"Rush" and Amended Exploration Plans and DOCDs

Home	About Us	Management Team	Services	Training	Careers	Regulatory Alerts	Map & Directions

Published on March 17, 2004

MMS Gulf of Mexico Region has been tracking the number of “RUSH” Exploration Plans and Development Operations Coordination Documents by Operator. MMS has also been tracking, by Operator, the number of plans that require corrections or additional information before the plan is approved. These statistics will be discussed as part of your Annual Performance Review.

A "Rush" status is defined as follows:

Exploration Plans with commence date less than 30 days from date received.
Development Operations Coordination Documents with commence date less than 60 days from date received.

Plans Received by MMS for 2003:

Type Plans	2004 Average Approval Times (Days)	No. Plans Recieved	No. of Plans with Rush Status	% Plans With Rush Status
Exploration
New	23.09	219	23	10.5%
Supplemental	19.36	88	26	30%
Revised	6.04	70	54	77%
DOCD
New	63.34	119	79	66%
Supplemental	47.18	159	110	69%
Revised	20.58	44	36	82%

MMS will also be reviewing "amendments to plans" in your Annual Performance Review. The 2003 statistics for amendments were as follows:

Type Plans EP's & DOCDs	No. Plans Recieved	No. of Plans Requiring Amendments	% Plans Amended
New	252	146	44%
Revised	98	15	15%
Supplemental	243	82	34%

Some of the general types of problems requiring amendments are:

Lack of consistency throughout plan
Description of schedule does not include all proposed activities
When a "rush" plan is submitted, no legitimate reason is given for the need to expedite the plan (examples: rig on location or enroute, lease expiration,)
Method of installation for platforms not discussed and whether a barge with anchors will be used.

If you would like to know your company’s statistics prior to attending an Annual Performance Review meeting, please contact Cathy Thornton at cathy.thorton@jccteam.com or (281) 578-3388.

This Regulatory Alert was prepared by J. Connor Consulting, Inc. to advise our clients of impending deadlines and applicable regulatory requirements. No official agency policy is implied.