The
ePermit Business Case Document (Feb. 2004)
(PDF, US Letter, 80 KB)
From the Executive Summary:
Before an oil and gas operator can drill a well on virtually any land within the continental United States, including navigable waters and contiguous three-mile offshore areas, permission must be obtained from the appropriate state oil and gas regulatory agency. State permission is required on private, state, and federal lands, and, except for tribally operated wells on Indian lands and the Osage Mineral Reserve in Oklahoma, state permission is also required for wells drilled on Indian lands.
On federal and Indian land, there is overlapping state and federal jurisdiction, as federal permission is required in addition to state approval.
In most states, when drilling on federal and Indian lands, operators must submit separate applications to both the US Bureau of Land Management (BLM) and to the state oil and gas regulatory agency. While the application and supporting materials submitted by the operator to the state is similar to the application package submitted to the BLM, there are differences, which vary from state to state, because each state has its own regulations and its own set of permitting forms.
With the advent of the Internet and electronic commerce technologies, both the BLM and the states realize the potential benefits that can be realized if operators are allowed to submit drilling applications and subsequent completion and operational activity reports electronically. The BLM and several states have already commenced the development and implementation of such electronic permitting and reporting solutions.
There is a growing recognition among agencies and industry that the development of uniform data transfer procedures, reusable computing resources, and supporting standards can accelerate the acceptance and reduce the cost of moving to electronic permitting.
A common approach to permitting data transfers will greatly simplify electronic filing for operators who must submit applications to both the BLM and the states as well as for operators who apply for permits in multiple states. A common approach to permitting data transfers will also facilitate sharing of associated well technical data between state and federal agencies. This will enable the state and federal governments to more easily share solution software designed to process and report on drilling application and completion data.
Thus, the associated business case sets out the tasks to accomplish this vision. These tasks involve defining and agreeing on a comprehensive and common set of data elements and definitions related to the electronic transfer of permitting, drilling, and completion data. These elements and definitions will include data used by the BLM and state agencies, from the common ones to those unique to a single agency. Based on the principle of maximizing consistency while respecting necessary differences, the proposed solution will allow for the transfer of exceptional data elements not defined in the common set. Moreover, where possible, the proposed solution will employ data definitions and transfer messages currently being standardized by industry for operational purposes.
Ideally, all private operators and state and federal agencies would engineer their computer solutions based precisely on the commonly defined, standardized data elements. In actuality, however, most agencies and most operators have significant investments in existing and currently developing computer solutions. While a great deal of comparable data is stored in such systems, the same information may be referenced with different names and may be stored in somewhat different formats. Therefore, the business case calls for the defining mappings with existing state, federal, and industry practices to facilitate effective data translations.
While defining such mappings to support translations is a significant effort, it is also an efficient approach because each mapping need be defined once and only once. For instance, if an operator drills in ten states and has wells on federal land, that operator must report and map to eleven somewhat dissimilar systems. As the goals of this business case proposal are met, that operator would only have to develop one mapping, as the agency-specific mappings will already have been defined. This is an essential benefit of this proposal for industry.
The associated business case document elaborates on this vision with specific proposals for a series of projects involving federal and state agencies and industry. The proposed projects spearhead a comprehensive, step-by-step approach to achieving the benefits described above. Additional participation from agencies and industry is being sought. There are opportunities for industry and other government agencies to join the proposed projects and opportunities to define subsequent and parallel projects tuned to the functional, timing, and economic needs of the participants. In the name of all of those who prepared these proposals, we commend this business case to you for serious consideration.
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