BOEMRE publishes checklist for operator permit applications

The US Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) said this week it is putting in place “significant improvements” in the oil and gas permit application process. Key improvements include:

• The publication of a “completeness” checklist for offshore oil and gas operators. This high-level checklist, which aligns with BOEMRE’s review process, includes the main components that need to be submitted by operators to make a permit application complete. This checklist does not ensure approval of an application but will clarify for operators what is needed in their submission.

The development of the checklist comes after multiple meetings with operators who have requested such additional guidance. The checklist can be viewed here.

• BOEMRE personnel will conduct completeness checks before beginning an in-depth, substantive review of the application. Bureau personnel will focus on identifying significant omissions during the initial review so as to quickly identify applications that are not ready for full review. Deficiencies and omissions will be communicated to the operator for correction at the same time. This does not guarantee that incomplete information will not be found later in the review, but the completeness check is designed to capture the major gaps in submission criteria early in the review process.

• Permits found to be complete will have a higher priority in the review process. The bureau has established priorities for reviewing permit applications as follows:

• Permits for ongoing operations, such as sidetracks or deeper exploration of an existing well;
• Applications deemed complete; and
• If staff time allows, applications that are not deemed complete, such as those missing a required containment plan or the necessary professional engineer certifications, may begin to be processed. This category also includes permit applications without an approved exploration or development plan.

BOEMRE has approved 43 deepwater permits for 15 unique wells that require subsea containment since an applicant first successfully demonstrated containment capabilities in mid-February. The agency says there are currently 24 permits pending, and 18 permits have been returned to the operator with requests for additional information, particularly information regarding containment.

The BOEMRE believes that, over time, these new changes will substantially reduce the number of permits that need to be returned to operators.