DOMESTIC PETROLEUM COUNCIL

9 February 24,2006

Content Analysis Group BLM Categorical Exclusions P.O. Box 22777 Salt Lake City, UT 841 22-0777

By E-Mail as a .pdf file attachment: BLMCX@fs.fed. us

Re: Notice of Proposed Revision to the Bureau of Land Management's (BLM) Procedures for Chapter 11 of the Department of the Interior's Manual 516 DM -- Managing the NEPA Process: Domestic Petroleum Council comments on the proposed categorical exclusion (CX) for geophysical operations

The Domestic Petroleum Council (DPC) strongly supports inclusion of the categorical exclusion (CX) for geophysical operations as part of the proposed revisions to the Bureau of Land Management (BLM) procedure for Chapter 11 (Section 11.9.B) of the Department of Interior's Manual 516 DM - Managing the NEPA (National Environmental Policy Act) Process. We also recommend consideration of additional categorical exclusions.

The BLM's role in helping to meet the energy needs of all Americans is more important today than ever before. Natural gas and oil beneath federal lands can and must continue to provide a crucial share of our domestic energy supplies. Identifying those resources and then developing and producing them can and must be accomplished efficiently in , environmentally compatible ways. The BLM geophysical operations CX proposal and others can help to ensure that that goal is met.

DPC member companies are the largest independent natural gas and oil exploration and production (E&P) companies in the United States. They are leaders in applying their technology and capital to the search for, and development and production of, oil and natural gas in the U.S. and around the world. From the perspective of these companies, limited access and regulatory delays constitute the most problematic aspects of permitting of oil and gas wells and rights-of-way on public lands. Many delays are associated with untimely and unnecessary NEPA analyses and the lack of applicable categorical exclusions. The DPC is pleased that the BLM recognizes these problems and is moving to be sure they are addressed. We urge the BLM to take this opportunity to ensure the applicable provisions will quickly begin reducing delays and increasing the access necessary to develop domestic energy.

Geo~hvsical Operations CX

Specifically as to the proposed geophysical operations CX, the DPC emphasizes that the success of our energy efforts depends first on the timely acquisition, processing and interpretation of geophysical information upon which investment decisions are based.

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In addition to being a key exploration and production tool for finding and efficiently producing natural gas and oil, geophysical operations (seismic surveys) are a also a tactical environmental management tool of the resource manager in minimizing and eliminating any lasting environmental impacts from oil and natural gas operations. The current and future use of seismic data minimizes the number of wells that need to be drilled to explore for, and develop, natural resources contained in the subsurface. Seismic surveys should be the preferred method for locating natural gas and oil resources on BLM managed lands.

Further, we support the BLM's recognition that geophysical exploration does not result in lasting impacts on surface resource values and often do not require new road construction. There is ample industry data that can demonstrate that a categorical exclusion for geophysical operations will not result in individual or cumulative effects on the physical or human environment and is justified and warranted under NEPA. BLM regulations ensure that virtually no surface damage is associated with seismic activities. The BLM Analysis Report (dated January 4, 2006) on results of the data call for NEPA analysis in support of geophysical exploration reached similar conclusions in recommending the CX proposal.

In addition to providing these comments urging approval of the BLM geophysical operations CX as sound management practice as well as good energy and environmental protection policy, we support the more detailed comments being filed by the International Association of Geophysical Contractors.

Additional CX Consideration

The DPC would like to also note that there are additional actions that warrant consideration for specific categorical exclusions so as to reduce or eliminate complex and lengthy NEPA analyses that may provide little or no environmental benefit. These include:

Fire control measures, including equipment mobilization and activation Requests for exceptions or modifications to existing lease stipulations when no new surface disturbance would result Approval of an application for a permit to drill (APD) related to onsite remediation efforts of groundwater or soils Sundry notices associated with: 9 Routine well workovers 9 Routine hydraulic fracturing to improve production or injection Disposal of produced water in accordance with State or Federal regulatory requirements Minor modifications or variances from activities described in approved development or production plans Maintenance and installation of new equipment on gathering line facilities, such as compressors, when there is no additional surface disturbance or when the surface disturbance is less than 2 acres.

The implementation of these categorical exclusions would help the BLM streamline the authorization process for routine operations by reducing the administration and paperwork, resulting in fewer man-hours for approvals. This streamlining would also provide BLM staff a better utilization of their time and skills to pursue environmentally compatible multiple use of the lands managed by the agency.

Should you have any questions, please call me at (202) 742 4300.

Thank you for considering our views.

William F. Whitsitt President