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Comments due Feb. 8 on regulation changes
BOEM, BSEE, propose changes to 2016 Arctic OCS exploration drilling rules to remove burdensome regs, reflect new technology Kristen Nelson Petroleum News
Proposed revisions to Arctic exploratory drilling regulations, announced Nov. 19 by the U.S. Department of the Interior’s Bureau of Ocean Energy Management and Bureau of Safety and Environmental Enforcement, were published in the Federal Register Dec. 9, with commits due by Feb. 8.
Interior’s November statement said the purpose of the changes was “to remove unnecessary, burdensome provisions while ensuring that energy exploration on the Arctic Outer Continental Shelf remains safe and environmentally responsible.”
“As countries like Russia increase their presence in the Arctic - including the use of U.S. technologies to develop their seabed resources, it is increasingly important to ensure that the United States has a strong presence in the Arctic OCS,” said Deputy Secretary of the Interior Kate MacGregor. “The Beaufort and Chukchi Seas have a long legacy of oil and gas development - we believe these proposed revisions will better harness new technological innovation and best science to allow for responsible domestic energy development off the coast of Alaska.”
Executive Order 13795, issued by President Donald Trump in 2017, directed Interior to review the 2016 Arctic Exploratory and Drilling Rule and report recommendations, Interior said.
The department said the revision team included career subject matter experts and regulatory specialists who looked to additional research in the review, including a BSEE-commissioned technology assessment program study, National Petroleum Council reports and consultations with “leaders of more than 23 Alaska Native tribes, Alaska Native Claims Settlement Act (ANCSA) corporations and municipalities throughout Alaska.”
The department said the revision team also addressed an issue not in the 2016 rule, lease suspensions for seasonal weather-related constraints.
2016 rule The Federal Register notice said the 2016 rule was a response to BSEE- and BOEM-initiated environmental and safety reviews based on experience in the Arctic OCS “gained from Shell’s 2012 and 2015 Arctic operations, and concerns expressed by environmental organizations and Alaska Natives.”
The notice says the 2016 rule was “narrowly focused, applying solely to exploratory drilling operations conducted during the Arctic OCS open-water drilling season by drilling vessels and ‘jack-up rigs’ (collectively known as mobile offshore drilling units or MODU) in the Beaufort Sea and Chukchi Sea Planning Areas,” designed to ensure those exploration operations were safe “while taking into account the unique conditions of the Arctic OCS, as well as Alaska Natives’ cultural traditions and their need for access to subsistence resources.”
The BSEE and BOEM review of the 2016 rule takes into account a congressional declaration in the Outer Continental Shelf Lands Act that policies and procedures for managing oil and gas development in the OCS be “intended to result in expedited exploration and development of the Outer Continental Shelf in order to achieve national economic and energy policy goals, assure national security, reduce dependence on foreign sources, and maintain a favorable balance of payments in world trade.”
The bureaus have also reviewed new information on technological developments in an ice environment and based on that review are proposing revisions in the 2016 rule to “reduce unnecessary burdens on stakeholders while still maintaining safety and environmental protection.”
Proposed changes Proposed changes include:
*BSEE proposes to eliminate reference to capturing water-based muds and cuttings where subsistence values might be impacted because the requirement appears to overlap with regulation by the U.S. Environmental Protection Agency and “might result in BSEE issuing requirements that contradict EPA’s requirements.”
*Source control and containment equipment would continue to be required when the operator is drilling or working below surface casing, but BSEE proposes to allow the operator to adjust the point during operations when it must position its capping stack “so that it is available to arrive at the well location with 24 hours after a loss of well control.” If the operator can demonstrate that operations would not encounter any abnormally high-pressured zones or other geological hazards before reaching the last casing point prior to penetrating a zone capable of flowing hydrocarbons in measurable quantities, “then BSEE will allow the operator to delay its positioning of the capping stack until reaching that casing point.”
*BSEE also proposes to eliminate the requirement that containment dome and cap and flow system be positioned to arrive at the well location within seven days of loss of well control because a study shows meteorological conditions in the Beaufort and Chukchi seas are “key factors limiting the time periods when SCEE may be safely deployed throughout the Arctic OCS,” and it isn’t practical for the agency to prescribe that certain SCEE “be positioned within proximity to a well location when the conditions for safely deploying this equipment in the Arctic OCS are limiting.”
*Same season relief well and subsea isolation devices requirements would be revised to provide the operator the option of using an SSID or having access to a relief rig by providing an operator the opportunity to adjust when during operations it must stage its relief rig from when working below surface casing to when drilling or working below “the last casing point prior to penetrating a zone capable of flowing hydrocarbons in measurable quantities” if the operator can demonstrate no abnormally high-pressured zones or other geological hazards would be encountered before reaching the last casing point.
*BSEE proposes to clarify when mudline cellars are required since the existing regulations can be read to require use of mudline cellars in all cases except when the cellar would present an operational risk “and that was not BSEE’s intent,” the agency said.
*BOEM proposes to eliminate the requirement for an integrated operations plan because the information required in the IOP overlaps that required in an exploration plan “and the IOP’s early information sharing is unnecessary in light of BOEM’s practice for reviewing and coordinating review of the EP.”
Additional issue The proposed rule also considers an issue not addressed in the 2016 rule - seasonal weather-related constraints in the Arctic OCS.
BSEE is proposing to add a new provision to its regulations which would provide operators who are conducting operations but prevented by seasonal constraints from completing the operations to obtain a suspension of operations which “would suspend the running of the lease term and effectively extend the term of the affected lease by a period equivalent to the period of such suspension,” providing operators who are “otherwise ready and able to conduct drilling operations with additional time to diligently explore their leases, without facing lease expiration due to interference by seasonal constraints unique to the Arctic.”
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