that may be used to more accurately locate
potential reservoirs of commercial quantities of hydrocarbons in
areas where geophysical surveys and/or drilling have not
occurred;
To eliminate some areas from future exploratory drilling, and
focus well-drilling activity in only those areas where the resource
is most likely present; and
To reduce unnecessary drilling and construction of associated
roads, well pads, and other surface disturbances that would
otherwise be needed to evaluate the subsurface formations and
possible reservoirs.
PURPOSE AND NEED
Example: Well exploration and development P&N
Allow COMPANY to exercise its legal right to reasonably drill and
develop its leaseholds and extract the leased hydrocarbons from
the subsurface;
Add to the existing knowledge of the complex subsurface geology
and reservoir characteristics of the Paradox fold and fracture belt;
Further define drilling and completion techniques necessary to
produce hydrocarbons from reservoirs in the Paradox fold and
fracture belt;
Provide additional data with which to evaluate future well spacing;
Confirm or disprove the interpretation of seismic data obtained
from a 2001 geophysical survey;
Provide additional data for use in evaluating the level of activity of
future drilling in the Paradox fold and fault system;
Allow natural gas to be transported to a nearby mine where it
would be utilized to operate the existing infrastructure; and
Contribute to available domestic oil supply if the wells are
productive.
PROJECT DESCRIPTION
How are you going to meet your P&N?
Development of a strategic project plan may not
be straightforward.
Pre-planning can shape/modify the scope and
time frame of the project.
PD may be (somewhat) issue-driven.
PROJECT DESCRIPTION
Scope and time frame:
Ask for what you want!
Initial project scope and time frame
(company)
Land Use Plan consistency
Approval time frame (agency)
Modified scope and time frame
(possible company re-appraisal)
PROJECT DESCRIPTION
Conceptual or site-specific?
Approach determined by the scope of the project and
flexibility of the project.
– Example: This EA discusses the purpose, need, and potential
environmental impacts of drilling three exploratory oil and gas
wells and is a site-specific analysis of potential impacts to the
human environment that may result from drilling 3 exploratory
oil and gas wells. The three wells were proposed under
individual APDs.
– Example: The Company proposes to drill approximately 1,800
new wells as infill wells to all productive formations beneath
the project area. Of these proposed new wells, the company
intends to drill approximately 630 completions by either
deepening an existing well bore or by drilling a twin well on
the existing pad.
Conceptual approach: Describe operational details in a
broad way, but with as many details as possible.
PROJECT DESCRIPTION
General operational details
Example: Approximately 20 temporary staging areas would
be located on public lands where the pipeline would cross a
road. The numbers and locations of staging areas on
private lands are yet to be determined. The preliminary
locations of staging areas on public lands would be chosen
to result in the maximum use of existing disturbance;
however the final determination of the number and location
of the staging areas would be cooperatively chosen by the
agency and the pipeline construction company.
Example: Gas will be transported from the wellhead via
gathering pipelines to two centralized compressor stations
located within the project area but owned by Another
Company. Each station consists of two 1,500 HP
compressors. The existing compressors are expected to
maintain acceptable pressure levels within the existing and
new gathering system; however, additional supplemental
compression may be needed to accommodate increased
volume, throughput, and field pressure needs.
PROJECT DESCRIPTION
The NEPA analysis will consider the
most conservative option.
Example: “Produced water will be trucked to 5 to
10 evaporation ponds, each requiring 10 acres,
for disposal.”
Example: “The Company proposes to drill
between 2,000 and 3,400 new well bores on new
and existing pads. Between 1,000 and 1,700
new well pads would be required.”
Within each example, which scenario will be
analyzed?
PROJECT DESCRIPTION
Include “existing environment”
Date, “as of…,” sets baseline.
Keep it current.
Exploratory or well development project: Number
of active wells, number of current locations, miles
of access road, current produced water disposal,
gas and oil processing and disposition, remote
monitoring, truck access/frequency.
Geophysical project: Wells (active and P&A), prior
seismic surveys, available roads.
PROJECT DESCRIPTION
Addressing issues
Applicant-committed environmental protection
measures.
Allow agency options for additional mitigation.
Include what makes sense.
– Company will comply with all applicable rules,
regulations, and guidelines.
– Company will perform resource surveys as needed and
determined by the agency.
Don’t promise too much (at least initially).
– Company will pave 20 miles of county road needed for
access.
– Company will perform offsite mitigation, as determined
by the NEPA analysis.
PROJECT DESCRIPTION
Alternatives Considered
Include them as part of your agency submission.
Helps the agency to formulate its own alternatives.
Address the resources you know to be of concern.
Explain your rationale in detail.
– Example: The Company considered an alternate pipeline
route that would increase the offset from a MSO nest
adjacent to the proposed route. The Company
determined that it would be able to construct near the
nest during certain times of the year and not affect the
owls.
Alternatives that you considered (but rejected) may be fully
analyzed in the NEPA document.
SUMMARY
Pre-plan: Approach the agency early.
Purpose and need: Clear and detailed.
Project description: Detailed, with operational
flexibility, up-front mitigation, and the
alternatives you considered.
Set a date for the official kickoff meeting.
Bring P&N, project description, and
alternatives considered.
Bring NEPA contractor if possible)
And you’re off…
MAXIMIZE YOUR
OPPORTUNITIES